Conference all assigned that some serious and widespread harm 
might result from the use of recombinant DNA technology. Since 
it is impossible to predict with any accuracy which organisms 
are hazardous, all organisms with recombinant DNA must be pre- 
sumed to pose a risk to humans and the environment if they 
escape from the laboratory. 
The role of the Guidelines must be to prevent any 
release of recombinant DNA. Although the Guidelines prohibit 
the intentional release of recombinant organisms, they assume 
that a certain amount of accidental release can be expected in 
PI and P2 facilities. The draft EIS in describing the protection 
provided by PI and P2 facilities states: 
"These measures do not provide absolute 
protection from exposures and the required 
primary barriers can be compromised by lack 
of attention to technique, poor placement 
of equipment and human error." 41 Fed. Reg. 
38436. 
The draft EIS goes on to explain that NIH assumes 
that such exposure will not harm the laboratory worker because 
only organisms which have been rated low or moderate-risk can 
be handled in PI and P2 laboratories. There is no scientific 
basis for assuming that organisms which are rated low-risk by the 
NIH classification system will in fact prove harmless. 
Since PI and P2 facilities are not designed to prevent 
all accidental release of recombinant organisms, recombinant 
20 
Appendix K — 146 
