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Greg Simon (Letters, 3 May, p. 629) makes the case that only federal regulation of releases of agricultural products will address health and safety concerns. Such a view is hardly surprising, since he drafted the federal statute for the comprehensive regulation of field research with recombinant DNA-manipulated organisms. The basic assumptions of this statute were contrary to those contained in the reports of the National Academy of Sciences (NAS) (1) and the National Research Council (NRC) (2) and also to the existing policies of government research and regulatory agencies. The statute would have regulated only those organisms that were manipulated with recombinant DNA techniques (and virtually all of them), but not organisms likely to be of high risk, such as those possessing enhanced fitness or pathogenicity or those that contain novel phenotypes. Such a statute would not have allayed public fears or conferred safety protection above that of current regulation, but it would have perpetuated the notion that process, rather than performance or should be the focus of regulation. It would, inevitably, have exerted a chilling effect on those wishing to use the newest techniques. This scientifically indefensible approach was criticized by government agencies, industry, and academia alike and was rejected by Congress.