UNIVERSITY OF WASHINGTON 
SEATTLE, WASHINGTON 98195 ’ 
Program in Social Management of Technology 
January 19, 1982 
Hon. Ray Thornton 
Chair, Recombinant DNA Advisory Committee 
ORDA, Bldg. 31, Room 4A52 
National Institutes of Health 
Bethesda, MD 20205 
Dear Chairman Thornton: 
I appreciated the ability to chat with you during the AAAS meetings earlier 
this month, and as promised this letter contains my comments on the Baltimore 
Campbell and Gottesman proposals regarding the status and nature of the r-DNA 
Guidelines which will be before the RAC at its upcoming meeting. 
At the outset I will state my conclusion: I oppose the Baltimore-Campbell 
proposal because it relies on assumptions which I do not share ( and believe 
are unwise) and evidence which is scanty. I favor continuation of the present 
Guidelines with their capacity for evolution; I would accept the Gottesman 
revisions as the "lesser-of-two-evils" but do not endorse them. Below I 
have organized my comments under four general headings: public policy consid 
erations, risk considerations, problems of logical reasoning, problems of 
"conflict of interest." My experience with r-DNA issues grows out of my mem- 
bership on the University of Washington IBC for 3 years, serving the U. S. 
Congress Office of Technology Assessment as a consultant on its applied 
Genetics Study, testifying before the special HEW panel which lead to the 
1978 Revised Guidelines, and numerous appearances in public forums and media 
discussions of these issues. 
(1 ) Public Policy Considerations 
The mechanisms which have been set up to oversee r-DNA research are a 
novel experiment. They represent one of the few examples in which science 
(as distinct from technology -- although r-DNA activities share aspects of 
the latter as well) has been subject to explicit public scrutiny and regu- 
lation. They have involved the establishment of new institutional arrange- 
ments, the IBCs, with a potential for citizen participation. This was done 
in recognition of the extraordinary power of r-DNA work to transform aspects 
of our social milieu. 
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