Bacteriology 
Biochemistry 
Food Research 
May 22, 1984 
Dr. William Gartland, Jr., Director 
Office of Recombinant DNA Activities 
Building 31, Room 3B10 
National Institutes of Health 
Bethesda, MD 20205 
Dear Dr. Gartland, 
Please consider the following comments with regard to the report of the 
Subcommittee on Investigations and Oversight of the Committee on Science and 
Technology of the U.S. House of Representatives entitled "The Environmental 
Implications of Genetic Engineering." 
The report states that it is addressing "...the deliberate release of all 
'genetically engineered' organisms and not just those created through recombinant 
DNA techniques." The subcommittee apparently fails to realize that virtually 
every crop and every animal produced agriculturally in the U.S. A. today has been 
"genetically engineered" using one or more genetic techniques. Since the report 
also recommends that "no deliberate release should be permitted by EPA, NIH, USDA 
or any other federal agency until the potential environmental effects of the 
particular release have been considered...", the USDA would be required to stop 
virtually all food production in the U.S. A. immediately. This is clearly an 
absurd situation. The scope of any regulation of this nature should be reduced 
considerably. I recommend that only organisms produced by recombinant DNA tech- 
niques be considered. 
Next, from experience with EPA's attempt to regulate the release of microbial 
pesticides, naturally occurring insect viruses specifically, I am aware of the 
deficiencies within EPA to regulate the release of biological organisms. Quite 
simply they lack sufficient expertise in this area and furthermore appear to be 
unable to identify or utilize knowledgeable consultants to help them establish 
appropriate tests and regulations. Because the majority of "deliberate releases" 
will be agricultural in their orientation and since NIH currently has the expertise 
in recombinant DNA risk evaluation, I feel that an interagency task force should 
be established and maintained as an oversight committee. In this respect, I agree 
with the subcommittee's recommendations. It should be possible to develop general 
guidelines which can be modified with time and increased knowledge concerning 
risks. With such guidelines in place, the panel would not need to evaluate every 
proposal. Rather, many proposals which fall under specific guideline categories 
could be evaluated by the institutional biosafety committees (IBCs) as is currently 
the case with recombinant DNA experiments in the laboratory. If such flexibility 
is not incorporated into the deliberate release program, the field testing of 
varieties of agriculturally important organisms could be unnecessarily hampered 
and become inordinately expensive. 
Universityof Idaho 
College of Agriculture 
Agricultural Experiment Station 
Department of Bacteriology 
& Biochemistry 
Agricultural Science Room 115 
Moscow, Idaho/83843 
[ 680 ] 
