Attachment III - Page 2 
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the cases vhich are of major concern. We recommend that the exortpt classes 
of experiments be considered carefully as examples of possible categories 
of activities vhich might be appropriate for expedited review. Not all 
applications should need to be seen by the full review structure. 
Our reading and discussion of the Federal Register notice centered on a 
number of concerns, some related to the issues noted above, and others having 
to do with the specific way in vhich the proposed regulatory structure would 
work. Sane of the questions raised and specific concerns are listed belcw: 
1. Where will the line between research and commercial application be drawn? 
Will a cannon line be determined for all agencies? For release into the 
environment as opposed to growth in contained facilities? 
In particular it is not clear how basic research with potential agricultural 
applications will be reviewed prior to the time it would be "environmentally 
related." We recommend that all laboratory and greenhouse research continue 
to under the purview of the NIH Guidelines and the RAC. 
2. Is it proposed that cell fusion research at the laboratory research level 
be subject to review? We strongly recommend that no such expansion of 
oversight of laboratory research take place without extensive discussion. 
Wbuld any of the broad definitions for biotechnology proposed by the Environ- 
mental Protection Agency (EPA) apply to laboratory research? 
3. Wbuld changes in the NIH Guidelines and major actions of the RAC require 
the approval of the Riotechnology Science Board? 
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