Document 19 
NATIONAL SCIENCE FOUNDATION 
WASHINGTON DC 20550 
nsf 
October 19, 1976 
OFFICE OF THE 
ASSISTANT DIRECTOR 
FOR ASTRONOMICAL 
ATMOSPHERIC, EARTH 
AND OCEAN SCIENCES 
Dr. Donald S. Fredrickson 
Director 
National Institutes of Health 
9000 Rockville Pike 
Bethesda, Maryland 20014 
Dear Dr. Fredrickson: 
The draft EIS on "Guidelines for Research Involving Recombinant DNA 
Molecules" has been reviewed by the Foundation's Directorate for 
Biological, Behavioral, and Social Sciences. As Dr. Atkinson com- 
municated to you by letter of August 30, 1976, those sections of the 
NIH guidelines prescribing the conditions and conduct of research 
and defining responsibilities were adopted by the National Science 
Board on August 20, 1976, and will apply to all NSF-supported research 
involving recombinant DNA molecules. We have these comments to offer 
for your consideration in preparing the final EIS: 
0 We are pleased that in the Foreword (p. 4) to the 
EIS you emphasize that the guidelines will be sub- 
ject to continuous review and modification in the 
light of changing circumstances. 
0 The draft EIS includes all pertinent major topics 
with appropriate attention given to the details 
which apply to each of the same topics. 
0 The draft EIS (p. 71) points out that it is currently 
impossible to assign specific probabilities to events 
related to risk assessment and that NIH is supporting 
research designed to improve this deficiency. We 
feel the NIH efforts to generate new information per- 
mitting better risk assessments merit a fuller discus- 
sion in the draft EIS. 
0 The draft EIS gives little attention to research 
specifically dealing with recombinant DNA from plant 
Appendix K — 78 
