seems to say, "Since we can't think of anything sensible to do, let's do something 
silly so that at least we are taking some action that Indicates some concern." I am 
sure these are not Susan's reasons for submitting her proposal; but If her proposal 
Is adopted, I suspect It will be because It Is perceived as setting the best pace 
for relaxation of the Guidelines, rather than because many people are convinced that 
It provides any protection from any danger. I remain convinced that honesty makes 
the best politics; and that If RAC sees no further need for regulation. It should 
say so. 
To my mind, the question of RAC's responsibility with respect to Industrial 
development has not yet been adequately addressed. I take It for granted that any 
technology practised on a sufficiently large scale, will have some undesirable side 
effects. That's been true of every other technology; why should recombinant DNA be 
different? Furthermore, the best time to think about minimizing any problems Is 
when the technology Is still emerging, before everything Is set up and running. 
Of course, the primary responsibility for monitoring emerging technologies does not 
rest with NTH or RAC, but with other agencies such as FDA, OSHA, EPA, CDC, etc. In 
the absence of any sign that recombinant DNA presents special hazards, RAC could 
justifiably opt to stay out of such matters. However, I believe that, as long as 
RAC continues to exist. It can serve a socially useful function by actively looking 
for potential problems and volunteering advice to those agencies as the occasion 
warrants. I %K>uld like to see such a function officially acknowledge by adding to 
the Guidelines as a RAC function something like "considering, and advising the 
Director NIH of, any potential problems connected with large scale production of 
organisms carrying recombinant DNA." The Director would then have the 
responsibility of formally transmitting RAC's conclusions to other agencies as 
appropriate. 
Something of this kind could provide what may be most needed In the years ahead — 
someone to keep an eye on what Is going on, and to suggest what safety testing may 
be needed In specific cases. I an sure that the representatives of Industry will 
continue to push the notion that "If It's safe In small scale. It's safe In large 
scale." I consider their argument spurious for at least two reasons. First, the 
basis on which RAC has accepted that cloning In certain hosts such as E. coll K-12 
Is quite safe Is the Improbability that a few bacteria that might escape could 
multiply extensively enough outside the laboratory to cause significant damage; for 
a large number of bacteria, that logic simply does not apply. Second, when we say 
something Is safe, we mean only that there Is no reason to expect danger. It would 
be Impractical to test everything for unexpected hazards. It would be silly to 
require extensive safety testing on every clone that will be gro*m In 10 ml amounts 
In the laboratory; If there were any danger, the tests might be more hazardous than 
the experiment. However, If any organism Is to be grown by the ton. It seems 
feasible to test It for unanticipated properties such as toxicity or allergenicity 
that might cause problems If not recognized In advance. 
I think It would be unwise to assume that the regulatory agencies will be able to 
handle such matters adequately on their own. The current administration Is 
unsympathetic toward regulation of Industry, and the agencies risk emasculation by 
the Woodshed sman's budgetary axe. 
In the Baltlmore-Campbell proposal, the large scale limit was retained as a 
prohibition. My reason for favoring that course was that the Issues I have 
mentioned above should be more fully aired and discussed before making any changes 
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