30 
Dr. Mazza said the FPA is not attempting to regulate research in so far as 
appropriate given the mandate of the law. In the December 31, 1984, Federal 
Register , EPA attempted to describe the implications and the limitations 
of the Toxic Substances Control Act (TSCA) and the Federal Insecticide, 
Fungicide and Roderrticide Act. 
Dr. Mazza said EPA has responsibility for regulating certain ccmmercial 
products. The EPA mandate for reviewing these products should mesh with 
the historical role of the RAC. Same problems may develop with this trans- 
ition. The EPA is very interested in making the fit between the EPA and 
the RAC work. 
Dr. Mazza supported the suggestion that more opportunities for exchange of 
information be created. 
Ms. Anne Hollander of the EPA, said EPA in the December 31, 1984, Federal 
Register discusses in great detail a number of different technologies and 
requests scientific comment on the risk implications of these technologies. 
She asked RAC to address the question of whether the different tech- 
nologies have different implications for risk. Ms. Hollander contended 
RAC itself is based on the premise there is something different about 
recombinant DNA technology. 
Dr. Davis said U.S. regulatory laws may be complex but RAC and the scien- 
tific community are not concerned with the law's complexity. Rather they 
are concerned with the complexity of the December 31, 1984, Federal Register 
proposal. He hoped it was crystal clear that a great many people do not 
think the proposed oversight mechanism is a good one. 
Dr. Davis said there was a difference in tone between the section of the 
December 31, 1984, Federal Register written by the EPA and those sections 
written by USDA and FDA. He said FDA and US DA expressed considerable 
confidence in the way RAC has been handling the issues and were willing to 
rely on RAC for general advice for fulfulling their responsibilities. The 
EPA document on the other hand is much longer, and raises all types of 
questions. He said he had written a lengthy criticism on the EPA section 
of the Federal Register announcement. He did not address in that letter 
any of the EPA's hypothetical scenarios because the document's basic 
assumption is that these organisms are a terribly dangerous set of organisms. 
He said he felt as if he "was in about 1974." Dr. Davis said in 1985 there 
is not much reason from a scientist's point of view to assume these orga- 
nisms are all terribly dangerous. 
Dr. Davis said the assumption DtPi is a toxic chemical to be regulated 
under TSCA puts the whole discussion in a framework that makes it extremely 
difficult for scientists to even want to start answering such questions. 
Mr. Mitchell said the Working Group on Biotechnology Coordination did not 
have time to comment specifically on EPA’s questions. Rather the working 
group focused primarily on the effect of the December 31, 1984, Federal 
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