CALIFORNIA ,INSTliUTE OF TECI-INOLOGY

Dr. A. Karin Ahmed
flatural liesolzrces Defense Council, Inc.
15 West 44t5 Street
New York, Iiew York 10036

?ear Dr. Ahmed:

I zm ple ased to support the petition of the. Environment&l Defense Fund
and the Lational Resources Defense Council to the Secretary of Eealth,
Educ.aticn and Welfare concerning recombinant CX4 activities. This petition
has two comFcnects: the first requests the Secretar; to promulgate interim
regulations to make the present NIX Guidelines concerning recombinant DE.4
research b,inding on all parties engaged in reccmb3znt X4 research in the
United States.  The second requests the Secretary to conduct a "legislative-
type" hppri-++ t.0 ght.+~i_n_ yery br~)aiQr basea tes+im-*-r 7rhi-h  rn; rhi  r,,;Tld
                                                      1---w "-, ..**..1.. LbC""  OUI.Ab 2.
reformulation of the present recombinant 3%'~. Guidelines, taking into
consideration issues not addressed and points of view not presented during
their development.

The Guidelines have been developed out of the concet$ that there is a
potential hazard to public health in  cer tain  forms of reccmbinant DBA
research.  It is evident that this hazard is not restricted to recomb<70
                                                            ,.,L?lt
DNA researc,h conducted with the aid of NIK (or other Federal) funds.
1 therefcre support their esCvension to cover all research activity in this
.field, however supported and wherever performed. This research does not
require elaborate facilities and large capital investment.  There is,
therefore, no reason to believe that it will be limited to large institutions
or industrial concerns with proven records of responsibility.  Further, the
virtual certainty of the development of new techniques. and of the cxtefision
of these techniques to additional organisms and higher life forms will rec_uire
8 free flow of infcrmation, a continuing updating of guidelines, and the
continuin& scrutiny of this field of research by a boZjr which will endeavor
to reflect the public interest.

The need to consider the reformulation of the Guidelines derives from the
perception that they were dcveloued from too narrow a perspective. In my
opinion the Guidelines were developed to address solely the immediate medical


Dr. A?.-. Km-in Emed
October 28, 1976
Page `2

hazards that night arise m the conduct of such research.  The Guidelines
do not address what I perceive as the larger, potcntlal ecologic&L and
evolutionary hazards implicit in this research.  'F!or do t'ko Guidelines
address the potential significance of the availability of this new tec'rslologi -
developed by scientists to solve their olrn scientific problms - to other
diverse sectors of OUT society, which my wish tc use it for their okm ends.
I belidve the Guidelines do not provide suff' -1cie:lt recognition of the fact
-that we are here creating novel living organists -~m~recwkfited in the
evolutionary orcier.  As living orga3is:zs they are self-cerpetuatixg 252
destir,ed to their okm indivicunl evolution.  I do cot believe x~e cm predict
the properties of these orgenisms - created by the fwior, of genes fron
disparate species - or their subsequent evolution, or their in!:?sct, present
and future, op. the existent biosphere.  \!c do not !3ok' that there is a
hazard here but neither do lie know there is not.  If such hazard exists or
develops it vi.11 be in this instance uniquely irreversible.   I believe 2
thoughtful.~eforoulation of the Guidelines to ta!re these circuzstssces into
account would be most appropriate.

Sincerely yours.

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Robert L. Sins&tier
Chairmn