at hand. These responses are adequate within a narrow interpretation of administrative procedures, but APHIS could have sought alternative methods of involving the public. As noted above, the agency has held public meetings to inform the public about its policies, but such meetings reach a very small audience.

Recommendation 5.1: For precedent-setting decisions involving permits and petitions, APHIS should actively solicit external scientific review.

External Input into the Establishment of Policy

As reviewed in Chapter 3, the present regulatory system used by APHIS was established in a series of policy-setting decisions. Starting in 1987 with establishment of the permit system, with its risk-based process regulatory trigger, several subsequent decisions excluded certain transgenic organisms from regulation. Two significant policy-setting decisions were the 1993 decision to establish a notification system and a process to petition for nonregulated status (the deregulation decision) and the 1997 decision to expand the notification system. APHIS did not use any formal processes (i.e., processes that are part of APHIS written policy) beyond the use of the Federal Register to announce 60-day public comment periods for involving the public in these decisions. For the 1993 decision, the agency used informal mechanisms to solicit public input, which included several public workshops and a scientific review by a subcommittee of ABRAC to evaluate the scientific merits of the 1993 proposal for a notification system. Increased utilization of a system of external scientific review of important policy decisions could help in securing greater public confidence in the regulatory process.

Recommendation 5.2: For changes in regulatory policy, APHIS should convene a scientific advisory group to review proposed changes.

Input of the general public in the process of policy development has been limited to the same mechanisms used in soliciting input on specific regulatory decisions. Actively broadening the basis for public involvement in environmental decision making is a difficult and potentially expensive proposition. Among the strategies that have been used by other agencies are advisory committees with representation from a number of self-identified advocacy groups, and public hearings. Outside the United States other approaches for distributing information and eliciting responses from the interested public have included consensus councils, blue



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