Dr. William J. Gartland, Jr. 
National Institutes of Health 
February 1 , 1984 
Page Three 
Accordingly, we strongly urge RAC to respond negatively to each of Dr. 
Talbot's questions, and to continue RAC's role rather than to weaken it. 
Ultimately, this will best serve NIH's biomedical constituency and its 
mission. We offer the following brief additional comments on the 
individual questions: 
1. As indicated, we think it appropriate for RAC to continue 
scientific review of deliberate release field testing. In any 
case, the intended definition of laboratory seems imprecise, and 
should be clarified to include fermentors of various sizes, green- 
houses and plant growth chambers. 
2. We believe that NIH scientific review of industrial rDNA 
activities has clearly contributed to a level of governmental and 
public confidence that impacts the orderly and stable development 
of rDNA science. A casting off of this role would be counter- 
produc t ive . 
3. RAC has conducted closed sessions in the past when discussing 
large-scale proposals from industry. Responsible decisions, pro- 
tecting the public's interest, are not and were not precluded by 
this approach. We believe that continuation of closed sessions to 
at least some degree is important for the necessary protection of 
proprietary data. Most governmental agencies regularly protect 
confidentiality while maintaining public confidence. NIH can re- 
fine its techniques in this area, with help from groups like IBA, 
so that neither public welfare nor proprietary information 
need be compromised. 
4. The boundaries of biomedical research are not clearly defined. 
Nobel Laureate Barbara McClintock's research on the genetics of 
maize demonstrated how genes can move around within the cellular 
genome and has substantial biomedical implications. NIH, in 
addition, has funded research on plant viruses. We believe that 
it would be unwise and illogical at this dynamic stage of rDNA 
any specific area of research to draw lines excluding research 
from review. However, while we feel that RAC should continue for 
now to review protocols for field testing of organisms constructed 
by rDNA techniques, we do believe it to be reasonable for RAC to 
reconsider and redefine this role from time to time as the tech- 
nology matures. There is historical precedent for this in RAC's 
oversight of large-scale work. 
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