Unless and until something goes badly, and identifiably, wrong in 
a recombinant DNA experiment, the regulation of this rapidly moving field is 
likely to be dominated by biologists. It becomes very important that the base 
for concerned biologists not be only those deeply involved in recombinant work. 
Wherever it is applied, regulation produces anguish. FAS sees this in every 
field in which it urges regulation v^ether it be in the Defense Department, 
HEW, State, Industry or wherever. It would be naive to conclude that the recombinant- 
interested biologists will not tend to apply a special standard to regulation 
that affects themselves. 
III. oonveniq«:e is not a public health standard 
Recombinant DNA safety standards should not weigh heavily the inconvenience 
to involved biologists of traveling to, or functioning in, high containment 
facilities. 
FPS does not weigh heavily — nor should the Nation — the onerous 
obligations placed on reactor operators or those which should be placed on industrial 
creators of toxic substances. It is counterargued that biological experiments 
restricted to inconvenient containment will not be done, much as reactor engineers 
considered that certain safety precautions would make nuclear power uneconomic. 
But neither position is tenable in the calculus of public health considerations. 
It is also argued that biologists wDuld go abroad to do experiments rather than 
do them in high containment here. But surely containment at any plausible level 
can be arranged geographically and institutionally so as to be more inviting 
than moving abroad — for most scientists. In any case, again, reverse brain 
drain is not a public health consideration. 
IV. A HIGH PRIORITY SHOULD BE GIVEN TO RE>DVING UNCERTAINTIES 
"Recombinant DNA regulation should give a very high priority to removing 
uncertainties surrounding potential biohazards by funding and encouraging 
suitable ejqjeriments." 
A number of FAS expert advisers are suprisingly confident that critical 
uncertainties can be resolved by experimentation. But especially because uncertainties 
can often only be reduced by rather dull work, incentives and priorities may 
be necessary to ensure that it is undertaken. The large number of uncertainties 
involved can be gauged by reading pages 38429-38431 and 38938. We must combat the 
human and institutional tendency to argue about speculations rather than to resolve 
uncertainties. 
V. IMPACT STATEMENT SHOUID BE MORE EXPLICIT ABOUT CONTAINMENT COSTS 
"Permanent Recombinant DNA regulations should not be tacitly based 
on the unavailability of suitable containment facilities if these 
can, in due course, be constructed. Nor should it be explicitly based 
on the expense of such facilities unless these costs are thoroughly 
revealed to permit their review by Government officials sufficiently 
high to obtain the necessary funds if they wish to do so. 
For $50-60 million ten regional P-4 laboratories the size of that 
at NIH (10,000 usable square feet) could be constructed. For another $50 million 
many local P-3 labs could be built. The total sum here is the anticipated price 
of a single B-1 bomber (in a fleet of 250) . It is entirely possible that 
high Government officials would consider the investment in these laboratories 
appropriate to the potential danger and possible benefit of this research. 
I certainlv do. Nevertheless, it is evident from the Imoact Statement (see 
Appendix K — 43 
