Consumer Coalition 1511 k street, n.w., suite 220 
for Health Washington, D.C. 20005 
202/347-8088 
"Consumers United for 
Better Health Care through 
Effective Planning" 
Dr. Donald S. Fredrickson September 25, 1978 
Director 
National Institute of Health 
Bethesda, MD 20014 
Dear Dr. Fredrickson: 
The procedures for public participation contained in the 
proposed revisions of the DNA recombinant research guidelines 
are woefully inadequate. The impacts of this research, both 
beneficial and deleterious, can be expected to have a tremen- 
dous impact on the public. Nearly all major decisions involving 
DNA research involve two principle components: (1) technical 
assessment of potential risks and benefits which may flow from 
alternative decisions; and (2) balancing of the identified 
potential risks and benefits in light of social values to 
determine which alternative should be selected. Nevertheless, 
the proposed guidelines would leave both the technical and 
value-oriented components in the hands of scientists and others 
selected by research institutions -- people whose personal 
interests and professional roles are likely to lead to incomplete 
and one-sided consideration. 
While research scientists share equally in the stake which 
all of us have in public safety, they can hardly be expected to 
attach the same weight as others to potential benefits and dangers 
of research. They have often chosen their profession precisely 
because they attach preeminent value to increasing the store of 
human knowledge, and they have been taught to emphasize that 
value throughout their professional training. Scientists associ- 
ated with research institutions are likely to perceive this 
responsibility as the quintessential characteristic — indeed 
the very raison d'etre -- of their professional roles. Fame and 
acclaim come not from efforts to ensure that experiments are 
conducted in ways which maximize safety, but from breakthroughs 
in scientific understanding. While research scientists as a 
group can undoubtedly be proud of the strenuous efforts 
frequently made to ensure that experiments will not endanger 
the public safety, their professional perspective will often 
lead them to focus most sharply on their responsibilities to 
D® 
[A-376] 
