Tho Director will shortly promuh ate the first sot of guidelines 
based on the committee's recommendations. Some scientists believe 
the recommendations, even if scrupulously followed by researchers, 
provide inadequate safeguards. Enforcement of the guidelines 
will be difficult enough for research funded by the NIH. They will 
not even apply to research not funded by the NIH , which includes 
some done at universities and all supported by industry and by 
the Department of Defense. 
Most knowledg cable scientists agree that there is little 
data on the magnitude of the risks involved with recombinant DMA 
research. In the absence of such data, it is not possible to 
evaluate the adequacy of safeguards proposed for the research. 
In this situation, wisdom and safety require extreme caution, 
including restricting the research to locations where, as nearly 
as possible, surviving organisms containing recombinant DNA can 
be totally contained. Damage arising from inadequate safeguards 
may be irreversible. On the other hand, if reliable data on the 
hazards of the research are acquired to establish that lesser 
restrictions would suffice to safeguard people and the environment, 
restrictions can always be relaxed accordingly. 
Rather than being permitted with virtually no constraints 
at an unlimited number of places, recombinant DNA research should 
be restricted through appropriate legislation and regulations to 
a few facilities which are equipped to prevent the escape of organisms 
containing recombinant DNA. There are now twenty-one such facilities 
in the United States. 
Scientists at institutions which do not have such facilities 
would not be precluded from doing recombinant DNA research. 
Arrangements could easily be made, through the NIH or a multi- 
university consortium for example, for the sharing of such facilities 
so that scientists would have access to a facility when they need 
to use recombiant DNA techniques in their research. Similar 
arrangements already exist for some resaerch in high energy physics 
and astronomy. 
Bill Scanlon 
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