Attachment IV - Page 3 
1. Does EPA intend its assertion of jurisdiction under 
TSCA to extend to field scale testing of genetically 
engineered organisms? if so, how will this be 
implemented. Since such jurisdiction is claimed 
under FIFRA as well, how will the two be coordinated? 
Is EPA considering lowering its 10 acre exemption for 
field testing of genetically engineered organisms 
under FIFRA? 
The Agency intends to publish a Federal Register notice 
later this year that will explain our plans for regulating 
biotechnology under TSCA and FIFRA and solicit comments on a 
number of issues. The notice will also describe the Office 
of Pesticides and Toxic Substances' (OPTS) strategy for 
requiring pre-test notification of field tests, including 
those under 10 acres, of genetically engineered microbes 
under FIFRA and TSCA. It will explain how EPA will require 
PMNs under TSCA for commercial production of engineered 
microbes and it will announce the establishment of an Agency- 
wide biotechnology committee to provide coordinated policy 
support to the program offices, and to provide guidance to our 
representatives to the RAC. 
2. Has EPA developed a program and management plan 
(budget, personnel, R&D requirements, procedures, 
guidelines and regulations, projections of workload, 
etc.) for implementation of its program under TSCA? 
FIFRA? If so, I would appreciate receiving a copy of 
any such plan or plans. 
EPA is in the process of developing the management aspects 
of its program plan (including personnel, research and develop- 
ment requirements, guidelines, and regulations) to implement 
its biotechnology program. OPP is hiring additional scientific 
personnel to work on biotechnology applications. 
The Office of Toxic Substances (OTS) also plans to hire 
additional specialists to complement its existing staff for 
the biotechnology program under TSCA. Public comments from 
the Federal Register notice on biotechnology, which EPA 
plans to publish later this year, will be used by OTS and OPP to 
refine their respective program plans. 
A research plan for biotechnology has been ongoing for 
several years. EPA's Office of Research and Development 
(ORD) has sponsored such activities as trend analyses of 
agricultural and industrial applications of biotechnology , 
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