since the estimated impact depc^nds upon "strict adherence 
to the NIH guidelines" (page 63), :i t cannot be expected that 
the estimated environmental! impact of recombinant DNA research 
performed with the guidelines in effect is at all realistic. 
The foregoing analysis would argue that extension of the 
Guidelines to all parties by Federal regulation on lav,’ may be 
the only way maximum compliance may be expiected. But Dr. 
Singer further points out "that neither a legislative nor non- 
legislative approach can assure absolute compliance from those 
who purposefully flout the Guidelines." A truly comprehensive 
impact 'statement should have indeed considered the environunental 
consequences of those who purposefully flout the Guidelines, 
as well as the possible deliberate misuse of recombinant DNA 
techniques. The impact statem,cnt on pages 31-32 only states 
that an analysi.s of such unknown quantities is "hypothetical 
and difficult." Yet the entire contents of the impact state- 
ment dealing with potential risks and benefits is equally 
speculative, a situation v;hich did not prevent conclusions 
from being drawn concerning the effectiveness of the Guidelines. 
Not only is this inconsistent, but, at a time of considerable 
international tension, especially among smaller nations, it 
is not out of the question at all to suppose that the relatively 
easy and inexpensive development of possible biological weapons 
through recombinant DNA technology might well be preferred 
over the development of atomic weapons as a route to presumed 
power. The impact statement avoids consideration of such 
questions entirely. 
Appendix K — 72 
