Dr. James B. Wyngaarden 
January 20, 1984 
Page 2 
Furthermore, the proposed experiment raises issues of use and abuse that 
go beyond the question of safety, narrowly defined. A report commissioned by the 
U.S.Army Dugway Proving Ground has concluded that "a more feasible use of re- 
combinant DNA than the creation of new pathogens is the cheap manufacture of 
toxins. . .Toxins could probably be manufactured by newly created bacterial strains 
under controlled laboratory conditions." * Could information from the proposed 
experiment — with or without the investigators' consent — be used for such purposes? 
Shouldn't the potential social costs of such work (development of a new knowledge 
base for biological warfare) be weighed in a consideration of this proposal?** 
4. A proposal to expand the membership and responsibilities of the RAC to include 
oyersight of proposals involving genetic engineering in humans. 
This policy decision is related to decisions about the boundaries for 
NIH oversight of recombinant DNA activities. If it is decided that the RAC will 
no longer review industry proposals, this will mean that some plans for genetic 
engineering in humans may be made in the private sector without government oversight. 
If it is decided that the RAC is the appropriate body to make such policies, 
how will committee members be selected? For an issue as large as genetic engineering 
in humans, questions of nomination, selection, and representation are clearly 
critical. Particular care needs to be taken to ensure that the composition of the 
committee reflects not only breadth in expertise but also in occupation and social 
position. 
I question whether the RAC is the right organization to consider policy 
issues such as these. The committee's charge is a narrow one, and the committee 
itself has generally construed its role narrowly. These issues should be brought 
before a more broadly constituted body before the RAC makes decisions on "safety" 
and broader policy is decided by default. 
Furthermore, because of the late circulation of the Federal Register 
announcement, premature consideration of these issues by the RAC on February 6 and 
7 will seriously undermine the democratic process. I would like to request that 
these decisions be postponed and that adequate arrangements be made for public 
comment, d.i scngsion, and. decision making at the appropriate .level . 
Sincerely, 
Susan Wrightr 
Head, Science Program 
Frank B. Armstrong, A. Paul Adams, William H.Rowe, "Recombinant DNA and the 
Biological Warfare Threat," unclassified version of a classified report 
commissioned by U.S.Army Dugway Proving Ground, TECOM No . 8-CO-513-FBT-021 
(May 1981). . 
** A discussion of military interests in biological research is given in 
Wright, S. and R.L.Sinsheimer , "Recombinant DNA and biological warfare," 
Bulletin of the Atomic Scientists 39 (.November 1983) . 
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