Document 10 
Solomon Garb. m.d. 
C40I .^CST COLFAX AVENUE 
DENVER. COLORADO >0214 
October 8, 1976 
Dr. Rudolph G. Wanner 
Assoc. Director for Environmental 
Health and Safety 
Building 12A Room 4051 
National Institutes of Health 
9000 Rockville Pike 
Bethesda, MD 20014 
Dear Dr. Wanner, 
I find the Draft Environmental Impact Statement for NIH Guidelines for 
Research Involving Recombinant DNA Molecules totally unacceptable and deficient. 
I will list a few of the obvious omissions and criticisms. 
1. The statement does not include any useful quantitation of the number 
of laboratories that will engage in this research, the number of square feet 
involved, the number of personnel involved, or anything else that can give us 
a way to judge the true environmental impact. Obviously, if the research were 
to be carried out only at Fort Detrick, the environmental impact (and risk) 
would be considerably less than if 100 laboratories throughout the nation do 
this research. 
2. Absolutely no provisions are made for inspection by outside agencies 
to insure compliance. Only committees from the same institution make inspections. 
The inspection requirements for these exceedingly dangerous experiments are 
weaker in this respect than the inspection requirements for hospitals, pharma- 
ceutical manufacturers, meat-packers, restaurants, and even barbershops I 
3. No provisions are made for identifying epidemics that may result from 
escaped organisms, or to deal with such epidemics. 
4. Nowhere is there any provision for meaningful participation by epi- 
demiologists, disaster experts, public health officials, veterinarians, nurses, 
plant pathologists or the general public. The entire program was designed, 
manipulated, certified and promulgated almost entirely by scientists who have 
much to gain financially and professionally from the research. 
5. No provision is made to regulate the entry of new organisms into 
commerce. If a scientist produces a new organism which he considers useful com- 
mercially, what or who exercises any restraint on his decision to go ahead and 
produce and use commercial quantities outside the containment facilities? 
There are many other points and details in which the statement is deficient. 
Appendix K — 27 
