COMMENTS OF THE FOUNDATION ON ECONOMIC TRENDS 
ON PROPOSED REVISION OF SECTION 1-C, NIH GUIDELINES 
FOR RESEARCH INVOLVING RECOMBINANT DNA MOLECULES, 
53 FEDERAL REGISTER 12752 (APRIL 18, 1988) 
The following are the comments of The Foundation on Economic 
Trends on the proposed revision by the Working Group on 
International Projects of the last paragraph of Section I-C of 
the National Institutes of Health Guidelines for Research 
Involving Recombinant DNA Molecules (NIH Guidelines) published in 
53 Fed. Reg. 12752. 
The Foundation on Economic Trends (Foundation) commends the 
National Institutes of Health (NIH) on its efforts to resolve 
linguistic ambiguities in Section I-C. As noted by the 
Foundation in its letter to the NIH of January 9, 1987, which 
instituted the review of Section I-C, allowing NIH funded 
deliberate releases of recombinant DNA abroad without compliance 
with the NIH Guidelines could lead to severe impacts on the 
environment and serious repercussions in the international 
diplomatic community. In its letter, the Foundation cited the 
international scandal over the Wistar experiment in Azul, 
Argentina involving a recombinant vaccinia and rabies vaccine as 
the paradigm example of the potentially catastrophic results of 
not applying the NIH Guidelines to deliberate releases abroad. 
Since that time it has also been reported that the Argentina 
experiment, which took place without notification of the 
Argentine government, may have led to infection of 17 workers by 
one or both of the viruses. 
In its January 9 letter, the Foundation suggested a proposed 
amendment to Section 1-C in order to prevent further 
international environmental hazards and embarrassments due to 
unregulated deliberate releases of genetically engineered 
organisms. This proposed amendment was published for comment in 
the Federal Register of March 11, 1987, and again on August 11, 
1987. There was extensive discussion of the amendment during the 
September 21, 1988, FAC meeting, including substantial comments 
by Fcurdation president, Jeremy Rifkin, and counsel Edward Lee 
Rogers . 
The Working Group on International Projects has row 
unanimously supported a reworked proposed revision of Section 
1-C. The Foundation approves of this revision with two 
significant exceptions: 
1. The proposed revision makes tie NIL Guidelines applicable 
to research involving deliberate release or testing in humans of 
recombinant DNA material, if that material is developed with NIH 
funds and "the research is a direct extension of the development 
process." (emphasis added.) The Foundation opposes the use of 
the concept "direct" extension as a qualifying and limiting 
factor in applying the NIH Guidelines to international 
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