Tab C - Page 6 
Dr. William J. Gartland 
April 24, 1985 
Page 2 
The Need For a Programmatic Environmental Impact Statement 
Man has had centuries of experience with plant breeding, a century of 
experience with genetically altering microorganisms, and half a century of 
experience with gene exchanges among microorganisms. No special 
concerns have been raised from release of organisms produced through 
man-made and man-selected genetic alterations. We consider these types 
of projects to be very safe; consequently, we have no regulations to govern 
release of genetically altered organisms which are regarded as safe. 
In comparison to traditional genetic technologies, recombinant DNA 
technology actually is more precise and predictable in its outcome. Thus, 
the level of concern about problems from recombinant DNA techniques 
should be no more than the level of concern associated with release of 
organisms developed using conventional techniques. 
The NTH should not prepare a Programmatic Environmental-Impact 
Statement unless there is a scientifically sound reason why application 
of recombinant DNA technology will inadvertantly create a serious 
environmental problem. The fact that a Programmatic Environmental 
Impact Statement has never been deemed necessary for traditional 
practices such as breeding and mutation, strongly suggests that a 
Programmatic Environmental Impact Statement would not be useful for 
recombinant DNA work. Arguments must be made by proponents of a 
Programmatic Environmental Impact Statement to demonstrate that a 
recombinant organism indeed has a greater chance to create environmental 
damage than a genetically altered organism derived through traditional 
practices. 
I appreciate this opportunity to comment on these important matters and 
hope that the procedural complexities that have diverted attention from 
moving this science ahead will soon be overcome. 
Sincerely, 
Vice President, Research and Development 
WJB:es 
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