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themselves (43 Fed . Reg . 33070) merely indicate that weight will be 
given in the decision making process "both to scientific and social 
benefits and to potential risks." Clearly, the standard for excepting 
experiments is different in the two documents. 
When differing interpretations of the same issue are given in 
different sections of the Federal Register package, it is impossible 
for EDF or a person conducting a recombinant DHA activity to ascertain 
which is the correct one. In addition, it is unrealistic to assume 
that the reader will scour all the documents in the Federal Register . 
Most important, the EIA and the Director's decision document do not 
have the indisputable force of law. EDF therefore maintains that all 
information necessary for compliance be included in the guidelines 
themselves. Finally, ambiguties such as the one described within 
the guidelines should be clarified. 
The second area of concern I will discuss today is the failure 
of the guidelines to specify procedures for public notification and 
public comment. The guidelines often indicate that a decision will 
be made "after appropriate notice and opportunity for public comment." 
(43 Fed . Reg . 33070) . No clarification of this is given. For example, 
the section of the guidelines dealing with certification of new host- 
vector systems makes no mention of proueaiues for public notification 
or public comment. (Interestingly, the Director's decision document 
states (43 Red . Reg . 33057) , "I agree that prior notification to the 
public should in the Federal Register be given when the RAC considers 
applications for certification.") 
The procedures for public notification and comment must be 
described, in detail, in the guidelines. Failing this, the public 
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