Dr. Donald Fredrickson 
October 5, 1979 
Page 2 
To put the matter in terms that the public can understand, a 
proposal to exempt some 85% of recombinant DNA research from government 
guidelines largely nullifies the past efforts to protect the public 
health against research abuses in this area. It also would eradicate 
any hopes that these problems can be solved by reasonable means and 
sensible discussions. This meat-ax elimination of public health precautions 
is a political act, not a scientific one. And it would encourage a 
meat-ax response by the public. At some later time, a change in political 
fortunes could put all biological research in a straight- jacket or 
eliminate most of the funding for this purpose. 
NIH can read the future by simply noting what has happened 
since Three Mile Island. The calls for a nuclear moratorium may not 
achieve their goal. However, sophisticated anti-nukes are now adopting 
a strategy of making nuclear power infeasible economically . Insurance 
requirements and the utility bond market can make a legal moratorium an 
academic issue. This same strategy can apply equally well to block DNA 
research. Elimination of government funding could end academic research. 
Similarly, regulations could make it too dangerous and costly for any 
corporation to do research in this area. 
This is not a remote possibility. All that it would really 
take for a "biological Three Mile Island accident" is a handful of cases 
of leukemia at some laboratory. This is something that could happen 
because of the careless way ordinary reagents are occasionally used. 
With media coverage of the threatened "cancer epidemic" and a few ambitious 
politicians, this could be a very real disaster for biological research. 
Moreover, if the Recombinant DNA Research Advisory Committee wipes out 
the present protection, there would be no problem in placing the blame 
for any real or imaginary disaster . It will be squarely on the National 
Institutes of Health, on the biologists who put their own interests 
above the public interest, and on the pressure groups (the universities 
and corporations) that pushed this thing through. 
The basic problem at Three Mile Island has been the inability 
of the utilities, the government agencies, and the physical scientists 
to realize the full extent of health hazards from low-level ionizing 
radiation. It is equally difficult for biological or medical scientists 
to realize the public health implications of recombinant DNA research. 
I have found no way to communicate my public health concerns to scientists 
who are focused on their own discipline. So instead, I have tried to 
paint a picture for the Committee of the possible consequences of a 
foolish decision. 
IDJB/mak 
CC: Robert Nicholas, Esq. 
General Counsel, Department of HEW 
Francine Robinson Simring 
Very sincerely your^, 
CL < 
Irwin D.J. Bross, Ph.D. 
Director of Biostatistics 
[ 344 ] 
