IBA 
Directors 
Officers 
President 
Ronald E. Cape 
Cetus Corporation 
Vice President 
Gabriel Schmergel 
Genetics Institute 
Secretary 
Hollis G. Schoepke 
G D. Searle & Company 
Treasurer 
John E. Donalds 
The Dow Chemical Company 
Hugh A D'Andrade 
Schering-Plough Corporation 
Richard L. Easterday 
Pharmacia, Inc. 
J. Leslie Glick 
Genex Corporation 
John R, Norell 
Phillips Petroleum Company 
David J. Padwa 
Agrigenetics Corporation 
George B. Rathmann 
Amgen 
Dear Dr. Gar t land: 
The following comments to the National Institutes of Health's Recombinant 
DNA Advisory Committee (RAC) are submitted on behalf of the Industrial Biotech- 
nology Association (IBA), a trade association representing many of the leading 
commercial biotechnology companies. A current membership roster is attached. 
RAC has been requested to modify the NIH Guidelines for Research Involving 
Recombinant DNA Molecules such that a specific class of genetic experiments 
would be prohibited. Such experiments involve the transfer of a genetic trait 
from one mammalian species into the germ line of another, unrelated mammalian 
species. This request is made not in response to any demonstrated danger, but 
rather because these experiments are said to violate species integrity and are 
therefore morally and ethically objectionable. We oppose the request as unrea- 
sonable and illogical. Philosophical arguments of this type have been invoked 
throughout history to obstruct scientific inquiry, and fail to take into 
account the benefits that have consistently accrued to society from such free 
inquiry . 
Initially, instead of focusing on philosophical and moral arguments, it is 
important to consider the implications of the petition's argument. The tech- 
niques of molecular biology have permitted scientists to unravel many of the 
secrets of gene structure and function. Early research concentrating predomi- 
nantly on the simple bacterium Escherichia col i paved the way for a greater 
understanding of the more complex higher organisms. Research on the genetics 
of maize pointed to the instability of genetic material, and demonstrated that 
genes are not in a fixed position on a chromosome but may be translocated. 
Over the past several years, such research has formed the foundation for mecha- 
nistic studies on carcinogenesis. As one major result of this research, scien- 
tists have identified a number of oncogenes and their means of action. The 
ability of scientists to transfer genetic information between organisms has 
Industrial Biotechnology Association 
21 1 5 East Jefferson Street 
Rockville, Maryland 20852 
Telephone: (301 ) 984-9598 
Harvey S. Price 
Executive Director 
October 12, 1984 
Dr. William J. Gartland, Jr. 
Executive Secretary 
Recombinant DNA Advisory Committee 
National Institutes of Health 
Building 31, Room 3B10 
Bethesda, MD 20205 
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