13 
in any situation as unprecedented and novel as this, one could 
not possibly justify a statement as strong as the preceding one. 
A number of important issues are discussed above, which received 
little or no attention in either the Guidelines or the impact 
statement, demonstrating that the assumption that the full range 
of possible hazards had been adequately considered is false. 
Assumption (2) . All parties engaged in Recombinant DIJA research 
and technology will respect and comply v;ith the UIH Guidelines . 
Clearly, in order for the impact on the environment of 
recombinant DNA research conducted under the NIH Guidelines to 
be as it is stated in the impact statement, it is a minimum 
requirement that all such research be subject to the Guidelines. 
While Dr. Fredrickson, the Director of NIH, has called upon all 
government agencies, private institutions and industry to volun- 
tarily adopt the Guidelines, only the National Science Foundation 
has thus far given any formal commitment. The pharmiaceutical 
industry has, in principal, agreed that the safety measures 
outlined in the Guidelines are appropriate, but seemed unwilling 
to disclose all of its activities to the public — or competitors 
in the interests of the presumed right to secrecy of private com- 
panies. The implications of this attitude would seem to be 
rather serious if one assumes, as do I and a large segment of 
the scientific community, that any form of research and tech- 
nology should proceed only with the informed consent of the 
public. This is especially true if there exists even a remote 
possibility of undesirable 
Appendix K — 67 
