From: Leland Walmsley [lelandnwa@yahoo.com]
Sent: Friday, December 17, 2004 4:49 PM
To: Dockets, FDA
Subject: RE: Docket No. 2004D-0369

  Dear Commissioner Crawford,

  I am writing to express my disappointment at the FDA's draft 
"Guidance
for Industry: Recommendations for the Early Food Safety
  Evaluation of New Non-Pesticidal Proteins Produced by New Plant
Varieties Intended for Food Use."

  I am deeply concerned that these new guidelines are a step backward 
in
strengthening public confidence in the regulation of
  genetically engineered foods.
  These new guidelines for genetically engineered crops still in 
testing
would allow them to contaminate the nation's food supply with
  genetic material.

  Companies are encouraged to voluntarily seek safety review of
genetically engineered traits that could escape field test plots and
  enter the food supply. Such review could have the effect of exempting
such contaminants from being declared food adulterants
  under existing Federal food safety laws. The developers of biotech
crops still in the testing phase now have no incentive to contain
  genetic pollution from whatever compounds they are engineering into
crop plants.

  These guidelines also allow companies to voluntarily perform an
abridged safety assessment of genetic material from biotech
  crops. This confidential, limited review would grant biotech crop
manufacturers the legal cover to allow these engineered test crops
  to enter the American food supply prior to full government pre-market
oversight and safety review. The proposed review involves
  no safety tests in animals, a standard method to test for toxicity. 
It
also excludes testing for unintended effects caused by genetic
  engineering, and sets no limits for the amount of contamination of
food allowed.

  I urge you to reject this misconceived policy.  The FDA should be
devising rules and procedures to STOP contamination of the food
  supply with experimental transgenic proteins, not give rubber stamp
approval to such contamination when it occurs.

  Finally, I urge the FDA to replace its current non-rigorous 
"voluntary
consultation" process with a mandatory, science-based review
  process designed to ensure food safety.





Sincerely, 
NWA, Inc. 
Leland Walmsley - CFO 
Santa Barbara: 805-684-1718     Cell: 805-895-9520


--------------------------------------------------------------------------------
Do you Yahoo!?
Yahoo! Mail - Easier than ever with enhanced search. Learn more.