Friends of the Earth 
72 Jane Street • New York, New York 10014 • (212) 675-5911 
May 17, 1976 
Dr* Donald Fredrickson, Director, 
National Institutes of Health 
U.S. Dept, ©f Health, Education & Welfare 
Bethesda, Maryland 200l!i 
Dear Dr. Fredrickson: 
We understand that you are considering adoption of the NIH Advisory Committee 
proposed guidelines for research involving the recombination of DNA molecules, 
preparatory to drawing up and issuing regulations, and would like to make some 
comments and suggestions at this time regarding the guidelines and regulations. 
Friends of the Earth is a national environmental organization, with many foreign 
affiliates, and has been active at all levels ©f government in the key environ- 
ment, conservation and natural resources issues of our day, including many which 
have direct bearing on human health and welfare such as nuclear power. Although 
at this time we are not qualified to scrutinize the specifics regarding DNA 
guidelines and containment (others have of course done so), we do have deep con- 
cern for the as yet unknown risks, the unquantifiable risks, and, not least, the 
broader social, ethical, political and evolutionary implications of genetic 
engineering in general. 
We have been particularly struck, in the small, preliminary steps being taken te 
deal with genetic engineering problems, with the parallels t© the nuclear power 
controversy, which of course received no public debate or scrutiny for the first 
twenty years ©f its commercial existence. Both nuclear power and genetic engineering 
seem to be proceeding ©n the assumption that they must proceed, yet no public 
debate has been initiated on genetic engineering even now as the impetus grows. 
We believe that all debate on this subject should start with the basic question? 
should genetic engineering (or any branch of it) take place at all? 
Further, since genetic research and its human or non-human applications are with- 
out a doubt major actions, particularly because HEW guidelines are involved, we 
believe that NIH should prepare an environmental impact statement in compliance 
with the National Environmental Policy Act. Hcwever, we would hope that this 
impact statement would not be limited only to the biohazards associated with 
recombinant DNA research but with the broader spectrum of issues as raised above. 
In this regard we would like to point out to you some of these areas of concern 
to which any proper EIS should be addressed. 
l)Evolut ionary 
What are the consequences of interfering with or re-directing evolution and 
natural selection? Of reducing diversity in the gene pool, as in gene therapy? 
Should recombinant DNA proceed without our knowing whether genetic barriers 
between species are adaptive or accidental, positive or neutral? Shouldn*t 
population geneticists such as Ernest Mayr be consulted on this? 
[ 542 ] 
