I. 
INTRODUCTION 
In these comments the Natural Resources Defense 
Council discusses both the National Institutes of Health (NIH) 
Guidelines for Research Involving Recombinant DNA Molecules 
(hereafter "the Guidelines") and the Draft Environmental 
Impact Statement on the Guidelines (hereafter the draft EIS) . 
The comments on these two documents are combined because the 
issues raised overlap. Although the draft EIS and the Guidelines 
are discussed in separate sections the entire comment should 
be considered applicable to both. 
The Natural Resources Defense Council, Inc. (NRDC) 
is a not-for-profit, tax-exempt corporation Organized under 
the laws of the State of New York, with offices at 15 West 
44th Street, New York, New York, 917 15th Street, N.W., Washington, 
D.C, and 2345 Yale Street, Palo Alto, California. NRDC is 
a national organization dedicated to protecting human health 
and the environment. Among the methods NRDC uses to achieve 
its objectives are: (1) monitoring the activities of federal 
and state governmental agencies to insure that health and 
environmental values are fully considered in decision-making; 
(2) improving agency decision-making which affects public health 
and the environment by submitting written comments on agency 
programs, participating in administrative proceedings, and filing 
lawsuits where legal duties are not being fulfilled; and 
Appendix K — 127 
