page 3 
6. Part IV, Section A (Pre-Field Trial Considerations) 
Better definition of the term "microcosm" is requested. It may well 
be that greenhouse or growth chamber experiments indeed represent 
microcosms of microbes, soil, plants, etc. Better definition of 
(non-target) "mobile organisms" is requested. 
7. Part IV, Section A, subpart 3 
Establishment of better defined, reasonable limits for estimating 
"dissemination by wind, water, soil, mobile organisms and other limits" 
is requested. 
8. Part IV, Section D 
The proposed requirement for monitoring "non-modif ied" microorganisms 
at the site of the trial is not felt to be either reasonable or 
technically feasible unless "non-modif ied" organisms are defined as 
spontaneous or induced genetic mutants which have not been genetically 
engineered. Such non-genetically engineered, but genetically 
marked strains could be tracked in the field by the use of appropriate 
selective microbiological media as has been amply shown in the Rhizobium 
and Pseudomonas literature, with the use of e.g., rifampicin resistant 
and naldixic acid resistant mutants. 
Monsanto appreciates the opportunity to provide our comments to the NIH-RAC 
ORDA Working Group on Release of Organisms to the Environment for considera- 
tion in its final draft of Points to Consider in The Deliberate Release of 
Microorganisms to the Environment. 
Sincerely, 
Will D. Carpenter 
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