Dr. Gartland 
2 
14 April 1978 
for survival in their natural environment". It appears inconsistent that 
the revised guidelines do not permit analogous use of non-pathogenic non- 
E. coli bacteria as hosts in experiments aimed at improving the quality 
or quantity of biological products made by those bacteria. 
(5) For example, an experiment involving the introduction of genes by 
recombinant DNA methods from Streptomyces coelicolor to Streptomyces 
lividans in order to design a more effective antibiotic, could simply not 
be done in the wild type antibiotic-producing strain at any level of con- 
tainment whatsoever. These organisms, although both closely related 
members of the genus Streptomyces , have not been shown to exchange DNA 
by natural physiological processes (although DNA can be exchanged by 
experimentally induced cell fusion) . Since the wild type recipient 
( Streptomyces lividans ) does not have a "low potential for survival in 
its natural environment" it could not be classified as an HV1 system. 
Thus, even though there would probably be unanimous agreement by scien- 
tists that the experiment I have described above poses virtually no 
risk whatsoever, the experiment could not be done, even under the highest 
levels of physical containment, under the proposed guidelines. 
(6) By defining an HV1 system in this way, the authors of the revised 
guidelines have effectively included recombinant DNA experiments 
carried out in wild type non -E . coli hosts among the list of "prohibited 
experiments". Certainly, the Advisory Committee could not have intended 
to place a Streptomyces coelicolor-Streptomyces lividans recombinant DNA 
molecule on the "too dangerous to be made" list while at the same time 
permitting the cloning of DNA from a wide variety of animal cell and 
viral sources in E^ coli K12 under minimal to moderate containment con- 
ditions. Yet, this is precisely the effect of the wording currently 
used in the revised guidelines. 
(7) The problem can be resolved simply by having the guidelines state 
that "wild type isolates of any bacterial species not known to be patho- 
genic to humans, to domestic animals, or to agriculturally important plants 
may be used as an HV1 host type vector system provided that all components 
of any recombinant DNA molecules introduced into such a host vector system 
are derived from other prokaryotic organisms within Etiologic Agent Class 1. 
Use of a non-E . coli HV1 system for the propagation of DNA derived from 
organisms other than those included in the Etiologic Agent Class 1, or 
which are derived from eukaryotic organisms, shall be subject to certifi- 
cation as described in the guidelines". I believe this modification of 
[Appendix A — 310] 
