Dr. W. J. Gartland 
- 2 - 
January 20, 1983 
acti nomycetes are clearly bacteria (prokaryotes) which with a 
few exceptions (e.g. some Acti nomyces and Nocard i a species) 
should be listed as Class T Agents . This blanket categorizing 
of acti nomycetes as Class II etiologic agents obviously affects 
the containment levels needed for rDNA experiments employing 
b. Containment levels for experiments involving exchange of DNA 
between species of streptomycetes are too high. None of the 
members of the ubiquitous streptomycete group of soil organisms 
is known to be pathogenic. Utilizing indigenous plasmids or 
phages as vectors, shotgunning cloning of DNA between species 
of streptomycetes should therefore be exempt from the guidelines. 
5 . In what ways are the Guidelines too stringent or too relaxed? 
Please see my response to question 4, above. 
6 . How frequently does your IBC meet? 
The UBRC holds regular quarterly meetings. It may also be called for 
ad hoa meetings, but this has not occurred recently. 
7 . Does your IBC have other responsibilities at your institution? 
If not, is it because of the way in which the NIH Guidelines are written, 
or is it because your institution has chosen to function this way? 
The Upjohn Company has chosen to function this way. 
Sincerely yours. 
No. 
Is it a general biosafety committee. 
No . 
Stephen B. Friedman, Ph.D. 
Chairman, UBRC 
SBF/kw 
[ 583 ] 
