2 
Today I wish to comment on the public policy aspects of the Proposed 
Revised Guidelines for Recombinant DNA Research issued by the Department 
of HEW on July 28, 1978 and my testimony is being submitted on behalf of 
the Coalition for Responsible Genetic Research. I will be directing most 
of my comments to the materials covered under "Roles and Responsibilities" 
in the Proposed Guidelines, directing my remarks to the introductory state- 
ment by Secretary Califano that the Department is particularly seeking 
"comment on the sections in the proposed revisions that establish the 
mechanisms for administering and revising the guidelines." In fashioning 
my comments I will be drawing in particular on the experience of the 
University of Washington IBC . 
In a commencement address at the University of Michigan in 1977, Secretary 
Califano pointed out that science has become too important to be left solely to 
the scientists. With specific reference to recombinant DNA research, he noted 
that policy deliberations in this area must be conducted with concern and 
deliberation; "this is the slowest way, the most inconvenient way — and in a 
democracy, the only way — to make such decisions." He went on to observe that 
decision-makers in science and medicine must learn the hard lesson that decision 
making behind closed doors breeds distrust, even if what happens behind those 
doors is perfectly legitimate. 
Although overall, the proposed revisions in the Guidelines are an advance 
over the existing Guidelines because of their increased clarity and evidence 
of some responsiveness to concerns which have been raised by members of the 
public regarding issues presented by DNA research, my comments will highlight 
what I perceive to be shortcomings in the document as published in the Federal 
Register; I am taking this approach in order to maximize what I consider to be 
the potential utility of my experiences and testimony for members of the 
hearing panel. I wish to make quite clear that my position should not be 
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