2 
"pollutant" is said to mean "chemical wastes," "biological 
materials", etc. It is strange that Congress would recite 
"biological materials" if it was subsumed in the concept of 
a chemical. In addition, there would have been no need for 
Congress to recite "disease causing agents" in the FWPCA 
definition of "toxic pollutant." Construing TSCA in pari 
materia with the FWPCA, one is led to the conclusion that 
biological organisms are not "chemical substances" within 
the intentment of TSCA. This conclusion is reinforced by 
the failure of Congress to consider biohazards in the 
hearings which led to TSCA. 
ABC does not dispute that DNA molecules are "chemical 
substances." However, ABC notes that salmon sperm DNA of 
heterogeneous sequence is listed on TSCA Inventory and 
therefore is not a "new chemical substance" subject to 
premanufacturing notification. "Ribonucleic acid", without 
limitation as to source, is also listed on the inventory. 
In addition, it is uncertain whether the mere replication of 
DNA within a living organism, when that DNA is not extracted 
from the organism is nonresearch quantities, is a 
"manufacture" of DNA within the meaning of TSCA. 
On the other hand, ABC recognizes that the public 
deserves reassurance that the safety of releases has been 
impartially and scientifically considered. ABC further 
recognizes that EPA has expertise in ecology that is of 
value in evaluating the safety of releases. Consequently, 
ABC has encouraged its members to cooperate with EPA, rather 
than to challenge its authority. ABC itself believes that 
both the industry and the public will benefit if the 
regulatory agency receives an education in biotechnology. 
ABC intends to work with EPA and kindred agencies toward 
both educating them on the intricacies of genetics and 
microbiology, and in turn learning of and responding to 
their specific concerns. 
2. Until such time as EPA's regulations are 
promulgated, an interagency task force should be 
established to review all proposals for deliberate 
releases . . . . 
ABC COMMENT: The statutory authority for the creation 
of this interagency task force are not clarified. The 
panel, as envisioned, does not appear to offer any 
particular advantages in expertise or representation over 
the existing Recombinant DNA Advisory Committee, which has 
several years of experience in reviewing the risks and 
benefits of specific RDNA research proposals. The creation 
of a new body without additional statutory authority would 
therefore appear to be counterproductive. 
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