To the Editor: In their review of the potential threat to human health by the commercial use of Burkholderia cepacia, Holmes et al. (1) focus on the biopesticidal uses of this bacterium in agriculture. By virtue of its ability to antagonize a number of soilborne plant pathogens, B. cepacia is an attractive natural alternative to currently used chemical pesticides, such as captan, mancozeb, and metalaxyl. The replacement of these highly toxic agents, which are among the mainstays of crop protection chemicals, by safer products is a laudable goal. However, despite being nonpathogenic to healthy humans (and thus classified as a Biosafety Level 1 species), B. cepacia can cause life-threatening pulmonary infection in persons with cystic fibrosis. Holmes et al. call for a moratorium on the use of B. cepacia in agriculture until more is known about risks from such use.

Perhaps of greater concern than agricultural use is B. cepacia's use as a bioremedial agent. Holmes et al. only briefly refer to the capacity of this species to degrade chlorinated aromatic substrates such as those found in certain pesticides and herbicides. By virtue of its extraordinary metabolic versatility, B. cepacia can use such compounds as nutrient carbon energy sources. In addition, some strains produce enzymes capable of degrading nonnutritive substrates, such as trichloroethylene (TCE), a major ground water contaminant used in the dry cleaning industry and in degreasing solvents.

The degree to which B. cepacia is being used in bioremediation products is unknown; however, the species has been used extensively to degrade ground water TCE contamination in at least one large U.S. city. A number of environment-friendly bioremediation products containing only naturally occurring, nonpathogenic bacteria are being marketed for use in drain opening and grease eradication systems. Because their formulations are proprietary, it is not known if these products contain B. cepacia; however, franchises that distribute such totally natural, noncorrosive, nontoxic products specifically target fast-food restaurants, photo processing facilities, and hospital radiology departments.

In the United States, the biopesticidal use of microorganisms such as B. cepacia is regulated by the Environmental Protection Agency (EPA) under the Federal Insecticide, Fungicide, and Rodenticide Act; however, the use of naturally occurring, nonpathogenic bacteria as bioremedial agents is essentially unregulated. Only new microorganisms (i.e., intergeneric or formed by combining genetic material from organisms in different genera) are regulated by EPA under the Toxic Substances Control Act (TSCA) (2). Ironically, TSCA regulations provide a strong disincentive to the development of safer microbiologic alternatives for use in bioremediation. For example, although the genetic elements responsible for TCE degradation by B. cepacia have been cloned, their recombination into another nonpathogenic bacterial host (e.g., Escherichia coli) would constitute a new microorganism, the licensure of which would be considered prohibitively time-consuming and expensive by many companies.

In Canada, biopesticidal uses of microorganisms are regulated by the Pest Management Regulatory Agency of Health Canada, under the Pest Control Products Act (PCPA); bioremedial uses are regulated by Environment Canada under the Canadian Environmental Protection Act (CEPA) (3). Both naturally occurring and genetically engineered microorganisms are strictly controlled under these acts. However, accurate species identification is the cornerstone of all notification of products under the Canadian regulations. This presents a further dilemma. At least five genomovars (discrete species) constitute what has recently been designated the "B. cepacia complex" (4). Insofar as the taxonomy of this group is poorly defined, there are no conventional taxonomic designations to distinguish pathogenic from nonpathogenic species. At present, it appears that all five B. cepacia genomovars are capable of causing infections in vulnerable persons (4).

Because the epidemiology of B. cepacia complex infection in humans is incompletely understood, the threat posed by the inclusion of this species in biopesticides and bioremedial products is difficult to quantify. However, we agree with Holmes et al. that such use should be approached with considerable caution. In a broader context, the commercial use of B. cepacia illustrates our incomplete understanding of nonpathogenic bacteria and their potential to cause human disease. Regulations governing the use of microorganisms in industry must constantly adapt to keep pace with the emergence of infections due to nonpathogens and limit risk to human health.

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