District 1199, National Union of Hospital and Health Care 
Employees, represents over 120,000 health care employees nationally 
in service, maintenance, clerical, technical and professional 
classifications in health care institutions . Included in our 
membership are technicians, technologists, scientists, clerical 
workers, aides and housekeepers employed in laboratories en- 
gaged in recombinant DNA research. We wish to comment on the 
two proposed revisions of NIH Guidelines for Research Involving 
Recombinant DNA Molecules from both an occupational health and 
public health viewpoint. 
1199 strongly opposed both the RAC and Gottesman Proposals. 
As health care workers we are well aware of the toll that new medical 
technology has taken on health care consiamers and employees . The 
best example of this is the indiscriminate use of diagnostic and 
theraputic radiation. The use of fluoroscopy to monitor tuber- 
culosis in the 1930 's and 40 's and the resulting increase in 
breast cancer taught us about the sensitivity of breast tissue to 
radiation. The widespread use of pelvimetry made clear the vul- 
nerability of the fetus, as studies linked x-ray exposure 
utero to increases in leukemia and genetic defects in those 
children. An increase in thyroid cancer has been related to the 
use of radiation therapy for enlarged thymus, tonsils, and adenoids 
in infants and children. 
Pioneers in the field of radiology and their successors also 
suffered a much higher death rate from cancers and other diseases 
now known to be sensitive to radiation. Radiation technology 
is not unique. Whether it is the use of benzene in laboratories 
or DES during pregnancy the trend has been to develop and apply 
new technology without regulation, study the effects years later 
(after the effects have become tragically apparent) , and then 
begin to regulate the technology. 
District 1199 believes that the NIH Guidelines as they now 
exist are proof that we have learned the lesson that our experience 
with radiation, toxic substances and pharmecuticals teaches: that 
new and rapidly growing technology must be strictly regulated 
until it is proven safe. Any change in the present NIH guidelines that 
goes beyond administrative streamlining is premature. The absence^ 
of an epidemic due to recombinant DNA research does not indicate 
that the guidelines are unnecessarily severe. Actually this is 
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