46 
Dr . Holmes agreed with Dr . McKinney but expressed some skepticism about 
using the AGS experiment as a risk assessment study as it was not designed 
to be one. 
Dr. Miller said FDA's philosophy is the amount of testing and oversight 
required should be that vhich is necessary and sufficient. He thought seme 
of Dr. Pimentel's suggestions represent a kind of "academic feeding frenzy" 
of things that are intellectually desirable but wholly unnecessary in this 
case. Dr. Miller felt it "unreasonable to penalize AGS by requiring them 
to do a risk assessment study for academic reasons in a situation virtually 
everyone believes is extraordinarily benign." 
Dr. Morris Levin of EPA said he did not feel the AGS proposal was dangerous. 
He asked Dr. Vidaver whether she had reservations which caused her to 
suggest five stipulations be attached to the approval. Dr. Vidaver replied 
she herself had no reservations; her five stipulations were offered to 
meet the concerns of several members of the assenbly. The five stipulations 
are in keeping with the conservative manner in which RAC has operated. 
Dr. Lacy felt a stepwise procedure, i.e., frem a very small release to 
larger releases would be the way to proceed in establishing guidelines for 
planned releases into the environment. 
Mr. Rifkin said he wanted to raise two levels of issues concerning the 
AGS proposal: (1) scientific questions about the AGS experiments; and 
(2) vhether these experiments should be postponed. 
Mr. Rifkin said RAC spends a lot of time on toxicity and pathogenicity, 
but something can be destructive in the environment without being pathogenic 
He said the questions that need to be raised in terms of data on this 
proposal are not about pathogenicity but vhether introducing INA“ in some 
way potentially harms balanced relationships. INA“ bacteria exist in nature 
but over millions of years they existed in a certain relationship to the 
INA + in a way that maintains a balance between INA“ and INA + and the rest 
of the ecosystem. When INA“ is concentrated through a procedure of placing 
it on crops, that balanced relationship is changed in the small area. If 
it is put over millions of acres of crops and is carrmercially viable, the 
relationships in those areas will be changed. 
Mr. Rifkin said the bacterium appears to promote and enhance the viability 
of frost-resistant plants and insects in the temperate regions of the world. 
He noted that many of the crops introduced in North America as cash crops 
were tropical in origin like tobacco and beans and com; these crops are 
frost-sensitive not frost-resistant. He argued that introduced INA“ 
bacteria would be enhancive to tropical insects and tropical plants that 
are frost— sensitive, but deleterious to the natural flora and fauna that 
INA"^ has enhanced over a period of time, i.e., frost-resistant plants 
and insects. 
[499] 
