4 
all who contemplate doing recombinant DNA research will respect 
and comply with the Guidelines, as it is to assume that serious 
mistakes will never be made, or that accidents will not happen or 
that equipment will not fail. 
In challenging the validity of these underlying assumptions, 
I do not wish to imply that the Guidelines, if strictly adhered to, 
do not afford a considerable degree of containment of agents 
containing recombinant DNA molecules. I would, however, conclude 
that the authors of the Draft Environmental Impact Statement, by 
not being sufficiently imaginative and by not showing sufficient 
respect for the unknovm , have underestimated the nature and 
magnitude of some of the potential hazards ^ I would further conclude 
that through naivity and an idealism which assumes only the best in 
people, the effectiveness of the NIH Guidelines in reducing the 
potential risk to the public and the environment has been 
overestimated . 
I would now like to analyze each of these assumptions in 
detail . 
Assumption (1) Those drafting the guidelines aid the imp act 
statement were able to correctly imagine the nature and complete 
scope fo the potential hazards of recombinant DNA research . 
The Guidelines consider all of the anticipated types of 
recombinant DNA experiments and assign a risk to each, dependent 
on the presence of "harmful genes" (never adequately defined in 
the Guidelines), the assumption that "the potential dangers are 
considered to increase as the organisms providing the source 
DNA approaches humans phylogeneti cally" although many have questioned 
Appendix K — 58 
