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1 should be by species, not genus, and added only on the 
2 basis of safety as well as exchange. Three, there 
3 should be full compliance with NEPA. 
4 Exceptions. The guidelines point out that 
5 weight must be given to scientific and societal benefits 
6 and potential risks, acknowledging that these decisions 
7 are not only technical, but political. This situation 
3 denands much broader representation in the decision- 
9 making. Appropriate notice and comment is simply not 
10 adequate. The decision is already made. The decision- 
11 makers can and do ignore public comment. 
12 Exceptions are easements of prohibitions. 
13 These experiments were not prohibited lightly; the ban 
14 should not be lifted without careful consideration of 
15 all possible consequences, drawing on the full range of 
16 expertise. 
17 Recommendations. All exceptions from the 
18 guidelines should be undertaken only after a full 
19 Environmental Impact Statement to allow for assessment 
20 as well as better public input and awareness. In the 
21 case of a single risk-assessment experiment, where con- 
22 tainment will not be breached, an El A may be satisfactory. 
23 Waiver on large-scale culture size should only 
24 be granted after full-scale risk-assessment studies on 
25 the organism and an EIS on the large-scale production 
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