University of Wisconsin-Madison 
LABORATORY OF GENETICS 
406 Genetics Building 
Madison, Wisconsin 53706 
0. Smithies 
Office: (608)262-2976 
Laboratory: (608) 262-1047 
October 17, 1984 
Dr. William J. Gartland 
Executive Secretary, RAC 
National Institute of Allergy 
and Infectious Diseases 
National Institutes of Health 
Bethesda, MD 20205 
Dear Dr. Gartland: 
This letter is to comment on the two amendments to the NIH Guidelines for 
Recombinant DNA Experimentation submitted by Mr. Jeremy Rifkin for possible 
consideration by the Recombinant DNA Advisory Committee (RAC) at its next meeting 
on October 29th, 1984. 
Mr. Rifkin states that his amendments are to protect "the principle of 
species integrity" transgression of which "violates the right of every species to 
exist as a separate, identifiable creature." He also wishes the committee to 
endorse his view that any transfer of genes between non-breeding mammalian 
species, particularly when a human is the donor or recipient, is abhorrent and 
"morally and ethically unacceptable." The basis for Mr. Rifkin' s assumed 
principle of species integrity is not stated by him, nor are any arguments 
presented to support his personal view that inter-species transfer of genes is 
morally unacceptable. 
I am a Hilldale Professor of Genetics and Medical Genetics at the University 
of Wisconsin-Madison, a member of the Genetics Section of the National Academy of 
Sciences, and a past President of the Genetics Society of America. I have been 
for many years and continue still to be an active investigator in the field of 
molecular genetics. I use recombinant DNA technology every day in my laboratory. 
I am also active in studying the natural evolution of genes in various species, 
including man. In all my studies I am constantly made aware of the great 
commonality of genetic material. Mammalian species that have no possible means 
of breeding at the present time have features in their genomes of remarkable 
similarity. Nowhere do I find evidence supporting any inviolate principle of 
species integrity. Indeed, there is increasing evidence that genetic material 
can be transferred from one species to another by viral and other microbial 
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