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Environmental Effects of Transgenic Plants: The Scope and Adequacy of Regulation
with considerable information to improve its regulatory procedures and could contribute to a more formal methodology for a learning system. One caveat regarding these models is that the cost of such an analysis is unknown, but might be high.
Recommendation 5.7: APHIS needs to formalize its learning process.
The best regulatory decision making depends on using the best information available. The committee has identified two interweaving factors that could increase the amount of information available for the regulation of transgenic plants. First, it has identified that the flow of information to and from external scientists during the APHIS decision-making process could be improved if external input were more actively sought by the agency and if the impediments to flow of data by “confidential business information” were reduced. Second, the committee perceives that the small APHIS staff and their high workload precludes the opportunity to develop the flexibility and breadth necessary to deal with the complex, diverse, and evolving challenges of a growing workload, new products, new environmental questions, and increase in the spatial scale of commercial production.