So little detail is given about each alternative that it 
seems very unlikely that any alternatives to the Guidelines 
were seriously considered or will be considered in the future. 
The draft EIS makes no attempt to do cost/benefit analyses or 
weigh alternatives to determine which is best. 
The alternatives themselves are barely described. 
For example, the description of federal regulation does not 
consider the types of regulation which could be adopted such as a 
total moratorium on research or different safety standards. Possible 
systems of enforcement are not discussed. The agencies which 
might be able to regulate recombinant research are listed, but 
the differences in their statutory authority are not discussed. 
For example, the Occupational Safety and Health Administration 
is mentioned as an agency which could regulate recombinant 
research, but the discussion does not mention that OSHA can 
regulate laboratory conditions but not transportation of 
recombinant materials. Regulation by each agency, the President, 
and Congress must be discussed separately so that the public 
and other government officials are fully informed of the options 
for regulating recombinant DNA. 
The environmental impacts of the alternatives are 
not discussed in any detail. For example, the discussion of the 
alternative of providing no NIH support for recombinant DNA 
research, describes the impact this would have on American 
16 
Appendix K — 142 
