-two- 
The NEPA states that "all practicable means" must be used to "assure for all 
Americans safe, healthful... surroundings" (§101(b2)). Since recombinant DNA research 
may lead to the creation of novel pathogens, monitoring of the escape and propogation 
of recombinant organisms is necessary for this kind of assurance. Not only does the NIH 
fail to establish a mechanism for the monitoring of recombinant organisms, but also 
its proposed means for detecting such organisms are highly questionable. Unsupported by 
any experimental data, the adequacy of the proposed methods is "not presently known" 
(Draft EIS, p. 72). The NIH offers no contingency plan for the control of pathogenic 
recombinant organisms. In the Draft EIS conditions are raised under which "reasonable 
means for minimizing further dispersal {of such a pathogen} could be undertaken (p. 72)." 
No such "reasonable means" are mentioned and indeed, they must be unknown to hospitals 
where the incidence of coli infection is increasing at an alarming rate. 
The single mention of research planned to assess the nature of dangers inherent 
in this line of research is vague. The NIH proposes only to "improve the ability to 
evaluate certain. . . probabilities" of events leading to the escape and propogation of 
a recombinant Escherichia coli (p. 71). The accompanying discussion of escape ignores 
such factors as carelessness or contamination of cultures, for example, and fails to 
recognize the need for a more long-range program of research to measure such probabilities. 
Generation of laboratory aerosols and the survival of presumably crippled hosts for 
gene manipulation are not the only problems to be discussed. To analyze the possibility 
of a dangerous accident requires that we investigate such apparently intractable questions 
such as whether recombinant DNA research would circumvent natural barriers to genetic 
transfer between eukaryotes and prokaryotes. 
The Draft EIS is limited in scope and does not "recognize the worldwide and long 
range character of environmental problems" as stipulated in the NEPA (§ 102(F)). The 
Draft EIS regards the industrial application of these techniques as necessary for 
realization of the potential benefits described in Scetion IV-C-2 of the Draft EIS. 
On the other hand, the NIH does not discuss either the possible dangers of the scaling 
up of recombinant DNA techniques to meet industrial production requirements or the 
environmental impact of such presumed "benefits". Since industry has already been 
stimulated by recombinant DNA techniques developed through NIH funding, the NIH cannot 
responsibly ignore these considerations. In addition, the Draft EIS fails to deal 
constructively with the problem of the application of these techniques to the development 
of biological warfare agents. 
A significant ommission from the Draft EIS is a discussion of techniques for 
obtaining large amounts of unique sequences of eukaryotic DNA by means other than 
the construction of recombinant hybrid organisms. Section 102 of the NEPA calls for 
"a detailed statement by the responsible official on. . . alternatives to the proposed 
action" to be included in the Environmental Impact Statement. Such a statement might 
begin with the fact that the first eukaryotic genes to be isolated were obtained without 
the use of a prokaryotic organism as a carrier (2). Other alternative techniques, 
such as the translation of DNA into protein, or the replication in large quantities of 
a purified segment of DNA, currently can be performed with measurable efficiency in 
cell-free systems. Clearly, there are experiments one might perform with recombinant 
DNA techniques which do not have readily apparent ^ vitro parallels. The questions 
such experiments intend to answer are not necessarily so remote that they cannot be 
approached from directions not involving the creation of novel organisms. Many in vitro 
techniques, such as the purification of DNA sequences coding for a particular messenger 
RNA species, are well within the molecular biology community's grasp within a few 
years time (3). 
The alternative of developing regional containment facilities geographically 
apart from areas high population density was slighted in the Draft EIS. The 
Appendix K — 169 
