Director , ORDfl 
Ru.9u.5t 
1937 
and footballs from break i n9 the 9ree nhou.ee . CIBh— bei'jy hoe a large 
research center near by . Therefore.* I suggest that- uRDR should -add a 
requirement that there shall be a mesh deflector at least 25 feet hi9h 
surrounding any 9reenhou.se that is less than 403 feet from home Plate 
of a baseball field.* or less than 200 feet from the nearest ed9e of a 
football field^ or hoc -feust -frono a <^o\f cov*r;<. , 
The Proposed containment Guideline does not Provide for adequate 
Protection of greenhouses from collision by vehicles. In Freder ick .* 
Maryland.* at Fort Detrick inside of the security fence.* there are 
Public roads. Public carriers such as city busses and ta is frequent 
these roadways. Persons employed at the warehouse near the existing 
research 9reenhou.se can tell you about Past collisions of vehicles and 
buildings at Fort De trick. I suggest that the guidelines should 
Provide for a definite minimum setback of the 9reenhou.se from 
roadways.* and also that curbs or barricades should be installed to 
P r e v e n t v e h icles f r o m c o 1 1 i d i n 9 w i t ki the 9 r e e n h o u s e . 
The Proposed Guideline does not require the FI or IRE to 
under tak e a car ef u 1 1 y contro 1 1 ed env i ro nme n t a l survey to est ab l i sh 
baseline levels of disease incidence on actual Populations who could 
by at t ec 
ted 
t lit a worst-case 
a. 
CCl 
dent. 
I su99e 
st that ORDR 
more 
c 1 ear l y 
address what survey 
are 
neces 
s ary . 
fis 
to 
surveys of Plant 
■=. 
nea 
r 9ree 
n houses > 
i t wou. l d be 
reas 
o 
nab l e 
to have 
a w 
iritten record of 
a. 
1 1 
sP ec i e 
s f ound • 
the radial 
dista 
n 
ce 
from the 
9r 
eenhou.se and comPa 
— • 
direct 
ion <to 
correlate to 
w i nd 
— • 
> j. 
signatur 
P IJ 
if the F'I or his 
de 
s i g 
nee on 
the re P 
ort > and own 
er sh i 
p 
of 
this dat 
a t 
o Pass immediate 
ly 
to 
the f 
edera l 9 
over nme Tit so 
that 
the 
P ub l i c m 
ay 
readily access a 
nd 
CO 
P y it. 
The Pr 
o p o s e d 9 u. i d e 
l i Tie 
i 
3 
vague > a 
nd 
it transfers some 
of 
the re 
sP ons i b i 
l l ty to cons 
u. 1 1 an 
t 
s , who 
have no 
d i r 
set compliance r 
es 
Pon 
s i b i l i 
ty to th 
e Pro i ect • a 
s the 
PI 
does. 
The Proposed guidelines do not address hazards of ProPane—9as 
heaters for greenhouses. RGR standards for 9as appliances were not 
developed for a Population consisting of biohazard containment zones.* 
but for norma l uses. The consequences ot a greenhouse explosion would 
be so contrary to GPDR's ob »ective that all necessary steps to Prevent 
it should be included. The Proposed guidelines Provide tor continuous 
monitoring of air pressure and flow only.* and only in BL4-P 
facilities. I suggest that language be added to require continuous 
monitoring for 9as in all greenhouses heated by natural 9as or Propane 
where recombinant BNR research occurs. It would be inequitable to 
Provide this life safety Protection to employees in only one class of 
facilities^ BL4- P. This requirement should apply to all classes- ot 
greenhouses . 
R l though in BL4-P it is Proposed to Put backflow Prevention 
devices on all liquid services* the guidelines wholly omit to Prohibit 
buried drains and liquid waste tanks under building slabs.* and the 
guidelines do not call for testing these for leaks and fixing the 
leaks. Most state Plumbing codes Prohibit discharges of Putrescible 
Recombinant DNA Research, Volume 13 
[343] 
