THE JOHNS HOPKINS UNIVERSITY 
BALTIMORE, MARYLAND 21218 
DEPARTMENT OF BIOLOGY 
October 9, 1984 
Director 
Office of Recombinant DNA Activities 
Building 31, Room 3B10 
National Institutes of Health 
Bethesda , MD 20205 
Dear Sir: 
I wish to comment on the ammendments to the NIH guidelines 
proposed by Mr. Jeremy Rif kin in his letters of August 21 
and 23, 1984. In my opinion, adoption of these ammendments 
would needlessly and drastically curtail significant amounts 
of research designed to further the understanding of the 
genetics of mammalian organisms. As with all such 
experimentation, one must weigh the potential benefits 
against the potential risks in order to reach a rational 
position. These are considered separately below. 
1. What are the risks? If there are any, they are not 
apparent to me. I flatly reject the hypothesis that each 
species has a telos which is violated by the introduction of 
foreign genetic material, and find this position to be 
logically untenable by any objective, rational, and informed 
person. There are any number of examples of the transfer of 
genetic material from one species to another in nature, 
which indicate that species barriers are not absolute. 
Transfer of genetic material from one species to another 
actually may be a significant mechanism of evolution. The 
introduction of genes in the laboratory is not qualitatively 
different from these naturally occurring phenomena. 
If Mr. Rifkin's contention that each species has a 
right to its species integrity is accepted, then the 
selective breeding done by farmers for thousands of years 
would have to be eliminated. It is common practice to 
selectively breed those animals which express desired 
characteristics, e.g. high milk production, large size, 
gentle temperment, etc. Over the years, this breeding leads 
to considerable alterations in the species involved. 
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