The assertions, without significant scientific support, by 
OSTP or any other agency, that these products are inherently 
without risk, are scientifically unsound and constitute flawed 
rule-making. 
This biotechnology regulation regime is particularly 
unfortunate when contrasted with the EPA's study group report on 
biotechnology, January, 1986. That report highlighted the 
critical shortcomings of knowledge in this area and outlined a 
regulatory framework based on sound predictive ecology 
principles. See Report of the Study Group on Biotechnology, U.S. 
Environmental Protection Agency, January, 1986. 
Additionally, the Foundation and Mr. Rifkin do not consider 
that the interagency or interdisciplinary advisory committees set 
out in the Framework adequate to assure the quality of 
decisionmaking necessary for sound regulation. The specific 
problem is that under such a system, the relevant experts may not 
have decision-making power. Without the appropriate specialists 
having sufficient authority and responsibility to implement their 
technical expertise, there is no assurance that their expertise 
will be an integral part of the decisionmaking process. 
Respectfully submitted. 
Edward Lee Rogers 
Suite T-200 
1718 P Street, N.W. 
Washington, D.C. 20036 
(202) 387-1600 
Counsel for Foundation on 
Economic Trends and 
Jeremy Rifkin 
Recombinant DNA Research, Volume 1 1 
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