6 
The Guidelines provide overlapping safeguards of both 
biological and physical containment. Thus, the recombinant 
host is a deliberately weakened organism for which the 
chances of survival outside the laboratory or conversion 
into a pathogen are negligible. Reinforcing the biological 
safeguards is the physical containment present in the four 
tiered laboratory system of the Guidelines. 
These safeguards are best described in connection with 
the specific dangers alleged by plaintiff in the present 
action. In responding to such allegations, the Society acts 
not as an adversary to plaintiff. Specific allegations 
simply provide a concrete setting in which to explain the 
biological and physical safeguards in recombinant DNA research. 
Plaintiff, in the Complaint, Memorandum Supporting the 
Motion for Temporary Restraining Order, and attached affidavits 
cites seven dangers to the Ft. Detrick experiment: 
(1) E^_ coli , the host organism is a 
ubiguitous organism residing in the 
human gut. Complaint K 9; Memorandum 
11 4; Affidavits 1| 3. 
Plaintiff's Complaint and the "expert" affidavits 
assert that the Ft. Detrick experiment will employ "the 
bacterium, E_^_ coli , which lives on land and in water all 
over the earth, and in particular is a common inhabitant of 
the large intestine of all warm blooded animals, including 
humans." Affidavits 113. 
"E. coli " , is the name given to a range of over 150 
strains of bacteria which have certain characteristics in 
common. In the numerous different strains, however, there 
are fundamental differences such as surface molecules, nutrition, 
growth rate and sensitivity to inhibitors. The differences 
determine the ability of different strains to survive in different 
[Appendix C — 148] 
