recombinant DNA research and technology but rather the beginning 
of full public consideration of all relevant issues. 
The guidelines apply only to recombinant DNA research 
supported by the NIH. While Dr. Donald Fredrickson, the 
director of NIH, has called on all government agencies and 
"all who support or conduct such research throughout the 
United States" (41 Fed . Reg . No. 131, p. 27906, July 7, 1976) 
to voluntarily adopt the NIH guidelines, only the National 
Science Foundation, Department of Defense, and the Energy Research 
and Development Administration have formally done so.* Therefore, 
a significant portion of recombinant DNA research and technology 
is not covered by any mandatory set of safety procedures, leaving 
the public unprotected from its potential hazards. Furthermore, 
it is the position of the petitioners that the public did not 
have an adequate opportunity to participate in the basic policy 
decisions underlying the NIH Guidelines. 
For these reasons, EDF and NRDC request that: 
(1) a public hearing of broader scope than those held this 
year at NIH be held on the questions of to what extent and 
under what conditions recombinant DNA research and technology 
should be allowed to proceed; (2) final regulations be 
promulgated based on the record of that hearing which would 
apply to all recombinant DNA research and technology in the 
* Dr. Joe Perpich, National Institutes of Health, personal 
communication . 
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