Mr. Brewer then suggested the following alternative revision to 
Section I-C of the NIH Guidelines: 
"The Guidelines are applicable to all recombinant DNA 
research conducted at or sponsored by an institution 
that receives any support for recombinant DNA research 
from the National Institutes of Health (NIH). This 
includes research performed by NIH directly. 
"An individual receiving support for research involving 
recombinant DNA must be associated with or sponsored by 
an institution that can and does assume the 
responsibilities assigned in these Guidelines. 
"For any recombinant DNA research done in another 
country, if that country has established rules for the 
conduct of recombinant DNA projects, then a certificate 
of compliance with those rules may be submitted to the 
NIH as evidence of compliance with the NIH Guidelines. 
Alternatively, if the host country does not have such 
rules, written acceptance of the proposed project by an 
appropriate Government office of the host country is 
necessary. The NIH reserves the right to withhold 
funding if the safety practices are not reasonably 
consistent with the NIH Guidelines." 
Mr. Brewer said this puts the burden on every institution to 
adhere to the NIH Guidelines and take them seriously and that 
additionally letters could be written to all institutions to say 
that the NIH expects people to live not only by the written NIH 
Guidelines but the spirit of these Guidelines. He said this 
could be done easily and would not discourage the normal exchange 
of scientific research material and ideas. This letter could be 
made a permanent part of the file for each institution and 
investigator. If this kind of rule had been in effect there 
would have been strong ground for the NIH to withhold further 
funding from Wistar or any other institution which violated its 
intent and spirit. 
Dr. Korwek asked if the NIH ruling that the Wistar project was 
not encompassed within the NIH Guidelines was because of the 
definition of "project," which the NIH interpreted to be 
synonymous with "research grant." Dr. Gartland said the history 
of the third paragraph of Section I-C was it was written to cover 
research grants being awarded to foreign institutions. 
Mr. Mannix asked which funds were being sought to be withheld, 
funds for a particular project or institution-wide funding. Dr. 
Gottesman said she believed it to be institutional funding which 
is a lever NIH has used with institutions to make sure everyone 
within an institution abides by the rules. Therefore a violation 
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