Those who indiscriminately scatter seeds of unknown nature must presumably bear 
with whatever weeds spring up as a result. No one can guess the specific consequences 
as recombinant ENA techniques proliferate worldwide, and as the capabilities of gene- 
splicing practitioners (for good or ill) become steadily more powerful with the accum- 
ulation of new knowledge, 'Curtiss chooses to ignore the proliferation and puissance 
issues altogether. He notes that "...enteric diseases are very well controlled in 
the United States (emphasis added) by sanitary engineering..." (p. 6). This is rem- 
iniscent of Wallace Rowe's comment, "Developed (emphasis added) countries know how to 
prevent epidemics of enteric bacteria..." ( Bulletin of the Atomic Scientists . May, p. 15). 
Those who wonder who will fill the moral vacuum regarding international agreements 
(deemed "essential" in the Guidelines) marvel at such parochialism. 
The much-touted Guidelines are relatively meaningless if potentially harmful ENA 
cannot be accurately recognized in advance. Donor ENA may be adventitiously contamin- 
ated with that from deadly bacilli or other tag-alongs. In addition, recent research 
hai largely destroyed the meaningfulness of the "harmful sequence" concept. It has 
been found that bacterial genes may jump from place to place on ENA molecules ( Science , 
30 July 1976, p. 39?). Moreover, we now know that gene sequences sometimes overlap, 
and occasionally are completely nested within a different gene's ENA sequence ( Science , 
10 June 1977, p. 1187). Furthermore, "spliced" viral messenger RNA has been found 
which is composed from three separated areas on the viral DNA molecule ( Science News, 
30 July 1977, p. 70). Thus the potential hazard of any given ENA sequence will depend 
in complex fashion on idiosyncrasies in the host's translation processes, and on epi- 
demiological and potentiating factors completely outside of the microorganisms under 
study — and beyond the training of the investigator. It may depend on the relative 
ability of possible victim organisms to generate antibodies, or on the likelihood that 
mutagenic chemicals or ionizing radiation may liberate a pathogenic subsequence by 
breaking a ENA chain at a key point. So much for the scientific foundation of the 
NIH Guidelines. Systematic basic safety research is almost completely lacking, and 
it may well be too dangerous to conduct many obvious risk-assessment studies until 
contaiment technology is improved; such is the plain meaning of the experiments 
ruled impermissible by the Guidelines. We know enough to say that certain organisms 
and procedures are especially likely to yield harmful consequences; we don't know 
enough to say that others are harmless. 
Pontius Pilate committed a heinous deed by washing his hands. If recombinant 
ENA practitioners seem determined to follow in the same tradition, what can citizens 
do? They can insist on pinning full financial liability (without regard to fault) 
on any scientist or institution which generates an injurious recombinant. Curtiss's 
attitude shows clearly on p. 13, where he says, "The worst possible provision (for 
Congressional legislation) would be a stipulation of specific liability. This would 
act as a de facto prohibition of recombinant ENA activities in this country, the con- 
sequences of which would be staggering," In other words, after twelve pages of de- 
tailed argument, Curtiss says in effect that the scientists, their institutions, and 
the insurance companies still aren't willing to risk their financial skins. What he 
means is, "Don't ask us scientists to put our money where our mouth is. Don't require 
us to shoulder our logical insurance responsibility. Instead, let's all jump off the 
pier together— investigators and the public alike— and hope that we catch valuable 
fish instead of just drowning." It is heartening that Litton Bionetics, Inc. was 
forced to withdraw from NIH-contracted PU recombinant-ENA experiments proposed for 
Fort Detrick, because of an inability to gain insurance coverage (Frederick Post, 
June lfc, 1977). 
* * * 
[Appendix A — 20] 
