6 
Dr. Johnson wrote that "With the large-scale containment classif ications 
a formal part of the guidelines, it seems to us that an unnecessary con- 
straint is placed on the IBC in its interpretation of 'appropriate' contain 
ment i.e., there are no choices other than Pl-LS, P2-LS, or P3-LS." 
Dr. McGarrity noted that Dr. McKinney had commented (tab 1121) on this 
proposal in a letter to the RAC. The comment encouraged the RAC to reject 
the proposal and to retain the current provisions of the Guidelines. 
Dr. McKinney stated in his letter: 
"The Guidelines provide adequate guidance for establishing con- 
tainment levels and reflect practices appropriate to these levels. 
...the Guidelines provide Institutions and the NIH the necessary 
degree of oversight for activities involving large-scale research 
or production with organisms containing recombinant DNA. This 
oversight is viewed as essential for activities in which the NIH 
is a participant." 
Drs. McGarrity and Wensink agreed with Dr. McKinney's observations. 
Dr. Wensink suggested that RAC might on a case-by-case basis recommended 
exempting certain E. -coli strains from Section III-B-5. Dr. Gottesman 
said the IBC already possesses leeway in prescribing containment 
conditions for large-scale experiments. 
Dr. McGarrity summarized a letter (tab 1124) submitted on September 14, 
1983, by Mr. Max Marsh of Lilly Research Laboratories in which he offered 
an alternative rrodification of Appendix C to Dr. Johnson's proposal. 
Mr. Marsh's letter requested that these proposals be referred to the 
Large-Scale Review Working Group for evaluation. The letter suggests the 
particular issues in large-scale operations that might be evaluated by the 
working group including the use of less expensive but highly effective 
filters in the exhaust air system of the fermentors. Dr. McGarrity noted 
that Mr. Marsh's letter contained documentation, but he felt the data were 
sparse. Dr. McGarrity also noted that the data on the survivability of 
microorganisms in aerosols were generated using E. coli ; E. coli is very 
susceptible to dehydration. These data should not be extrapolated to 
S. cerevisiae or to B. subtilis which are more resistant to desiccation. 
Mr. Marsh said the costs of Pl-LS are economically significant for new 
facilities. 
Dr. McGarrity said he did not intend to offer a motion concerning the 
proposals. Mr. Mitchell said the issue should be referred to the Large- 
Scale Review Working Group. As no motion was offered, the discussion ended 
IV. PROPOSAL TO INCLUDE STREPTOCOCCUS MUTANS IN SUBLIST F OF APPENDIX A 
Dr. Gottesman began review of the proposal (tabs 1115, 1116, 1117/III) of 
Dr. Francis Macrina of the Medical College of Virginia of the Virginia 
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