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NATIONAL AGRICULTURAL CHEMICALS ASSOCIATION 
THE MAOISON BUILDING 
1155 Fi(te«nth Street, N.W., Washington. 0. C. 20005 
202 • 296-1 565 Cum nag/khcu 
Dr. Earl C. Spurrier 
Vice President 
Regulatory Affairs May ^ 5 ^ 1985 
Dr. William J. Gartland 
Director 
Office of Recombinant DNA Activities 
Building 31, Room 3B10 
National Institutes of Health 
Bethesda, Maryland 20205 
Dear Dr. Gartland: 
The following statements from the National Agricultural Chemicals 
Association (NACA) X/ are in response to the April 15, 1985 Federal 
Register notice inviting comments on "The Environmental Assess- 
ment and Finding of No Significant Impact" concerning the appli- 
cation to the National Institutes of Health (NIH) , under the NIH 
Guidelines for Research Involving Recombinant DNA Molecules to 
Field Test Ice Nucleation Minus Bacteria to Control Frost Damage 
to Plants. Also included are comments on the need for a program- 
matic Environmental Impact Statement. 
The Environmental Assessment and Finding of No Significant Impact 
The NIH assessment appears to be well researched and documented. 
It represents a balanced, thorough and plausible evaluation of 
the environmental effects and impact of conducting research as 
proposed in the ice-nucleation-minus-bacteria project. It is 
apparent that all possible and relevant avenues of projected and 
potential concern were investigated and addressed. The document 
clearly goes beyond reasonable requirements to reassure the 
public that any possible field escape of the bacteria will have 
The National Agricultural Chemicals Association 
(NACA) is a nonprofit, trade organization of manu- 
facturers and formulators of pest control products 
employed in agricultural production. NACA's membership 
is composed of the companies which product and sell 
virtually all of the technical crop protection mate- 
rials (active ingredients) and a large percentage of 
the formulated products registered for use in the 
United States. 
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