techniques, microinjection, chemical poration, cell fusion) that 
can produce genetically novel organisms but will not necessarily 
involve "a joining of natural or synthetic segments to DNA 
molecules" outside living cells. References 4-13 provide a 
sample of techniques currently capable of producing so-called 
transgenic organisms — those with DNA from dissimilar parent 
organisms . 
The key to these new transgenic techniques is that they are 
not dependent upon vectors to transfer the foreign DNA. Although 
these techniques are not yet well understood, it is known that 
small pieces of foreign DNA introduced into a cell without 
vectors can become incorporated into the chromosomes and be 
expressed. 
As a result of these advances, transgenic organisms may be 
produced by a number of techniques, including, but not limited to 
recombinant DNA. Transgenic techniques that do not require 
"recombinant DNA" procedures produce organisms that can be 
identical to organisms created with recombinant DNA techniques. 
RAC members acknowledged the deficiencies in the current 
Guidelines at June 3, 1988, meeting in a discussion of amendments 
to the Guidelines regarding transgenic animals (14, 15, 16). 
Certain experiments with transgenic animals are not subject to 
the Guidelines because the DNA added to the animals is not 
"recombinant DNA" as defined by the Guidelines. According to 
meeting participants, 
o "...there is a serious and significant loophole that needed 
to be addressed..." (16, p. 18); 
o the technology exists to create non-recombinant transgenic 
organisms ("...the technology is moving fast enough that by 
the time this [transgenic animal amendment] went anyplace 
that there will be such things", (16, p. 26); 
o some transgenic organisms pose hazards ("...if you're 
injecting DNA into an animal .. .you 've potentially created 
something that might be harmful, so you shouldn't let it 
wild. You couldn't let it out into the wild." (16, p. 39). 
SUMMARY 
Gene transfer technology has now moved beyond recombinant 
DNA techniques. The NIH should delay no longer in developing 
Recombinant DNA Research, Volume 13 
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