Ray Thornton, Chairman 
November 20, 1981 
Page 2 
(A) The Guidelines as they now exist would be no more than 
a voluntary code of standard laboratory practice with 
no mandated review of experiments by the Committee, and 
there would no longer be sanctions for scientists who 
exceed the bounds of safe experimentation. 
It Is our belief that some scientific experiments should require public 
review. The scientific community cannot Isolate Itself from the larger 
community that It serves and presume that an Individual scientist Is al- 
ways capable of deciding that the degree of hazard associated with a par- 
ticular experiment Is acceptable to the public. Moreover, where public 
funds are spent, the expenditure of those funds carries with It an ac- 
countability to the public. Just as the public has a right to regulate 
the conditions under which human subjects are used In research, so does 
the public have the right to ensure that drug-rest stant or toxigenic or- 
ganisms are not constructed. Certainly, If such organisms are constructed 
the public must be assured through some form of open review that they are 
not released Into the environment. 
Scientists must accept (and we believe the majority do) the need to re- 
strict certain hazardous laboratory practices to protect health and safe- 
ty while realizing that these restrictions do not represent an Infringe- 
ment of their Intellectual freedom. It would, we believe, be prudent for 
scientists to continue to share their Insights with an Increasing number 
of people. To do otherwise might Invite a public reaction based on fear 
rather than on understanding. 
Another concern that arises In this regard Is that without reasonable Guide- 
lines, the burgeoning industrial use of recombinant ONA technology would have 
no review. Up to now private firms have voluntarily submitted to review by 
the RAC. This voluntary compliance implies a consent to be governed and 
thus submission to the Guidelines then becomes non-voluntary, as we are sure 
you are aware. 
If the Guidelines become only a voluntary code of standard practice, pri- 
vate firms wl 1 1 be more likely not to comply. The biotechnology industry 
Is still too young for the Inherent safety or hazard of the industry to be 
clear. Until the Industry matures and this matter becomes clearer, we be- 
lieve that a degree of caution should be exercised. The Industry Is very 
promising, however, and caution should be combined with encouragement. In 
our view. 
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