Tab C - Page 25 
be referred to as P. syr ingae thus avoiding the confusion as to 
their pathogenic associations. 
The need for a programmatic EIS to address any release of 
genetically engineered organism is unlikely to be resolved in the 
near future. Environmental concerns and risks must be expressed 
on a case-by-case basis (as was the original approach of NIH-RAC) 
due to the large 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. 
I do believe programmatic statements are sorely needed to define 
the expected environmental fitness of broad groupings of 
enginnered organisms and the potential risk of detectable 
presistance. 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 
genral 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 
regulation 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 
requirement’s 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-specific EIS would 
be needed for small scale testing. 
I hope this somewhat lengthy^ and rambling letter will be helpful 
to your office in some way. 
Sincerely , 
Trevor Suslow, Ph.D. 
Director of Product Research 
Staff Scientist Plant Pathology/Biocontrol 
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