14 
composition of the very bodies charged with monitoring genetic 
engineering. The RAC, for example, must now draw at least 6 of 
its 25 members from persons "knowledgeable in applicable law, 
standards of professional conduct and practice, public atti- 
tudes, the environment, public health, occupation health or 
related fields." 2J./ Currently, nine RAC members are from 
these areas. 22/ We understand that additional environmental 
expertise on the RAC derives from inclusion of a plant patholo- 
gist and terrestrial ecologist. Further, the Guidelines require 
Institutional Biosafety Committees (IBC's) and state that all 
IBC ' s must be composed of "members so selected that they collec- 
tively have . . . the capability to assess the safety of recom- 
binant DNA research experiments and any potential risk to public 
health or the environment." 23 / 
By asserting that current environmental oversight is in- 
sufficient, EPA is overlooking the fact that it can itself 
participate directly in decisionmaking relevant to genetic 
engineering. First, EPA is a member agency of the Federal 
Interagency Committee on Recombinant DNA Research and a 
21 / 48 Fed. Reg. at 24562 (emphasis added). 
22 / OTA Report II at 550 n.l. 
23 / 48 Fed. Reg, at 24560. There must be at least two 
members not affiliated with the institution who represent 
the interest of the surrounding community with respect to 
health and the environment . 
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