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committee of which you are a Cinderella member has been in place as the 
nontechnical advisory group providing citizen input to these decisions that 
we are talking about. Recall that during the time that we have been in this 
phase, this mode, we have been watching and waiting for legislation which 
prescribed all kinds of other remedies and hierarchical structures. It is 
partly for that reason that we have not a more baroque or highly constructed 
arrangement than we have today. But Ms. King's point is very well taken; 
one that must certainly be addressed because when you talk about lifting 
prohibitions and look at the range of prohibitions now, just the one alluded 
to here, that of releasing a recombinant product into the environment, would 
clearly require, doubtless, environmental impact assessments, statements, and 
a great many other decisions that would not reside here. 
MR. HELMS: I guess my point was simply that you did have a mechanism 
extant. In other words, there was another committee besides just yourself. 
You wouldn't take that recommendation from the — 
DR. FREDRICKSON: You are right, I certainly would not. 
Yes, Ms. Menard. 
MS. MENARD: I was wondering if I could ask Dr. Helinski for a clarifi- 
cation. If you maintain that the conditions for transformation of cells are 
not all that unusual, then why is work with naked DNA not more strictly covered 
in the Guidelines? 
DR. HELINSKI: You say why is it not? 
MS. MENARD: Well, if you maintain that the conditions for the trans- 
formation of cells are not that unusual, then why is the work with naked DNA 
not covered in the Guidelines? 
DR. HELINSKI: My reading of the Guidelines, that work with naked DNA, 
once extracted from the bacteria, are indeed included. The containment lev- 
el is greatly reduced, but they are covered. 
Secondly, I think it is well worth emphasizing again that E. col i K-12 
is a very unique organism with respect to tr ans formab i 1 ity . We can show 
t r ans formab i 1 i ty of E. coli K-12, but if you take a common intestinal tract 
organism, the so-called smooth strain of E. coli that we all have, I don't 
know of anyone who has been able to transform such E. coli. 
DR. FREDRICKSON: Other comments from the Committee, or questions? 
Dr. Chilton, do you have a technical comment here? 
DR. CHILTON: Yes, a question. You haven't spoken at all about the 
possibility of escape through the tr ansduc t ional route, that is the first 
point. The second point is, Are data being collected by field trials on 
the rate of escape in the sewage system, for example? 
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