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Federal Register 
natural steps in evolution. Mr. Rifkin is surely 
not well-informed when he tries to protect a 
non-existent principle of species integrity. 
* * * Mr. Rifkin is asking for a blanket 
prohibition on moral grounds. In doing this he 
shows that his view of morality is sorely 
limited, for he does not consider the moral 
harm of allowing human genetic 
abnormalities, some of which cause great 
( misery, to go uninvestigated when we have 
available tools for their study and possible 
j treatment. The door would be closed on 
! important avenues to the alleviation of 
I human suffering if Mr. Rifkin’s amendments 
were to be passed. 
Dr. David Baltimore, Director of the 
j Whitehead Institute, wrote: 
I oppose this proposal * * * it would 
seriously hamper experimental research. The 
transfer of genes from one species into 
another is often a necessary part of protocols 
designed to understand how inserted genes 
behave in host organisms. If the gene is not 
foreign to the host species, its activity is often 
impossible to distinguish from that of 
endogenous genes. 
Regarding Mr. Rifkin’s contention 
concerning the “telos” of species, Dr. 
Baltimore wrote: 
Genes of human and dogs are not 
imprinted with human or canine qualities; 
they are parts of systems and often they are 
virtually identical. 
Dr. B. L. Horecker of the Roche 
Institute of Molecular Biology wrote: 
I would oppose ahy such blanket 
restriction on research and the quest for new 
scientific information as a dangerous 
precedent that is incompatible with scientific 
freedom. How the results of such research 
are implemented becomes a matter for 
regulation, but not the conduct of the 
research per se. 
Dr. Robert M. Bock of the University 
of Wisconsin-Madison wrote: 
Rifkin’s edict could sentence humans to 
continued suffering from autoimmune and 
genetic diseases even after future 
understanding shows safe ways to prevent 
such sufferings and loss of life. 
Fourteen letters containing fifteen 
signatures opposed to Mr. Rifkin's 
proposal were received from various 
societies. These letters were from Dr. K 
W. Allard, President, Genetics Society 
of America: Dr. Robert H. Foote, 
President, Society for the Study of 
Reproduction; Dr. Andrzj Bartke, 
Executive Vice President for the Society 
for the Study of Reproduction and 
Immediate Past President of the 
American Society of Andrology; Dr. 
Charles F. Whitten for the Board of 
Directors of the National Association for 
Sickle Cell Disease; Dr. Warren H. 
Pearse, Executive Director of the 
American College of Obstetricians and 
Gynecologists; Mr. George Zeidenstein 
of the Population Council; Mr. C. 
/ Vol. 50, No. 47 / Monday, March 11, 1985 / Notices 
William Swank, Executive Vice 
President of the Ohio Farm Bureau 
Federation, Inc.; Dr. Elizabeth M. Short, 
Director, Division of Biomedical 
Research and Faculty Development of 
the Association of American Medical 
Colleges; Dr. Harlyn O. Halvorson, 
Chairman, Public and Scientific Affairs 
Board and Dr. Monica Riley, Chairman, 
Committee on Genetic and Molecular 
Microbiology, American Society for 
Microbiology; Dr. Sheldon J. Segal of the 
Rockefeller Foundation; Dr. Preston V. 
Dilts, President, Association of 
Professors of Gynecology and 
Obstetrics; Dr. David E. Rogers of the 
Robert Wood Johnson Foundation; Mr. 
Harvey S. Price, Executive Director, 
Industrial Biotechnology Association; 
and Dr. Charles Yanofsky, President, 
American Society of Biological 
Chemists. 
Nine letters with twelve signatures 
opposed to Mr. Rifkin’s proposal were 
received from physicians. 
Dr. Henry A. Peters of the University 
Hospital and Clinics of the University of 
Wisconsin-Madison wrote: 
As a member of the Medical Advisory 
Board of the Muscular Dystrophy 
Association, I would like to express my 
objections to this unscientific proposal, 
which, because of its probable effect on 
research and hopefully treatment, poses a 
very amoral act. 
Five letters with twelve signatures 
opposed to Mr. Rifkin's proposal were 
received from individuals involved in 
animal care and animal husbandry. 
Among this group, Dr. Neal L. First of 
the University of Wisconsin-Madison, 
wrote: 
... the added gene to the genome of a 
cow, sheep, or pig may add to the diversity ol 
that species in a way which enhances its 
survival or well-being as countless mutations 
have done through the generations. 
A letter commenting on Mr. Rifkin’s 
proposal was also received from Mr. 
Alexander Morgan Capron, Professor of 
Law, Ethics and Public Policy of the 
Georgetown University Law Center. In 
stating his opposition to Mr. Rifkin’s 
proposal, Mr. Capron wrote: 
. . . scientific knowledge and discovery 
. . . are high values in our society and 
attempts to control experimentation that 
stand in the way of advances in knowledge 
or discovery of medically useful procedures 
require substantial justification. 
It seems to me that this justification is 
absent in the case of Mr. Rifkin’s 
proposal. . . . 
Through December 31, 1984, 26 
additional letters with 28 signatures 
were received after the October 29, 1984, 
RAC meeting. Twenty-five of these 
letters with 27 signatures were opposed 
to Mr. Rifkin's proposal. Of these letters, 
twenty-two letters with 24 signatures 
were received from the general public. 
These letters originated from: Boston. 
Massachusetts; Salem, Massachusetts; 
Winthrop, Massachusetts: Logan, Ohio: 
Athens, Ohio; Louisville, Kentucky; 
McArthur, Ohio; New Straitsville, Ohio; 
Albany, Ohio; and Elizabethtown, 
Kentucky. Three letters with three 
signatures were sent by scientists. One 
letter containing one signature 
supported Mr. Rifkin’s proposal. 
I-B-3. The Draft Minutes of the Relevant 
Part of the October 29, 1984, RAC 
Meeting 
Mr. Mitchell asked Mr. Jeremy Rifkin 
of the Foundation on Economic Trends 
to present his proposal (tabs 1182, 1183, 
1184, 1186/11, 1187, 1194, 1195). 
Mr. Rifkin said while closely related 
species may be bred by traditional 
practices, nature rather narrowly 
proscribes what can be accomplished. 
"Species walls, mating boundaries 
establish some limits as to the kind of 
recombinations that may occur through 
natural methods." Mr. Rifkin contended 
the experiments of Dr. Brinster of the 
University of Pennsylvania in which 
genes from one mammalian species are 
introduced into another species are 
qualitatively different from preexisting 
breeding programs. 
Mr. Rifkin said to date the biological 
unit of manipulation has been the 
organism; now the unit of manipulation 
has become the gene. The unit of 
importance ceases to be the species 
itself, but rather the composition of 
genetic materials. Mr. Rifkin contended 
society is beginning a very long, 
protracted journey which will reshape 
our concept of life so that we will 
increasingly see the importance of life at 
the genetic level and not at the species 
level. 
Mr. Rifkin said some researchers 
argue the human growth hormone gene 
transferred into mice by Dr. Brinster is 
not unique, that it’s only a chemical. Mr. 
Rifkin said this argument is a form of 
scientific reductionism; if this gene is 
simply a chemical, then certainly every 
other gene that makes up the human 
species is simply a chemical. If there is 
nothing unique about transferring this 
gene and if the transfer of this gene 
poses no ethical, moral, or public policy 
questions, “at what level would there be 
questions posed?" Would the animal 
have to take on human characteristics 
before a problem would be identified? 
Mr. Rifkin asked RAC to develop 
detailed criteria. “What genes are 
permissible in the human gene pool to 
transfer other species? What genes in 
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