In 1982, Steven Lindow from the University of California, Berkeley, was the first to ask permission to deliberately release genetically engineered microbes – the ice-minus bacterium – into the environment.

The ice-minus bacterium, an rDNA modified version of a bacterium found on many plants, was developed by Dr. Steven Lindow of the University of California at Berkeley. The naturally occurring strain increases plant sensitivity to frost, causing frost to form in plant tissue at relatively mild temperatures.

In 1984, Federal District Judge John J. Sirica ordered a delay in the first proposed outdoor experiment using genetically engineered organisms. He ordered the National Institutes of Health not to authorize any more experiments that would release such organisms into the environment until a full hearing.