B 
deliberate release experiments." If the goals of the experiments can be 
attained in other ways, these methods should be adopted. If the investiga- 
tor can demonstrate that all possibilities for obtaining the information 
or attaining the goal in any other way than field testing were exhausted, 
this might be adequate demonstration that alternatives had been considered . 
Dr. McGarrity said Mr. Rogers misinterpreted the purpose of the working 
group document. The working group document is intended to aid investigators 
in preparing proposals for review under the NIH Guidelines; it is not 
intended to provide directions on preparing environmental assessments (EAs) . 
Dr. McGarrity reemphasized that the document before RAC was a preliminary 
draft which would undoubtedly be revised. 
Dr. Gottesman said it is naive to imagine that a series of contained tests 
could generate all the necessary information. Stall-scale field testing 
should be permitted in situations where data indicate field testing is 
reasonable. The results of the small-scale field test will indicate 
whether large-scale field testing should be permitted. The appropriate 
approach is to perform the field test, monitor it carefully, and evaluate 
the results. 
Dr. Clowes said Mr. Rogers' wish to establish standard scientific protocols 
is simplistic; standard protocols cannot be devised at this time because of 
the diversity of potential organisms and ervirorments. The Working Group on 
Release Into the Environment believes the most realistic, safest procedure 
is to evaluate preposed field tests on a case-by-case basis. Dr. Clowes 
said the experiments would be evaluated in decreasing levels of containment: 
first in the laboratory; then in contained systems such as growth chambers 
and greenhouses. The experiments will be performed in limited field tests 
only after testing in laboratories and greenhouses. 
Mr. Jeremy Rifkin of the Foundation of Economic Trends said genetically 
engineered organisms are alive, unpredictable, can reproduce, migrate, and 
cannot be recalled. He contended that if a predictive ecology cannot be 
developed because the variables are too great, society: 
"...ought to reevaluate whether we want to start a process when we start 
authorizing and introducing for field experiments not three experiments, 
but hundreds and then thousands of experiments, over the coming decade." 
Dr. Pimentel asked clarification Of the statement in the preamble of the 
working group document that "if the probability of any one of these factors 
is zero, the risk should be considered zero." 
Dr. Gottesman offered the example of an organism capable of causing a great 
deal of ecological harm if it survived in the ervirorment but where the 
probability of its surviving in the environment was zero; in this case, the 
risk would be zero. 
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