My name is Deborah Feinberg and I am the Environmental 
Scientist for the New York State Attorney General's office. 
I would like to thank the Department of Health, Education and 
Welfare for this opportunity to comment on the Proposed Revised 
Guidelines for Recombinant DNA Research. 
The Proposed Guidelines under discussion today constitute 
a substantial downgrading in containment from the original 
National Institutes of Health (N.I.H.) Guidelines. This office 
believes that such a reduction in containment levels is not 
warranted by scientific evidence. We therefore recommend that 
the original NIH Guidelines remain in effect. 
The Proposed Revised Guidelines contain a number of 
assumptions to which we take exception. My office strongly 
objects to the statement by the Director of N.I.H that those 
concerned with the potential hazards resulting from recombinant 
DNA activities now bear the burden of proof to show such hazard 
(p. 33097) . This and other statements purporting the safety of 
I 
recombinant. DNA research, which are directly reflected in the 
I 
reduced containment levels, sure not substantiated by empirical 
data. There is no basis for downgrading the Guidelines based on 
experimental results. That we have as yet not experienced an 
instance of pathogenicity resulting from recombinant DNA 
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