ELI LILLY AND COMPANY 
INDIANAPOU3, INDIANA -4020© 
C. W. PETTINGA, Ph. D. 
EXECUTIVE VICE PPESIOENT 
November 7, 1977 
DonaldS. Frederickson, M. D. 
Director 
National Institutes of Health 
Department of Health, Education, and Welfare 
Bethesda, Maryland 20014 
Dear Don: 
Enclosed are our comments on the proposed revisions in the NIH 
Guidelines on Recombinant DNA Research. An identical copy has 
been furnished to the Pharmaceutical Manufacturers Association 
which will comment on behalf of a number of companies. 
Since the moratorium on research involving recombinant DNA 
and the publication of the initial guidelines, several aspects of 
this situation have become increasingly obvious. Recombinant 
DNA research will not be as dangerous to mankind as initially 
postulated by its opponents. Also, the potential benefits to man- 
kind may not be as rapidly achieved as originally thought by the 
proponents. 
Although Lilly has supported the concept of legislation to provide 
for the licensure of recombinant DNA research facilities, certain 
of the legislative proposals currently before the Congress do cause 
our scientists concern. The regulation of research, i. e. , the 
regulation of inquiries to establish new knowledge, is an extremely 
difficult task and must be approached with great caution to avoid 
inhibiting the growth of knowledge. We continue to believe that 
research is best left unregulated but, if licensure of some sort 
is necessary, that the restrictions on responsible laboratories 
be minimal. 
We appreciate the opportunity to comment on the proposed revisions 
in guidelines. We are also grateful for the objective, intelligent 
leadership that you and other members of the National Institutes of 
[Appendix A — 36] 

