III. COMMENTS ON THE NIH GUIDELINES 
A. Suininary of Coitunents and Reconmendations On 
The Guidelines 
The Guidelines should be designed to prevent any release 
of recombinant organisms into the environment. All recombinant 
research should be conducted in P3 and P4 laboratories, since 
NIH recognizes that PI and P2 laboratories are not designed to 
prevent accidental release. The Guidelines' system for classifying 
experiments on the basis of risk should be simplified. We do not 
now know enough about the hazards of recombinant DNA to determine 
which of thirteen containment systems a particular experiment should 
be assigned to. No more than three categories of hazard should 
be used. Finally, the enforcement provisions of the current 
Guidelines are weak. HEW should adopt revised Guidelines, which 
are regulations binding on all parties conducting recombinant 
research and which use a licensing system of enforcement. 
B . The Guidelines Should Be Designed to Prevent 
Any Release of Organisms Containing Recombinant 
DNA Into the Environment (Section II of the Guidelines ) 
At present we do not know enough about the behavior of 
the novel organisms which will be created by recombinant DNA 
techniques to predict the effects they will have on human health 
or the environment. However, the scientists who first called 
for a moratorium, abided by it and participated in the Asilomar 
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Appendix K — 145 
