Mr. Rif kin agreed there was still some room for interpretation 
and said, "There is no way that you can develop any kind of 
legal standard that cannot in some way be misinterpreted or 
abused." However he felt the CEQ definition was a "federal 
standard," whereas "direct" had no standard definition used by 
any agency in similar matters. 
Mr. Rif kin said he did not agree with the proposal to allow 
foreign countries not having their own guidelines to issue 
written acceptance in lieu of compliance with the NIH Guidelines. 
He said this would weaken the existing NIH Guidelines. He said 
the point was that the NIH had set international standards and 
that other governments had looked to the RAC and the NIH in 
adopting their own standards. He said the NIH had a 
responsibility for ensuring no double standards are set for 
research and that it has a responsibility for any kind of 
international application of research which it funds. Not to do 
so would send a clear message to other nations that they could 
use third world countries, or other countries, as dumping grounds 
for deliberate release experiments. He said to prevent this he 
would like the wording suggested by the Foundation on Economic 
Trends to be substituted for the proposed wording. 
Upon questioning by Dr. McGarrity, Mr. Rif kin said he did not 
suggest that Wistar was involved directly in the Argentinean 
release of the rabies vaccine. 
Dr. Johnson said he did not wish to comment on the CEQ 
definitions but that he was concerned with the concept of an NIH 
grantee trying to ensure appropriate control of downstream 
research. 
Dr. Neiman said he questioned the legal precedent of the use of 
the term "foreseeable" as to whether it was based on an 
understanding of connectiveness in a scientific sense. He said 
he preferred the use of the word "direct," even if undefined. 
Dr. Neiman asked how the working group intended to cover the 
issue raised by the Foundation of countries who did not have 
their own guidelines as addressed in the final sentence of the 
proposed amendment to Section I-C. Dr. Cohen said it was 
considered as an oversight mechanism to cover those instances 
where no guidelines are in place and approval comes from a 
country to do research on a disease which is endemic to its 
geographic area or population. 
Dr. Neiman said Mr. Lanman's suggested wording used sponsorship 
by an institution, as opposed to the project, as the basis for 
potential enforcement and that seemed consistent with what is 
done generally for human experimentation in this country today. 
He endorsed this approach. 
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Recombinant DNA Research, Volume 13 
