Contrary to what Miller writes, EPA has not proposed to regulate whole plants, only certain pesticidal substances produced in plants. EPA developed this proposal over a five-year period and sought broad public input at several meetings of its Science Advisory Panel. We can quibble about the definition of what should fall within EPA's scope, but the agency has broad legal regulatory authority under the pesticide statute. BIO filed 19 pages of comment last February. We argued that EPA should narrow the focus of this oversight to only those pesticidal substances that have a toxic mode of action or are foreign to the food supply. This position was approved by all of the BIO member companies, large and small, that are developing new crops through biotechnology. This was not a position dictated by one or two companies, as Miller asserts.
EPA is responsible for the registration of a wide variety of ...
