Oklahoma State University 
OFFICE OF THE DEAN & DIRECTOR 
DIVISION OF AGRICULTURE 
STILLWATER, OKLAHOMA 74078-0500 
139 AGRICULTURAL HALL 
405-624-5398 
College of Agriculture Agricultural Experiment Station 
Cooperative Extension Service 
May 26, 1987 
Dr. William Gartland, Director 
Office of Recombinant DNA Activities 
12AA1 Parklawn Drive, Room 58 
Rockville, MD 20852 
Dear Dr. Gartland: 
In response to the Federal Register notice of March 11, 1987, the 
Committee on Biotechnology, Division of Agriculture, National Association 
of State Universities and Land-Grant Colleges, offers the following 
comments . 
The proposed amendments to the "Guidelines for Research Involving 
Recombinant DNA Molecules" by the Foundation on Economic Trends and Jeremy 
Rif kin is unnecessary and inappropriate. The language is vague and overly 
broad and would not serve to further safety in research involving 
recombinant DNA molecules. The proposed amendment would apply to 
development of recombinant organisms and also to products under the purview 
of the guidelines for projects performed abroad. The NIH Guidelines are 
designed to provide safety in research ; other safeguards apply to product 
development. The language, "all such work that is reasonably foreseeable," 
is so broad to include techniques or processes beyond the scope of the 
Guidelines. The remainder of the proposed amendment concerning the 
definition of NIH support is so unclear as to avoid utility. 
The Committee on Biotechnology recommends that the Recombinant DNA 
Advisory Committee deny approval of the amendment proposed by the 
Foundation on Economic Trends and Jeremy Rifkin in the March 11, 1987, 
issue of the Federal Register (52 Fed. Reg. 7525). 
Division of Agriculture, NASULGC 
jh 
cc: 
Committee on Biotechnology 
1332 ] 
Recombinant DNA Research, Volume 13 
