Lilly R*s«arch LaboratoiiM 
A Division o( Ell Liny and Coinpany 
307 East McCarty Street 
Indianapolis Indiana 46285 
Irving S Jonnson Ph 0 
Vice PinOani 
January 29, 1982 
Dr. William J. Gartland, Jr., Director 
Office of Recombinant DMA Activities 
Building 39, Room 4A52 
National Institutes of Health 
Bethesda, Maryland 20205 
Re: Recombinant DNA Research 
Proposed Revised Guidelines for Research Involving 
Recombinant DNA Molecules, 46 Fed . Reg . 59368 
(December 4, 1981) 
Dear Bill: 
Eli Lilly and Company (Lilly) has been involved in recombinant 
DNA research and product development for several years. In 
addition to observing the 1974-76 moratorium on certain types 
of recombinant DNA research, Lilly scientists have voluntarily 
complied with the guidelines since their inception. Company 
representatives have regularly attended meetings of the NIH 
Recombinant DNA Advisory Coimnittee, suggested certain 
modifications in the guidelines, and studied and commented on 
proposals advanced by others. 
The proposed modifications in the guidelines might appear to 
impact primarily on NIH grantees and thus be considered to affect 
somewhat less directly, the non-NIH funded research laboratories 
that comply on a voluntary basis. We feel, however, that contin- 
uing unnecessary limitations on any significant part of the 
country's research endeavors adversely affects the entire 
research community. Furthermore, the obvious encouragement given 
to foreign practitioners of recombinant DNA technology by their 
respective governments places a responsibility on our Federal 
agencies to permit all U.S. laboratories, whether academic, 
government, or industrial to remain competitive in such efforts. 
Anticipated public health and environmental risks in relation to 
recombinant DNA activities have not developed; increased inputs 
from experts in the fields of infectious disease etiology and 
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