Document 37 
DEPARTMENT OF AGRICULTURE 
orncE or the secretary 
WASHINGTON. D. C. 20250 
December 6. T976 
Dr. Donald S. Frederickson 
Director, National Institute of Health 
Building 1, Room 124 
Bethesda, Maryland 20014 
Dear Dr. Frederickson; 
This is in response to Mr. Charles Custard's letter of September 2, 
1976, to Dr. David J. Ward of this Deparment asking for comments on 
the HEW "Draft Environmental Impact Statement" concerning the "Guidelines 
for Research Involving Recombinant DNA Molecules" as recently issued by 
the National Institutes of Health. 
The Department of Agriculture especially understands the continuing 
opportunities for accruing benefits to agriculture and society as a 
whole through further research to improve plants, livestock and poultry, 
and to control their diseases and other pests. We have reviewed both 
the research guidelines as published by NIH (Federal Register, July 7, 
1976) for recombinant DNA molecules and the associated environmental 
impact statement (Federal Register, September 9, 1976). 
The Department finds the environmental impact statement on the whole 
to be objective and sound. However, we are concerned that there be 
some reasonable balance which minimizes any potential for serious harm 
to world food and fiber production without unduly impairing research 
needed to further increase the quantity and quality of these materials 
so vital to man. 
Our greatest concern is that the public might misinterpret parts of 
the environmental impact statement. We must avoid creating any 
erroneous impression in the minds of people of the public, press, and 
legislatures that the recombination of DNA is something new and 
dangerous. It is the basis of life and occurs naturally with each 
sexual reproduction. It has led to the development and continuing 
evolution of the marvelous and indispensable genetic diversity between 
and within species. The experimental recombination of DNA through 
plant and animal breeding, which makes use of this diversity, has 
resulted in greatly improved crops and livestock for the benefit of 
mankind . 
The guidelines and the environmental impact statement should make clear 
that conventional plant and animal breeding approaches have resulted in 
great good and no harm, and that the guidelines do not apply to them . 
Appendix K — 181 
