opportunity for defense against charges, and protection 
against discrimination of the party bringing charges. 
Such grievance mechanisms should be established and 
publicized to all recombinant DNA workers to facilitate 
the reporting to NIH of Guideline violations. 
To summarize, the New York State Attorney General's 
office believes that there is no scientific justification 
for the relaxation of containment levels contained in the 
Proposed Revised Guidelines. On the contrary, the expression 
of eukaryotic DNA in bacteria exhibited in such experiments 
as the successful insulin production work, prove that higher 
and lower organism gene boundaries can and will be crossed 
by mam.. The Rowe-Martin experiment shows that naked DNA, 
far from being inactive, does infect cells. Unsubstantiated 
claims of the safety of recombinant DNA research pervade 
the Director's Decision document and the Environmental 
Assessment document and are reflected in these newly 
proposed Guidelines. We strongly believe that the 
containment measures are too lax and should be increased 
in order to protect health and environment. 
By delegating increased authority to institutional 
biohazard committees and allowing them wide discretion in 
setting containment levels, the Proposed Guidelines ensures 
- 10 - 
[ 349 ] 
