183 
I think that is marvelously short and clear and broad. What I am asking 
is because this definition is broader, wouldn't you say that although some 
of the containment levels might be lower in France or other European coun- 
tries that might adopt this or a similar definition, that there might indeed 
be better containment because there would be areas not excluded from the 
definition. 
DR. FREDRICKSON: Dr. Tooze? 
DR. TOOZE: I think there is a lot to be said, indeed, for the French 
definition, and you can argue that that is a very simple definition where 
you don't have to put in a lot of exemption clauses. I think if a defini- 
tion occupies several pages, it begins to become a bad definition. 
Of course, this will include within recombinant DNA or genetic engineer- 
ing certain kinds of experiments. It doesn't necessarily include them inside 
their guidelines, which is the crucial question. 
DR. FREDRICKSON: And now, Ms. Simring, for your concluding remarks. 
MS. SIMRING: I would like to talk about the classification, to begin 
with, of the host-vector systems, on the basis of hazard to humans, which 
is the fundamental framework for the original Guidelines. It is based on a 
phylogenetic ranking — that is, overall risk to humans is assumed to decrease 
as phylogenetic distance increases. Although this framework of hazard to 
humans may be valid, it must remain still an assumption until there is suffi- 
cient scientific data to support it. Furthermore, many scientists have indi- 
cated that the assignment of levels of risk — that is, PI through P4 and EK1 
through EK3--within this framework is arbitrary. 
The NIH Guidelines do not adequately deal with the use of recombinant 
DNA in plants and animals. In a letter from Dr. Peter Day of the National 
Science Foundation [sic], he indicated that the 1976 Guidelines have "no 
classification system for pests and pathogens of plants and animals on the 
basis of their hazard to agriculture such as exists for etiologic agents of 
disease on the basis of their hazard to humans." And probably Dr. Chilton's 
problem derives from just this lack of classification. His letter, which 
reported the conclusions of a two-day conference of plant-animal scientists, 
urged the NIH to develop such a classification in the revised guidelines, 
but the proposed revisions, unfortunately, do not reflect this. 
Dr. Peter Albersheim — his letter was referred to earlier — a biochemist 
at the University of Colorado, has expressed concern over the use of the 
organism Agrobacterium tume fac iens in nitrogen fixation work. This bacte- 
rium causes crown gall disease in plants, and Dr. Albersheim raised a number 
of questions about the effects of modified strains on plants. This is just 
the kind of problem which needs to be addressed in an environmental impact 
statement . 
The report of the Environmental Protection Agency study group on recom- 
binant DNA, which I mentioned earlier in the day, was "concerned with the 
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