Attachment II 
FOl INDATI ON ON ECONOMIC TRENDS 
1346 Connecticut Avenue. NW, Suite 1010 Washington. DC 20036, (202) 466-2823 
Page 1 
My name is Jeremy Rifkin. I am president of the Foundation on Economic 
Trends in Washington, D.C. I am requesting that the following issues be 
placed on the agenda of the Recombinant DNA Advisory Committee (RAC) 
meeting. 
♦Issue: On June 22, 1983, the Subcommittee on Science, Research, 
and Technology and the Subcommittee on Investigations and Oversight 
of the Committee on Science and Technology held hearings on regulating 
the release of genetically modified organisms into the environment. Among 
those testifying were Geoffrey Karny, Senior Analyst, Biological Appli- 
cations, Office of Technology Assessment (OTA); Don R. Clay, Acting 
Assistant Administrator of the Office of Pesticide and Toxic Substances 
of the Environmental Protection Agency (EPA); Martin Alexander, pro- 
fessor of Agronomy, Cornell University, and former chairman of the Re- 
combinant DNA Study Group of the Environmental Protection Agency 
Science Advisory Board; and Frances Sharpies, Zoologist, Oak Ridge National 
Laboratory. Ail of these witnesses testified that the deliberate introduction 
of genetically engineered organisms into the environment poses a potential 
danger to plant, animal, and human health. According to Dr. Alexander, 
"alien organisms that are inadvertently or deliberately introduced into 
natural environments may survive, they may grow, they may find a suscep- 
tible host or other environment, and they may do harm. I believe that 
the probability of all these events occurring is small, but I feel that it is 
likely that the consequences of this low-probability event may be enormous." 
In addition, in a suit filed in Federal Court on September 14, 1983, 
the Foundation on Economic Trends secured affidavits from some of America's 
most prominent ecologists, population geneticists, entomologists, and plant 
pathologists corroborating the testimony of the witnesses who appeared 
before the June 22nd hearings in Congress. Given the wide consensus of 
opinion by so many distinguished experts, I would like to know why the 
National Institutes of Health has failed to comply with the minimum standards 
of the National Environmental Policy Act which requires an environmental 
assessment or an environmental impact statement for such experiments. 
♦Issue: In reviewing requests for experiments that require the deliber- 
ate release into the environment of genetically engineered organisms, the 
RAC is responsible for assessing the risk factors that such experiments 
might pose to plant and animal life and to the broader ecosystem. This 
kind of risk assessment requires scientific expertise in the fields of ecol- 
ogy, botany, plant pathology, entomology, and population genetics. Yet 
no such scientific experts sit on the RAC. In his testimony at the June 
22nd Congressional hearings, Goeffrey Karny of OTA pointed out that from 
a regulatory perspective, there is "an important limitation to the way the 
NIH guidelines deal with deliberate release.. ..virtually all of the scientific 
experts on the RAC are molecular biologists or experts in human health. 
[ 212 ] 
