6 
B. EPA Documents Indicate That If the Agency- 
Exercises Authority Under TSCA as to Deliberate 
Release of Genetically Engineered Organisms, 
It Will Seek Authority Over the Entire Genetic 
Engineering Industry 
EPA interprets TSCA as providing it with comprehensive 
regulatory control over genetic engineering. If EPA assumes 
jurisdiction over DNA and microorganisms in order to regulate 
deliberate release of organisms into the environment, EPA 
apparently also would seek authority over far more. It would 
assert authority over the genetically altered DNA 1/ and 
microorganisms 2/ utilized in the manufacturing process of all 
genetically engineered products and over the companies which 
produce the new forms of DNA. 3 / 
It appears that EPA wants to regulate the genetic engi- 
neering manufacturing process, even when used to manufacture 
1/ See letter from Marcia Williams, Acting Director, Office 
of Toxic Substances to Warren J. Lyman of Arthur D. Little, 
Inc., at 2 (hereinafter referred to as Lyman Letter). See 
also statement of Don R. Clay, Acting Administrator, 
Office of Pesticide and Toxic Substances, Before the Sub- 
committee on Science, Research and Technology and Subcom- 
mittee on Investigations and Oversight, Committee on 
Science and Technology, House of Representatives (June 22, 
1983) at 9 (hereinafter referred to as Clay Statement). 
2/ See Regulation of Genetically Engineered Substances Under 
TSCA, Chemical Control Division, Office of Toxic Sub- 
stances, Office of Pesticides and Toxic Substances, United 
States Environmental Protection Agency, Washington, D.C., 
March 19, 1983, at 16 (hereinafter referred to as EPA 
Position Paper) . 
3 / Lyman Letter at 2. 
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