Attachment IV - Page 2 
We agree that to the greatest extent practicable all 
relevant scientific and technical skills available to Federal 
agencies should be brought to bear in review of proposals for 
deliberate release. The Cabinet Council Working Group will 
be addressing the need for the kind of interagency task force 
you are recommending. 
The report's fourth recommendation would give the 
interagency task force responsibility for approving research 
scale releases, provided that a plan for reviewing proposals 
is underway in 90 days. EPA is now considering steps to 
deal with small scale field test proposals under FIFRA and 
TSCA . In the interim, we believe the RAC is best equipped to 
review nonpest icidal field scale releases. The RAC, as you know, 
has representatives from all major Federal regulatory agencies 
with responsibilities in biotechnology and provides an excellent 
forum for interagency deliberation on issues associated with 
deliberate release. For pesticides, the Agency's plan includes 
proposing a policy to require a several month pre-test notifi- 
cation to EPA when conducting field studies for research 
purposes on less than 10 acres of land (or 1 acre of water) 
with microbial pesticides. For TSCA uses, EPA is considering 
the possibility of narrowing the PMN exemption for research 
and development substances so that field tested organisms are 
not eligible. 
In summary, we agree with the subcommittee recommendations 
that formal communications and agreements with other agencies 
are important in bringing all available scientific expertise 
to bear in the evaluation of scientific issues associated 
with biotechnology. We also agree that it is important to 
employ interagency mechanisms suqh as the RAC in the evaluation 
of research scale releases. As I indicated earlier, our 
activities in the Cabinet Council Working Group, the IRMC, 
and the RAC, as well as our close coordination with other 
Federal agencies are accomplishing these goals. 
The Agency has also prepared answers to the Subcommittee's 
specific questions pertaining to the appropriate role of EPA, 
NIH, and USDA for assessing release of genetically engineered 
organisms into the environment for field scale testing as 
well as for further commercial purposes. Your questions and 
our answers are as follows: 
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