a way as to protect the public and the environment from harm 
whether or not "foreign" DNA is involved. 
Dr. Margaret Mellon from the Environmental Law Institute asked 
for clarification of the relationship of the NIH Guidelines to 
the evolving role of the US DA. 
Dr. Talbot responded by saying that the USDA had been using the 
NIH Guidelines. In the June 26, 19 86, ".Coordinated Framework," 
they had published their own guidelines for public comment which 
were modelled after the NIH Guidelines. A subsequent Federal 
Register notice said that in lieu of separate USDA Guidelines, 
USDA would propose new provisions relating to agricultural 
research for inclusion in the NIH Guidelines. 
Dr. Sue Tolin said that the USDA indeed had relied on the NIH 
Guidelines but "we see the need to get sane additional things 
into it. The approaches that are being discussed in terms of 
developing Appendices L, M, N, and 0 will certainly go a long way 
towards those and we plan to be working very closely with NIH on 
those areas." She also added that not only does USDA sponsor 
research, but they also have statutory regulatory authority. 
Dr. Gottesman said that scientists involved in genetic research 
other them recombinant DNA technology would be selecting strains 
with deletions or rearrangements which they may wish to introduce 
into the environment. If they wish to introduce such strains 
into the environment this would have to be dealt with by 
regulatory agencies. An organism engineered by recombinant DNA 
technology to produce these same deletions and rearrangements 
should require no more and no less regulation merely because of 
the process used to arrive at the same end product. Removing the 
extra layer of RAC and NIH review still leaves the standard 
re/iew by the regulatory agencies. 
Dr. Cohen agreed that there was no need for RAC or NIH review of 
rearrangements or deletions in microorganisms, but said with 
higher organisms you are dealing with something different. Dr. 
Davis said it was a case of probabilities. He felt the 
probability of making a bacterium more dangerous by deletion or 
rearrangement was exceedingly low. He felt this was not 
necessarily the case with viruses, although there were other 
mechanisms to ensure safety of virus vaccines. He said that 
unnecessary review of safe experiments could be very expensive 
and time-consuming. 
Dr. Walters said that he seemed to be hearing two separate 
concerns, one concern for eukaryotes and one concern for 
microorganisms. He asked what the risks were with higher 
organisms that were not adequately covered by some other 
mechanism. If there are no major concerns about higher 
organisms, then the only thing left to debate is environmental 
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