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1 "Under the first exemption, experiments with 
2 recombinant DNA molecules that are not in an organism 
3 need not be subject to the guidelines. This is based on 
4 the safety of these experiments." That is the analysis 
5 of the rationale for the first exemption. 
6 One of the things that is really troublesome 
7 in this Assessment is that mostly it is just a reprint of 
8 the Director's Decision, probably 90 percent of the 40 
9 pages. It looks bulky, but there is really very little 
10 of an assessment in it. But in the language from the 
11 Director's Decision, it mentions the first exemption, and 
12 says, "This is in recognition that naked DNA, which is 
13 rapidly inactivated in nature, is extremely unlikely to 
14 be hazardous . " 
18 Now, there has been controversy and debate on 
16 that point this morning. It needs to be explored, and it 
17 needs to be explored in an Impact Statement. 
18 I could go on with the other exemptions, but 
19 the level of analysis is similar. They say, well, this 
20 is based on occupational safety and the environment, but 
21 it doesn't say why. It doesn't give any kind of either 
22 scientific judgment or experimental data for it. 
23 There is a lengthy discussion of E. col i in 
24 which a nunber of issues are not at all addressed 
25 in the Environmental Assessment. Also, there is 
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