Dr. Donald Fredrickson 
October 12, 1976 
Page 4 
with DNA from insects is hardly an isolated case. Through pro- 
visions such as the use of embryonic tissue and 99% pure DNA 
that allow reductions in the stipulated containment level, broad 
classes of experiments involving the transfer of unknown genes 
into bacteria can be carried out at low levels of containment. 
Like the classification itself, the validity of these provisions 
has been widely questioned . 
But an even more critical factor with respect to possible 
harm to the public is the number of facilities engaged in gene 
transplantation. Even if the guidelines represented ideal pro- 
cedures, it is unrealistic to hope that the ideal will be univer- 
sally attained in hundreds of institutions across the country. 
The history of other hazardous enterprises which have proliferated 
shows that people have fallen short of the ideal, or the hardware 
has. People have off days, or they are under pressure (it must 
be remembered that this is a "hot" area of science) , and mistakes 
are made. Or mistakes are made even under ideal conditions, 
simply because nature is more complex and we are more fallible 
than we realize. The Draft Environmental Impact Statements states 
that infections that occurred at the army's biological warfare 
facility at Fort Detrick during the period 1925-1975 occurred as 
a result of "the absence of genuine efforts to control contami- 
nated air, liquid wastes, refuse, and laundry. "H If "genuine 
efforts" can be absent in a national biological warfare facility 
dealing with known pathogens, is it realistic to expect that they 
will be constantly present in hundreds of gene transplantation 
laboratories across the country when the risks are unknown to 
practitioners of the art? 
In the introduction to the guidelines, it is claimed that 
they "allow the research to go forward in a manner responsive and 
appropriate to the hazards that may be realized in the future. 
We conclude, on the contrary, that public safety is simply incom- 
patible with a policy of proliferation under the guidelines. The 
latter protects research to a much greater extent than they pro- 
tect the public. It may be argued that the guidelines will slow 
down the pace of research, or cause it to proceed "under a yellow 
light. But it is clear that the public would not tolerate 
unrestricted inquiry in this area any more than it would tolerate 
the free manufacture of nuclear devices. The guidelines generate 
an image of responsible science which may allay the fears of 
the public, but there are serious reasons for doubting that the 
precautions taken will be effective. 
II. Consideration of alternative courses of action 
The Draft Environmental Impact Statement considers some pos- 
sible alternative courses of action for this area of research and 
development. Our comments on the general characteristics of these 
alternatives follow. 
Appendix K — 33 
