20 
its working groups should not be pressed into making a full scale review of 
trivial modifications. 
Dr. Gottesman said experiments involving plants can be placed in either of two 
categories; the applications are either covered by Appendix L or must be reviewed 
on a case-by-case basis by RAC. She asked if such a distinction could be made 
for microorganisms. 
Dr. McGarrity suggested a checklist might be generated. He said lawyers, vho 
do not know the science, like to see checklists. Dr. Amtzen agreed that a 
checklist might be developed. He suggested proposals involving denitrifying 
bacteria might be approached in this way. 
Dr. Gottesman said the working group should decide how specific a checklist 
should be; it will be difficult obtaining specific answers to all questions 
simply because all questions may not be equally applicable in all cases. 
Dr. Fedoroff suggested data on water habitats as well as on soil habitats 
might be pertinent in a review of microorganisms. 
Dr. Hollander called the attention of the working group to the EPA document 
distributed earlier in the meeting (Attachment III). Dr. Rissler said the docu- 
ment lists the questions which might be asked concerning the characteristics of 
organisms. She felt there is a limit to the number of questions vhich can be 
asked. 
Dr. Fedoroff asked how the EPA document had been developed . Dr. Hollander 
replied that the document had been generated by EPA staff. Dr. Fedoroff asked 
Dr. Hollander if EPA has requested a group of scientific experts to review the 
document. Dr. Hollander replied that EPA has not yet requested expert review on 
this document but would do so. Dr. Hollander said she hoped the working group 
would offer EPA its evaluation of the document. 
Dr. Fedoroff asked why EPA was soliciting working group evaluation of the 
document. Dr. Tolin said EPA has agreed to abide by the NIH Guidelines; EPA 
is abiding by that agreement in coning to RAC for RAC advice and aid in drafting 
EPA documents involving reccmbinant DNA. 
Dr. Gottesman moved that each member the working group should respond indivi- 
dually to the EPA document; a subgroup of the working group would write a 
draft document concerning guidance for experiments involving field testing 
of microorganisms. The smaller group might use those portions of the EPA 
document which are useful. Dr. Amtzen seconded the motion. Dr. Scandalios 
asked the EPA representatives if they were comfortable with such a suggestion. 
They replied that they were comfortable with such a process. By a vote of 
twelve in favor, none opposed, and no abstentions, the working group accepted 
the motion. 
Dr. Gottesman then moved to adjourn. Dr. Fedoroff seconded the motion, arri it 
was unanimously approved. Dr. McGarrity adjourned the meeting at 3:15 p.m. 
[ 444 ] 
