Brookhaven Organization of Scientists
P. O. Box 929
Upton NY 11973

Sidney H. Kahana, President
Tel: 516-344-3738
Gerry M. Bunce, Vice President
Stephen L. Dewey, Secretary
Alfredo U. Luccio, Treasurer
Stephen E. Schwartz, Past President

October 1, 1999

Mr. Douglas J. Hinckley
Office of Counterintelligence, CN-1
Docket No. CN-RM-99- POLY
U.S. Department of Energy
1000 Independence Avenue, SW
Washington, DC 20585.

Re: Polygraph Examination Regulation; Proposed Rule, 10 CFR Parts 709, 710, and 711
[Docket No. CN-RM-99-POLY] RIN 1992-AA24

Dear Mr. Hinckley:

The Brookhaven Organization of Scientists (BOS) is a membership organization consisting of scientists
and professionals at Brookhaven National Laboratory. We, the executive committee of BOS, write to
express our views and concerns regarding the proposed rule Polygraph Examination Regulation dealing
with polygraph testing at Department of Energy National Laboratories. We ourselves perform research in
basic and applied science in areas ranging from environmental research to accelerator based science and
astrophysics. Scientists at BNL work with scientists at all the National Laboratories, including Los
Alamos, Oak Ridge, Sandia, and Livermore. Although we concur in the need for security in areas of
defense research, we strongly oppose the imposition of polygraph testing in the National Laboratories.

The grounds for our opposition include the following:

1. Polygraph testing is in principle demeaning to the individual by constituting an unreasonable invasion
of his or her privacy.

2. Polygraph tests and their interpretation may be used arbitrarily against staff.

3. Imposition of polygraph testing will severely inhibit the ability of the DOE laboratories to attract and
retain high quality scientists and thereby damage the ability of the laboratories to fulfill their missions.
In this sense, we believe that polygraph testing will undermine national security.

Above all, we oppose polygraph testing because it will exert a chilling effect on the conduct of science in
the DOE National Laboratories.

Sincerely yours,

Sidney H. Kahana

Gerry M. Bunce

Alfredo U. Luccio

Stephen E. Schwartz

Brookhaven Organization of Scientists is an association of scientists and engineers at Brookhaven National Laboratory
dedicated to keeping BNL "A place where superb science flourishes."Brookhaven Organization of Scientists is not
affiliated with Brookhaven National Laboratory or the Department of Energy.