Dr. Donald Fredrickson 
4 
January 19, 1978 
As for privately sponsored researchers, inability to publish 
is not an effective sanction, and even when coupled with the ex- 
posure to legal liability may not be enough. Legislation is un- 
doubtedly needed. It should require adherence to the guidelines, 
permit federal inspections, provide some structure of fines 
for disobedience, and preempt state and local legislation. Such 
legislation is not needed to protect the public from the conscientious 
industrial researchers whose companies have been voluntarily complying 
with the guidelines right along. It is needed to deter less 
responsible researchers from entering this field and destroying the 
reputations of those whose record to date is so good. 
The preceding suggestions are based on the belief that peer 
review, coupled with some local oversight using national standards, 
is the appropriate enforcement philosophy for this research. It 
presupposes, however, the existence of guidelines which are scienti- 
fically reasonable since restrictions for which there is an inadequate 
rationale, encourage disobedience. Finally, it puts the burden of 
responsibility on the scientists where it ought to rest in the hope 
that it will act as a vote of confidence in their integrity. Because 
the scientists doing this research were the first to share its 
problems with the public, even though restrictions were sure to 
follow, they have earned our trust. We should not now reward that 
behavior by imposing such conditions on this research as might change 
the relationship between the scientists and the pubic from cooperative 
to adversarial. 
I trust these remarks will be of assistance to you in continuing 
your exemplary efforts to accomplish the difficult task of drafting 
the Revised Guidelines. Thank you for the privilege of participating 
in the discussion concerning them. 
Sincerely 
/ 
Dennis J. Helms 
Special Assistant to the 
Attorney General 
DJH: lea 
[Appendix A — 221] 
