- 2 - 
Further, the oversight of experimental field testing of rDNA organisms can 
be approached much the same as the issue of large scale use of rDNA organ- 
isms. Recommendations for physical containment of large scale research 
or production were included in the Guidelines. Similarly, a section 
could be included which articulated points to consider in field testing of 
rDNA organisms. 
In response to question 3, we believe it is appropriate that RAC continue 
to hold closed sessions in which proprietary data is discussed. Such 
information is protected by the Freedom of Information Act, and provisions 
set forth in Section 552 b (c) (4), Title 5, U.S. Code and Section 10 (d) 
of Public Law 92-463 permit closed meetings. In some cases, proprietary 
information must be disclosed if members are to have all available inform- 
ation necessary to make a well-informed decision. To prohibit RAC from 
holding closed meetings would limit the scope of information available 
to the committee, thereby making it difficult to arrive at sound decisions. 
Clearly, this is contrary to the public interest. 
Advance notice of RAC meeting agendas and publication of RAC decisions is 
required by the Guidelines. In fact, the Guidelines suggest that RAC may 
desire to give advance notice of proposed decisions so that interested 
parties may comment before the decision is finalized. The RAC does not 
operate in a vacuum. Its deliberations and recommendations are on public 
record and open to scrutiny. RAC also has the option to release proprietary 
data to the public through the Freedom of Information Act after advising 
the data owner 15 days prior to the release. The information can be released 
sooner if it is considered necessary to protect against iminent hazard to 
the public or the environment. 
In summary, we believe that the RAC has functioned well as a central advisory 
body for the review of all rDNA proposals and should continue to do so, 
thereby providing continuity to the research and development of the technology. 
Further, consideration of proprietary data in closed meetings continues to be 
appropriate. 
Thank you for the opportunity to comment. We would be pleased to clarify any 
of our comments should you so request. 
Sincerely 
Micnaex j . koss 
VP, New Product Development 
MJR: bs 
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