Dr. Gottesman said she felt it would be good to go through the 
same type of exercise with the plants as was done with the 
animals. This is to analyze what is actually being done by the 
proposal in relation to what currently exists in the NIH Guide- 
lines. She said her interpretation was that since pathogens for 
plants are not normally pathogens for humans or animals, essen- 
tially anything with whole plants, if less than two-thirds of the 
eukaryotic viral genome were being introduced was to be performed 
at BL1 . The rest would require review and approval by the IBC 
and would fall under the Section III-B category of the NIH 
Guidelines . 
Dr. Fedoroff said that was her interpretation, but there was no 
provision in the NIH Guidelines for working in an open green- 
house. Dr. Gottesman said the issue was really that a green- 
house was not defined in the original NIH Guidelines. Appendix P, 
paragraphs 72 through 161, provides a description of greenhouses, 
how to work with them, and what practices are appropriate. This 
would be new information. 
Dr. Gottesman said there were three things that had been done 
essentially. Paragraph 68 states that whole plants regenerated 
from cells in tissue culture, but still in axenic cultures, 
should remain exempt. If tissue culture is exempt, what would 
happen if a plantlet were regenerated from it? It previously was 
exempt in tissue culture. Dr. Tolin said this was merely a 
clarification, and it is just differentiated tissue. 
Dr. Gottesman said that a hierarchy of risk had been set up to 
place experiments in the Sections III-B and III-C categories of 
the NIH Guidelines requiring IBC notification and review and 
approval, and this was a change in the NIH Guidelines. 
Dr. Fedoroff said this would also act to give guidance to IBCs, 
and would clarify that experiments with exotic pathogens would 
require prior approval by the IBCs. Also, it allowed IBCs to 
reclassify experiments for containment requirements based on 
biological controls that are inherent on an experiment-by- 
experiment basis. 
Dr. Gottesman said she felt uncomfortable that some experiments 
could be performed at a given containment level without first 
being approved by the IBC but merely by notifying the IBC that 
the experiment was being done at that level. In the past with 
animal pathogens, approval of containment must first be looked at 
by the IBC. Dr. Tolin replied that currently with any experiment 
where only notification of the IBC is required that the IBC is 
still responsible to review the proposals. This can be done 
after initiation of the experiment. Based upon the biology and 
prior experience, the experiment could be stopped and containment 
raised. 
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