Dr. William Gartland 
and vaccines. We favor the proposal by the RAC's Working Group on Definitions 
to amend Section III-A-2 by adding parallel sections to be written as 
Appendices M, N. and 0 covering respectively animals, microorganisms, other 
than vaccines, and vaccines. We also urge appropriate Federal, private, and 
public involvement in the preparation of the criteria for these new 
Appendices . 
During the December meeting, the RAC Working Group on Definitions passed a 
motion concerning changing the definition of recombinant DNA. It was felt 
that certain types of such experiments which do not include the introduction 
of foreign DNA need not be subjected to these Guidelines. Of the two options 
presented, we favor option 2 for the following reasons. The proposed 
modification of Section III-A-2 provides clear, concise and much needed 
clarification of the concept that deliberate release is essentially a 
dangerous event. The proposed use of describing such releases as "planned 
introductions" under accepted scientific practices in which there is adequate 
evidence of biological and/or physical control of the recombinant organisms is 
consistent with Departmental, environmental, and safety concerns. Although 
the proposed changes would exempt experiments involving deletion derivatives, 
single base changes, rearrangements and amplifications within a single genome, 
these same types of experiments would still require other Federal agency 
review and approval before release from containment. 
The final proposal in this notice deals with reducing the physical containment 
requirements for low risk microorganisms used in industrial fermentations. 
We support Dr. Frank Young's proposal to reduce unnecessary containment 
procedures currently described in BLl-LS for such large scale fermentations. 
We feel that the containment conditions need to be no greater than those 
employed for unmodified host organism experiments. 
Sincerely 
Administrator 
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