Dr. Donald Fredrickson 
October 12, 1976 
Page 3 
to progress rapidly."® In judging this position, it must be 
borne in mind that gene transplantation may result in irreversible 
damage to ourselves, to future generations, and to the biosphere 
on which we all depend. Policy decisions in this area cannot be 
given responsible form through compromise. For compromise evades 
the question of whether proliferation increases risk and which 
values must take precedence. 
We conclude that the central question of policy for genetic 
manipulation research and development has not yet been faced, 
and that real participation by the public in policy decisions 
has yet to occur. Under the present conditions — proliferation 
of facilities under the guidelines — policy continues to be made 
by default. The longer this situation continues, the more diffi- 
cult it will be to effect a change of policy, should that be 
judged necessary. Only an immediate moratorium will leave open 
policy options so that the public has the freedom to make a mean- 
ingful decision on a matter which vitally affects its interests. 
The following discussion addresses the implications of the 
present proliferation, and considers alternatives, and the role 
of the public in making the final decision. 
J. Inadequacy of the present policy of proliferation 
under the guidelines 
According to the Draft Environment Impact Statement, the aim 
of the guidelines is "the protection of laboratory workers, the 
general public, and the environment from infection by possibly 
hazardous agents that may result from recombinant DNA experiments." 
Supporters of the guidelines are confident that this objective 
has been met. Implicit in the introduction to the guidelines is 
the claim that the classification of the risks has been appropriate 
and the precautions for the containment adequate.® But what is 
the foundation for this claim? Not, it would seem, the assurance 
that the guidelines are based on firm knowledge of the risks and 
well established principles of classification and containment. 
As we show in the accompanying position paper, each of those 
principles lacks scientific confirmation.® Nor has either princi- 
ple been subjected to the scrutiny, involving full publicattion 
of results and thorough empirical and theoretical consideration 
of alternatives by the entire scientific community, usually re- 
quired in science. The votes of the NIH guidelines committee 
on containment levels and authenticity of "weakened" strains for 
biological containment — which appear to be the source of confi- 
dence in the guidelines — are no substitute for normal scientific 
practice . 
Furthermore, despite the absence of hard facts about the 
risks, the guidelines allow many experiments to proceed with 
minimal precautions. The notorious classification of experiments 
Appendix K — 32 
