A Brief History of
Biotechnology Risk Debates and Policies
in the United States


by Philip Regal
Professor of Biology
University of Minnesota-St. Paul
St. Paul, Minnesota, USA


an occasional paper of

The Edmonds Institute
20319-92nd Avenue West
Edmonds, Washington 98020


published with the help of grants from:

The Warsh-Mott Legacy
The Funding Exchange
The HKH Foundation
The Foundation for Deep Ecology


Scope of this Historical Synopsis

The Earliest Voiced Concerns. Analyses by scholars and scientists of the future impacts of genetic engineering divided early into the following range of concerns:

1. Economics, Ethics, Politics. Global social, economic, and political dislocations and ethical enigmas could follow the growth of the new bio-technologies and products (Blank 1981, Bud 1993, Cavalieri 1985, Hanson 1983, Kenney 1986, Krimsky 1991, Krimsky and Wrubel 1996, Lear 1978, Regal 1987, Teitelman 1989, 1994, Yoxen 1983).

2. Biohazard, Biosafety. Some biotech projects could present serious risks to human health and the environment (Fowle 1987, GAO 1988, Grobstein 1979, Halvorson et al. 1985, House of Representatives 1984, Rogers 1977, Jackson and Stich 1979, Krimsky 1982, 1991, Levin and Strauss 1991, Macdonald 1993, U.S. Congress OTA 1993, Watson and Tooze 1981, Wright 1994, Zilinskas and Zimmerman 1986).

3. Biological Warfare. Military uses of biotechnology present various concerns. The potential for 'designer diseases' to lead to an international biological arms race (Dando 1994, Elkington 1985, McDermott 1987, Pillar and Yamamoto 1988, Roberts 1993, Spiers 1994, Wright 1990, 1994, Zilinskas 1992).

4. Agricultural Germ Plasm. New economic forces driven by biotechnology developments could lead to losses of agricultural diversity and germ plasm (Doyle 1985, Kloppenberg 1988, Lacy et al.1991, Regal 1997).

5. Human Genetic Engineering. Genetic engineering of the human germ line could have political, social, and physical dangers (Blank 1981, Cranor 1994, Hamilton 1972, Harsanyi and Hutton 1981, Hubbard and Wald 1993, Kimbrell 1993).

Additional Concerns as the Nature of the Biotech Community Changed. Changes in the biotech community in the late 1970s and 1980s began to raise a host of additional questions about the ability of molecular biology to police itself given increasing conflict of interests, competitive pressures, the need for continual large direct and indirect subsidies, and the need to maintain a positive public image to maintain subsidies, investments, and political power (Krimsky 1991, 1996, Regal 1987, 1996).

By the 1980s, factions that advocated aggressive competition, so-called 'free-markets,' and deregulation had become quite powerful in parts of Europe and the United States. The pressure was strong to 'privatize' the public investment in the development of biotechnology as much as possible.

Molecular biologists were becoming entrepreneurs and not merely consultants to industry. Many had bet their personal finances as well as their careers on the financial success of biotech. The line between university research, government research, and industry was becoming thinner and thinner.

The Limited Scope of the Following Historical Analysis. All these past concerns for the future are still very much alive. But the present report will emphasize the history of the second of the above five areas that have seriously concerned scholars and scientists -- notably, the biohazard and biosafety concerns.

The Engineering Ideal in Biology

The ideal of reducing life to human control was promoted most vigorously and thoroughly by Jacques Loeb in the 1920s after he had moved from the University of Chicago to the Rockefeller Institute, during an era when it seemed that technology could and would domesticate the planet.

Then in the 1930s the Rockefeller foundation under physicists Max Mason and Warren Weaver began to recruit chemists and physicists to create the new science of what would be called molecular biology. The expansive Rockefeller program began with the highly idealistic assumption that nearly all human problems could be solved by genetic and chemical manipulations (Abir-Am 1987, Kay 1993, Pauly 1987, Regal 1987, 1996).

The agenda for molecular biology and the engineering of life thus was infused with complete optimism from the start, and there was only a positive view of the promise of the new science and of the bio-technologies that it was supposed to produce eventually. Risks and other negative developments were not considered or planned for.

Mason and Weaver had left research in physics in disgust with quantum mechanics and turned to administration. Weaver wrote that they kept their faith that nature would be found to be simple and sought to infuse this faith into a new Molecular Biology. The faith that they sought to preserve had been motivating physical scientists since at least the 17th century, but it had been seriously shaken by philosophers of science by the earliest 20th century (see discussions and references in Regal 1989, 1990b, 1996).

Physicists and chemists had long shared a very old and seductive 'reductionist' and 'determinist' dream that had extended even to biology. It had been promoted by philosopher/scientists such as René Déscartes, who argues in his 1637 Discourse on Methods, for example,

If we possessed a thorough knowledge of all the parts of the seed of any animal (e.g. man), we could from that alone, by reasons entirely mathematical and certain, deduce the whole conformation and figure of each of its members, and conversely, if we knew several peculiarities of this conformation, we would from those deduce the nature of its seed.

But the history of physics and chemistry in fact came to prove that nature is more frustratingly subtle than the dreams of simplicity. As Sir Arthur Eddington quipped in the 1930s, "We used to think that if we knew one, we knew two, because one and one are two. We are finding that we must learn a great deal more about 'and'."

Simple facts did not necessarily combine in ways that a simple logic would predict. Descartes, for example, predicted that there could not be space empty of matter, because, "A vacuum is repugnant to reason." Yet physicists eventually had to face the fact that space is not filled with ether, as they had long reasoned (quotes from Mackay 1977).

In the case of DNA, the molecule is stable in a test tube. But it is not stable in populations of reproducing organisms. One cannot reduce the behavior of DNA in living organisms to its chemical properties in a test tube! In living systems, DNA is modified, or 'destabilized' if one prefers, at a minimum by mutation, gene flow, recombination, and natural selection. This would make it extremely difficult or even impossible to have a true genetic engineering, in the sense in which it had been spoken. Many molecular biologists certainly 'knew' facts about mutation and natural selection as abstract facts, but they were not a working part of their professional consciousness.

Phase I: Early Safety Concerns -- Germ Warfare and Biohazard

Much of this period has been well-covered in Wright's 1994 history, and Grobstein 1979, 1986. This section owes a great debt to those sources.

1960s: Concerns about Germ Warfare. Scientists first began to question in the 1960s whether recombinant DNA technology would always be used safely. At that time the military in the United States began to show an interest in using recombinant techniques to make 'designer weapons' that would transcend the limits of the old biological weapons (e.g., Wright 1994, p.118).

[Designer weapons designated, for example, diseases that would selectively kill one group of people. To illustrate: the Associated Press reported scientific testimony before the Reconciliation Commission to the effect that the white government of South Africa had research programs in place to engineer diseases that would kill only blacks. Just before the South African presidential election, the United States and Britain tried to convince the government to destroy their stockpiles, but the program was not terminated until Nelson Mandela became president (Associated Press 1988).]

Fear of the Public. The scientists discussed their concerns in small meetings that were not attended by the press. The discussions contributed to broader questions in the late 1960s about the potential misuse of the new technology.

The reactions of those who later were to become the leaders of molecular biology set the tone for the future. They argued that risks should not be discussed in public or the public might end the freedoms of the research scientists and cut funding for recombinant DNA research. They argued that so much good would come from the research that it was worth great risks.

1972: Nervous Laboratory Workers. The first genes were spliced in 1971 and recombinant techniques were soon widely used. Many laboratory workers began to wonder if what they were doing was safe. When they would gather at meetings and discuss specific projects, serious questions were raised that could not be answered.

It should be kept in mind that molecular biology grew out of physics and chemistry. These physical scientists who were starting to rearrange the molecules of heredity knew relatively little about living organisms, and some of them were starting to become concerned about the limitations of their discipline. Some of their concerns may have been over-reactions, while others were appropriate.

There were only private meetings about safety in the early 1970s.

1973: Biohazard Controversies Get out of Hand. Discussions at a June 1973 Gordon Conference led the organizers to call for a moratorium on some recombinant research and for the U.S. National Academy of Sciences to set up a committee to study questions about the safety of certain laboratory projects.

Concerns over the safety of some genetic engineering projects began to be discussed in publications for the general scientific community.

Wright's research found that leaders of the scientific community then began to express concerns that a 'panic response' would develop.

Leaders of the scientific community, such as the president of the National Academy of Sciences, became troubled over the uncontrolled debate and sought ways to keep the control of molecular biology and its controversies within the scientific community. The result, however, was that, "decisions on whether to slow research were being made by the very people on whom pressures to pursue genetic engineering were the strongest" (Wright 1994, p.137).

Scientists began to talk in 1974 about containment of experiments and about using 'disarmed' laboratory host organisms in order to be doubly safe.

The faction in favor of taking the risks began to argue that while the risks could not be exactly predicted,

1. The great potential benefits would outweigh the physical, social, economic, or ethical risks.

2. Laboratory experiments could be contained, and thus, whether they were dangerous or not, there was no reason to stop recombinant research.

3. The freedom of scientists to pursue whatever research they saw fit was too important a principle to sacrifice.

4. "If hazards could arise in using new biotechnologies ... many scientists were quick to insist that the general public should not deal with them; policy-making decisions were claimed to be the right and responsibility of scientists alone." (Wright 1994, p.135).

1975: Asilomar -- The Public Sees Part of the Debates. It was clear by 1974 that the diverse controversies would grow and could not be contained by the scientific leadership. So a conference that would be attended by the press was scheduled at Asilomar, California for February 1975. The conference was a success for the leadership for several reasons:

1. The conference recommended that recombinant DNA research should proceed.

2. It promised that the molecular biologists could and would police themselves.

3. It left the public with the impression that the only substantial issue about the development of recombinant DNA technology was the biohazard question of laboratory safety. Thus the economic, social, political, military, ethical, and future ecological issues largely dropped from public view.

4. The questions about the safety of specific laboratory projects soon became blurred and the more general, if unlikely, issue emerged regarding the safety of any and all laboratory work with recombinant DNA. There was a focus on highly improbable, but easily dismissed, concerns such as those implied in the question, "Will any arbitrary mixing of DNA across species boundaries be highly dangerous?"

The negative consequence of the Asilomar conference was that a number of serious issues were neglected and passed on for the future to discover again. As Clifford Grobstein put it,

Despite the creation of an NIH-led interagency committee for federal coordination, a forum for concerted deliberation on the excluded Asilomar agenda never came into existence. So the public policy debate and, to some degree, the public impression of recombinant technology remained fixed on worst-case scenarios symbolized by the Andromeda strain (Grobstein 1986).

Concerns over the possible social, economic, and other problems from genetic engineering were reduced to the simple technical matter of containment and to the improbable concern that a biohazard scenario would emerge. As Grobstein warned, the result of this 'success' was to fence the issue within the turf of a special interest group within the scientific community and to prevent further effective deliberation by other scientists and the educated public of the complicated and serious social issues that lay ahead (Regal 1996).

Phase II: 1984 -- The New Deliberate Release Problem

The issue of 'deliberate release' or 'deliberate introduction' was among those issues that faded from view as a result of the Asilomar and Research Advisory Committee focus on contained laboratory experiments and disarmed laboratory organisms.

Thus it came as a surprise to many biologists in 1983-1984 that the technology had advanced greatly and that the genetic engineers were contemplating the 'release' or 'introduction' of ecologically competent genetically engineered organisms (GEOs) into the environment, where it was planned that they would thrive.

It was disturbing that essentially the same types of arguments were being used to argue that ecologically competent GEOs would cause no problems, as had previously been used to argue that ecologically incapacitated laboratory GEOs would not cause problems.

These facts were collectively surprising for several reasons:

1. Much of the scientific community was under the incorrect impression that the molecular biologists had been policing themselves, and that they had been thinking ahead and would make certain that biotechnology would be used wisely. Yet it was becoming clear that they had not made thorough reviews of the issues that were sure to emerge in the future, such as the deliberate release issue or economic, political, ethical, and social issues.

2. Many scientists who were not inside the biotech community were unaware that the field was progressing so fast that it would become possible to make ecologically competent GEOs in the foreseeable future.

There were several reasons why progress in genetic engineering had become somewhat opaque:

A. The intellectual gulf between molecular biologists and traditional biologists continued to widen as the molecular biologists forged close ties with industry and government.

B. The genetic engineers felt stung over the publicity and restrictions following Asilomar, and sought to keep a low profile among potential critics.

C. The close ties of genetic engineers with business often resulted in an atmosphere of industrial confidentiality.

D. The impression had spread that genetic engineers only worked with ecologically incompetent GEOs and that this was the cornerstone of safety.

1984: 'Deliberate Release' -- Ecological Discussions. The first meeting between leading university ecologists and molecular biologists, genetic engineers in industry, and representatives from government agencies took place at the Cold Spring Harbor Banbury Center in August 1984 and was organized by John Fowle III and me. The participants at the Banbury Conference quickly confirmed that the arguments that had been used to estimate that ecologically specialized laboratory GEOs were unlikely to cause ecological problems could not be used to estimate that releases of ecologically competent GEOs would be safe. There would be dangers and the consequences could in some cases be substantial (Brown et al. 1984). The United States Government was at the brink of deregulation, but this and subsequent conferences, such as one in Philadelphia in June of 1985, confirmed that the potential for dangers was a serious matter scientifically (Halvorson et al. 1985). Unknown to many scientists outside of Washington, D.C. there had earlier been Congressional hearings on the risks of introducing GEOs into the environment and a Congressional Report concluded that the probability of risks was low, but that the consequences could be extremely great (House of Representatives 1984). This conclusion was in agreement with an earlier internal Environmental Protection Agency document by Frances Sharples, eventually published in the Recombinant DNA Technical Bulletin (Sharples 1983). The participants at the Banbury Conference concluded that the intellectual issues were more challenging than many would at first suppose and that it would be a major task to educate the scientific community to deal with the future.

The Demise of Generic Safety Arguments. A variety of theoretical arguments were being used from about 1974-1986 to insist that all releases of GEOs would be safe. These generic safety arguments were criticized systematically at a series of scientific symposia, workshops, and in professional publications by Professors Philip Regal of the University of Minnesota, Robert Colwell, then at the University of California, Berkeley, and Richard Lenski, then at the University of California, Irvine (Colwell 1989: Lenski 1993; Regal 1985, 1986, 1988, 1993, 1994; Colwell 1989).

As a result, these generic safety arguments are seldom used anymore in discussions among experts. However, they are still in circulation among scientists who have not studied the technical issues, and they are still used by biotech public relations persons, and so they are briefly noted below. Criticisms are referenced and, in bold italics, summarized following each generic safety argument:

1. Genetic engineering is not different from ordinary sexual reproduction or conventional breeding and so it presents no unusual risks (But see Regal 1986, 1994). rDNA differs in at least four fundamental ways from both ordinary sexual reproduction and convention breeding. 1) Adaptive traits can be 'leap-frogged' over vast phylogenetic distances to form radically new combinations of competitive features. 2) sexual reproduction and traditional breeding are largely limited to exchanges of alleles (which are variants of genes), and exchanges typically demand substitutions and adaptive trade-offs and compromises, but with rDNA this class of exchange-based trade-offs can be circumvented. 3) Sexual reproduction and traditional breeding cannot normally reprogram the large fraction of genomes that are functionally homozygous. But rDNA holds the potential to reprogram fundamentally important genetic programs that are normally protected against change. 4) Transgenes often have unusual genetic side effects, apparently when a host organism's editing and buffering systems do not recognize them and cannot correct or control them properly.

2. Genetic engineering will always impose such a great added metabolic burden that GEOs will always be ecologically incompetent (But see Crawley et al. 1993, Doyle et al. 1995, Holmes 1996, Lenski 1993, Mikkelsen et al. 1996, Regal 1986). Experiments have shown that sometimes there is not the 'expected' metabolic burden. Moreover, if the adaptive benefits of a new feature outweigh its costs, it will be favorable to the organism. Costly adaptive features are quite common in nature.

3. Genetic engineering can create nothing really new because millions of years of evolution have tested every possible combination of genes. And whatever does not exist today has been proved to be maladaptive (But see Regal 1986, National Academy of Sciences 1987, pp.12-13). This was a version of the old Doctrine of Plenitude from philosophy and religion. Calculations easily show that every possible combinations of genes could not possibly have been tested by evolution. Moreover, careful studies of extinction indicate that much extinction has been random, due to catastrophes, or due to changing conditions and to being in the wrong place at the wrong time. This suggests that many extinct species, were they reconstructed, might well flourish today in some part of the globe.

4. Genetic engineering can only make an organism less perfect than nature has made it (But see Lenski 1993, Regal 1985, 1986, 1988, 1994, 1996). This assumes that natural organisms are perfected; again an idea from philosophy and religion, and sometimes from mathematical simplifications, not from modern empirical science. Scientists generalize instead that organisms are adequately adapted, not perfectly adapted.

5. Nature keeps all populations in balance. It will reject transgenic novelties or keep them in balance as it did the original hosts (But see Regal 1985, 1986, 1989, 1993). 'Balance of nature' theories have had a long history in religion, philosophy, and popular thought. But modern scientific studies have indicated that the idealistic theories were drastically misleading. Both observations and modern theory allow that some species may 'explode' demographically when the dynamics of their interactions with the physical or biological environment change.

These theoretical arguments have been in error because for the most part they have been based on:

1) Merely superficial understandings of the underlying genetical dynamics of natural sexual recombination and selective breeding compared to genetic engineering, and

2) Outdated and pedestrian ecological and evolutionary thinking that is rooted in the 'balance of nature' models developed by natural theology in the 16th through 19th centuries.

The Ecological Society of America (ESA) conducted a review and issued a report in 1989 (Tiedje 1989) that reviewed in detail the implications of progress in ecological concepts for the GEO risk issue. the preface to the publication explains that the manuscript was widely circulated among and approved by ESA members.

Phase III: The Continuing Quandary over Regulation

The following leans heavily on my experience and close involvement as an advisor on the scientific aspects of ecological risk assessment throughout the 1980s.

Deregulation Categories? The immediate reaction of many in the biotechnology industry to the demise of generic safety arguments was to want to get on with their work. 'Just tell us what we can and can not do. Give us two lists -- a yes list and a no list.' The regulators were under pressure to devise categories for introduced GEOs that would not need regulation. But in each attempt, the criteria for classification proved to be too simple.

The following are examples of the categories for deregulation that were discussed in the mid-1980s. Some problems with each are briefly discussed and appear in bold italics following each proposal. Note that these proposed categories are actually process-based categories in the sense that they do not ask what are the actual biological properties of the GEO product itself, but 'how was it made?' --'from what?'

1. Changes in only one or a few genes (should not be regulated). The probability of risk from changing only one or a few genes may be low, but not insignificant. The number of genetic changes is not definitive of risk; the phenotypic nature of any change and its contribution to fitness is what is important.

2. Internal rearrangements of DNA within a species ....

Changes in regulatory genes can have major phenotypic effects and have been important in evolution and adaptation. Also, the genetic code is simple and nucleotides can be rearranged to make any gene imaginable.

3. Genetic recombinations between species in the same genus .... The probability of risk may be low, but not insignificant. The source of transgenes is not by itself definitive of risk.

4. Domesticated plants .... Nearly all genetically engineered corn and wheat may be ecologically safe outside of their centers of germ plasm diversity. But 'domesticated' is not a scientific category. Many cultivated species are not so ecologically incapacitated as corn and wheat. Moreover, questions about food safety should not be overlooked even if ecological concerns are minimal.

5. Native organisms that are altered genetically and reintroduced into their native environments .... Resident species are adapted to local climates, soils, predators, diseases, etc. and in most cases where the genetically engineered host is a resident, the GEO could actually have a large advantage relative to a GEO made with a host from another region. The suggestion that local diseases and predators would keep the GEO from a local host 'in balance' is unrealistic because few species are 'regulated' and the genetic changes of concern would often be those that could overcome local sources of mortality such as heat or water stress, disease, etc.

6. Microorganisms .... With the exception of pathogens, such as chestnut blight, influenza, smallpox, etc., there are not examples of microorganism transport that have caused great ecological disturbance of the sorts that have been seen following the transport of non-indigenous plants and animals. But this may simply be due to the fact that species of microorganisms have been dispersing everywhere for hundreds of millions of years and there are in fact no truly non-indigenous forms of non-pathogenic bacteria. Science does not know enough about the natural history of microorganisms.

Thus, after years of deliberation it has not been possible to make a simple list of GEOs that it can be predicted would be categorically safe.

'Case-by-Case' Reviews Necessary. It seemed impossible to make comprehensive lists of all possible safe and unsafe GEOs, including lists based strictly on how or from what the GEO was made. Thus the frustrating conclusion was that GEOs would have to be evaluated on a case-by-case basis. Case-by-case does not necessarily mean that every strain of GEO must be studied extensively, but it does mean that every 'type' of project should be evaluated in terms of its own particularities by experts with a broad understanding of organismal biology and ecology.

Obviously there are no universal rules about how to make case-by-case evaluations for all the possible types of GEOs that might be constructed. And there is no universal definition for what a 'type of project' or 'situation' is or when 'enough' information has been provided.

The devil is in the details. Case-by-case means that the scientific community will have to be assured that each 'situation' has been reviewed by an appropriate mix of qualified experts that has articulated its collective decision with scientifically acceptable reasoning and is prepared to be accountable for its decision.

There has been considerable complaint that the regulatory agencies have not been using scientifically comprehensible criteria in making risk assessments to date (Doyle et al. 1995, GAO 1988, Rissler and Mellon 1993, 1996, PEER 1995, Regal 1994, Wrubel et al. 1992).

This lapse stems in part from the fact that the agencies have been under enormous political pressure to expedite the progress of genetic engineering. As a result they have not adequately staffed themselves with experts from the proper ecological and other scientific disciplines nor built the infrastructure to deal with the difficult scientific challenges ahead, let alone with the volume of paperwork expected.

The Familiarity Pitfall

It is commonly agreed that 'familiarity' with the unmodified relative of the GEO or the GEO itself should be a key consideration in risk assessment.

The pitfall is that 'familiarity' means different things to different people. One can be familiar with an organism in terms of its taxonomy, molecular structure, agronomic features, marketing characteristics, and so on. None of these forms of familiarity are or will be key to making sound biosafety evaluations. That is, there are many forms of scientific expertise that may be quite inappropriate for making sound safety evaluations. An ecologically oriented plant systematist may have a familiarity with the unmodified relative of a GEO that is valuable in one case, and a traditional economic botanist may have the necessary familiarity in another case. And in some cases the familiarity of agronomists or geneticists with the parent plant may be of only tertiary value.

Moreover, names do not necessarily mean what they might seem. For example, many scientists call themselves microbial ecologists because they study interactions of two or more species, as in fermentation processes. But they may not be familiar with modern concepts of the dynamics of natural communities. A traditional economic botanist should know a great deal about the systematics, biogeography, and ecology of crop plants and their relatives. But other economic botanists may not be familiar with this sort of information and they may be much too specialized to be valuable resources for risk evaluations. It is often said naively that a GEO will be safe if the unmodified relative is familiar, and or that various previous engineerings of the parent "did not cause problems". Yet it is not enough to have grown a GEO or its parent under simple conditions, even for years, to be able to predict how it may interact in nature.

The type of familiarity that would be a valid aspect of risk assessment would be familiarity with those particular characteristics of the unmodified relative and the GEO that could influence its ecological future and its effects on health. Often, "The Principle of Familiarity" is used to suggest that since something is known about the unmodified parent organism or about closely related organisms, the GEO will behave in the same manner. The Principle of Familiarity comes from the chemical industry, where, if the structure and activity of a chemical is known, then closely related chemicals, with nearly the same chemical structures, will likely behave the same way. This often, but not always, works for chemicals. But it rarely works for organisms.

Simple inorganic chemical reactions always occur in the same manner in a constant environment. But living organisms adapt and change with amazing regularity. Mutation, recombination, genetic drift, and natural selection are always at work in reproducing populations. Add to this the fact that genetic engineering has an implicit uncertainty regarding where transgenes insert, how many transgenes will insert, how much mutation they will cause, how errors produced by the transgenes will be corrected or buffered by the host, and it is highly doubtful whether this Principle of Familiarity could ever be applied to GEOs.

Further, if engineered organisms are different enough from all other organisms to be patentable, then it follows logically that unmodified relatives and GEOs are not similar enough to use the Principle of Familiarity. The Precautionary Principle may make more sense: 'First, do no harm', or 'If you don't know how something works, don't use it'. The criterion of 'familiarity' may sound superficially reasonable, but, without careful definition, it can only mislead.

The False Sense of Security Trap

Scientists began to express concern over the future of genetic engineering some thirty years ago, even before the most simple gene splicing had become possible. There was a progression of experience among persons who studied genetic engineering safety issues, and this progression sometimes resulted in a false sense of security. Broadly speaking, the "shared progression of experience" was (and is) this:

1. First the individuals or organizations becomes enormously concerned about the unknowns of this potentially powerful and rapidly advancing technology. They begin to worry that any genetic engineering project might unexpectedly turn into a frightening disaster. One GEO is the same as the next to them.

2. Next they learn that countless genetic engineering projects have been done in laboratories with no known disasters. They do not understand why this is so, but the history of safety with experimental strains of organisms seems to make a statement about all potential GEOs.

3. They begin to feel foolish that they were so concerned over projects that turned out to be harmless. They begin to fear looking foolish in the eyes of those who can affect their careers.

4. They conclude that genetic engineering is 'not as dangerous as people think'.

5. They assume that just as their own concerns were emotional overreactions to the unknown, the concerns of other scientists are the same thing.

6. They become convinced that risk assessment is only a political necessity to keep an ignorant public calm. They become wary of taking concerns too seriously. Or, if they do have concerns, they become wary of showing them too publicly.

7. They do not bother to develop the scientific background to understand the particular sorts of risks that systematic scientific analysis has found to be realistic. They do not make the effort to understand the scientific reasons why so many GEOs have been made safely even though there are legitimate concerns about dangers. They oversimplify the risk issue.

8. They become careless genetic engineers and/or risk assessors.

9. Some may concede that there are risks, but because they have not informed themselves well, they may assume that all risks will be trivial, and so there is no pressing need to develop an intellectually powerful scientific capacity to make safe GEOs and to make sound risk assessments.

10. They may not have heard about the problems or potential problems that have happened. Or, if they hear that problems were averted in such cases as the Brazil nut allergenicity that was passed on to soybeans, or the Klebsiella bacteria that was linked to the death of plants, they assume that the fact that the projects were stopped means that 'the system is working'.

11. The interest in development of a safe technology finally is compromised.

Individuals and whole groups have often gone through this progression over the last 30 or so years. So have whole groups. Great concerns about various dangers from genetic engineering were expressed by molecular biologists in the days before Asilomar. There was no careful analysis of future risks at the time and so the concerns that were originally well focused were easily oversimplified by a leadership preoccupied with calming the community. The concerns were easy to dismiss in their oversimplified form. They were:

1) Fears that any arbitrary GEO might cause a worst-case scenario like the Andromeda strain.

2) Fears that the technology itself could magically cause a worst-case scenario.

3) Fears that crossing species boundaries, or familial boundaries, etc. were inherently dangerous, regardless of the nature of the transgenes and the host.

Once it could be said that thousands of GEOs had been made in the laboratory without any accidents, many scientists and journalists whose concerns had been vague began to feel by the 1980s that they had foolishly overreacted. They became reluctant to become identified with the 'foolish people' their leadership held up as examples of those with concerns about safety.

They became reluctant to inform themselves about the new biosafety concerns over deliberate releases that began to emerge in 1984.

Thus the community of molecular biologists and genetic engineers is today divided on the risks of genetic engineering and on the need to regulate.

Sociologist I. Rabino surveyed 430 recombinant DNA scientists and reported in 1991 that 61% felt that however inconvenient, the general controversies over safety had made the genetic engineering community become more responsible. Only 24% felt that the controversies had been harmful over-all to genetic engineering. 72% felt that the advice of ecologists should be sought on safety issues, and many of those felt that this was important to do even if it meant that the United States would lose its competitive edge because of the controversies over recombinant DNA. It was only a small minority who did not want research/industry to seek ecological advice (Rabino 1991).

Rabino's findings are consistent with my own experience in working closely with the genetic engineering community for over a decade. But I would add that the small minority that is opposed to ecological input have tended to be more vocal and more active in government politics and with the investment community -- to be 'better connected' and more influential -- than the majority of research scientists.

The fact that so many recombinant scientists answered in the Rabino poll that they were willing to risk having the United States lose its competitive edge may not mean as much as it superficially seems. 'America's competitive edge' is a slogan, and many workers feel that it does not have precise meaning outside of the context of getting local and federal support for biotech. Biotech may well be destined to become dominated by multinational companies. American genetic engineers are ultimately aware that their colleagues may well be speaking loudly in patriotic terms one day, and the next day actively selling their ideas or small companies to foreign-based corporations.

Yet the overall outcome of the progression from strong concern to fear of overreaction has been to promote a false sense of security, a tendency to avoid serious study of the issues and to impede and divert progress toward the development of a scientifically sound biosafety infrastructure.


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The terms GEO and transgenic used in this essay closely follow traditional definitions such as those endorsed by the American Chemical Society and other scientific organizations. For example:

Genetic engineering: "The formation of new combinations of heritable material by the isolation of nucleic acid molecules, produced by whatever means outside the cell, into any virus, bacterial plasmid or other vector system so as to allow their incorporation into a host organism in which they do not naturally occur, but in which they are capable of continued propagation." (from p. 100 of the 1978 Genetic Manipulation Regulations)

Transgenic animal: "An animal whose genetic composition has been altered to include selected genes from other animals or species by methods other than those used in traditional animal breeding." (p. 238 of the 1978 Genetic Manipulation regulations). Note: the use of 'transgenic' to include hosts altered with artificial genes, or organelles, for example, is looser than this definition, but is unmistakably in the same spirit.