TUFTS UNIVERSITY 
Department of U rban and 
Environmental Pohcy 
June 11. 1982 
Dr. William J. Gartland, Jr. 
Executive Secretary 
Recombinant DNA Advisory Comnittee 
National Institutes of Health 
Building 31 
Bethesda, Maryland 20205 
Dear Bill: 
I strongly support the Goldstein-Novick amen<*nent that the NIH Guidelines prohibit 
the construction of biological weapons by molecular cloning. 
I have enclosed a segment of a paper entitled "Social Responsibility in an Age of 
Synthetic Biology: Beyond Biohazards" to be published in Envirorwent . The section 
deals with biological weapons and recombinant DNA molecule technology. In the essay 
I conclude that there are three levels of social accountability over the use of rONA 
for constructing biological weapons. 
First, there is the Convention on the Prohibition of the Development, Production and 
Stockpiling of Bacteriological and Toxin Weapons which became effective in the US in 
March 1975. A United Nations review comnission report issued in March 198D concluded 
that biological materials constructed by rONA techniques are covered by the Conven- 
tion’s articles. Second, there is a federal law (PL 93-6D8) requiring the Department 
of Defense to submit an annual report that explains expenditures in chemical and bio- 
logical research programs. Third, there is an internal ruling by the Undersecretary of 
Defense that all rONA activities funded by ODD will be conducted in compliance with 
the NIH Guidelines. 
Unless the RAC continues to play a strong oversight role in the use of rONA techniques 
that involve cloning toxigenic genes, genes that code for inmunosuppressants or 
virulence factors the society will lose a critical area of oversight. 
The Goldstein-Novick proposal provides an unambiguous statement of NIH's responsibility 
in this important area. Despite the DOD memoranda on the application of the rDNA Guide- 
lines to work funded by the military, as of August 1981 ORDA's list of institutions 
that have registered IBCs included one of three military research centers that do bio- 
logical research. The list included the US Army's chemical and biological research 
division at Frederick, Maryland, but did not include the Naval Bioscience Laboratory at 
Dakland, CA and the Halter Reed Army Institute of Research in Washington. If the DOD 
is serious about conforming to the Guidelines, it is curious that all the biological 
be registered with ORDA and have appropriate IBCs. 
Medford, M«sMchusetls oai;5 
617 6a®- v»o, ntension 737 
[ 791 ] 
