FORM LG-4870 
E. 
#Plt ) 
US «T»TM Off 
ESTABLISHED 1802 
I. du Pont de Nemours & Company 
INCORPORATED 
Wilmington, Delaware 19898 
LEGAL DEPARTMENT 
February 3, 1984 
Director 
Office of Recombinant DNA Activities 
Building 31, Room 3B10 
National Institutes of Health 
Bethesda, MD 20205 
Gentlemen : 
Proposed Amendments of the NIH Guidelines 
and Comments by the Director, NIAID 
On behalf of E. I. du Pont de Nemours and Company 
(Du Pont) , I am pleased to submit the following comments on 
the above-captioned subject matter published at 49 Fed. Reg. 
696 (1984). 
I. Proposed Amendments of the NIH Guidelines 
and Comments by the Director, NIAID 
Du Pont wishes to advise the National Institutes of 
Health that it concurs in and supports the decision of the 
Director, NIAID, that a generic environmental impact statement 
or assessment is neither proper nor required by law. Du Pont 
further supports the position of the Director that each appli- 
cation be given careful consideration and the determination of 
whether an environmental impact statement (EIS) or assessment 
is appropriate will be made on a case-by-case basis. We support 
the careful analysis of each proposed experiment subject to 
review under the guidelines and, in this way, rather than 
through a needless requirement of an EIS, will the federal 
environmental policy goals be best served. 
II. Questions Concerning Boundaries 
for NIH and RAC Oversight 
As a company with a long-term interest in the develop- 
ment of a viable biotechnology industry in the United States, 
Du Pont wishes to commend NIH and RAC for developing an approach 
to the oversight of recombinant DNA research that brings both 
caution and flexibility to the scientific review of proposed 
applications of biotechnology. It is our view that the evalua- 
tion and expansion of the role of RAC oversight of biotechnology 
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