DEPARTMENT OF THE ARMY 
U S, ARMY MEDICAL RESEARCH INSTITUTE OF INFECTIOUS DISEASES 
FORT DETRICK, FREDERICK, MARYLAND 21701 
SGRD-UIZ-C 9 June 1982 
William J. Gartland, Jr., Ph.D. 
Director 
Office of Recombinant DNA Activities 
National Institute of Allergy and 
Infectious Diseases 
National Institutes of Health 
Building 31, Room 4A52 
Bethesda, Maryland 20205 
Dear Dr. Gartland; 
Thank you for bringing this proposed amendment to my attention. I will plan 
to attend the RAC meeting on 28 June when this comes up for discussion. Prior 
to that time, however, you may wish to distribute to RAC members the following 
formal comment from my Agency. 
DoD Statement 
The DoD has no objection to the proposed amendment but believes it is unnecessary 
in view of the U.S. understanding of the terms of the Biological Weapon Convention 
(BWC) which already prohibits the use of recombinant DNA techniques for 
development of biological or toxin weapons. 
The DoD position is to support and abide by the NIH Guidelines in full, in both 
its in-house, and contract funded research. This position would not change if 
the amendment was adopted. 
There are, however, several items in the rationale for the proposal as developed 
by the authors which require correction so there is lio misunderstanding. The 
statement that "the development prohibition is generally interpreted in military 
circles as applying only to the assembly of delivery vehicle" is false. The 
Department of Defense compliance with the BWC was clearly stated in a 
certification to the President in January 1976 by the Secretary of Defense that 
all programs were in full compliance with "prophylactic, protective, and other 
peaceful purposes" permitted by the Convention. 
Further, the statement "the developiaent of biological weapons for "defensive" 
(e.g., deterrent) purposes would be excluded" is also seriously mistaken as 
the position statement prepared by the Arms Control and Disarmament Agency (ACDA) 
[ 788 ] 
