3 
3. 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 by the interagency review 
panel* . . « 
ABC COMMENT: The deliberate release of genetically 
engineered organisms into the environment is likely to have 
one of three purposes: pollution abatement; protection of 
plants from pests; and beneficial leaching of minerals from 
their ores. 
Thus, the deliberate release of organisms into the 
environment is designed to promote environmental health by 
abating dangerous concentrations of toxic pollutants, 
increasing the efficiency of sewage treatments, providing an 
environmentally sounder alternative to the use of chemical 
pesticides, and facilitating continued exploitation of 
present mining sites. 
The well meaning recommendation by the subcommittee 
staff will ensure that these purposes are only belatedly 
realized. Releases are to be prohibited until after (1) the 
agencies individually develop recommendations to the task 
force of methods of evaluating the safety of releases, (2) 
the interagency task force agrees upon a "uniform set of 
guidelines", and (3) the specific release intended is 
reviewed in accordance with those guidelines. The 
moratorium is to apply to "any environmental release, 
regardless of size or intent." 
In addition, in view of the rather ambiguous status of 
the interagency task force, ABC is concerned with regard to 
procedural safeguards which will be applied to the 
deliberations of the interagency panel. 
4. The task force should consider the need for 
oversight of research scale releases.... 
ABC COMMENT: It is not clear how the task force will 
define "research scale releases." In addition, it is 
unclear whether the member agencies, and in particular, EPA, 
have the requisite authority to require premanufacturing 
notification in the case of "new chemical substances," there 
is an express exemption for "scientific experimentation and 
analysis" under Section 5(h)(3). In addition, a number or 
organisms are already listed by species on the TSCA 
Inventory (e.g., the insect pathogen B. thuringiensis ) and 
therefore are not "new chemical substances" by definition. 
[ 728 ] 
