ON PUBLIC PARTICIPATION: 
COMMENT ON PROPOSED REVISED NIH GUIDELINES 
FOR RECOMBINANT DNA RESEARCH 
Dorothy Nelkin 
I would like to comment on the proposed revised guide- 
lines for recombinant DNA research, and in particular on the 
issue of public participation as outlined on page 33045 and 
in Part 4 of the Federal Register, July 28, 1978. Many re- 
cent controversies over science and technology suggest the 
growing erosion of trust in decision-making authority as 
citizens increasingly seek accountability, demystification, 
and often a more direct voice in policy decisions. The DNA 
dispute suggests that science itself is not exempt from such 
public scrutiny. This problem of trust has stimulated govern- 
mental efforts to involve citizens more directly in the creation 
and implementation of policies, and administrative agencies are 
groping for ways to make their decision-making procedures more 
sensitive to citizen voices and therefore more acceptable. 
Participation has become a sort of "catchword" for these efforts 
and indeed appears in the proposed revised DNA Guidelines. 
Participation however is an ambiguous and often threaten- 
ing concept. As a principle it is a source of legitimacy, but 
as a procedure it may be inefficient and obstructive. There 
is considerable fear that greater public involvement may virtually 
paralyze science and technology. Thus participatory measures 
are instituted with reluctance and great caution. It seems 
useful at this point to look critically at some of the existing 
participatory procedures as the N.I.H. considers participation 
in the form of "public notice" and the increase of "public" mem- 
bers in the I.B.C. 
Most participatory reforms simply expand the possibility 
of informing the public about decisions. Other procedures channel 
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