Zoecon Corporation 
A Sandoz Company 
Tab C - Page 9 
975 California Avenue, Palo Alto, California 94304-0859 
RO. Box 10975. Palo Alto. California 94303 (415) 857-1130 
May 8, 1985 
N. I.H. Office of Recombinant DNA Activities (0RDA) 
Building 31 RM. 3B10 
National Institutes of Health 
Bethesda, MD 20205 
Subject: Research Involving r DNA Molecules by 
Drs. Steven Lindow and Nlckolas Panopoulos: 
Environmental Assessment and Finding of No 
Significant Impact. 
Dear Sirs: 
Zoecon Corporation , A Sandoz Company is pleased to submit these comments on 
the subject EA and P0NSI. Zoecon is a pioneer in the development of so called 
'biorational 1 pest control agents and is one of the larger producers of both 
biochemical and microbial pesticides. 
Zoecon agrees with NIH's Comprehensive Environmental Assessment and finding 
of no significant impact with respect to the testing proposed by Drs. Lindow and 
Panopoulos. The facts that: (a) the INA" deletion mutant of the Pseudomonas 
syringae pv . syringae is isogenic with the naturally occurring syringae 
INA + and contains no foreign DNA; and (b) that non isogenic INA“ mutants 
produced through undirected mutagensis have been previously tested without 
adverse environmental effects; argue convincingly that the risk associated with 
the proposed field use is negligible. Also there is a finite probability that 
such isogenic deletion mutants have occured naturally in the past without 
notable effect and that the persistence and competitiveness of INA“ mutants in 
general is insufficient to allow them to displace the wild type whose INA + 
character probably confers a distinct competitive advantage for epiphytic 
colonization. 
With respect to the need for a Progranmatic Environmental Impact Statement, 
Zoecon believes that in view of the increasing responsibilities of ocher Federal 
agencies notably the Environmental Protection Agency, such programmatic EIS 
should not be required of N. I.H. It seems likely that future reviews by ORDA 
will focus, as in the past, on laboratory hazards rather than specifically on 
environmental impact. It is hoped however, that sufficient cooperation will 
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