Richard M. Hartzman 
ATTORNEY AT Law 
25 1 WEST 07Th STREET 
SUITE 52 
NEW YORK. NEW YORK 10024 
2 12 • 
865-9255 
September 21, 1978 
Mt. F. Peter Libassi, Esq. 
General Counsel 
Department of Health, Education and Welfare 
Hubert H. Humphrey Building 
Washington, D.C. 
Dear Mr. Libassi: 
As you requested at last Friday's hearing on the recombinant DNA guidelines, I 
am sending you my comments and recommendations on the proposed revisions. 
While the enclosed document details my comment and recommendations, I would 
just like to indicate here the great concern of Friends of the Earth that pro- 
visions for NEPA compliance, for public participation, and for risk assessment 
be written into the recombinant DNA guidelines themselves. Vague discussions 
of these matters in supporting documents which have no force of law give us no 
assurance of their proper fulfillment. 
With respect to NEPA, agreement on appropriate compliance for the proposed re- 
visions and for future actions concerning DNA activities could constitute the 
basis for a settlement of the pending Friends of the Earth lawsuit. This is a 
serious problem on which discussions should be initiated in order to move to- 
ward resolution. I am willing to meet with you to pursue this matter further. 
My sense at the hearing on Friday was that it would be extremely difficult to 
reach a final decision on the revisions without having further proceedings. 
Perhaps some informal group meetings could be arranged and possibly there could 
be an opportunity for reply comment. 
I would like to compliment you for the evenhandedness with which you conducted 
the hearing. 
Very truly yours 
Richard M. Hartzman 
cc: Dr. Donald S. Fredrickson 
Dr. Julius Richmond 
Dr. Henry Aaron 
enc 
[A-231] 
