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Office of Government Ethics
Suite 500
1201 New York Avenue, N.W.
Washington D.C. 20005-3917
Attn: Richard M. Thomas
Associate General Counsel

RE: Proposed Rule Exemption and Amendment Under 18 U.S.C. 208(b)(2) RIN 3209-AA09

Dear Mr. Thomas:

The American Society for Microbiology (ASM), the largest single life science organization with approximately 39,000 members, supports the proposed rule which would permit government employees to serve in their official capacity in the governance of nonprofit organizations. The current law unduly limits the opportunity for government scientists to participate on nonprofit boards and as officers of nonprofit organizations. We agree with OGE’s conclusion that such service with nonprofit organizations does not present any realistic concern regarding the ethical duties of government employees.

The ASM also agrees that the current limitations on government employee service to nonprofits unnecessarily limits the professional development of government scientists, which in turn, affects adversely the desirability of pursuing a long term career with the federal government. It also reduces the opportunity for the exchange of ideas and information between those within and outside federal agencies. Having federal scientists able to serve in their official capacity as officers and directors in nonprofit organizations is of great benefit to the scientific community as well as to the professional careers of the government scientists themselves.

The ASM encourages OGE to promulgate this rule as proposed.


Bonnie L. Bassler, Ph.D., President, ASM
Roberto Kolter, Ph.D., Chair, Public and Scientific Affairs Board