TUFTS UNIVERSITY 
Graduate Program in Urban Social and 
Environmental Policy 
September 8, 1978 
Dr. Donald S. Fredrickson, Director 
National Institutes of Health 
9000 Rockville Pike 
Bethesda, Maryland 20014 
Dear Dr. Fredrickson: 
As a former member of the Cambridge Experimentation Review Board who 
participated in the first citizen review of its type in the history of 
American science on the hazards of recombinant DNA research I have some 
sincere concerns to express about the newly proposed guidelines for the 
research (Federal Register, July 28,. 1978). My remarks will focus primarily 
on Section IV of the revised guidelines entitled "Roles and Responsibilities." 
On the favorable side, I find that there are many positive additions, 
in these revised guidelines. Many areas are spelled out in greater detail, 
with more clarity and with greater attention given* to public accountability 
than I find in the original guidelines. I wish to congratulate you in pro- 
ducing a document that reads more easily to the informed citizen. 
The concerns I wish to raise fall into the following categories: 
Medical Surveillance; Institutional Bio-Safety Committee; Biological Safety 
Officer; Recombinant DNA Molecule Advisory Committee. 
1. Medical Surveillance 
According to Section IV A-l-e (Fed. Register, 33084) institutions 
have the discretion to determine the necessity of medical surveillance. 
Such discretion given to institutions will result in vastly different 
standards. Many out of economic exigency or pressure from investigators 
will seek the path of least resistance. Under such provisions smaller 
Institutions which do not possess the full range of environmental medical 
services are unlikely to be in a position to initiate the kind of medical 
surveillance procedures that larger institutions are capable of where such 
services are already available. 
- 1 - 
[A-92] 
Medford, Massachusetts 02155 
617 628-5000 
