Dr. Fredrickson 
- 2 - 
October 15, 19/6 
Consider the precedent that is being set by most of the guidelines. 
The guidelines seriously constrain many experiments for which there is 
neither documented evidence for hazard nor consensus within the community 
that such inquiry would be hazardous. If we accept the principle that 
recombinant DNA research can be prohibited or severely limited in the 
absence of documentary evidence or the absence of consensus that such 
inquiry would be harmful we would be forced by consistency to accept 
this principle for any scientific inquiry. I claim that a scenario 
leading to world-wide disaster can be constructed concerning any scientific 
inquiry. Hence all science would, by accepting these principles, become 
subject to political veto. While it is totally appropriate for society 
via its political apparatus to decide on what it wishes to fund and not 
fund it seems inappropriate to prevent everyone within the scientific 
community from doing such work. I recognize that the guidelines technically 
only apply to the NIH funded research but it is clear that the rules are 
intended to apply to everyone doing science in the United States. 
Let me give an example of how these regulations could be logically 
extended to areas of research we currently feel should continue. Consider 
research involved with synthetic chemistry. While one can project the 
likely result of a given set of reactions it is not possible to be 
certain what compound will be created in a new chemical reaction. 
Therefore, one cannot be certain that the new reaction will not create a 
powerful new toxin or mutagen. Such a new mutagen when released into 
the sewage system could alter the genetic makeup of an existing disease 
producing organism rendering that organism more virulent and less susceptible 
to treatment with known drugs. If we follow the precedent of the recombinant 
DNA research guidelines and ignor the likelihood of such an event, 
shouldn't we establish a mori tori urn on all synthetic chemistry until we 
can design containment laboratories and "suitable" protocols which will 
be required for all such research? 
While I could dwell on the more direct costs to our health-directed 
research capacity caused by the abandonment of the consensus or documentable 
definition of hazard, the most serious effects are likely to be more 
subtle. We have historical experience with institutional regulation of 
scientific inquiry in order to protect the public welfare. Two notorious 
examples are the regulation of genetic research in Russia during the 
40 's and 50 's and the regulation of scientific inquiry in Italy by the 
Inquisition. It is popular to view these events as an example of villians 
imposing their will on the innocent for purely tyrannical purposes and 
therefore not applicable to our situation. I think the historical 
evidence tells us that these institutions were in the end controlled by 
such individuals but that in the beginning they were established by 
sincere well-meaning people truly concerned with what they thought to be 
the best interests of the public. 
Appendix K — 51 
