Comment from Emily Scott

[200.202(e), 200.220] To Whom it May Concern: I am a professor working in the areas of medicinal chemistry, drug design, biochemistry, and pharmacology. I am writing in my personal capacity to oppose the proposed revisions to sections 200.202(e) and 200.220 that would restrict international scientific collaboration and isolate American scientists. My field is very international. I have collaborators and colleagues all over the world with whom I publish new scientific knowledge that advances the treatment of human diseases including prostate cancer, breast cancer, diabetes, metabolic liver disease, and rare diseases like spastic paraplegia. Advances in these areas would be held back by this rule. Additionally, I am the chair of the International Conference on Cytochrome P450s, a biannual conference bringing together the leaders in our field to promote scientific sharing, collaborations, and advances. The conference rotates between N. America, Asia, and Europe and limiting those countries that can host the meeting and who can attend the meeting would be very disruptive to our field. Our work employs X-ray crystallography to determine the atomic structures of human proteins with their substrates and inhibitors to advance drug design. In this work we rely on travel, detector work, computing, data-sharing, joint governance, or foreign institutional partners. Most notable would be CERN where X-ray crystallography data collection occurs. Bans on collaboration with “covered foreign countries,” if interpreted broadly, would directly undermine my ability to do globally relevant biomedical research. My work depends on the ability to exchange data, reagents, protocols, computational methods, and scientific expertise across borders, particularly for pathogens, host-pathogen interactions, drug metabolism, and therapeutic discovery questions that do not respect national boundaries. A broad ban could affect my research in several concrete ways. It could prevent me from collaborating with scientists who have access to regionally important pathogen strains, clinical isolates, outbreak data, or patient-derived samples. It could also restrict travel to international meetings, participation in multinational consortia, co-authorship with foreign scientists, sharing of screening data or structural data, and use of international facilities or datasets. Even when the scientific rationale is clear and the collaboration is low-risk, the need for case-by-case political approval could delay work long enough to make time-sensitive studies impossible. This would be especially damaging for infectious disease and global health research. Countries such as China, Nigeria, Pakistan, and Russia have large scientific communities and may be sites where important pathogens emerge, circulate, or are studied. Cutting off collaboration with entire countries would reduce access to local expertise and surveillance data, make U.S. research less representative of global biology, and weaken our ability to respond quickly to emerging infectious threats. The chilling effect may be as harmful as the formal prohibition. Universities and investigators may avoid collaborations, data-sharing, student exchanges, or joint publications simply because the compliance risk is unclear. That would isolate U.S. scientists, slow discovery, reduce reproducibility across diverse biological and geographic contexts, and make federally funded research less effective at addressing global scientific problems. This rule could impose broad, politically driven barriers to international scientific collaboration by restricting data-sharing, travel, technical assistance, indirect support, and joint research with “covered foreign countries,” a category that could shift with each administration. Such restrictions would create uncertainty and delays for legitimate, low-risk collaborations, including work involving infectious disease, global health, climate, astronomy, and other fields that depend on cross-border expertise and infrastructure. The result would be to isolate U.S. scientists from global research networks, weaken access to critical data and samples, and reduce the speed and quality of federally funded science.