PANT III (Cont'd) 
P.»gc Nine 
Attachment IV - Page 13 
released into the environment would appear to fall within the 
authority of the National Science Foundation during research, 
and the EPA upon product application. Do these agencies have 
sufficient expertise in the molecular biological sciences to 
make an adequate risk assessment. 
12. If in the event the EPA is to involve itself in 
laboratory research, what burden will be placed upon scientific 
investigators providing information for the initial pre- 
manufacturing notice. 
13. There needs to be a clarification as to the need of 
oversight or regulation of fermentation activity in industry. 
14. A clarification needs to be made as to who is to make 
the determination as to what constitutes research and what activi- 
ty constitutes commercial application. 
15. In connection with the applications to the respective 
agencies, will there be a uniformity of standards as to what is 
safe, and as to where the burden will fall, in establishing such 
safety. Under existing oversight and regulations there does not 
appear to be uniformity of standards between the respective 
agencies, or within several of the agencies. 
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