38 
are available. Barbara Rosenberg of Sloan-Ketter ing Institute, Dr. Burke 
Zimmerman's Report on Recombinant DNA for the House Subcommittee on Health, 
these are just two of the criticisms that are available. 
In addition, until the Curtiss views and data on the transfer of foreign 
DNA are published and subjected to independent criticism and experimentation, 
we must await the resolution of their status. The NIH justification cannot be 
termed complete without consideration of alternative views, further notwith- 
standing the absence of an officially accepted transcript of the Falmouth 
Conference, and of publication of data by Curtiss and others. The Recom- 
binant DNA Advisory Committee approved on June 23 the proposed revised 
Guidelines. We question how the Falmouth Conference can be used as justi- 
fication for these revisions when the revisions were approved on the very 
day following the Falmouth Conference. Whatever else the proposed revised 
Guidelines are based on, it could not have been the formal results of the 
Falmouth Conference. 
The proposed revised Guidelines for Recombinant DNA Research would 
generally relax containment standards, limit their applicability to novel 
recombinant DNAs , and provide the NIH with virtually unlimited power to 
bestow exemption from those Guideline requirements. But we have not yet 
been convinced that the original Guidelines of June of '76 were adequate 
to their purpose, nor do we believe that there has been sufficient risk- 
assessment to warrant relaxation of the Guidelines at this time. 
One last point, if I may, indicative perhaps of the NIH's approach 
to developing safeguards, thus far is the apparent failure to consider 
the options of perhaps more stringent as well as less stringent standards. 
This approach is exemplified by the provisions in the Guidelines which 
permit exemptions from standards under specified circumstances, but do 
not provide for further restrictions should this be warranted or needed. 
DR. FREDRICKSON: Thank you, Ms. Simring. Will you remain at the 
podium? 
Mr. Hutt. 
MR. HUTT: Could you give us some idea how much additional time you 
are asking for when you said that the record — 30 days for additional comment 
was not sufficient? 
MS. SIMRING: I would like people here to contribute too. I think 
at least another month. 
MR. HUTT: And you would in that time — you believe that you would 
be able to gather together all of the information that you would wish to 
present? 
MS. SIMRING: I would think so. If there are people who work a lit- 
tle more slowly or who have more heavy commitments in other areas, perhaps 
they would like more time. 
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