To: Hon. Ray Thornton 
January 19, 1982 
Page 6 
category and is essentially unsupported by any body of experimental work; 
it is merely a nice mental construct. 
Related to this logical problem is the inherent contradiction between the 
discussion of "natural exchange mechanisms" and evolutionary fitness 
(40 Fed. Register 59387, 59388-89) set forth by the RAC Working Group. 
Engineered genetic exchanges between species which do not do so in nature 
(say sea urchins and £. col i ) can not be claimed to be harmless because nature 
must have weeded out such "monstrocities. " There is no evidence at all that 
such matings occurred in the past and failed as "unfit". The concern over 
evolutionary implications logically means that only recombinations which 
have occurred in nature should be permitted in the laboratory or industrial 
establishment (perhaps to increase the volume of specimens, etc.). Contrary 
behavior must necessarily rest on an assumption that the evolutionary con- 
cern is false or trivial. 
(4) Problems of "Conflict of Interest" 
In the Working Group's summary of arguments it is stated that "most 
scientists now conclude, after almost a decade of experience, deliberate 
risk assessment experimentation, and theorizing, that the potential risks 
of recombinant DNA research have not materialized and most probably will not." 
(46 Fed . Register 59391 ). This statement is literally true -- most scientists 
do hold such a belief. I have attempted above to show why, however, I think 
the belief is ill-founded. We should be aware that most scientists have 
sociological and psychological reasons for so believing; for many this is 
merely a generalized "conflict of interest" reflecting their socialization 
into their profession and that profession's historical mores, but for others 
there is the more traditional basis (pecuniary, status and esteem) operating 
as a conflict. 
Public interest in the accelerated commercialization of r-DNA work is very 
high. TV documentaries, AAAS sessions, etc. all indicate this. The norms 
and protocols of university coimunities are being severely stressed by the 
conflicting roles of the PI as benevolent scientist and as a principal in a 
cortitiercial firm. The secrecy and competition thus engendered will also in- 
crease the probability of unexpected consequences and hazards materializing. 
At this time, abolishing the Guidelines and the units of local oversight 
would be sending exactly the wrong signals to the major actors and the general 
public. Until such time as commercial r-DNA work is regulated (and I believe 
it presents far greater risks and concerns than laboratory work), the current 
Guidelines at least provide some mechanisms for accountability over the 
academic-cortmercial intermix. 
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