37 
We appreciate the extensive work that has obviously gone into the prep- 
aration of this meeting under pressures of many kinds from many sources. 
You know, I wish that there were someone who could make me recombinant 
spectacles that would make me comfortable for near and far. 
I would like to state for the record, however, that because of the 
portentous scope of this issue, that my presentation today is far from 
its completion, for I received the necessary National Institutes of Health 
documents which consist of some more than 500 or 600 pages only within the 
last two weeks. It was not possible for me, and I daresay for many others 
as well, to read, digest, compare, and evaluate the copious materials and 
to shape them into the designated areas of discussion in so short a period 
of time. 
Although Friends of the Earth has been involved in this issue for 
almost two years, and in correspondence with Dr. Fredrickson for not much 
less than that, we had to request by telephone that these documents be sent 
to us. It is most regrettable that the NIH did not select alternatives 
such as earlier and wider distribution of materials to insure adequate 
preparation time, or a later date for this meeting in order to provide 
adequate preparation time for us all on many sides of the issue. I urge, 
therefore, that the NIH extend its time limit for comment so that those who 
are submitting written testimony can give these documents their due measure 
of time and concentration. 
Unfortunately, haste in many forms has not been a stranger to the course 
of recombinant DNA research. The New York Times , Business Week , and the 
Report on International Activities by the Interagency Committee of November 
attest to the rapidity with which commercial development has been proceeding, 
despite continuing controversy, despite lack of regulation, despite Guideline 
violations engendered in part by competitive haste, and despite lack of the 
classic sort of evidentiary data that has traditionally been the hallmark of 
scientific investigation. The haste to push ahead has led at times to omis- 
sion of standard scientific canon, and to the use of informal and incomplete 
commentary. For example, a letter to Dr. Fredrickson informally reporting on 
the Falmouth Conference by Chairman Sherwood Gorbach was used as a basis for 
the proposed revised Guidelines and for other actions, yet the Gorbach letter 
does not indicate the sense of concern expressed at the Falmouth meeting that 
E. coll K-12 might transfer its foreign genetic material to wild E. coli 
strains and to other species in the human gut. Indeed, Dr. Gorbach closes 
his letter with the statement that further investigation should be of high 
priority. We would like to indicate that letters illustrating these points 
by Dr. Bruce Levin of the University of Massachusetts, Dr. Richard Goldstein, 
of Harvard Medical School, and Dr. Jonathan King of MIT were sent to Dr. 
Fredrickson, yet none of this correspondence was included as reference along 
with the others concerning the Falmouth Conference which is listed in the 
Green Book. 
Similarly, another basis for the revision of the Guidelines, the Chang- 
Cohen experiment, is not balanced with references to peer criticisms which 
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