FRIENDS OF THE EARTH 
620 C Street, S.E., Washington, D. C. 20003 
(202) 543-4313 
David Brower, President September 15, 1978 
WRITTEN COMMENTS BY PAMELA LIPPE, ASSISTANT LEGISLATIVE DIRECTOR , 
ON THE PROPOSED REVISED GUIDELINES FOR RECOMBINANT DNA RESEARCH 
I. Introduction and Overview 
We in the public interest community look at recombinant DNA 
as a powerful new technique and technology with unprecedented 
potential for benefit and harm. Contrary to recent scientific 
pronouncements, we do not wish to stop recombinant DNA research 
or scientific progress; we simply wish to achieve the benefits 
without incurring unnecessary risks. 
The scientific community looks at recombinant DNA as a power- 
ful tool which will allow them to answer questions beyond their 
previous understanding, and to do things that stretch the limits 
of their imagination. 
While it is understandable that scientists more clearly per- 
ceive the beneficial aspects of their efforts, a quick survey of 
recent scientific and technological breakthroughs illustrates 
the time bomb and elusive nature of many of science's most cher- 
ished dreams. 
As the Stevenson subcommittee pointed out in its recent over- 
sight report, "At issue is the extent to which research scientists 
should be entrusted with responsibility for their own conduct, 
individually or through peer review, or be subjected to external 
control and scrutiny." 
Our position is that if the situation is serious enough to 
develop guidelines for the conduct of this research, then it is 
serious enough for the guidelines to be enforced. Self-regulation 
has never worked in the past. There is no reason to expect that 
recombinant DNA is to be any different. 
In general, my comments will focus on the procedural aspects 
of the guidelines as requested by Secretary Calif ano. I hope 
that you find these comments and recommendations useful. 
II. Scope and Applicability 
We support efforts to further extend the guidelines to the 
private sector such as those in the proposed revisions. It is 
unfortunate that no more comprehensive mechanism exists to trans- 
form the guidelines into full-fledged regulations — legal 
authority extending to industry and academia alike, and to both 
effectively. 
Committed to the preservation, restoration, and rational use of the ecosphere 
[ 352 ] 
