The draft EIS's discussion of impacts does not 
inform the public, in terms a layman can readily understand, 
of harm which may result from recombinant DNA research. The 
section on impacts merely describes the theoretical/mathematical 
bases for determining the probability that a particular hazard 
will occur. The discussion lists all of the events which must 
occur if an organism with recombinant DNA is to cause disease 
or environmental damage and states that the probability of harm 
occurring is the product of the probabilities of each listed 
event. But the draft EIS never goes on to describe specific 
damage which may be done to humans or the environment. 
The discussion of impacts states repeatedly that 
all of the hazards of recombinant DNA research are very speculative. 
The mere fact that impacts are speculative does not excuse NIH 
from discussing them in detail. As outlined above NIH can 
describe the hazards it sought to guard against in promulgating 
the Guidelines, and discuss hazards foreseen by critics of the 
Guidelines, to give the public a clear picture of the real 
impact of this new technology. 
E . The Discussion of Alternatives is Inadequate 
(Section VI, draft EIS) 
The discussion of alternatives is very sketchy. It 
reads like an after-the-fact justification of the Guidelines. 
15 
Appendix K — 141 
