274 
But let me turn lastly, because it is, I think the most important thing, 
to the issue of procedure. These Guidelines embody what, to a layman, appears 
to be enormous scientific ingenuity. But to a person who has spent a lifetime 
in regulation, they are pedestrian at best from the standpoint of control and 
regulation, and the concepts with which regulatory people are involved every 
day. The regulatory issues here are very simple. Indeed, compared to many in 
the rest of the Government, they are trivial. And yet there is no reflection 
in these Guidelines of the procedural aspects that, many have been concerned 
about, many of the people who appeared as witnesses. I have a specific 
suggestion, that just as you have an RAC to deal with the scientific issues, 
that you have a small ad hoc group of people who are concerned with procedure 
and who work every day in the area of regulatory procedure, who could offer, I 
think, some useful guidelines about the procedural aspects. 
Let me just list the areas that need further work in that. How are you 
going to devise a list of non-novel experiments? What procedure? Exemptions 
from the Guidelines. Future down-classification or up-classification of con- 
tainment, et cetera, levels. Certification of new HV systems. Large volume 
exceptions. Nominees for the RAC. Future modifications of the Guidelines 
themselves. These are not substantive issues; these are basic procedural 
questions. I don't think one procedure should be applied to all of them, but 
it would be a simple matter for a small group to sit down and work out these 
problems, literally in 24 hours. They needn't be too stringent. I certainly 
would oppose legalistic procedures; I would oppose the concept of having a 
body like this look at every revision. That can be done much more easily, and 
18 months ago in my letter I made some suggestions about those also. 
I think I have taken more than my time, Mr. Chairman, but I wanted to 
make those points. 
DR. FREDRICKSON: Thank you, Mr. Hutt. 
I do want the Committee to know that I read your letters 18 months ago, 
and I will be glad to furnish a copy of Section 361 and the Interagency 
Committee Report to those who would like to know another view of the useful- 
ness of that statute. But I certainly would not pretend to compete with Mr. 
Hutt's experience in that regard. 
Dr. Ann Vidaver, Department of Plant Pathology at the University of 
Nebraska. Dr. Vidaver. 
DR. VIDAVER: Thank you. I have some specific comments and some general 
comments. To begin with, the definition of DNA — 
DR. FREDRICKSON: I think you will need to speak up. Dr. Vidaver. 
DR. VIDAVER: Okay. I have both specific and general comments to make. 
Specifically the definition of recombinant DNA, both in the old or the present 
Guidelines and the revised Guidelines. Using the word "infect" I think has an 
unfortunate connotation and meaning. The word "infect" has a very specific 
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