critics, NIH should consider both the comments that have been 
filed on the Guidelines and the published literature on the 
subject. NRDC attaches two articles which describe some of the 
risks foreseen by these critics. 
Finally, in discussing the impact of uncontrolled recom- 
binant DNA activities, the final EIS should discuss the extent 
to which the transportation of organisms with recombinant DNA 
molecules is currently regulated. Section II-C of the Guidelines 
states that transportation of recombinant materials is governed 
by regulations of the Public Health Service, the Department of 
Transportation, and the Civil Aeronautics Board. The final EIS 
should describe these regulations and point out the gaps in 
their coverage which might result in accidental release of these 
micro-organisms into the environment. For example, the PHS regu- 
lations (42 C.F.R. §72.25) apply only to etiologic agents listed 
in the regulation. If a micro-organism which is not listed 
were used as a host-vector in a recombinant experiment, it would 
not be subject to the transportation regulations. The hazards 
of transporting recombinant materials should be fully discussed. 
2. Impact of the Guidelines and Experiments Conducted 
Under the Guidelines (Sections VII-A and VII-B 
Of the Draft EIS) 
In considering the impact of the Guidelines and experi- 
ments conducted under the Guidelines, NIH makes two crucial 
13 
Appendix K — 139 
