77 
AFTERNOON SESSION 
DR. FREDRICKSON: Ladies and gentlemen, we will begin our afternoon 
session. We are continuing with presentations from public witnesses rela- 
tive to the subject of physical containment. Next to appear is Dr. Susan 
Wright. Dr. Wright, are you ready? 
DR. WRIGHT: Is this on physical containment? 
DR. FREDRICKSON: This is physical containment, yes. 
DR. WRIGHT: I have no comment on this. 
DR. FREDRICKSON: You have none on this? All right. 
Then may we turn to Ms. Francine Simring. Ms. Simring? Ms. Simring 
has five minutes. 
MS. SIMRING: I would like to talk about the interconnection between 
the physical-containment levels and the Environmental Impact Statement 
which was published this past month of November. The National Environmental 
Policy Act requires a detailed Environmental Impact Statement, and insures 
that major Federal actions are not undertaken before, one, assessment of 
risks and possible benefits, two, exploration of alternatives. This might 
mean alternative procedures or physical-containment levels, et cetera, study 
of environmental impacts, full disclosure of the basis for action, and an 
opportunity for effective public participation in the decision-making pro- 
cess. 
No Environmental Impact Statement has been prepared for the proposed 
revised Guidelines. The Environmental Impact Statement — those are the fat 
and medium-thin Yellow Books that you have. That Impact Statement was 
developed for the original, 1976 Guidelines, which has just been released, 
and which cannot be considered a substitute for the required Impact State- 
ment for the proposed revised Guidelines. 
If the NIH had complied with NEPA in this matter, full disclosure of 
data and analysis of environmental factors would have been provided to the 
public well in advance of this hearing. Compliance by NIH with the NEPA in 
developing the revisions could have provided the proper framework for objec- 
tive decision-making and public input. It is clear that a full EIS should 
have been prepared and made available to the public well in advance of this 
meeting, as I have just said, and it is our opinion that no decisions be 
made on these revisions until an Environmental Impact Statement is prepared 
for them, and public hearings held. 
We are hopeful, I would like to add, that this hearing today will pro- 
vide information toward that end. 
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