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Executive Summary

rDNA-DERIVED PRODUCTS' REGULATION BASED ON PRODUCT PROPERTIES and not on production processes should be the basis for regulation, Genex Corp. Senior VP David Jackson told a Senate Environment & Public Works toxic substances subcmte. hearing Sept. 27. Asserting that in regulating rDNA derived products "people have to look at the product and not the process itself," Jackson contended that "it is perfectly possible that the two organisms which result from the modification by two different sets of techniques will be literally identical." In such a case, he said, "it would be very difficult to argue that one organism should be regulated differently from the other simply because a particular set of techniques had been used to construct it." The "vast majority" of rDNA products "fall into categories currently regulated by FDA or EPA [Environmental Protection Agency] or USDA," Jackson said. "In these categories, regulation is generally on the basis of the product's characteristics and the uses to which it is to be put," he said, "and not on the basis of the technology used to produce the product. I see no reason why this present regulatory structure needs to be fundamentally altered for products produced in, containing, or consisting of genetically engineered organisms." Subcmte. Chairman Durenberger (R-Minn.) convened the two-day session, Sept. 25 and 27, to examine the "potential environmental consequences of genetic engineering." Opening the second day of hearings, he commented, "I believe we are correct in approaching the new genetic engineering technologies with prudent caution."

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