for description of the long-term effects of the discovery of x-ray 
on our civilization immediately after Rontgen showed the invisible 
radiation would penetrate some objects and not others and that these 
effects could be measured. Science deals with 1 i mi ted extrapolation 
from known experimental results; the data from one experiment must 
be digested and interpreted before the next can begin." 
III-B-l-j. National Agricultural Chemicals Association 
The letter from Dr. Spurrier states: 
"From our point of view, the Environmental Protection Agency and 
the U.S. Department of Agriculture, including APHIS, are taking 
leadership roles in agriculturally oriented research dealing with 
recombinant DNA and genetically engineered plant varieties. With 
the already published EPA interim guidelines dealing with pesticide 
research and notification, and the soon-to-be proposed rulemaking on 
the subject, it appears that the role of NIH, as oversight, should 
in the future be directed to only those activities of broad national 
concern involving public health issues. The technology of bio/genetic 
engineering, particularly in agriculture, is progressing in a very 
positive manner. The need for detached oversight such as the develop- 
ment of very comprehensive Environmental Impact Statement by NIH to 
comply with certain interpreted requirements of NEPA seems now to be 
procedurally redundant unless there is a scientific reason to question 
a basically unknown revelation. 
"At this time, there is no reason to believe that genetically engineered 
organisms are any different than organisms that mutate during natural 
selection. Over the years, plant breeding techniques have used 
chemically induced mutations to assist in mass selection. In genetic 
engineering, the biological derivation is actually more precise and 
predictable. It would appear that very strong arguments would have to 
be made to justify the need for a programmatic Environmental Impact 
Statement to demonstrate that a genetically engineered organism 
has a greater chance to invoke environmental harm than an organism 
altered by traditional practice." 
III-8-2. Comment Indicating the Need for a Programmatic EIS "Is Unlikely 
to Be Resolved in the Near Future ." 
The letter from Dr. Suslow states: 
"The need for a programmatic EIS to address any release of genetically 
engineered organism is unlikely to be resolved in the near future." 
Dr. Suslow then goes on to give arguments which seem to support the concept 
that a programmatic EIS is not required when he states: 
"Environmental concerns and risks must be expressed on a case-by-case 
basis (as was the original approach of NIH-RAC) due to the large 
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