VI. SPECIFIC TECHNICAL COMMENTS AND RECOMMENDATIONS 
A. Scope 
NRDC supports the extension of the guidelines to 
experiments which incorporate synthetic DNA segments 
into DNA molecules (§ I-B of the guidelines) . NRDC also 
supports application of the guidelines to all institutions 
which receive NIH funds regardless of whether the 
recombinant research is NIH supported. (§ I-C) . 
We also favor extension of the 'guidelines to 
industry. The establishment of a voluntary registry 
for private industry is a step in the right direction 
(43 FR 33044). But as we have argued in other comments 
and the NRDC and EDF petition, the guidelines should be 
promulgated as binding regulation applicable to all 
parties conducting recombinant DNA research under the 
7/ 
authority of the Public Health Services Act.— 
B. Prohibitions 
Prohibitions in §§ I-D-3 and I-D-5 allow the creation 
of pathogens and the transfer of drug resistance to pathogenic 
organisms if such combinations are known to occur "naturally.” 
This ignores the fact that such "natural" combinations can 
be either extremely rare or extremely toxic. For example, 
though gonorrhea has been treated with penicillin for many 
years, a strain of gonococcus with resistance to the drug 
has only recently been found. This is no reason to sanction 
7/ 42 U.S.C. § 264. 
[A-187] 
