Dr. Donald Fredricksoii 
October 12, 1976 
Page 6 
position paper speaks to these considerations more fully. To 
summarize our conclusions from these more detailed analyses: 
the risks from the use of recombinant DNA techniques are real, 
if not fully understood at present; the theoretical basis on 
which levels of containment have been assigned to experiments is 
questionable; the efficacy of biological containment is not yet 
assured; the adequacy of monitoring for vectors carrying foreign 
genes is not known and has not been generally instituted; monitor- 
ing methods have not been articulated in relation to the legal 
system. 
In this light, the most prudent course of action is to con- 
fine research in the immediate future to a single facility, oper- 
ated under the highest containment conditions and with the most 
extensive monitoring possible. 
The proliferation of laboratories naturally entails a mode 
of supervision and monitoring which relies on principal researchers 
and their colleagues. This is the method of supervision suggested 
by the guildlines. It is essential that the safety of any 
facility engaged in such novel and risky research be under the 
supervision of well trained, full time, professional safety of- 
ficers who are not themselves involved in biological research. 
These officers must have the authority and the will to shut down 
any project which does not comply with rigorous safety standards. 
It is unrealistic in the extreme to expect researchers, or their 
colleagues, to thoroughly enforce safety regulations in their 
spare time, upon themselves. 
It should be noted that the use of a small number of national 
laboratories with professional supervision of safety has proven 
very successful in the field of high energy research. 
Furthermore, the research effort should first be directed to 
the following areas: 
a) the development of a host organism that is not a resident 
of the normal human environment and does not exchange DNA with 
organisms in that environment. 
b) determination of the effectiveness of biological contain- 
ment with this new host organism. 
c) determination of the nature and level of the risks in- 
herent in gene transplantation. 
The Draft Environmental Impact Statement states that a policy 
alternative such as this one would make no distinction among 
experiments. That is true. With the possible exceptions noted, 
our present ignorance both of the risks of gene transplantation 
and of the effectiveness of precautions for containing them makes 
most distinctions meaningless. 
Appendix K — 35 
