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RobinZ comments on Open Thread, September, 2010-- part 2 - Less Wrong
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S.J. O'Brien and J.J. Goedert (1996) (the paper cited by Vladimir_M) specifically references Koch's postulates. The accidental infection of laboratory workers is only one of five items cited in reference to (I believe) #3, "The cultured microorganism should cause disease when introduced into a healthy organism."