is presented. The basis for the assumption that harmful 
effects "should be extremely unlikely" (p. 63) is not supported 
by past experience and the NIH should present a full discussion 
and support its statements with empirical data from past 
experience. 
4. Again, there is a need for discussion of past 
experience when the DEIS states that the "NIH is currently 
supporting research designed to improve the ability to evaluate 
certain of these (laboratory-acquired infection) probc±>ilities" 
(p. 71) . VIhat does the literature to date suggest and what 
kind of studies are proposed? What aspects of containment 
failures are being investigated? These questions are never 
answered. 
D. CONTAINMENT TECHNIQUES 
Despite the very name of this impact statement, 
there is no discussion of the NIH Guidelines. There is no 
discussion of why various experiments were assigned to 
particular physical and biological categories. Indeed, the 
DEIS contains no discussion of the merits and limitations of 
physical and biological containment. The extent of the ability 
of containment techniques to control the escape of recombinant 
organisms is never discussed nor is their any mention of the 
success rates and historical incidence of infection using 
these techniques. Such a discussion is necessary because no 
physical or biological containment facility is fool-proof. 
-14- 
Appendix K — 94 
