Lilly Research Laboratories 
A Division of Eli Lilly and Company 
Lilly Corpofaie Center 
Indianapolis. Indiana 46285 
Irving S Johnson. Ph 0 
Vice Presdem 
(317) 276-4391 
January 20, 1987 
Dr. William J. Gartland, Jr. 
Director, Office of Recombinant 
DNA Activities 
National Institute of Allergy 
and Infectious Diseases, 31/3B10 
National Institutes of Health 
Bethesda, Maryland 20205 
Dear Dr. Gartland: 
Eli Lilly and Company is a research-based corporation that 
develops, manufactures, and markets human medicines, medical 
instrument systems, diagnostic products, agricultural products, 
and cosmetics. We are actively involved in recombinant DNA 
research in several areas of life sciences. Therefore, we would 
like to make the following comments on the proposed actions 
published in the December 19, 1986, Federal Register , 5 1 , No. 244. 
I. Dr. Talbott proposes amendments to Sections I-A and III-A of 
the NIH Guidelines to relieve the need for the NIH Recombinant 
Advisory Committee (RAC) to review experiments submitted to 
other federal agencies with notification of ORDA of the 
action taken. 
We support adoption of the proposed revisions. 
II. The Working Group on Definitions of the RAC proposes 
definitions of deliberate release by revisions of Section 
III-A-2 of the NIH Guidelines. 
We support adoption of the proposed revision of this section 
which adds clarity to the Guidelines and properly addresses 
the issue of deliberate release. 
III. The Working Group on Definitions of the RAC proposes two 
alternatives for the definition of recombinant DNA by 
revision of Section I-B or Section III-A-2 of the NIH 
Guidelines . 
Recombinant DNA Research, Volume 1 1 
[259] 
