Henry Miller raises a serious question about recommendations made in two recent National Research Council reports on plants produced with recombinant DNA techniques.1 Unfortunately, Fred Gould and Jennifer Kuzma do not supply a satisfactory response.2 Gould and Kuzma argue that, "taken to its simplest logical conclusion," prior National Research Council findings that "the 'product, not process' is the major concern" would leave only two options: "regulate all plant varieties or regulate none." Nothing could be farther from the truth. A third and more appropriate option is a tiered regulatory framework that applies heightened scrutiny only to plant varieties with unfamiliar phenotypes and phenotypes judged to have high-risk properties, regardless of how they were produced.
The 1989 NRC report3 to which Miller refers even suggests ways in which plant varieties could be stratified vertically into risk categories, rather than defaulting to the scientifically unsupportable judgment that all products of rDNA technology ...
