CARNEGIE INSTITUTION OF WASHINGTON 
Department of Embryology 
115 West University Parkway 
Baltimore, Maryland 21210 
Telephone: 467-1414 
October 1, 1984 
Director 
Office of Recombinant DNA Activities 
Building 31 - Room 3310 
NIH 
Bethesda, MD 20205 
Dear Sir: 
In this letter, I wish to object to the proposed ammendment to the NIH guide- 
lines on Recombinant DNA forwarded by Mr. J. Rifkin as it was described in the 
Federal Register 49^ #184 (September 20, 1984). 
The introduction of foreign genes into the germ line of mammals other than 
humans has many potential benefits for mankind. Genetic changes by modern methods 
can be done rapidly and with much greater precision than conventional breeding and 
selection programs. Indeed, it may well be possible to change a desired trait 
with much less overall genetic changes and in fewer organisms by use of cloned 
genes and gene transfer methods than was heretofore possible using long-term 
breeding methods. At any rate, the overall genetic changes are minimal by gene 
transfer with no reason to believe that the species would be placed in any danger. 
The introduction of genes into the germ line of humans is a subject of 
considerable discussion and debate at the present time. There are many instances 
such as well-defined genetic defects that may be amenable to gene therapy, and 
there is no reason to rule out foreign genes categorically for these uses. Official 
committees are wrestling with the pros and cons of this kind of research and therapy. 
Committees exist to protect humans from many kinds of intervention and to regulate 
the research on human subjects and human material. Categorical prohibitions at 
this time are not needed and unnecessarily restrictive. Let the debate continue 
until a reasonable conclusion emerges. Even then, it is a mistake to adopt such 
categorical restrictions that would limit future options. 
Mr. Rifkin's reason for this ammendment is that "the crossing of species 
borders, and the incorporation of genetic trails from one species directly into 
the germ line of another species represents a fundamental assault on the principle 
of species integrity and violates the right of every species to exist as a separate 
identifiable creature". This is his own interpretation of the rights of animals. 
It is highly personal and in no way constitutes grounds for such all encompassing 
rules. 
(con ' t) 
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