24 
to be appointed to the committee. In addition to these considerations 
the public should.be assured that the committee will function without the 
sort of blatant partisanship which has characterized some of the actions 
of the present chairperson. 
There is one portion of The Director's Decision (FR 33044) which high- 
lights some of the fundamental failures of the NIH to come to grips with the 
nature of the problems presented by DNA regulation. It is a demonstration 
of a failure to understand the probablistic nature of risk to imply that 
because harm has not in fact occurred that it is less likely and that the 
"burden of proof" should therefore shift regarding attitudes to vigilance. 
The footnote citation to a March 1978 Subcommittee report of the House 
Committee of Science and Technology ought to be carefully analyzed. "The 
burden of proof of safety factors should not be borne exclusively by 
proponents of recombinant DNA research; opponents must assume a corresponding 
burden," it states (FR 33047). The most important element of this statement 
is the qualifier "exclusively." The main thrust of the academic work over 
the past decade in the area of science, technology and public policy, 
and in the development of the notion of technology assessment, is that 
the proponents of technological change, who would be thrusting impacts on 
affected parties, should , in the main, bear the burden of proof in assuming 
the risks, etc. The Director's remark is highly ironic to those of us 
who have been attempting to raise social policy issues, or have been 
questioning the unseemly haste with which some of the research is being con- 
ducted and the attendant pressures which have been put on the regulatory 
system. We feel we have been bearing a heavy burden for the past several 
years; our resources are slender and our access to information has been 
limited; our desire has been to assure that research in the area is 
safe, not to "restrict" it, as the Director claims. We feel that any 
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