Dr. Donald Fredrickson 
December 27, 1977 
page -5- 
4. Hazards of biological research in general . 
As I implied above that DNA recombinant research may be no more hazardous than 
biological research in general, I should make it explicit that I am not suggesting 
(as Jim Neel seemed to be doing) that there is a need for regulation of an even 
more extensive segment of research. I share with many scientists the rather 
parochial tendency to draw on different types of research for my comparisons, as 
though bacteriological research were the sole, or even a major, human activity 
that influences the growth and distribution of bacteria. But certainly the 
doctor who prescribes penicillin to a patient, the farmer who puts another acre of 
soil under cultivation, and the city that builds a new sewage disposal plant 
all have much greater impact in this respect than the research biologist does. 
I suspect that the total impact of all biological research activities is quite 
trivial, although there may be exceptions. 
5. Burden of proof . 
Finally, I must comment on Mr. Hutt's summary statement, in which he reiterated 
his viewpoint that the burden of proof must be on the scientist to prove that the 
research is safe, rather than on others to prove that it's dangerous. I'm not 
sure that I really understand his point (and may even be misstating it here) . 
I suspect it's derived, to some extent, from other areas of practice - e.g., drug 
manufacturers must demonstrate the safety of their products by performing feeding 
tests to show they are not toxic; clothing manufacturers should test flame retar- 
dants for carcinogenesis, etc. In these areas, there is clear precedent for 
expecting danger, based on previous experience with other products, and standard 
tests are available to evaluate specific risks. With recombinant DNA research, 
neither of these conditions obtains. The risks if any are unknown. What passes 
for "risk assessment" tests various aspects of containment but does not deal 
directly with danger. I suspect that Mr. Hutt's viewpoint is colored by a 
residual impression that there is some a priori grounds for expecting the research 
to be dangerous, but I may be wrong. At the moment, the activities of molecular 
biologists seem to be judged by quite a different standard from those applied 
to the farmer, the doctor and the sanitary engineer mentioned in my previous 
paragraph. 
I apologize for the length of this letter, and also for the fact that it does not 
consist of specific suggestions for the immediate task at hand. However, evalua- 
tion of the revisions to the Guidelines does require an assessment of the overall 
status of the questions that generated the Guidelines themselves. 
AC /an 
cc: Jonathan King 
David Suzuki 
Dennis Helms 
James Watson 
Paul Berg 
George Wald 
Robert Sinsheimer 
Bernard Davis 
Peter Hutt 
James Neel 
Sincerely yours, 
: V' ; 
i,<T 
Allan Campbell 
Professor of Biology 
[Appendix A — 160] 
