4 
The assessment has been constructed so as to give the appearance of a lengthy 
document, but it is disheartening to discover that it is mostly a reprint of 
the Director's Decision printed in the same issue of the Federal Register. 
Some portions of the Director's Decision are modified in the assessment with 
the result that the two documents are often contradictory. Illustrative is the 
discussion of the "somewhat arbitrary" character of the guidelines which is de- 
scribed in my second general recommendation. 
A prime example of the lack of analysis concerns the basis for the exemp- 
tions stated on p. 33110: 
This [first exemption] is based on the safety of these experiments.... 
[T]he basis [for the second exemption] is occupational and environmental 
safety.... This [third exemption] was strongly endorsed by several public 
commentators on the basis of no hazard. The fourth exemption ... allows 
certain of the experiments previously classified at P1+EK1 to be excluded, 
again with the strong endorsement of several public commentators on the 
basis of no hazard. 
The emptiness of this "assessment" is obvious. Not much more is said in the 
relevant portions of the Director's Decision reprinted in the assessment on p. 
33109. For the first exemption it is stated that: 
This is in recognition that "naked" DNA, which is rapidly inactivated in 
nature, is extremely unlikely to be hazardous under experimental condi- 
tions . 
No data is given or studies cited which could substantiate this assertion, and 
as we have heard in testimony today, there is still scientific controversy over 
this hypothesis and there may be evidence to the contrary in the as yet unpub- 
lished data from the Martin-Rowe experiment performed at the NIH. Concerning 
the second exemption it is said that: 
This statement clarifies a category of "self-cloning" experiments that are 
considered safe enough to be excluded from the Guidelines. 
Why they are considered safe enough, and what data supports this conclusion, is 
nowhere to be found. No further rationale is given for the other exemptions. 
None of these exemptions should be permitted until there is adequate risk as- 
[A-235] 
