Document 11 
UNIVERSITY OF WASHINGTON 
SEATTLE, WASHINGTON 98195 
Department of Zoology 
October 12, 1976 
Dr. Donald S, Fredrickson 
Director 
National Institutes of Health 
9000 Rockville Pike 
Bethesda, Maryland 20014 
Dear Dr. Fredrickson, 
I am writing to comment on the Draft Environmental Impact Statement 
for the "Guidelines for research involving recombinant DNA molecules." My 
specific comment on the Impact Statement is that no mention (p 40-45) is 
made of the requirement that "An insect and rodent control program should 
be provided" for P-1 through P-4 levels (P 27912-27912, Federal Register 
Vol. 41, No. 131). The need to have such animal control programs is, I feel, 
a real one. I would like to see more emphasis given in the Impact Statement 
to the effects of such programs. This would serve to bring public and 
scientific attention to this important precaution. 
In general, I like the purpose and direction of the guidelines. However, 
I would prefer to see several additional safeguards in the next revision: 
(1) A requirement that recombinant DNAs be tested in animal models or in 
population competition experiments 
(2) that "antidotes" such as bacterial viruses be readily available to 
workers who become exposed to moderate or high risk recombinant DNAs 
(3) a recommendation that all recombinant DNA work in the United States 
be subject to regulation; 
(4) that provisions be made to verify that no work is being carried out 
for biological warfare with recombinant DNAs. 
Si 
Charles D. Laird 
CDL/hw 
Appendix K — 29 
