III-A-l-i. Industrial Biotechnology Association 
A May 19 letter from the Industrial Biotechnology Association (IBA) was 
signed by Harvey Price, Executive Director, IBA. The letter states: 
"The Industrial Biotechnology Association would like to express its 
agreement with the conclusion of NIH's enviornmental assessment in 
the ice-nucleation experiment case, that the modified field test 
proposal would have no significant environmental impact. We believe 
that the formal assessment makes clear that NIH's conclusion is supported 
by careful thought and abundant scientific evidence. While mindful of 
other public interests, the interest of encouraging such promising 
biotechnology research argues that NIH's substantial and conscientious 
effort to date should now be judged as fully adequate." 
III-A-l-j. Lilly Research Laboratories 
A May 14 letter from Lilly Research Laboratories (LRL) was signed by 
Irving S. Johnson, Ph.D., Vice President, LRL. The letter states: 
"There can never be an original experiment with zero risk. With 
admirable caution, the NIH-Recombinant DNA Advisory Committee (RAC) 
has recommended approval of experiments that carefully 
probe new areas of application of recombinant DNA technology. The 
field test proposal of Dr. Lindow and Panopoulos is such an experiment. 
The environmental assessment prepared by NIH summarizes current 
knowledge about all factors bearing on possible environmental effects; 
we concur with the logical conclusion that no significant environmental 
impact should result." 
III-A-l-k. National Agricultural Chemicals Association 
A May 15 letter from the National Agricultural Chemicals Association (NACA) 
was signed by Dr. Earl C. Spurrier, Vice President Regulatory Affairs, 
NACA. The letter states: 
"The NIH assessment appears to be well researched and documented. 
It represents a balanced, thorough and plausible evaluation of the 
environmental effects and impact of conducting research as proposed 
in the ice-nucleation-minus-bacteria project. It is apparent that all 
possible and relevant avenues of projected and potential concern . 
were investigated and addressed. The document clearly goes beyond 
reasonable requirements to reassure the public that any possible 
field escape of the bacteria will have no adverse effects on or in 
the environment. The expert consultants who were involved are 
world-renowned for their scientific credibility and judgment. 
As such, the Environmental Assessment clearly supports the continuation 
of the research and the conclusion that this experiment will not 
adversely affect the environment in any substantive manner." 
6 
[ 170 ] 
