May 30, 2006 - ASM Comments on Department of Commerce Deemed Export Advisory Committee

US Department of Commerce
Bureau of Industry and Security
Regulatory Policy Division
14th and Pennsylvania Avenue, NW, Room 2705
Washington, DC 20230

Attention Docket No. 060505121-6121-01
The American Society for Microbiology (ASM) is pleased to see the Department of Commerce Bureau of Industry and Security (BIS) announcement in the May 22, 2006, Federal Register to create a Deemed Export Advisory Committee (DEAC) that will review and provide recommendations to the Department of Commerce on deemed export policy. The ASM is the largest single life science society with over 42,000 members who work in academic, industrial, medical and government institutions and laboratories. In a May 19, 2005, letter to BIS, the ASM commented on the adverse consequences to the conduct of fundamental research that would result from the adoption of the Department of Commerce Office of Inspector General (OIG) recommendations to revise the Export Administration Regulations (EAR). The ASM commends the decision by BIS not to make changes at this time in the EAR and to establish a forum to review deemed export control policy and to determine whether to recommend changes to that policy that will not impede the ability of US industry and academic research to continue at the leading edge of technological innovation. The ASM appreciates the opportunity to provide comments and stands ready to work with the Department of Commerce BIS to ensure the protection of national security without encumbering scientific and health related research and testing.

Sincerely,

Stanley Maloy, Ph.D., President, ASM

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