Working for the Nature of Tomorrow, 
NATIONAL WILDLIFE FEDERATION 
1412 Sixteenth Street, N.W., Washington, D C. 20036-2266 (202) 797-6800 
December 7 , 1988 
HAND DELIVERED 
Ms. Rachel Levinson 
National Institutes of Health 
Office of Recombinant DNA Activities 
Room BIC 34 
9000 Rockville Pike 
Bethesda, MD 20892 
Dear Ms. Levinson: 
I am writing on behalf of the National Wildlife Federation 
(NWF) , the nation's largest conservation education organization. 
The NWF requests that the National Institutes of Health 
(NIH) Recombinant DNA Advisory Committee (RAC) recommend to the 
NIH Director that the Guidelines for Research Involving 
Recombinant DNA Molecules ("Guidelines") be expanded to encompass 
research involving organisms engineered by techniques other than 
recombinant DNA. 
Expanding the scope of the Guidelines is necessary because 
recent advances in science have added to the list of techniques 
capable of producing genetically novel organisms. A growing 
number of such organisms are not subject to the current 
Guidelines, which provide oversight only of those organisms 
formed by narrowly defined recombinant DNA techniques. Like 
recombinant DNA, these new techniques will produce organisms that 
may pose human health and environmental risks. 
We readily acknowledge the difficulty of defining the scope 
of NIH guidelines in an era of rapid technological change. 
Although there may be other approaches, to begin the discussion, 
we propose that Section I-B of the NIH Guidelines, Definition of 
Recombinant DNA Molecules, be replaced by a new section bringing 
within the scope of the guidelines all organisms into which 
foreign DNA has been stably integrated, regardless of technique. 
We do not propose particular language because we believe that the 
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