UNIVERSITY OF CALIFORNIA, SAN FRANCISCO 
BERKELEY • DAVIS • IRVINE • LOS ANGELES • RIVERSIDE • SAN DIECO • SAN FRANCISCO 
SANTA BARBARA • SANTA CRl'Z 
SCHOOL OF MEDICINE SAN FRANCISCO, CALIFORNIA 94143 
DEPARTMENT OF BIOCHEMISTRY AND BIOPHYSICS (41 s) 666-4324 
October 23, 1984 
Dr. William J. Gartland 
Executive Secretary, RAC 
National Institute of Allergy and Infectious Diseases 
National Institutes of Health 
Bethesda, Maryland 20205 
Dear Dr. Gartland, 
I am writing to express my strong concern over the amendments proposed 
by Mr. Jeremy Rifkin, which were published in the Federal Register (volume 
49_:37016-37017, which I received today), for discussion at the RAC meeting 
to take place October 29, 1984. I was informed in a phone conversation with 
the RAC office today that it would be possible to have these comments 
accepted so long as they arrived by October 26th. 
Although I am presently the Vice-President of the Genetics Society of 
America as well as President-elect (for 1985), I am presenting my comments 
not in any official capacity for the Society but rather as a concerned — 
deeply concerned — geneticist. 
Mr. Rifkin's amendment of August 23, 1984 proposes a prohibition of 
transfer of a genetic trait (i) from a human being into the germ line of 
another mammalian species and (ii) from any mammalian species into the germ 
line of a human being. I am opposed to a blanket prohibition of these two 
types of procedures in large part because I believe that such procedures 
will yield information that will have important, beneficial consequences for 
the health and well being of both humans and other mammals. My specific 
reasons follow. 
DNA transfer from humans or other mammals into non-human mammals makes 
it possible to address fundamental questions in developmental biology 
concerned with gene expression. In addition such transfer experiments make 
it possible to address fundamental questions concerned with carcinogenesis. 
Information gleaned from these experiments is certain to provide important 
new insights into disease processes both in humans and in other mammals. 
The end result will be a literal strengthening of species, a deeper 
understanding that will improve the ability of these species to combat 
disease . 
Without hearing the report of the Working Group on Human Gene Therapy 
that is to be presented at the October 29 meeting, I am hesitant to take a 
firm position on the transfer of traits from a human or non-human mammal 
into the human germ line. Obviously, this procedure must be considered 
within the context of guidelines governing experimentation involving human 
subjects. With these disclaimers aside, my present personal feeling is that 
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