To: Hon. Ray Thornton 
January 19, 1982 
Page 5 
"the perceived risk associated with genetic engineering includes ethical 
and moral hazards as well as physical ones. It is important to recognize 
that these are part of the general topic of risk. To some, there is just 
as much risk to social values and structure as to human health and the 
environment. (For further discussion, see ch. 13)". (At p.207). Chapter 13 
referred to, is nine pages long (in a report which is 331 pages in length) 
and is entitled "Genetics and Society". Less than one page of this chapter 
can be said to be devoted to ethical issues, and at least one third of that 
page is taken up by a long quotation from one religious philosopher favoring 
genetic engineering. The superficiality of this treatment, and its imbalance, 
are outrageous (there are numerous theologians urging caution , as well as 
ethical views which are not religiously based). But, as the report so can- 
didly notes, "the present Guidelines are a comprehensive, flexible, and non- 
burdensome way of dealing with the physical risks associated with r-DNA while 
permitting the work to go forward. That is all they were ever intended to 
do." (p. 217) The Guidelines "do not address the admittedly uncertain, 
long-term cultural risks," (p. .217). Ethical risks and concerns relevant to 
recombinant techniques, have to do with the possibilities of intentional 
misuse; the inviolability of evolutionary boundaries; maldistributions of 
access to information and power; and the very nature of how risks are eval- 
uated. These issues must be resolved before regulatory controls are abandoned. 
In sum, I cannot agree with the conclusion offered by Drs. Baltimore 
and Campbell in support of their proposal that "since 1976, neither experi- 
mental evidence nor solid theoretical arguments have been advanced to support 
the position that recombinant DMA research poses any danger to human health 
or to the integrity of the natural environment" and that the hazards "appear 
to be non-existant. " (46 Fed . Register 59382). 
The fact that there have been so few known incidents is quite likely 
because of the Guideline's cautionary influences. Elimination of the Guideline 
procedures is thus logically likely to increase the probability that risks will 
turn into active hazards. 
(3) Problems of Logical Reasoning 
Proponents of r-DNA research have unfortunately often used fallacious 
logical arguments to support their positions on public policy issues. For 
example, there is the false syllogism that the combination of genetic materials 
from two species each of which is considered to be relatively harmless must 
itself be harmless. Certainly there are examples in other natural sciences 
(if not biology itself) in which synergistic effects or unexpected products 
have occurred. Since the host will occupy a different ecological niche from the 
donor, the expression of the foreign DNA in that environment may be harmful by 
itself. The specific argument that the proH^uct of introducing toxic genes into 
a host cannot be more pathogenic than the donor itself falls within this general 
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