OFFICERS 
Coleman Burke 
Chairman of the Board 
K. William Wiseman 
Vice Chairmen 
Dr. Amy Freeman Lee 
Secretary 
John A. Hoyt 
President 
Paul G. Irwin 
Vice President/Treasurer 
Murdaugh Stuart Madden 
Vice President/ 
General Counsel 
Patrick B. Parkes 
Vice Presldent/Fleld Services 
Patricia Forkan 
Vice President! Program 
and Communications 
Dr. John W. Grandy 
Vice President/ 
Wildlife and Environment 
Phyllis Wright 
Vice President/ 
Companion Animals 
Dr. Michael W. Fox 
Scientific Director 
DIRECTORS 
Rosemary Bennlng 
Amanda Blake 
Samuel A. Bowman 
Dr. Carol Browning 
Coleman Burke 
Jack Conlon 
Donald S. Dawson 
Irene Evans 
Anna Fesmlre 
Regina B. Frankenberg 
Harold H. Gardiner 
Robert W. Gilmore 
Glsela H. Karlan 
Dr. Amy Freeman Lee 
Jack W. Lydman 
Virginia Lynch 
John W. Mettler, III 
Inga Prime 
O.J. Ramsey 
Marilyn G. Seyler 
Everett Smith, Jr. 
Robert F. Welborn 
K. William Wiseman 
HONORARY DIRECTORS 
Alda Flemming 
Virginia Mllllken 
Andrew Wyeth 
The Humane Society of the United States 
2100 L street, N.w. 
Washington, D.C. 20037 
(202) 452-1100 
May 16, 1984 
The Director 
Office of Recombinant DNA Activities 
Building 31, Room 3B 10 
National Institutes of Health 
Bethesda, MD 20205 
Comment on the recommendations offered in the report 
"The environmental implications of genetic engineering," 
prepared by the staff of the Subcommittee on Investi- 
gations and Oversight of the Committee on Science and 
Technology. 
I strongly urge that the NIH Recombinant DNA Advisory 
Committee consider adopting or endorsing as appropriate 
the recommendations of this report. Namely: that the 
EPA should proceed with its stated intention to extend 
its authority to include all deliberately released 
organisms not specifically identified as part of the 
legal obligation of another agency. The EPA should 
exercise the authority to oversee the deliberate 
releases of any genetically engineered organisms into 
the environment. The EPA should establish formal 
communications and agreements with other agencies to 
ensure that gaps and redundancies in the regulatory 
structure do not occur. Secondly, until EPA's regu- 
lations are promulgated, an inter-agency task force 
should be established to review all proposals for 
deliberate releases. EPA should take the initiative 
in organizing such a panel. Ideally such a panel 
should include one member of the public not involved 
with government or industry who has some expertise on 
environmental issues and is knowledgeable about 
ecological conservation and related concerns. Such 
an oversight panel should have a permanent role to 
play even after EPA has promulgated regulations. The 
NIH should cease its practice of evaluating and 
approving proposals for deliberate release from 
commercial biotechnology companies. Furthermore, no 
deliberate release should be permitted by any agency -- 
EPA, NIH or USDA -- until potential environmental 
effects of the particular release have been considered 
by the inter-agency review panel. Both the USDA and 
the NIH should seriously consider revising the member- 
ship of their respective recombinant DNA Advisory 
Committees to include individuals specifically trained 
in ecology and the environmental sciences. 
MICHAEL W. FOX, DSc , PhD, BVet Med, 
MRCVS, Scientific Director 
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