JAN 6 1987 
UNITED STATES DEPARTMENT OF COMMERCE 
International Trade Administration 
Washington, D C 20230 
Dr. William J. Gartland 
Director, ORDA 
Bldg. 31, Room 3B10 
National Institute of Health 
Bethesda, MD 20892 
Dear Dr. Gartland: 
After reviewing the proposed changes in the NIH Guidelines for Research 
Involving Recombinant DNA Molecules , I find the suggested changes to be 
reasonable. 
However, I would strongly urge that in the proposed revision of section 
III-A-2 of the NIH Guidelines you consider the first alternative, namely 
to redefine recombinant ENA, rather than to modify section III-A-2. 
By redefining recombinant ENA, the guidelines demonstrate support of the 
definition adopted by the OSTP and strengthen the objective of the OSTP 
document by demonstrating a coordinated approach. 
In contrast, if you become involved with the question of deliberate 
release, you are opening up a pandoras box for which there are numerous 
definitions and very little agreement. 
Additionally what may be "accepted scientific practice" today may not be 
tomorrow. I believe that suggestion #2 has the potential of becoming a 
rather argumentative modificiation 
Hope you had a happy new year. 
Best Regards, 
M Heilman 
Science Advisor 
for Biotechnology 
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