important to prevent BL2-P biosafety level from being lowered to BL1-P, in 
which window screens are not required. 
171. We question that anyone can know how far "a distance ... an airborne virus 
or microorganism may be expected to be disseminated." This containment 
criteria should be removed, or "a distance" should be changed to "the farthest 
distance . " 
172. This containment criterion should not apply to spore formers, s' 5 nee they 
may readily survive the until wild hosts are available. 
173. The associated insect or animal vectors should be absent the facility 
and the surrounding geographic area. 
174. This criterion makes little sense. Many organisms require an obligate 
host in order to reproduce, but can survive long periods or disperse in the 
host's absence. For example, there are reports of rhizobia being found in 
fields in which no legumes have been grown for decades (cited in Hiltbold, et 
al., 1985), implying that microbes may survive for long periods in the absence 
of their host. 
As in the animal guidelines, the plant guidelines should provide for training 
of personnel (FR section 334), disposal of needles (223), and monitoring of 
waste/runoff (268). 
In summary, although the proposed animal containmnet guidelines should be 
adopted, the proposed plant containment guidelines are inadequate. As 
detailed above, we are especially dissatisfied with the guidelines for BL1-P 
containment and biological containment for microorganisms. We urge the RAC to 
incorporate our suggestions. 
Thank you for your attention. 
Yours truly, 
Staff Scientist 
References : 
Hiltbold, A.E., Patterson, R.M. , Reed, R.B. 1985. Soil Sci. Soc. Am. J. 
49:343-348. 
Recombinant DNA Research, Volume 13 
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