Letter from APS

Comments on Receipt of a Notification to 
Conduct Small-Scale Field Testing of a Genetically Engineered Microbial Pesticide

Following is a letter sent to the Environmental Protection Agency from President C. Lee Campbell on behalf of APS:

Re: Environmental Protection Agency OPP-50837; FRL-5761-4.

I am writing on behalf of the American Phytopathological Society (APS) with regard to the item on a small-scale field test of a microbially engineered pesticide as listed under EPA docket control number OPP-50837.

APS is a professional organization of approximately 5,000 scientists and plant health specialists with a mission to promote the discovery and diffusion of scientific information on plant diseases and their control in the United States and worldwide. This purpose includes the dissemination of scientific information needed to make and implement sound national and international policies on plant pathogens and disease control.

The American Phytopathological Society is highly supportive of biocontrol efforts to reduce dependence of biocontrol efforts to reduce dependence on chemically synthesized fungicides, most of which have a broad spectrum of activity. Thus, the APS is supportive of such small-scale field testing of species of fluorescent pseudomonads. As we understand it, the work is simply to test an engineered isolate that has anti-fungal genes transferred from one pseudomonad to another, both of which inhabit the rhizosphere. Since the bacteria will be applied to seed, there will be minimal exposure of people and non-target organisms to these bacteria. We are unaware of any negative environmental impact of using Rifampicin-resistant marker genes to facilitate monitoring, since such antibiotic resistance is to be found in the normal soil microflora. Thus, our society is highly supportive of this and similar tests that improve our understanding  of the ecology of biocontrol agents with plant pathogens. Such systems may result in an increasingly safe food and fiber supply.

Sincerely,
C. Lee Campbell
The American Phytopathological Society

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The American Phytopathological Society