AMERICAN FEDERATION OF LABOR AND CONGRESS OF INDUSTRIAL ORGANIZATIONS 
EXECUTIVE COUNCIL 
GEORGE MEANY LANE KIRKLAND 
SECRETARY- TREASURER 
PAUL HALL 
MATTHEW GUINAN 
FREDERICK O'NEAL 
GEORGE HARDY 
WILLIAM SIDELL 
ALBERT SHANKER 
SOL C. CHAIKIN 
CHARLES H. PILLARD 
LLOYD McBRIDE 
EMMET ANDREWS 
WM. W WINPISINGER 
JOHN H. LYONS 
PETER BOMMARITO 
JERRY WURF 
AL H. CHESSER 
MURRAY H. FINLEY 
C. L. DELLUMS 
EDWARD T. HANLEY 
WILLIAM H. McCLENNAN 
DAVID J. FITZMAURICE 
ALVIN E. HEAPS 
WILLIAM H. WYNN 
A. F. GROSPIRON 
THOMAS W. GLEASON 
S. FRANK RAFTERY 
MARTIN J. WARD 
JOSEPH P. TONELLI 
GLENN E. WATTS 
ANGELO FOSCO 
J. C. TURNER 
KENNETH T. BLAYLOCK 
HARRY R. POOLE 
FRED J. KROLL 
815 SIXTEENTH STREET. N.W. 
WASHINGTON. D.C. 20006 
(202) 637-9000 
September 7, 1978 
Dr. Donald S. Fredrickson, Director 
National Institutes of Health 
Bethesda, Md. 20014 
Dear Dr. Fredrickson: 
We appreciate the opportunity to comment on the NIH Proposed Revised Guide- 
lines for Recombinant DNA Research. The specific technical details, we are 
sure, will be addressed by many others, but we would like to comment on cer- 
tain general policies and provisions of the Guidelines. 
The Guidelines currently apply only to grantees of the NIH. However, the 
Congress is continuing to explore extending the constraints of the Guidelines 
to all those engaged in this line of research, and whether or not new legis- 
lation is passed in the near future, the Guidelines will undoubtedly form the 
technical base upon which the Occupational Safety and Health Administration, 
the Environmental Protection Agency and state and local public health depart- 
ments will act to protect the health of laboratory and production workers, 
as well as the general community. 
We do not believe this is an appropriate time to weaken the Guidelines. The 
field is a new one, and with all due respect to the many eminent scientists 
active in the field (not all of whom are of the same mind, by the way. See, 
for example, the attached article by Dr. Jonathan King) , no one can say that 
after only a handful of years of research on a limited number of organisms 
we know all the questions, let alone sufficient answers to guarantee reason- 
able protection of the public. We most definitely do not agree with your 
statement on P. 33044, Federal Register, July 28, 1978, regarding a shift in 
the burden of proof to those who desire to protect the health of the public 
by restricting Reccrmbinant DNA research. The statement borders on irrespons- 
ibility, and must be removed. 
One can understand the desire of academic researchers to push their investiga- 
tions to the limit of human imagination. One can also understand the desire 
of industrial scientists to rapidly exploit new scientific developments with- 
out the delay that may possibly result from promulgation of protective regula- 
tions. But we feel that there is ample evidence to justify application of the 
old adage, "better safe than sorry". Let us cite just one example from another 
[A-88] 
