Dr. William J. Gartland 
Page 3 
May 14, 1985 
Tab C - Page 19 
those in which the recombinant methodology involves 
expression of entirely new substances or eliminates a 
unique control susceptibility without providing an 
alternative. However, recombinant systems — as in the 
ice-nucleation experiments — that simply accomplish 
through a different mechanism what occurs in nature 
cannot be viewed as unique. It is very doubtful that 
any test method of examination of the altered organism 
could distinquish which pathway was employed in achieving 
the change. In particular, mechanism changes in the 
genome of an organism which can be documented as occurring 
naturally such as spontaneous deletions, point mutations, 
transversions, transpositions, translocations, and 
insertions might be considered an exempt category. Also 
included could be self-cloning experiments, those in 
which the organisms can be shown not to survive beyond 
one season in the environment, and those which simply 
provide increased amounts of essential amino acids or 
other simple nutrients. 
The question of possible occupation of an unusual 
ecological niche is not answered through such action; 
the fact to be realized, however, is that the same 
unanswered questions exist for organisms undergoing 
mechanistically natural changes. 
These are not uniquely the province of recombinant 
DNA technology. New ecological concerns are constantly 
being raised in a biologically dynamic world. The 
advisory role of the RAC is properly played when it 
provides recommendations bearing on the applications of 
recombinant technology in previously unprecedented 
situations. The technological fix of a technological 
error is no worse than the technological fix of a natural 
error; the natural fix of a natural or technological 
error (a new environmental equilibrium) is frequently 
not in the interest of humanity. The important feature 
in an environmental release experiment where uncertainties 
about occupation of a new ecological niche are great is 
that there is retention of or insertion of a control 
susceptibility , £.£. , chemical sensitivity, sterility, 
essential nutrient growth requirement. 
[284] 
