research in this field, but doesn't mention the environment. There 
IS no discussion of whether this would protect the public 
health and the environment better than the Guidelines. 
Several reasonable and important alternatives are 
not discussed at all. The possibility of a moratorium on 
all recombinant research is not discussed. Such a moratorium 
could be passed by Congress or by executive order governing 
federal agencies and federal regulation governing industry 
and other private parties. The alternatives of promulgating 
the Guidelines or similar safety standards as regulations 
binding on all parties conducting recombinant research is 
not discussed , even though the Department of HEW has the 
authority to promulgate such regulations. Section 361 of the 
Public Health Services Act (42 U.S.C. §264) gives the Secretary 
of HEW the authority to promulgate regulations to protect the 
public from communicable diseases. The draft EIS repeatedly 
recognizes that recombinant DNA activities may create or 
increase the virulence of infectious agents, making regulation 
under §361 appropriate. 
F . T he Draft EIS Does Not Discuss or Evaluate 
Any of the Long-Range Impacts of Recombinant 
DNA Technology 
By funding recombinant DNA research NIH is helping 
to launch a major new technology whose impact on man's environment 
17 
Appendix K — 143 
