COMi'-lENTS Oi^ Tllii DR.A.FT EM VI RONMENTAL 
IxMPACT STATEMENT FOR THE NTH GUIDELINES FOR RESEARCH 
INVOLVING PJiCOMLIHANT DNA MOLECULES 
Subraitted to the Di^rector of NIH, 18 October, 19 76 
by Burke K. Zimmerman, Ph.D. 
Staff Scientist 
Environmental Defense Fund 
1525 IBLh Street, N. W. 
Washington, D. C. 20036 
The Draft Environmental Impact Statement for the NIH Guide- 
lines for Research Involving Recombinant DNA Molecules discusses, 
among other topics, both the potential hazards and benefits of 
recombinat.nt DNA research per se , the environmental impact of 
recombinant DNA research performed as specified in the Guidelines, 
and alternatives to the issuance of the Guidelines by NIH. 
On page four of the introduction to the impact statement, 
it is stated, "In issuing the Guidelines, the NIH Director pointed 
out that they will be subject to continuous review and modification 
in the light of changing circumstances." The implication of this 
statement is that the Guidelines are the best we can do on the 
basi.s of existing knowledge, and that various parts of the Guide- 
lines may be either overly strict or not sufficiently stringent 
to protect the public health and the environment from any untoward 
effects resulting from recombinant DNA research. 
The impact statement then goes on to develop the argument 
that, in the absence of data, one must assume that recombinant DNA 
research poses a wide spectrum of potential risks to human health 
and the environment in general. It is further argued that if work 
is performed as described in the NIH Guidelines, there will be 
Appendix K — 55 
