In its 1986 Policy Statement on microbial products subject to the Federal Insecticide, Fungicide and Rodenticide Act and TSCA (51 FR 23313, June 26, 1986), EPA clarified that living organisms, including microorganisms, were considered chemical substances under TSCA. The 1986 Policy Statement defined new microorganisms for purposes of Section 5 of TSCA as those formed by deliberate combinations o