160 
so that they do grow to flowering, seed-producing whole plants from a single 
cell stage in a number of plant species. But the input I had from the scien- 
tists I have talked to is that this is at an early stage of development, per- 
haps where the coli cloning of prokaryotic and also animal cells was one to 
two years ago, and it should be considered as likely to change very substan- 
tially. 
I would like to comment on some of the experimental Guidelines, that 
there are statements about the responsibilities of the institution and the 
committees that might imply that a safety officer would be required to hold 
the M.D. in order to carry out some of the evaluation of medical records. 
I would hope that there is freedom of the institutions to conduct these ac- 
tivities by distributing these functions, and that that was not an intention 
that the biological safety officer would be required to be an M.D. 
DR. FREDRICKSON: That discussion will be tomorrow, Dr. Bock. 
DR. BOCK: That will be tomorrow, very good. 
I think that is really all the comments I had at this point. 
DR. FREDRICKSON: Dr. Chilton, you do want to comment? 
DR. CHILTON: Yes. 
DR. FREDRICKSON: Please do so now. 
DR. CHILTON: I would like to address some remarks to the containment 
level that is ordered for the cloning of plant pathogenic bacterial DNA in 
the revised Guidelines. The treatment, it seems to me, is not a reasonable 
one. The containment level that is required for all such experiments, re- 
gardless of what type of bacterial pathogen we are speaking of, is P3+EK2, 
and it is clear that plant pathogens are not all of equal virulence or of 
equal agronomic significance, so it seems to me that we need to reconsider 
this . 
I would support strongly the classification of plant pathogenic bacteria 
which was recently proposed in a letter to the Director by four plant pathol- 
ogists, Drs. Kado, Panopoulos, Shepherd, and Bruening. These four experts 
recommended no higher containment than P2+EK2 for the cloning of plant path- 
ogenic bacteria, and they suggested that it should be taken into consideration 
where the cloning experiment is being done, and whether the pathogen that is 
being treated is a significant pathogen in that geographical location. For 
example, if you are in Alaska and you are cloning a cotton pathogen, then 
obviously the risk is considerably diminished over doing the same experiments 
in North Carolina. 
So I would strongly urge that we adopt the recommendation of these four 
experts. They suggest a containment level of no higher than P2+EK2 for all 
of these experiments — cloning of any type of plant pathogenic bacterium. 
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