In this way knowledge about the effects of an accidental release 
of recombinant organisms can be obtained without the undesirable 
event of an accidental release. 
The guidelines, as revised, offer virtually no protection to 
the natural environment both in terms of current and future research 
developments in this field. Amending and revising any set of guide- 
lines are difficult and time consuming tasks. We do not necessarily 
request revision as much as the addition of materials which provide 
suitable environmental safeguards. We would like to see the Recombinant 
Advisory Committee that oversees these guidelines include 
representation of knowledgeable specialists in environmental processes 
and effects on ecosystems and their biota. Such persons might help 
to redirect research for those applications leading to potentially harm- 
ful environmental consequences. Future revisions of the guidelines 
must also include the needed environmental safeguards. 
We note the provision for voluntary submittal of protocols by 
private parties, which do not come under the mandatory application 
of these guidelines. Our experience does not lead us to believe that 
voluntary controls provide effective deterrants. We hope, however, 
that all such parties will in fact, submit their protocols for review, 
and abide by the guidelines. It will not only afford protection to 
our citizens and our environment, it should serve as a valuable 
safeguard against potential liability from the impact of R-DNA 
research and application. In the absence of definitive control, 
this provision is helpful. 
EPA does not desire to stifle recombinant DNA research. There 
is much benefit to be derived from its proper application. However, 
in summary I wish to state that we are greatly concerned that the 
research be confined to well controlled laboratory conditions and 
persons knowledgeable about safe handling of possibly pathogenic 
materials to preclude any chance for accidental release. The 
natural environment is inextricably related to the health and 
welfare of people. Thus, indirect health protection for people 
requires direct protection of the environment. 
[A-154] 
