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RSFUCNANCIES ANE 7ACTITIES TO THE ERAFT ^:^^raOM■rENTAL MPACT STATEMENT ON 
"GUIL’ELINES FOR RESEARCH EVOLVING RECOMBINANT DNA MOLECULES"^ 
o 
li. Douglas DeNike, Ph.D. 
Sierra Club - Angeles Chapter 
2 UIO West Beverly Boulevard 
Los Angeles, California 90057 
"When there are no regulations governing an activity, it is reasonable to say 
that this activity is unregulated, " 
"Microbes do not have morals," 
"The law of the jungle is fine — if you happen to like living in a Jungle," 
"There are plenty of creatures here who would not hesitate to eat you, if only 
they knew how. Your job is to keep them from learning how," 
"Botulinum toxin, the most potent biological poison known, causes fatal neuro- 
muscular paralysis in most vertebrates, in nanogram quantities." — Kao, 
Drachman, & Price, Science. September ?U, 1976, p, 1256, 
* * « 
Scope . The draft Environmental Impact Statement (EIS) evidences a fundamental 
flaw In conception — a genetic defect. It is oriented to the environmental impact 
of the NIH Guidelines , not to the environmental impact of the widespread unree'jiated 
practice of recombinant fh'A technologies . Thus its scant 102 pages do not evaluate 
Tlie basic~issues of the prospective risks and benefits of INA recombination, and 
whether the former might massively outweigh the latter. Rather, the fram.ework of 
discussion is the implicit question, "Are the National Institutes of Health Guide- 
lines better than nothing?" Almost anything is better than nothing, and the NIH 
Guidelines are slightly better than the Asilomar guidelines which preceded them. 
They remain, however, lethally deficient. 
^Copies of the draft EIS and Guidelines are available without charge from Dr, Rudolf 
G. Wanner, Associate. Director for Environmental Health and Safety, Division of 
Research Services, Room 1:051, Building 12A, National Institutes of Health, Pethesda, 
Maryland 2C01Ii, Comments on the draft EIS should be submitted to the Director, 
National Institutes of Health, Bethesda, Maryland 20011: by October 18. 1976 . 
Comments on the Guidelines will be received until November 1. 
^Pending formulation of national policy, the Sierra Club California Regional Con- 
servation Committees have provisionally voted to oppose recombinant U!A research 
until better evidence of safety is available. The comments in this paper are the 
sole responsibility of the author. 
Appendix K — 172 
