SELECTED ISSUES FOR COMMITTEE REVIEW 
I. Introduc tion: Definition and Exemp tions 
The definition and exemption for "non-novel" exchangers evoked 
much public comment in which a number of recommendations were made. 
For example, it was urged that the definition be expanded to include 
segments of chemically synthesized DNA. Much of the comment 
concerning the exclusion for non-novel exchangers pertained 
to the proposed standards and procedures for developing a list. 
The public views concerning the definition and exemption included: 
• that safety rather than novelty should be the criterion for 
exclusion ; 
• that the criteria for determining novelty were not explicit; 
• that the list of non-novel exchangers should not be limited to 
the exchange of chromosomal DNA but should also include plasmid 
exchange (others, however, urged that the list not be broadly 
drawn at the species level but should deal with exchange at 
the subspecies level); 
• that experiments classified as PI + EKl should be exempted 
from the Guidelines; 
• that the proposed revised definition would appear not to permit 
"self-cloning" experiments. 
Recommendations on the process for developing a list included: 
• that the burden of proof be on the Director to compile a list of 
[ 502 ] 
