17 
efficacy and safety is one of the worst examples of scientific 
research to be found anyv;here. And there are volumes of testi- 
mony given in various governmental hearings vvhich support the 
contention that lying, doctoring data, and a variety of un- 
savory practices have been common in the pharmaceutical industry. 
What is the basis for Dr. Singer's optimism? It would seem 
that if the potential risks are even no greater than those 
expressed in the Guidelines on the impact statement, one cannot 
rely simply on goodwill, the presumed pressure from, one's 
peers, scientific journals or the concern over liability. 
In order for the environmental impact of recombinant 
DNA research under the Guidelines to have been realistically 
assessed, it is at least necessary that all parties comply with 
the Guidelines. The Senate hearing on 22 September and ex- 
perience with the drug companies over the yea.rs argues against 
that assumption. As Dr. Singer stated in her letter of 17 
March, "However, the absence of sanctions will encourage 
sloppiness on the part of even well-meaning individuals and 
irresponsible behavior on the part of some others." 
Thus, while the impact statement mentions extension of 
the Guidelines by law, it is implicit that voluntary compliance 
is to be expected. Yet, it would appear that at this time, 
some six weeks after the impact statement was released, that 
this likelihood is a very unrealistic expectation. Therefore, 
Appendix K — 71 
