Dr. William J. Gartland, Jr. 
January 20, 1987 
We support adoption of the proposal to clearly redefine 
recombinant DNA by revision of Section I-B. The concept 
that certain types of recombinant DNA experiments which do 
not involve the introduction of foreign DNA need not be 
subject to special regulation is an extremely important 
concept. Modification of the definition in Section I-B to 
define this concept insures that exemptions from special 
rDNA regulations will be applied throughout the research 
process and not only in the deliberate release phase. 
However, we would propose changes in the wording of the 
footnote to clarify what we perceive as ambiguities caused 
by the use of the words "organism" and "strain." It is 
unclear whether "organism" as presented in this context 
refers to organism at the genus or species level. The use 
of the word "strain" in this section is more restricting 
than current guidelines and creates confusion as it relates 
to Section III-D (Experiments which are exempt from Guide- 
lines) of the Guidelines. In an attempt to clarify these 
ambiguities we would propose the following wording for the 
footnote : 
Rearrangements involving the introduction of 
DNA from different species of an organism will 
be considered recombinant DNA, deletions, 
single-base changes and rearrangements within 
a single genome will not involve the intro- 
duction of foreign DNA and therefore would not 
be considered recombinant DNA. 
In the event that the RAC would choose to redefine 
recombinant DNA by revision of Section III-A-2 of the 
Guidelines, we would offer the same justification for 
changing the wording of the proposal (Section III-A-2-C) 
from "different strains of the same organism" to "different 
species of the same organism." 
IV. Dr. Frank Young proposes revisions of Appendices C-II, 
C-III, and C-IV which would permit the large-scale fermen- 
tation of E. coli K-12, B. subtilis , or S. cerevisiae if 
modified by recombinant DNA techniques under the same levels 
of physical containment as the unmodified organism. 
We support the proposed revisions which are significant 
changes that provide appropriate consistency throughout the 
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