bl 
All right, then, I 
would ask them again to 
of physical containment 
their five minutes will 
am going to turn to the invited witnesses, and I 
be as specific as possible in addressing the matter 
in their presentations. What they can save us from 
be gratefully received. 
Ms. Pfund, I think you are first. 
MS. PFUND: I don't have that much to say on this particular section, 
but one thing that occurred to me as we were learning about the various 
mechanisms for physical containment is that you have very elaborate grada- 
tions based on an increased degree of risk, yet when it comes to shipping 
these materials the increase in containment is more on the volume of the 
agent rather than on the degree of hazard, whether it is PI or P4 . I am 
just a little concerned that the regulations don't address the fact that 
there is going to be increased risk if we do have extensive mailing of 
these organisms around the country and abroad, or wherever. I think there 
ought to be a little more control on the shipping. For one thing, there 
might be some way of making sure the person you are sending it to also 
follows the Guidelines for this research, and as well, maybe increase the 
precautions you take as the organism you are using is increased in hazard. 
I don't see that anywhere in the revised Guidelines nor in the original 
Guidelines, really, and I think it is something that ought to be addressed, 
because I think as more and more are mailed around — I mean, there is a 
revision in these Guidelines in that you are using Registered Mail, which I 
guess is an improvement, because it means that the people receiving — well, 
the sender is going to receive notice that what he sent has arrived. But 
there is always the possibility that it will arrive in some state worse than 
it was sent in. So I just think that is a problem that needs considering. 
Also, in the containment introduction I still see some "shoulds" in- 
stead of "shalls," and while you may have changed some of the wording in 
the actual levels of containment, where you are talking about the training 
in aseptic techniques and the development of an emergency plan and the 
immunization of workers, it is all still "should." It is not imperative. 
You say the training "should" include aseptic techniques, biohazards com- 
mittees "should" develop emergency plans, and workers "should" be immunized. 
I would suggest that you make this a real commitment and make it explicit 
rather than just hope for the best. 
That is about it. 
DR. FREDRICKSON: Thank you, Ms. Pfund. 
Is the Department of Transportation member of the Interagency Committee 
here? Yes. I just wanted to ask you a question — to ask you to think about 
it. With reference to the shipment, these Guidelines refer to using the 
Public Health Service code. In the EMBO telegram to us, there is a feeling 
that there should be an international procedure developed for shipping recom- 
binant DNA molecules, and if you can't answer that now, perhaps later you 
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