Tab A - Page 10 
He wrote (l), "I have read the request to the RAC from Drs. Steven lindcw and 
Nicholas Panopoulos which you sent me for comment. I find their proposal to 
field test Ice nucleation deficient mutants of P. s^. syringae and E. herbicola 
for bloccntrol of frost injury to be a very worthwhile project which should be 
done. I cannot see that there is any hazard in constructing and releasing 
these mutants. Mere deletion of INA genes should not Increase the fitness of 
these bacteria or what pathogenicity they might have. Furthermore, the use of 
rONA procedures is designed to Insure well-defined homogenic strains for 
experiments and should not generate any strains which could not otherwise arise 
by natural genetic ' processes . Drs. Lindow and Panopoulos appear to have 
thought of almost every possible means to minimize and monitor the spread of 
their bacteria in the environment. Moreover, even if the mutant strains are 
disseminated, it is doubtful that they would be able to establish new epiphytic 
populations from small doses of inoculum because resident populations of very 
similar bacteria are undoubtedly already established in their plots and 
surrounding crops." Subseauently , the USDA Recombinant DNA Committee 
recommended that NIH approve the proposed field test. 
In the Federal Register of June 1, 1983, NIH announced that "permission Is 
granted to Drs. Steven Lindow and Nickolas Panopoulos of the University of 
California, Berkeley, to release under specified conditions Pseudomonas 
syringae pv . syringae and Erwinia herbicola carrying j_n vitro generated 
deletions of all or part of the genes Involved in Ice nucleation," along with 
the finding that this action presents "no significant risk to health or the 
environment. (A) 
7 
[ 204 ] 
