"Current knowledge does not permit accurate 
assessment of whether such changes will be 
advantageous, deterimental or neutral and 
to what degree, when considering a particular 
recombinant DNA. At present, it is only 
possible to speculate on ways in which the 
presense of recombinant DNA in a cell or 
virus could bring about these effects." 
41 Fed. Reg. 38429 
The draft EIS also lists thirteen events which must occur for 
a particular organism with recombinant DNA to cause harm. 
(41 Fed. Reg. 38438) . The probability that such harm will 
occur cannot be calculated unless the probability of each of 
the thirteen events can be calculated. Such precise determina- 
tions cannot now be made, but a classification system with thir- 
teen containment levels requires almost this level of precision 
if it is going to genuinely protect the environment from harmful 
organisms . 
Since the likelihood of harm cannot be calculated with 
precision, the Guidelines provide for the ranking of experiments 
on the basis of untested theories. These theories may be 
inaccurate or not comprehensive enough to be used as the basis 
for predicting risk. 
The central assumption underlying the classification 
system of the Guidelines is that most cells with foreign DNA 
from higher organisms are more hazardous than those with DNA 
from lower organisms. Therefore, more containment is required 
for experiments which take DNA from primates than those which 
22 
Appendix K — 148 
