log would be burdensome and would be inconsistent with the risk 
of experiments at that containment level. She suggested the IBA 
language be substituted for paragraph 89 as printed in tab 1290. 
Dr. Tolin underlined that this would only be for experiments at 
BL1-P . 
Dr. Pirone said he also had found Dr. Tolin' s summary an 
excellent aid to understanding the proposed changes in the NIH 
Guidelines. He suggested it be made available through some 
mechanism to the IBCs. 
Dr. Pirone said he was also confused about possible exceptions 
for some experiments which may be judged to be at the BL3-P 
containment level. When evidence of biological containment 
exists, it could be as safely performed at the BL2-P level. He 
said he felt this rationale should be more "up front" and 
suggested that paragraph 44 be deleted in its entirety, and the 
following wording be added to paragraph 46: 
"BL3-P or BL2 plus BC containment is 
recommended. ..." 
Dr. Gottesman said she thought paragraph 44 was still useful to 
have in the document. Dr. Pirone agreed saying the suggested 
wording could be added to both paragraphs 44 and 46; but he 
wanted it in paragraph 46. He felt this would be more consistent 
and put the issue up front for both the investigators and the 
IBCs. Dr. Tolin said she thought this was the intent of the 
working group. 
Dr. Richardson pointed out an inconsistency with paragraphs 108 
and 114. Paragraph 108 offers no alternative to autoclaving 
plant materials at BL2-P, whereas paragraph 114 provides alter- 
natives to autoclaving. Dr. Fedor off asked Dr. Gar t land to 
assure that these two were consistent. 
Dr. Richardson asked if there was scientific justification for 
high efficiency particulate air (HEPA) filtration of exhaust air 
from the BL3-P facility as is required in paragraph 133a. 
Furthermore, in paragraph 160, there were provisions which 
required a back-up source of power, meaning an emergency 
generator, at BL4-P which would exceed requirements for maximum 
containment laboratories working with such hazardous materials as 
Lassa fever virus. 
Dr. Fedoroff said she felt the whole category of BL4-P was 
unnecessary. She felt the requirement for a back-up power source 
could and should be eliminated. She added that the requirement 
for an autoclave was something that had come up in the original 
version of the document and should have been stricken in the 
final version. Dr. Fedoroff said that the IBA letter had also 
contained some suggestions on changing the wording of the second 
[76] 
Recombinant DNA Research, Volume 13 
