20 
of understanding," creating a committee to sort out the regula- 
tory responsibilities. Unfortunately, with bovine interferon, 
the only product to be considered thus far by the committee, the 
memorandum of understanding was misunderstood. "Both agencies 
claim jurisdiction, and the committee is split along agency 
lines. Several attempts to resolve the impasse on scientific 
grounds have failed .... In the meantime, the manufacturer 
has encountered additional costs and burdens by attempts to meet 
the requirements of both agencies." 39 / 
If EPA were to assume jurisdiction in the expansive manner 
it contemplates, long-range planning difficulties would multiply. 
It is virtually certain that cost and delays for product approval 
would increase with the resultant failure of many of the smaller 
genetic engineering firms. Consequently, the United States 
could have difficulty maintaining its international competitive 
position in genetic engineering, and there would be a loss of 
jobs and revenue as well as significant export of valuable 
technology. 40/ 
39/ See OTA Report II at 363. 
40 / This threat of technology export is compounded by the fact 
that TSCA does not apply to anything that is being 
manufactured for the purpose of export unless the 
government can prove (which it could not) that the 
(Footnote continued on next page) 
[ 720 ] 
