Dr. William J. Gartland, Jr. 
January 29, 1982 
Page two 
the sense that experiments which he proposes are subject to 
external scrutiny both by IBCs and by NIH. These review pro- 
cedures may not be completely satisfactory, but are certainly 
better than pure professional self-regulation . 
II . The special nature of the risks of rPNA require a heavier 
reguliTtory burden than might be necessary in other areas . 
The rDNA controversy poses problems of feared catas ^ihe, 
with uncertainty as the dominant feature. The problem of un- 
certainty is intensified given the possibility tha. , search 
into fundamental biological or physical sturctures may alter 
those structures in a way that does not normally occur in the 
natural environment. How then is this problem different from 
industrial production of toxic chemicals and airborne or water- 
borne effluent which may have long term health effects? The 
mcertainty involved may be equally pronounced as to carcino- 
genic or mutagenic effects or ecological damage. Radioactive 
materials pose unique half-life problems, requiring thousands 
of years in the cases of some materials to decay to a non- 
threatening level. Certain toxic chemicals likewise may not 
degrade, or may break down in pernicious and unpredictable 
ways. Both radioactive materials and toxic chemicals may 
enter the food chain or other ecological niches in ways which 
pose similar long term threats. With either type of hazard, 
however, the risk is enhanced because of the sheer volume of 
the hazardous substances produced as a byproduct of large 
scale commercial use and production. Production and use can 
therefore be reduced, stopped, or altered; regulatory measures 
to govern shipment and storage can be implemented; the source 
of the hazard, being traceable, can be pinpointed. 
Research, such as biological research represented by the 
rDNA controversy, offers hazards of a different order of magni- 
tude. The putative risks involve pathogens, altered organisms, 
changed immunological defenses. The source of these hazards 
can reproduce and mutate if an adaptive niche is available. 
The level of production required for self-sustaining growth re- 
quires only a single laboratory experiment, unlike toxic 
chemical byproducts, which are linked to commercial levels of 
production. Attention to research hazards is therefore best 
directed at the earliest stages of investigation. 
This comparison suggests that hazards of rDNA research pose 
problems earlier, not being dependent upon volume production to 
[ 742 ] 
