4 
5. Frederickson, because of the potential escape of 
hazardous organisms in DNA research, promulgated "guidelines" 
for the conduct of such experiments. 41 Fed. Reg. 38427, Sept. 9, 
1976. By later preparing a "Draft Environmental Impact Statement" 
to cover the guidelines, which in turn govern the Ft. Detrick 
experiments, it would appear that the defendants are estopped 
to deny the Ft . De trick experiments require an Environmental 
Impact Statement. Environmental Defense Fund v. Corps, of 
Engineers, 325 F. Supp. 728, (E. D. Ark. 1970-71), --F. Supp. 
7 -^, (E. D. Ark.), 342 F. Supp. 1211, (E. D. Ark.), aff'd, 470 
F.2d 289, (8th Cirl 1972). Sierra Club v. Hardin, 325 F. Supp. 
99, (D. Alas. 1971). 
6. Frederickson has further committed himself to the 
view that an environmental impact assessment of the Ft. Detrick 
experiments is required. In his "Decision of the Director, NIH, 
to Release Guidelines for research on recombinant DNA Molecules". 
41 Fed. Reg. 27902, July 7, 1976, Frederickson states: 
A number of commentators urged 
NIH to consider preparing an 
environmental impact statement 
on recombinant DNA research 
activity. They evoked the 
possibility that organisms 
containing recombinant DNA 
molecules might escape and 
affect the environment in 
potentially harmful ways. 
I am in full agreement 
that the potentially harmful 
effects of this research on the 
environment should be assessed. 
As discussed throughout this 
paper, the guidelines are premised 
on physical and biological con- 
tainment to prevent the release 
[Appendix C — 48] 
