degree of variability in organism, target site, and introduced or 
altered gene function. I don't believe anyone can predict the 
diversity of potential basic or applied research needs that would 
cover all situations or sources of risk." 
However, while Dr. Suslow does not seem to favor a single programmatic EIS 
for all NIH approvals of proposals to release into the environment 
organisms containing recombinant DNA, he then goes on to argue for 
"prograiranatlc statements" of "broad groupings of potential releases." 
He states: 
"I do believe programmatic statements are sorely needed to define 
the expected environmental fitness of broad groupings of engineered 
organisms and the potential risk of detectable perslstance. It would 
be against this series of broad statements compiling currently available 
Information that lay people and cross-disciplinary scientists could make 
preliminary judgements concerning risk to the environment. For example, 
where the general need or intent of a research program is to release 
and test a biological control agent, the organism must be environmentally 
competent and competitive. This would be covered by different broad 
criteria than an engineered Rhizobium which can be introduced to 
plants in a way that avoids its competitive disadvantage to other 
native Rhizobium spp and can thus be tested, at a preliminary stage, 
without concern for its ability to persist. Similar examples can 
be drawn for differences between deletion mutations and novel 
expression or novel regulations of genes in the released organism, etc. 
Thus by compiling data to cover broad groupings of potential releases 
by, perhaps, experimental objective as it relates to environmental 
fitness and subdivided by function (i.e. toxin, antibiotic, enzyme, 
polysaccharide, etc.) guidelines covering experimental requirements 
prior to release might be more readily determined. Hopefully this could 
expedite consideration and review of release proposals by highlighting 
potential areas of concern for the researcher. More detailed analysis of 
the Individual experiment could then refer to a more generalized 
environmental statement if the review committees find no significant 
risk in the proposed release. No additional comprehensive or site- 
specfic EIS would be needed for small scale testing." 
III-B-3. Comnent Indicating a Programmatic EIS is Required 
The only comment received indicating that a programmatic EIS is required 
for NIH approvals of release into the environment of organisms containing 
recombinant DNA molecules was the following sentence from Mr. Rogers' 
May 14 letter: 
"For the reasons stated in our appellate brief, which arguments we 
incorporate by this reference, and as indicated by the court of 
appeals opinion on the question, there are a number of factors 
suggesting that a programmatic EIS is required." 
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