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consequences. We can have no assurances of safety 
until we understand how an organism will interact 
in a complex ecological situation. 
The proposed revised guidelines exempt from 
compliance non-novel exchanges. The rationale behind 
this exemption is that such exchanges take place in an 
unregulated manner in nature. We have two objections 
to this exempt category. First, the exemption list 
is too broad. Given that one member of the genus is 
known to exchange genetic material with an unrelated 
species in nature we should not extrapolate that all 
members of that genus should be exempt. We must ask 
whether other members of that genus would meet this 
organism in a natural setting. 
Second, the rationale for these exemptions 
ignores basic ecological considerations, such as natural 
rates of exchange and the effects of concentrated 
products of such non-novel exchanges in the env ironment . 
If one piece of DMA is exchanged naturally, that does 
not mean that the transfer of any segment of DMA from 
that organism is safe. Similarly, if the organisms 
exchange DMA in a ximited manner, increasing the rate 
of exchange could result in the concentration of an 
enzyme or hormone within an organism with unknown 
results. In the laboratory we do not reproduce natural 
[ 155 ] 
