Dr. Fredrickson 
-3- 
October 15, 1976 
We have historical experience with institutionalized systems which 
are not dependent on documentation or consensus for their "facts". 
Witness the House Unamerican Activities Committee hunt for wrong-doers 
or the Salem Witch trials. It is a dangerous precedent to institutionalize 
a program to establish what can and can't be done ("right" and "wrong") 
based on a political polling procedure without documentation or consensus. 
Can we be confident that these historical precedents will not be repeated - 
again, here in America? 
These guidelines can be expected to expose society to real hazards 
to their individual freedoms. If the putative hazards from recombinant 
DNA research are thought to be real and large in magnitude, it is conceivable 
that we should be willing to risk these freedoms to insure against such 
a biological hazard. I think the NIH Environmental Impact Statement 
should face this issue because of its gravity and should include the 
NIH's assessment of the cost that these guidelines will impose on intellectual 
freedom. It seems to me particularly important that the NIH spell out 
why they feel this is an exceptional case which warrants the abandonment 
of the normal criteria for documentation or consensus in the assessment 
of a hazard. 
Secondly, I think the NIH impact statement needs to acknowledge 
that the guidelines represent a serious drag on the research in this 
area. We should not deceive ourselves and think that this work can 
proceed as vigorously under the severe constraints imposed by these 
guidelines. Therefore, the impact statement should include the NIHs 
assessment of the reduction in research vigor that these guidelines will 
entail . 
Associate Professor 
Department of Bacteriology 
Curriculum in Genetics 
University of North Carolina 
Chapel Hill, North Carolina 27514 
on sabbatical 
NIH, NICHD 
Appendix K — 52 
