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September 13, 2000


Letter to New England Biolabs and Response from its


Dear Mr Ellard:

It is because of the other good work that UCS does that I was long a
financial member of that organisation. Further, I was one of 10
scientists asked by Jane Rissler and Margaret Mellon in 1991 (when they
were with the National Wildlife Federation) to join a panel that
eventually resulted in the book "The Ecological Risks of Engineered
Crops". Like two other members of the panel, I asked to have my name
removed from the acknowledgements of that effort. The approach by
Rissler and Mellon was simply one-sided and often obscured facts that
got in the way of their apparent agenda. I also dropped out of UCS
when they joined it. A review of my concerns was upheld by an external
expert, Dr Ian Baldwin.

I respect Rissler and Mellon as among the more reasoned critics of the
debate, but Dr Comb's characterisation of their views as "rigorous
scientific analysis" does not accord with my personal experience. My
understanding of "rigorous scientific analysis" is that data both
favorable AND opposed to your perspective should be presented and
considered. Nor does the characterisation that Rissler and Mellon
advocate for "effective controls regarding the use of transgenic crops"
seem to fit. It would seem to be more correct that Rissler and Mellon
advocate for "no use of transgenic crops". Not in more than nine years
of interacting with Rissler and Mellon (and following their writings)
have I found them to support the use of any transgenic crop. And I
have asked them for such an example.

I continue to find NEB's apparently unqualified support of the UCS
inconsistent with the humanitarian and environmental aspirations of so
many of the researchers who buy NEB's products. If your association
with UCS is having any influence on UCS policy, I for one have not seen


Dr. Donald Comb, the President of New England Biolabs, has
written the following in response to criticism concerning the support
of UCS by NEB.

right,right,left,leftNew England Biolabs

Beverly, Massachusetts


right,right,left,leftNew England Biolabs has
recently received criticism from some members of the scientific
community for supporting the Union of Concerned Scientists (UCS). In
light of these concerns, I want to clarify the rationale behind our

UCS, a group of about 60 scientists from various disciplines, is based
in Cambridge, Massachusetts. They spend 90% of their effort on
humanitarian and environmental work unrelated to transgenic plants.
They have long been involved in explaining the risks of global warming
and the need for reducing carbon emissions. They took the lead in
explaining to concerned citizens and government agencies how important
shortcomings in our proposed missile defense projects would abrogate
the long-term Anti Ballistic Missile Treaty. They are working on the
establishment of favorable and cost-effective renewable energy, arms
control, advanced technology cars, regulation of nuclear power plants
and the dangers in the misuse of antibiotics.

About 10% of UCS's effort is directed towards advocating for effective
controls regarding the use of transgenic crops. While we all agree that
any new advances must be ecologically restrained and proven safe for
human consumption, their apparent irrevocable attitude towards
genetically modified crops represents neither mainstream molecular
biologists nor NEB. However, we do feel that their tenacity and
dedication to rigorous scientific analysis to help change humanity's
stewardship of the earth deserves recognition. On the issue of
transgenic crops, we believe our relationship with UCS enables NEB to
play a part in advocating sensible discussion and eventual consumer
acceptance of these novel agricultural advances.


Donald G. Comb, Ph.D.

President, New England Biolabs


James V. Ellard

Marketing Communications, Director

New England Biolabs, Inc

Tel: (978) 927-5054 ext.213

FAX: (978) 921-1350

e-mail: ellard@neb.com

NEB WWW Server: http://www.neb.com


*PLEASE NOTE NEW EMAIL ADDRESS: rick.roush@adelaide.edu.au


Richard T. Roush

Associate Professor and Director Phone +61 8 8303-6590

Centre for Weed Management Systems FAX +61 8 8303-7125

Waite Institute ;-_|

University of Adelaide /

Glen Osmond 5064 (

South Australia





"Weeds - Australia's most underestimated environmental threat"