Dr. Donald S. Fredrickson 
Page 2 
February 19, 1976 
One other aspect of plant work should also be incorporated into the guidelines in 
my opinion. That relates to containment of newly derived plant species, giving them 
adequate testing before allowing them to be planted in the field. The guidelines are 
quite adequate for the containment of plant cells, organelles and plant parts. Con- 
tainment presents no problem here as these have low replication rates, fastidious 
nutrient requirements, don't form aerosols, etc. My concern relates to the lack of 
guidance once a new plant is produced. We need procedures to ascertain if, in addition 
to the introduction of desirable characteristics, we haven't inadvertantly created an 
organism with undesirable characteristics. 
I feel therefore, that the guidelines should include restrictions on the release of 
plants from controlled greenhouse or growth chamber facilities until they could be properly 
tested through several generations while the plant is still contained. Once the plant is 
propagated in the field it may be too late. TWo areas where testing is warranted come 
to mind: 
1) . Plants and plant parts such as seeds and fruits should be tested to ensure that 
they are not toxic to animals which might be likely to eat them. 
2) . In the hoped for situation where the capacity for nitrogen fixation is introduced 
into new plant species testing should be done to ensure that these plants don't have a 
significant competitive advantage over other plants and thus become pests in themselves. 
We must assure ourselves that we don't produce a "super crab grass".' 
Sincerely yours. 
Professor 
MZ/mh 
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