Document 15 
DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE 
PUBLIC HEALTH SERVICE 
NATIONAL INSTITUTES OF HEALTH 
BETHESDA, MARYLAND 20014 
October 15, 1976 
Dr. Donald Fredrickson 
Director 
National Institutes of Health 
Building 1, Room 124 
Bethesda, Maryland 20014 
Dear Dr. Fredrickson: 
I would like to make a few comments concerning the Environmental 
Impact Statement on Recombinant DNA Research Guidelines issued September 
9, 1976. 
My major concern is the absence of comment on what I consider to be 
the most detrimental impact that these guidelines will have on society. 
In many ways, reading the September 9 statement is very similar to 
what I imagine it would be like to read an environmental impact statement 
on a project to do away with the publishing media in order to reduce 
paper consumption and hence to protect our forests and watershed. While 
such protection is vital one would expect this imaginary impact statement 
to assess or at least mention the cost to society from the losses of 
free speech and individual freedoms that such a course of action would 
entail . 
The September 9 statement makes no assessment of the damage that 
will be done to intellectual freedom and hence society in the course of 
applying these guidelines in order to protect individuals from the 
"hazards" of recombinant DNA research. 
Virtually all of the public discussion concerning this issue has 
revolved around putative direct benefits (cheap antigens for vaccines, 
pharmaceutical production, crop improvement, pollution control, etc.) 
versus the putative direct hazards (pollution, novel disease organisms, 
increased concentration of deleterious genetic material in the environment, 
etc.). There are, of course, less direct consequences which our historical 
experience should lead us to recognize as being at least as likely as 
the so-called hazards associated with this work. 
Appendix K — 50 
