assumptions which must be discussed in the final EIS. Those 
assumptions are: 
1. That all NIK-supported research will be 
conducted in accordance with NIH Guidelines. 
2. That the Guidelines adequately protect the 
public from the hazards of recombinant research. 
NRDC does not agree with either of these assumptions. 
It is unrealistic to expect that all NIH grantees will voluntarily 
comply with the Guidelines fully, all of the time. Furthermore, 
we do not believe that the enforcement mechanisms of the 
Guidelines are adequate to insure a high level of compliance. 
Experiments conducted in violation of the Guidelines will pose 
the same hazards as experiments which are not covered by the 
Guidelines. Even a few non-complying experiments pose a risk 
to public health and the environment, because even one release 
of an organism with recombinant DNA could, if it survives and 
multiplies, cause spreading and unstoppable harm. The final 
EIS must evaluate the likelihood that the Guidelines will be 
followed and the risk to the public from non-complying experiments. 
NRDC does not believe that we know enough about the 
hazards of recombinant DNA to assume that the Guidelines, if 
followed, will adequately protect the public. These inadequacies 
of the Guidelines are discussed in detail in Parts II-B and III-C 
of these comments. 
14 
Appendix K — 140 
