2 
<- 
2. Many of the key arguments on hazard derive from studies done under 
the assumption that manipulation would be limited to E. coli K12. For 
example, the Falmouth Conference explicitly excluded consideration of 
introduction of foreign DNA into organisms closer to wild strains, or 
other than E. coli . The current proposal opens up a variety of 
organisms to genetic manipulation in the absence of registration, 
notification, record keeping or health surveillance controls. 
In addition, claims about the lack of nagative effects, not with- 
standing the lack of studies to identify such effects, might well be 
due to the efficacy of the present guidelines in preventing careless- 
ness or release into the environment, rather than the lack of intrinsic 
survivability or hazard from genetically modified organisms. 
Thus, much of the fundamental logic is profoundly flawed: under 
conditions of strong regulation there were no problems, therefore there 
is no need for regulations. This is akin to saying that since there 
have been no major nuclear reactor accidents under the Nuclear Regulatory 
Commission, we can do away with further oversight by the NRC. 
3. Most of the activities, investigation, and discussion of the RAC 
over its history have focused on laboratory scale operations. However, 
the technology is rapidly expanding into commercial application with 
the attendant problems: large scale production and growth of the 
organisms; intentional introduction of modified organisms into the 
environment; selection for hardy rather than debilitated strains, work- 
forces without training in pathogenic microbiology or even standard 
microbiology. 
Since the existing guidelines set the standard for regulating 
commercial development, the dismantling of these guidelines represents 
the undercutting of the process of devising controls for commercial 
application and environmental uses before this use has been properly 
launched . 
4. We are concerned over sharp conflicts of Interest, not revealed 
in the Federal Register. For example, according to the Boston Globe of 
December 10, 1981, Professor Baltimore is the second largest private 
stockholder of Collaborative Genetics, which is to go public in 
January. His holdings would have a value of over $5,000,000. This 
information should have been made public, and in fact Professor Baltimore 
should have disqualified himself from the RAC deregulation proceedings. 
The Gottesman proposal represents a far mpre reasonable course of 
action; the Guidelines would remain mandatory and provide a means for 
minimum controls and some caution without encumbering the development of 
the technology. The rapid progress of genetic engineering technology 
under relatively tight guidelines clearly points out that these guide- 
lines have not retarded technological development unduly. The long 
term productive development of this technology requires the trust and 
cooperation of all sectors of our society; community, labor, environ- 
mentalists and church groups. This will require a government apparatus 
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