January 11, 1978 
Dr. Donald Frederickson 
National Institutes of Health 
Bethesda Maryland. 
Scott Thaclier 
28 Munroe St. 
Somerville, Mass. 02134 
Dear Dr. Frederickson: 
I was grateful for the opportunity to participate in the open NIH 
hearings on December 14 and 15, 1977, on proposed new guidelines for recom- 
binant DNA research. At that time I criticized the NIH for not appointing 
a guidelines committee wuich was not more representative of scientists' and 
non-scientists' views .' >,Here are my criticisms and suggestions in more 
detail. 
1) Include non-scientists, and scientists in fields not closely related 
to recombinant DNA research, in deliberations from the beginning of any 
revisions of the guidelines. The guidelines committee had little such 
perspective and,, indeed, was not even representative of the feelings of 
molecular biologists themselves on the caution required for evaluating the 
research. A successful effort to have primarily non-scientists take part 
in deliberations on research safety can be seen in the report of the Cam- 
bridge Experimentation Review Board ( Bulletin of the Atomic Scientists , 
May 1977, p. 2). This group showed that in a few months they could grasp 
and responsibly eVduluate the consequences of recombinant DNA research and 
make suggestions for safety regulations that are still being debated nationally 
— for example, whether to institute a program to maintain for' many years 
the health records of workers who have been in recombinant DNA laboratories. 
Non-scientists must be given long-term involvement in these discussions so 
they can educate themselves enough to challenge some of the assumptions made 
by scientists more deeply involved in the field of recombinant DNA research. 
2) The NIH should take nominations for this committee from the following 
groups who have showed concern over regulation of the research: several 
labor unions, including the Oil, Chemical, and Atomic Workers' and the 
AFL-CIO; environmental groups such as Friends of the Earth, the Sierra 
Club, the NRDC, and many others; involved and knowledgeable community gov- 
ernments such as in Cambridge, Mass. , and Ann Arbor, Mich; and groups of 
science activists such as Science for the Feople and the Coalition for Res- 
ponsible Genetic Research. Statements of the nominees 
^-should be part of the public record, followed by public hearings on 
their selection. A brief resum£ of the qualifications and activities of the 
committee members should be included with guidelines which they write. 
It was disturbing that the proposed revised guidelines did not even show re 
the committee members' names. 
3) The Advisory Committee 4b the Director of the NIII, brought together 
just for these hearings, was the most broadly representative group of non- 
scientists to consider the research for the NIH so far. Their effect is 
certain to be not much more than token, however, since the tenure of most 
of the committee members was limited to the two days of the hearings. The 
formation of thcb a committee, with little ability to follow uj^on its 
recommendations, whitewashes the more difficult problems ofiTOJe^S&ed 
parties, only a sampling of are given in paragrfl||U two, in the direction 
of scientific research and its regulation. 
Xro <t -)>). 
- / L- 
Scott M. Thacher Graduate student, Committee on Higher Degrees 
in Biophysics, Harvard University 
Member: Science for the leople, 897 Main St., 
Gambiriidge, Mass. 02139 
[Appendix A — 209] 
