EBA 
Directors 
Industrial Biotechnology Association 
Officers 
2115 East Jefferson Street 
Rockville, Maryland 20852 
President 
J. Leslie Glick 
Genex Corporation 
Telephone: (301) 984-9598 
Wee President 
Robert Fildes 
Harvey S. Price 
Biogen 
Executive Director 
Secretary 
Gabriel Schmergel 
Genetics Institute 
Treasurer 
John Donalds 
The Dow Chemical Company 
February 22, 1983 
Ronald E. Cape 
Cetus Corporation 
Hugh A. D’Andrade 
Schering-Plough Corporation 
Harry Green 
SmithKIine Beckman Corporation 
Dr. William J. Gartland, Jr. 
John R. Norell 
Director, Office of 
Recombinant 
Phillips Petroleum Company 
DNA Activities 
David J. Padwa 
Building 31, 4A52 
Agrigenetics Corporation 
National Institutes 
of Health 
Hollis G. Schoepke 
G. D. Searle & Company 
Bethesda, Maryland 
20205 
Dear Dr. Gartland: 
The comments below are submitted on behalf of the Industrial Biotechnology 
Association, a trade association representing a number of leading companies en- 
gaged in commercial biotechnology activities. A current association membership 
list is enclosed. 
We support the continued effort of the NIH in its program to assess the 
risks of recombinant DNA research as outlined in the Federal Register (47 FR 
55104) . We should like to suggest that the risk program be expanded to the 
area of environmental assessment, and that studies on the survival and conju- 
gation of recombinant organisms in nature be initiated. Since research and 
manufacturing using recombinant organisms has increased, some have expressed 
concern about the release of such organisms. Such studies would provide an 
excellent supplement to the _in vivo studies previously reported, and also comply 
with a request from the Environmental Protection Agency that more attention be 
paid to environmental assessment. Furthermore, data from these studies will be 
of assistance in evaluating requests by biotechnology companies for the scaling 
up of growth of recombinant organisms. 
HSP/ agr 
Enclosure 
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