Environmental 
Defense 
Fund 
1525 18th Street, NW, Washington, D.C. 20036 '• 202/833-1484 
September 15, 1978 
STATEMENT OF THE ENVIRONMENTAL DEFENSE FUND 
ON THE PROPOSED REVISED NATIONAL INSTITUTES 
OF HEALTH GUIDELINES FOR RECOMBINANT DNA RESEARCH 
SEPTEMBER 15, 1978 
Good morning. My name is Leslie Dach. I am a Science Associate 
with the Environmental Defense Fund (EDF) . EDF is a non-profit organ- 
ization with over 46,000 members. EDF undertakes legislative, judicial 
and administrative actions to minimize human exposure to toxic chemicals 
EDF has been deeply involved in the national debate on recombinant DNA. 
In 1976, EDF petitioned the Department of Health, Education and Welfare 
to use its authority under §361 of the Public Health Services Act to 
regulate recombinant DNA activities. EDF submitted comments on the 
current NIH recombinant DNA guidelines and has testified before Congress 
and the Advisory Committee to the Director of the National Institutes 
of Health on the issue of recombinant DNA. 
EDF thanks Secretary Calif ano for holding this public meeting. 
Because of the limited time alloted to each speaker, I will only be 
able to touch on a small number of EDF's concerns. EDF intends to 
submit extensive written comments on the proposed guidelines. 
Today, I would briefly like to discuss the following five aspects 
of the proposed revised guidelines: 
1. the need to rewrite sections of the guidelines to eliminate 
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ambiguity. 
2. mechanisms for assuring adequate public participation in 
NIH activities mandated by the guidelines , 
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