For persons who do not share your level of intimate knowledge of the 
Guidelines, the Federal Register notice regarding deliberate release is 
sene what incomplete . Although the current language of II1-A-2 is quoted on 
page 45651, the context within which it exists is not given, and neither 
grammatically nor logically can it stand alone. Is it an exception to a 
general rule? Is it a definition? etc. In other words, do the changes 
proposed (topics II and III of the notice) expand or contract the 
possibilities or ease of environmental release? While the naterial can 
certainly presuae that readers have a secondary education, providing context 
is at least courteous and, indeed, nay be essential for co-rprehers ibility . 
Substantively, I wish to address the guidelines relevant to gene 
deletions. I oppose relaxing the Guidelines on this point, as would occur 
under the definitions of "deliberate release" and or "reconbinant DMA" in 
topics II and III of the Register notice. My reasons are several: 
o Mo experimental evidence is cited in support of the proposal and 
even if the deletion of a gene in one species has only benign 
consequences this certainly is not scientific proof that the 
deletion of any other gene in that species, or any gene in 
any other species, would also be benign. 
o The proposal seers to be bottomed on logic instead of enpiricisn, 
and such logic could well be risleading and faulty although 
apparently straightfeward and simple (see ry article "Institutional 
Biosafety (remittees and the Inadequacies cf Risk Regulation," 
Science, Technology and Hunan Values , Vol. 9, Issue No. -9, Fall 
I9S-, pp. 16-34.) Sinplistic syllogisrs, such as are behind this 
deletion proposal, are not always valid. The reasoning seers to be 
A is harmless or of known harm 
3 constituent is harmless 
Therefore, A- 5 is no rore harmful. 
Yet if A is a moderate solution of lye (sodium hydroxide' and 3 is 
water, then the conclusion is false. If the syllogism need not held 
for inanimate substances, how can we rely on it for living material 
with all its additional vagaries and possibilities cf interaction. 
o The deletion of a gene would appear likely to result in the elimination 
of the production of any proteins that gene codes for, but dc we know 
it will have no effect on the coding sequences of other, perhaps 
adjacent, genes? I do not believe enough is known about intracellular 
interactions to reach a conclusion with certainty. 
o The deletion of a gene, and any proteins it helps to produce or 
regulate, could have substantial ecological effects by altering 
the organism's pool of available protein substances and thus. 
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Recornfcanant DNA Research. Volume 1 1 
