© United States 
Department of 
Agriculture 
Office of 
Grants and Program 
Systems 
Washington, D.C. 
20250 
February 6, 1984 
Dr. William J. Gartland, Jr. 
Director 
Office of Recombinant DNA Activities 
NIAID-NIH 
9000 Rockvil le Pike 
Bethesda, Maryland 20205 
Dear Dr. Gartland: 
The Department of Agriculture offers the following comments on the questions 
posed in Dr. Talbot's memorandum of December 21, 1983, concerning the 
boundaries for NIH AND RAC oversight of recombinant DNA research. The 
questions were discussed in detail at a recent meeting of the USDA Recombinant 
DNA Committee. 
1. Should the NIH Guidelines be limited strictly to work done in the 
1 aboratory? No. In our opinion, the RAC should continue to review 
requests for release of recombinant DNA containing organisms for field 
testing in a manner similar to the current procedure. 
2. Should NIH accept for review only individual proposals funded by NIH 
or only proposals funded by the Federal Government? No. The Department 
supports the continuation of the current operational policies of the RAC, 
including review of all federally funded research and of industrial or 
other nonfederally funded research. At the present time, no other 
organization has a mechanism in place to conduct such reviews. 
3 . Should all portions of all RAC meetings be open to the public? No . 
The current practice of closing RAC meetings to protect proprietary data 
should be encouraged to continue. In the questions dealing with release 
into the environment, however, it may be beneficial to prepare parts of 
the request for an open presentation. 
4. Should the NIH Guidelines be limited strictly to biomedical 
research? Adamantly no. The Department could present a number of strong 
arguments against such a move, including the fact that NIH funded much of 
the research leading to discovery of the Ti plasmid of Agrobacterium 
tumef aciens 
I look forward to continued cooperation with you. 
Sincerely 
Chairman 
Agriculture-RAC 
SUE A. TOLIN 
USDA Representative to the RAC 
[660] 
