GEORGETOWN UNIVERSITY LAW CENTER 
WASHINGTON, D. C. 20001 
October 10, 1984 
ALEXANDER MORGAN CAPRON 
PROFESSOR OF LAW. 
ETHICS AND PUBLIC POLICY 
Dr. William J. Gartland 
Executive Secretary, RAC 
National Institute of Allergy 
and Infectious Diseases 
National Institutes of Health 
Bethesda, MD 20205 
Dear Dr. Gartland: 
202-624-8327 
Dr. Ruth Kirschstein has 
by Mr. Jeremy Rifkin in letters 
suggestion that I might wish to 
proposals to you in advance of 
kindly sen 
of August 
communicat 
the October 
t 
2 
e 
me the proposals made 
1 & 23, with the 
comments on these 
29th RAC meeting. 
My comments will be brief because I trust that you will 
hear at greater length from those who are better able to describe 
the shaky biological premises on which Mr. Rifkin's proposals 
rest, as well as their dire consequences for scientific 
investigation and clinical progress. I will address myself only 
to the proposition asserted in the August 23 proposal that the 
NIH should announce that "experimentation involving the transfer 
of genetic traits between animal and human germ lines to be 
morally and ethically unacceptable." 
As anyone who has thought about the ethics of biomedical 
research and practice recognizes, it is true that scientific 
knowledge and discovery of new forms of medical treatment are not 
the only values, nor necessarily even the highest goals, in an 
ethical society. On the other hand, they 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 proposals for two reasons. First, even 
assuming that the term "genetic trait" has a well established 
meaning, the "transfer" of the DNA sequence responsible for such 
a "trait" from one animal to another (a human) might well involve 
the "transfer" of a DN/ sequence very close (perhaps identical) 
to one that occurs "naturally" in members of the second animal 
species, but which is more readily available from, better 
characterized in, etc. , the first animal than from fellow members 
of the second animal's species. The notion (on which the Rifkin 
proposals apparently rest) that DNA sequences are species 
limited"--so that any transfer from one to another violates 
species integrity — not only ignores Darwinian theories of 
evolution (based, as is now known, upon DNA changes) but ignores 
the fact of total or substantial similarity of the DNA sequences 
among species, including homo sapiens. 
[507] 
