Comments on NIH's Draft EIS for Guidelines 
for Research Involving Recombinant DNA Molecules 
The draft EIS with its supporting appendices which include 
the guidelines represents enormous and commendable effort 
to protect workers, the public, and the environment from 
infection by possibly hazardous agents that may result from 
recombinant DNA research. In most instances, the EIS and 
appendices are as clear, concise, and complete as may be 
possible under present conditions of uncertainty and 
speculation about the benefits and risks likely to result 
from this relatively new field of scientific investigation. 
Generally, the soundness of the documents can be appraised 
by reasonably educated citizens without feeling a need for 
expertise in molecular biology. However, in several instances 
more references or other assistance are needed to help a 
reader of the EIS know when a statement is based on real and 
published data, on speculation, or on opinions . ref lecting 
common knowledge among experts. 
Detailed comments provided below point up uncertainties we 
find in the EIS and the guidelines. The comments reflect 
era's major concerns about the limited scope of control, 
inadequacies of current ability to confidently assess 
probability of hazards, and the lack of emergency contingency 
plans for mitigating effects of a spill of infectious 
material outside a laboratory. 
As mentioned above the first major concern is the limited scope 
of control provided by the guidelines. For example, the guide- 
lines apply only to NIH-funded investigators who are expected 
to enforce rules having no weight of law. Investigators funded 
by the private or industrial sector are expected to comply only 
as they volunteer to do so. Consequently, we find no way to 
estimate the real or potential effectiveness of these guidelines 
to control much of the recombinant DNA research. 
We are also concerned about the lack of reference to any exist- 
ing or recommended plan for emergency teams of specialists 
equipped and ready to respond promptly to accidental spills of 
possibly infectious agents shipped by public or private carrier. 
Pages 2740 and 2941 make it clear that such accidents are 
expected to be reported to the shipper and to the Biohazards 
Control Office of the Center for Disease Control in Atlanta, 
Georgia. However, we find no indication of who might be 
responsible, trained, and equipped for local actions fOr 
cleanup, decontamination, or monitoring for possible threat to 
public health following such an accident. Advance planning for 
such contingencies seems essential. 
Appendix K — 161 
