132 
VII. ENVIRONMENTAL IMPACT OF THE GUIDELINES 
This section has been extensively revised in response to many 
points raised by the commentators and with a view to clarifying and 
updating the material generally. An effort was made to provide 
additional information, not only to answer substantive questions but 
also to provide more background so that readers would be better able 
to understand this section and to formulate their views. 
A. Impact of Issuance of NIH Guidelines 
Many commentators challenged the adequacy of the Guidelines to 
protect the public and the environment from alleged hazards of 
recombinant DNA research. This section of the EIS now states 
explicitly that a totally risk-free situation was not the aim of the 
Guidelines. The following subsection addresses this issue. 
1. Impact on the Safety of Laboratory Personnel and on the Spread of 
Possibly Tlazardous Agents by Infected Laboratory Personnel 
One commentator questioned whether the containment requirements 
of the Guidelines were adequate and based on firm knowledge of the 
risks and well-established principles of classification and containment 
[12]. Several recommended that documentation be provided to support 
the assertion that "potentially harmful effects from research with 
high-risk recombinant DNA molecules should be extremely unlikely, 
given strict adherence to the NIH Guidelines" [3, 12, 17, 20,26], One 
commentator also questioned the advisability of (a) permitting P3 -level 
research to be conducted in class III biological safety cabinets in 
facilities where directional air flow and exhaust air capabilities were 
not present and (b) not requiring secondary decontamination of waste 
water for Pi, P2, and P3 levels of physical containment [20]. Other 
commentators felt that the requirements for P2, P3, and P4 facilities 
should be made more stringent [12, 38]. In view of these kinds of 
questions, the text of this subsection of the EIS has been radically 
revised to document the adequacy of the containment requirements 
and to show the bases on which judgments in this regard have been 
made. For example, the discussion of past successes in conducting 
biohazards programs has been much expanded, in response to one 
commentator who explicitly criticized the Draft EIS for its lack of 
such documentation [20]. 
The physical containment safeguards required by the NIH Guidelines 
are based on the accumulated knowledge and experience in the area 
of biological safety that has been acquired over the last three decades. 
The EIS draws extensively on the experience at Fort Detrick in the 
containment of serious human pathogens. 
