Dr. Cohen said the working group tried to deal with this issue. 
The proposal was not designed to impede responsible research, but 
to make sure that appropriate people know the research is going 
on so that any potential problems can be dealt with. He said any 
suggestions to this end would be most welcome. 
Dr. Gottesman said she saw the proposal as making applicability 
more specific, limited to projects only, rather than the overall 
work being undertaken by an institution, when dealing with a 
foreign institution. She questioned whether this proposed 
amendment to Section I-C would have helped in the Argentinean 
incident had it been in place. She said it was really addressing 
a different issue. 
Dr. McGarrity said that the collaboration was with a commercial 
organization, not an academic institution, and in his opinion 
unless commercial organizations voluntarily followed the NIH 
Guidelines such experimentation would not be covered. 
Dr. Gartland said he understood that Wistar turned the vaccine 
over to a French company who then collaborated with PAHO which 
conducted the field trial in Argentina. Mr. Jeremy Rif kin said 
his understanding was that the NIH supplied funds specifically to 
Wistar to conduct the research and the only portion of the 
research that was not funded by NIH was the small portion of 
funds needed to do the experiment in Argentina. 
Dr. Gottesman asked Mr. Lanman if his suggested rewording of 
Section I-C would cover the Wistar incident. Mr. Lanman said it 
was directly pertinent because his issue was to what extent 
domestic applicability should differ from foreign applicability. 
He asked how we would deal with the same situation if it occurred 
domestically. He said the phrase "sponsored by" might be a more 
ambiguous term and subject to more interpretation. 
Mr. Rif kin commended the working group for their recommendations. 
He said the key word was "responsibility," and the reason the 
issue was raised at all was the nature of the experiment in 
Argentina. He said Wistar had received millions of dollars from 
NIH to develop a rabies vaccine and then took money from other 
sources to conduct the field experiment in Argentina in 
connection with PAHO and a French company. He said the working 
group did a good job at closing the loopholes but that the phrase 
"direct extension" still left a loophole for interpretation. 
Mr. Rifkin said there was legal precedent in definitions found in 
regulatory language promulgated by the Council on Environmental 
Quality ( CEQ) for the use of the word "connected" rather than 
"direct." He said that actions are connected if they, "cannot or 
will not proceed unless other actions are taken previously or 
simultaneously and are inter-dependent parts of a larger action 
and depend on the larger action for their justification." 
Recombinant DNA Research, Volume 13 
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