11 
course, a finding of no significant risk cannot be made with respect to 
the first category -- risk assessment experiments. But in both categories 
there should be a requirement of NEPA compliance. 
5. Exemptions . As indicated in my comments on the environmental im- 
pact assessment, the making of specific exemptions in the guidelines is 
premature. However, there should be general language in the regulations 
providing for exemptions, after completion of risk assessment, NEPA com- 
pliance, public participation and a finding, based on experimental data, 
that the exemption presents no significant risk to health or the environ- 
ment . 
6. Certification of host-vector systems . In Section II-D2-b-(l), 
which specifies the data to be submitted for certification of HV-1 systems 
other than E. coli K-12, the following additional data should be required 
to be submitted: the organism's biological and ecological interactions 
with other organisms in its natural habitat; and its role, if any, in in- 
dustrial, agricultural, and medical work, whether beneficial or harmful. 
This is vital information for assessing the risks of using an organism in 
recombinant DNA activities, in performing the kind of analysis required by 
NEPA, and in building a body of information for dealing with future prob^ 
lems . 
7. Membership of the Recombinant DNA Advisory Committee . The compo- 
sition of the RAC has already been discussed for Friends of the Earth by 
Pamela Lippe. I would only like to add that the Federal Advisory Commit- 
tee Act, 5 U.S. C. App. I §5, requires that all federal advisory commit- 
tees (1) be properly balanced in terms of the points of view represented 
and the functions to be served, and (2) not be inappropriately influenced 
by the appointing authority or by any special interest. Just in terms of 
point of view represented on the RAC, the critical scientific viewpoints 
[A-242] 
