II . SUMMARY OF COMMENTS AND RECOMMENDATIONS 
In these comments the Natural Resources Defense Council, 
Inc. (NRDC) addresses two types of issues: (1) the inadequacy 
of the scientific evidence on which NIH relies in relaxing 
the guidelines; and (2) the weakness of the proposed 
administrative and enforcement provisions. 
Available scientific information on the risks of 
recombinant DNA research is still sketchy and incomplete. No 
conclusions can be reached about the safety of this type of 
research until a comprehensive risk assessment program has 
been completed. 
The evidence NIH cites as a basis for lowering containment 
levels does not support the extensive reduction in protection in 
the proposed revised guidelines . Much of the evidence has 
never been published or is available only in summary form. 
By withholding the scientific basis for its decision, NIH has 
prevented critical review of the data by the scientific 
community and has effectively excluded the public from having 
a say in the policies behind these proposed revisions. While 
some of the new experimental findings relieve some concerns, 
they also show that there are some potentially serious risks 
associated with some recombinant DNA research. In our detailed 
technical comments we identify potential risks and scientific 
issues that need to be resolved by further research. We 
also recommend stricter containment for some kinds of experiments. 
The proposals to decentralize administration of the 
guidelines and increase the discretion of the Administrator 
[A-178] 
