simpler document was needed to express the RAC's conclusions on 
these matters. 
Dr. Tolin responded that part of the complexity is the form in 
which the NIH Guidelines are written. The major classifications 
are based not on biosafety, not on the organism, not on the 
potential risk of an experiment, but rather on who gives approval 
and what approvals are required. She disagreed that the RAC 
should not deal with the issue of large animals and plants. The 
NIH and other Federal agencies fund research in these areas and 
other Federal agencies also comply with the NIH Guidelines. 
Further, Dr. Tolin said that when the USDA attempted to draw up 
its own set of guidelines, it was told that there should be one 
set of guidelines for the Federal government. Dr. Tolin said 
that IBCs have been asking for guidance in these areas. This is 
an attempt to assure both the public and the IBCs that contain- 
ment levels are consistent and appropriate for the safe conduct 
of research. 
Dr. Johnson said he agreed with Dr. Davis on the issue of the 
complexity of the document. He added that he believed the 
purpose of the NIH Guidelines is not to impede work but to 
stimulate it. He said he believed this proposal would have the 
effect of impeding future work. 
Dr. Gottesman said she wanted to propose the RAC accept the 
changes with respect to animals. She believed that the way to 
proceed was to start moving things into exempt categories or 
categories requiring less review as a step toward stimulating 
research. 
Mr. Mitchell asked Dr. Gottesman to refer specifically to tab 
1290 and the paragraphs if she were making a motion. Dr. 
Gottesman said the new information which would be added would 
start on page 11 of tab 1290 and would include paragraphs 17, 21, 
25, and 29. All of these refer to simply changing BL1-4 to BL1-N 
through BL4-N . The next change would be in paragraph 32, 
changing the title of Section III-B-4 from "Whole Animals and 
Plants," to "Whole Animals." Paragraph 34, 37, 41, and 182 
through 341 would be added as well to the NIH Guidelines. 
Dr. Gottesman made this in the form of a motion. 
Dr. Walters asked Dr. Gottesman to accept as a friendly amendment 
that the definitional language in the text being moved be dupli- 
cated at the beginning of Appendix Q. Dr. Gottesman agreed with 
the friendly amendment. Dr. Musgrave asked that paragraph 285 be 
amended to have the age mentioned therein changed from 18 to 16. 
Dr. Gottesman accepted this also as a friendly amendment. 
Dr. Epstein seconded Dr. Gottesman 's motion. 
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Recombinant DNA Research, Volume 13 
