The result is a set of guidelines that do not reflect the kinds of 
concerns such decisions properly require. 
For example, on p. 33043 of Federal Register Volume 43, Number 146, 
the statement: 
"... There was overwhelming sentiment for exempting from the 
Guidelines experiments involving recombination of DNA within 
the same strains or from pairs of organisms that transfer 
genes in nature." 
Also, p. 33051 addresses the question of the public's role in the 
exemption process by stating, in part: 
"the membership of the RAC will be broadened modestly as 
needed for expertise, but provisions for public notice and 
opportunity to comment . . . can be used to ensure adequate 
public input when the issues warrant." 
The revised guidelines implement this pholosophy with under language 
found in Part IE4, E5 and Part IVBld. 
The underpinning for these rules is the assumption that if it 
occurs in nature it is okay. This totally ignores the question of rate 
of recombination under forced laboratory conditions. 
The parallel and equally fallacious arguement is, "Because nuclear 
fission occurs naturally on earth, regulation of experimentation can be 
minimal and exempted by an appointed Washington official." 
Whomever in NIH is accepting the proposed exemption criteria is 
adopting a simplistic notion of reality. 
In general, NIH is seeking to relax the safeguards imposed on 
various experiments. Physical containment is not the fail-safe system 
you are being led to believe. 
While in St. Paul, I personally inspected the air handling equipment 
of more firms and manufacturers than most people will see in a lifetime. 
While taking courses- in environmental micro-biology, I studied and 
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