5 
sessment and a detailed environmental impact statement prepared. 
The discussion of E. coli K-12 illustrates the biased nature of the envi- 
ronmental impact assessment. From the testimony at today's hearing it is ap- 
parent that a number of issues concerning this organism have not been ad- 
dressed. In addition, while the letter from Dr. Gorbach in regard to the Fal- 
mouth risk assessment workshop is quoted at length, no mention is made in the 
assessment of the letters from Drs . Levin, Goldstein and King which had differ- 
ing views about the results of Falmouth. Dr. Bruce Levin, a population ecolo- 
gist from the University of Massachusetts, who participated in the Falmouth 
workshop, stated that: 
I don't believe that evidence available through existing efforts at risk 
assessment is sufficient to justify a relaxation of the current NIH guide- 
lines on recombinant DNA research or of the efforts to enforce them. 
Dr. Richard Goldstein, Professor of Microbiology at Harvard Medical School, and 
Dr. Jonathan King, Professor of Microbiology at MIT, both attended the Falmouth 
workshop and jointly wrote to the Director of the NIH concerning that meeting: 
The meeting was serious and the participants did not belittle the problems 
associated with assessing risk in the construction of hybrid E. coli . The 
discussions were lively, with very frequent recognition that many classes 
of risk could neither be dismissed nor accurately assessed, without fur- 
ther experimentation. 
In terms of safety, we feel that there is no basis for a loosening of the 
NIH Guidelines until much more experimental data has been collected, and 
much broader experience and expertise brought to bear on the problems. 
Both of these letters were published by the NIH in the Recombinant DNA Techni- 
cal Bulletin, Vol. 1, No. 1, Fall 1977, but were utterly ignored in the envi- 
ronmental assessment. This kind of omission clearly violated the intent of 
While lengthy, though biased, attention is paid to E. coli K-12 in the as- 
sessment, there is virtually no analysis or assessment of the use of other 
hosts or vectors, some of which are already in use, such as. Bacillus subtilis. 
or have been developed for use, such as, Saccharomyces cerevisiae (baker's 
NEPA. 
[A-236] 
