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The report makes a single brief reconmendatlon regarding changes In part IV 
of the Guidelines. Yet the proposal on containment mandates corresponding changes 
In Part IV. Those sections of IV dealing with aspects of part III that would no 
longer exist (e.g. , IV-[>-3-f, IV-D-5-b) and with the prohibited experiments should 
be eliminated. Also, the recommendations make part II-D-1, II-D-2 and II-D-3 moot. 
If part of the motivation for the changes Is to make the Guidelines more understand- 
able and straightforward. Irrelevant sections should be omitted. 
There Is a sense In which the recomendatlons appear Inconsistent. This Is 
perhaps best described by comparing them to the Baltlmore-Campbell proposals. The 
latter represent a smaller change In containment than the proposal of the working 
group because the prohibitions were maintained and because biological containment 
remained a factor. On the other hand, the Baltlmore-Campbell approach represented 
a larger change In regulation since the Guidelines became voluntary on a national 
baala, though not necessarily within an Institution. The report of the working 
group deals with the scientific Issues relevant to containment, but only very 
briefly with those relevant to regulatory mechanisms. Further, the statements 
about regulatory Issues do not adequately support the recommendation to leave the 
extensive system of IBCs, RAC, ORDA, etc In place. The final report should deal 
explicitly with why changes In regulatory procedures are or are not recommended. 
Absent such discussion, the reconendatlons are oiystlfylng and likely to engender 
additional skepticism In the scientific comasjnlty. Clarifying the amblvalency, 
should entail dealing with one of the more difficult aspects of the present scene, 
namely, the public perception of scientific and technological risks. On the one 
hand, the available scientific evidence Indicates that the Initial questions about 
recombinant research have been answered to the effect that no serious potential 
for unique hazard exists. Yet, It Is Impossible to make an absolute statement; 
only the probability of risk can be described. The public, however, may remain 
anxious, to varying degrees, absent absolute assurances. If the recommendation to. 
maintain the complex system of control Is motivated by a concern for the anxieties 
of the public (a motivation that Is not Inappropriate If such anxieties exist) 
then I believe the report should so state. I offer the following possible wording 
for consideration and debate. 
"The concerns about potential hazard that were raised when recombinant 
DNA experiments were first Initiated need to be reevaluated In the light 
of present scientific evidence. That evidence, gathered over the last 
seven years, supports a conclusion that the likelihood of any untoward 
effects from these experiments Is exceedingly low. Thus, the extensive 
and complex system of containment and control embodied In earlier ver- 
sions of the Guidelines Is no longer warranted, according to scientific 
evaluation. Nevertheless, the RAC recognizes that while scientific 
assessment can yield probabilities. It can never provide certainties. 
Accordingly, public concern about the experiments may remain and there- 
fore some continuing evaluation and oversight Is desirable." 
Sincerely yours 
C 
National Cancer Institute 
[607J 
