COMMENT AND RECOMMENDATIONS OF RICHARD M. HARTZMAN ON THE PROPOSED REVISED NIH 
GUIDELINES ON RECOMBINANT DNA RESEARCH AT THE PUBLIC HEARING IN THE DEPARTMENT 
OF HEALTH, EDUCATION AND WELFARE ON SEPTEMBER 15, 1978. 
COMMENT 
I represent Friends of the Earth in the litigation which is mentioned in 
the environmental impact assessment on the proposed revisions, and I am testi- 
fying here today on behalf of Friends of the Earth. 
NEPA compliance 
The major point I wish to make concerns compliance with the National Envi- 
ronmental Policy Act (NEPA) . It is apparent from the testimony already given 
at this hearing that considerable controversy still surrounds the scientific 
aspects of recombinant DNA activities. NEPA is the best instrument available 
for the resolution of these controversies. It requires the preparation of an 
environmental impact statement for all major federal actions which could sig- 
nificantly affect the environment (including effects which are potentially ben- 
eficial as well as deleterious), and it requires that such a statement be pre- 
pared before taking action. The CEQ Guidelines and extensive HEW procedures in 
Chapter 30 of the General Administration Manual of HEW govern NEPA compliance. 
NEPA is a fundamental environmental law which provides the only mandatory for- 
mal mechanism for technology assessment. It also provides for public input in 
government decisions affecting the environment. The basic idea underlying NEPA 
is "think before you act", "tell everyone what you are thinking", and "act 
wisely" . 
From the beginning of the recombinant DNA program at the NIH, only the 
most feeble effort has been made to comply with NEPA. The final Environmental 
Impact Statement on the 1976 guidelines came out over a year after the guide- 
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