5 
ABC COMMENT: ABC has no objection to this 
recommendation. However, ABC would point out that USDA's 
authority under the Public Health Service Act has been 
explored in several congressional hearings and reports, in 
the meetings of the Federal Interagency Committee on 
Recombinant DNA Research, and in various letters written to 
and published by NIH. 
S n Vi mi ■!-+■ • 
C<f V; S' — 
Dr. Bruce F. Mackler, Esquire 
General Counsel 
Iver P. Cooper, Esquire 
Patent and Associate 
Regulatory Counsel 
ASSOCIATION OF BIOTECHNOLOGY 
COMPANIES 
Post Office Box 39221 
Washington, D.C. 20016 
[ 730 ] 
