Ill -A-3-b- ( 8 ) . My Response to Comments in Section III-A-3-b-(7) 
Dr. Pimentel is citing other experiments that could be done in the laboratory 
before the field test is allowed to proceed. Dr. Gliessman writes of wanting 
to "ensure zero probability of problems." 
One can always do more and more experiments in the laboratory in order to 
become more and more convinced that a proposed field test is safe. However, 
I believe, as did all the members of the NIH Recombinant DNA Advisory 
Committee, and the majority of respondents to our April 15, 1985, Federal 
Register notice, that sufficient information exists today, without additional 
experiments , to make a judgment that the proposed field test poses no 
significant risk. I recommend that no change is needed in response to the 
comments given in Section II I-A-3-b-(7) . 
Ill -A-3-b- ( 9 ) . In his May 14 letter, Mr. Rogers states: 
"Again there was not an adequately interdisciplinary review of the 
experiment. Insofar as we have been able to determine, the scientists 
listed as consultants have not made direct research contributions 
in the discipline of ecology of microorganisms. Dr. Kelman, the one 
scientist whose expense borders on this area, has made his contributions 
primarily in the area of physiology of parasitism, expecially as 
regards bacteria. Another one is a virologist, and the others are 
predominantly genetic engineers. The assessment would have been 
improved had qualified ecologists in the relevant specialities been 
included as consultants. Issues can only be recognized and dealt 
with adequately if there are qualified experts undertaking the 
evaluation." 
In his March 11 delaration, Dr. Gliessman states: 
"Those consulted in the preparation of this assessment did not 
include an ecologist or evolutionary biologist. I feel that 
a broader range of expertise would be very important, expecially 
since many of the aspects involved deal with ecological and 
evolutionary processes in the environment." 
III-A-3-b-( 10) . My Response to Comments in Section I II-A-3-b-(9) 
The NIH has gone far beyond all requirements in involving consultants 
in the review of the January 21, 1985, EA-FONSI. Neither the National 
Environmental Policy Act nor the Council on Environmental Quality (CEQ) 
Regulations for Implementing the Procedural Provisions of the National 
Environmental Policy Act (40 CFR 1500-1508), nor Part 30, Environmental 
Protection, of the General Administration Manual of the Department of 
Health and Human Services (HHS), require the NIH to involve any persons 
outside of NIH in the preparation or review of an EA-FONSI. The NIH 
nevertheless consulted all the persons listed In Part 6.0 of the January 21, 
1985, EA-FONSI. This is a distinguished list of consu-1 tants . Dr. Kelman, 
a member of the National Academy of Sciences, and chairman of its Section 
on Basic Biology and Agricultural Sciences, in his curriculum vitae 
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