DEPARTMENT OF STATE 
Washington, D C. 20520 
BUREAU OF OCEANS AND INTERNATIONAL 
ENVIRONMENTAL AND SCIENTIFIC AFFAIRS 
June 18, 1982 
Dr. William Gartland 
Director, Office of Recombincuit 
DNA Activities 
National Institutes of Health 
Building 31, Room 4A52 
Bethesda, Maryland 20014 
Dear Bill: 
This is to comment on the amendment to the National 
Institutes of Health (NIH) Guidelines on Recombinemt DNA 
which has been proposed by Drs. Novick and Goldstein. 
I have discussed the issue with Dr. Robert Mikulak of 
the Arms Control and Disarmament Agency and find myself 
in accord with that Agency's views as expressed in Dr. James 
L. George's letter to you of June 8, 1982. In addition to 
the views expressed in that letter amd as a non-voting 
member of the Recombinant DNA Advisory Committee (RAC) I 
have some additional observations. 
It has been ny understanding that the puzrpose of the 
RAC is to advise the Director, NIH regarding safety aspects 
of experiments involving Recombinant DNA and of the NIH 
Guidelines. I believe that this issue introduces a political 
element into the RAC that is beyond the scope of its official 
mandate. Moreover, while there is no question about the 
propriety of members of the RAC expressing their opinion 
on this issue, the last paragraph on the first page of the 
rationale for the proposal gives me a great deal of concern. 
The description of the US military's interpretations of pro- 
visions in The 1972 Biological Weapons Convention is stated 
without substantiation or specific attribution. I believe that 
description is false. 
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