School of Sciences and Health Professions 
Office of the Dean • (804) 440-3274 • Norfolk, VA 23508-8508 
OLD DOMINION 
UNIVERSITY 
October 4, 1984 
Director 
Office of Recombinant DNA Activities 
Building 31, Room 3B10 
National Institute of Health 
Bethesda, Maryland 20205 
Dear Sir: 
I wish to object to the request of Mr. Jeremy Rifkin to the National 
Institute of Health, as recorded in the September 20, 1984 issue of the 
Federal Register , "to prohibit any experimentation involving the transfer 
of a genetic trait from one mammalian species into the germ line of another 
unrelated mammalian species." Such a regulation would clearly negate all 
the progress that has been made in genetic regulation in the last 50 years. 
It would severely restrict the exciting opportunities for developing unique 
qualities of food, fiber, and research animals, and sacrifice, at the beginning, 
the potential for human use in the relief of severe genetic disorders. 
Furthermore, to impose a suspension of all National Institute of Health 
research grants for any institution that engages in such experimentation, 
regardless of the funding source , will be tantamount to terminating most 
of the health related research in this country because all the major research 
institutions will unquestionably be involved. It would again set the scene 
for forcing United States scientists to either wait angrily while watching 
their foreign counterparts move ahead with the field, or to join them or 
to proceed in a clandestine manner. 
I would like to call Mr. Rifkin's attention that the "telos" of a 
mammal was "violated" the first time it was tamed or selectively bred and 
that nature "violates" this hereditary sanctity by continual evolutionary 
experimentation, including direct gene transfer via retro viruses. 
I find it interesting that the restriction applies only to mammals, 
where it is "morally reprehensible," implying that it is acceptable to 
violate "telos" of a worm, fish, snake or chicken. 
The implications of this movement would be severe, and for the future totally 
crippling. Please fight it fiercely! 
Sincerely 
Joseph C. Daniel, Jr. 
Dean 
JCD, Jr : jr 
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