October 14, 1976 
Document 14 
The Director 
National Institutes of Health 
Bethesda MD 20014 
Dear Sir: 
I would like to make the following brief comments on the 
draft Environmental Impact Statement for the NIH "Guidelines 
for Reseairch Involving Recombinant DNA Molecules". 
1) In general, I see an EIS approach to guidelines which 
themselves are of no legal significance and can be enforced 
only by refusal or withdrawal of NIH funds as being absurd. 
In fact, this may be worse than no EIS at all, in that it 
may reassure the public that something is being done about 
potential hazards of recombinant DNA research when such is 
not the case. 
2) I feel the EIS is also Inadequate in that it does not 
evaluate the basic issues of the prospective risks and benefits 
of such research, and whether the risks may far outweigh any 
possible benefits. 
3) The options of federal monopoly over recombinant DNA 
activities and an international monopoly utilizing multi- 
laterally supervised sites ought to be included. 
4) I am particularly concerned that the possible use of recom- 
binant DNA research for the design and production of biological 
warfare weapons - and especially those which may be developed 
to attack only persons with specific genotypes (expressed pheno- 
typically as skin color, hair texture, etc.) - be discussed 
fully and appropriate provisions to prevent such use be made. 
5) In short - I think your guidelines and EIS are pure Mickey 
Mouse in the face of hazards that may be even more likely to 
occur and more devastating than nuclear warfare. What we have 
got to have quickly is national and international legislative 
control over all facets of this reseairch, with stringent 
penalties for those who ignore matters of public safety and 
the well-being of the biosphere. 
Sincerely, 
Margaret Puls 
901 Sherman Apt, 906 
Denver CO 80203 
Appendix K — 49 
