From: John Hagen-Brenner [satweavers@earthlink.net]
Sent: Thursday, March 29, 2001 12:59 AM
To: fdadockets@oc.fda.gov

Please consider my comments before making your decision  about requiring
labeling of genetically altered food.  I believe that this issue is being
swept under the rug and that the ramifacations of this new technology are
already very serious.  Please do not allow the producers of genetically
altered seed or food to market their product without warning labels and
identifying the presence of genetically altered food.  Here are my concerns:

The controversy over GMOs seems to rage increasingly over time. As more
facts are uncovered, even government scientists are in disagreement over the
issue. This is exacerbated by the fact that scientific outcome can be swayed
by the money powering the study. Depending on who's paying, either genetic
engineering is the tool to save the world or it is an inexact science with
unpredictable results. Either way, already the havoc this technology has
wrecked is mind-boggling, like a badly written science fiction story no one
would believe. Opposition to genetically engineered food in the US is
growing daily, and is not relegated, as you indicate, to a few fringe
groups. I have noticed that within the past six months, even the most
conventionally focused agriculture publications - the glossy ones with all
the big agribusiness ads - are publishing articles that question the wisdom
of GMOs, specifically questioning claims for increased yields and the
impossibility of containing pollen drift.

A few years ago it would have seemed impossible that pollen drift would pose
such threat. In fact, it has become such a problem that Aventis, the company
that developed the GMO StarLink corn, has posted a website to assist farmers
in marketing their non-GMO corn crops that were unintentionally invaded by
pollen from GMO fields. The website opens with an apology from Aventis for
any problems caused by the StarLink =
corn. Aventis' actions can be contrasted to Monsanto that has sued hundreds
of farmers, charging them with stealing GMO seed. (Saving seed from one year
to the next is against the Monsanto seed purchase contract). Presence of
GMOs in non-GMO fields can be explained by a number of methods, including
pollen drift. Damages levied in these legal cases are typically the proceeds
from one year's corn crop. Few farmers I know could sustain such cost. Just
the cost of legal defense in such an attack would put most of us under.

The marketing barrage from all manner of companies
selling chemicals, seeds, implements, etc. claims they can improve our
crop yields. If low yields were our problem the year 2000 season would not
be considered such a financial disaster. From my point of view, low yield
is not the problem. Low market price - caused by overproduction is. Further,
if crop yields had anything to do with solving world hunger, no one would be
hungry. People are not starving because of low food production. They are
hungry because they cannot afford food. Biotechnology is not the solution,
and in many cases exacerbates the problem.

It is said that the regulatory agencies (EPA, USDA, FDA) can
protect consumers against unintended health impacts from GMOs, which include
allergens, antibiotic resistance, decreased nutrients, and toxins. But, we
all know there are products mistakenly approved that are later recalled. In
the case of genetically engineered food, the results would likely be
irreversible - either on the environment or on people. I believe your
statement that there has been no harm from the consumption of GMOs is
fallacious and irresponsible. There have been documented incidents of GMO
products causing significant health problems, including long term disability
and death. The consequence of not labeling GMO foods is that problems, such
as allergic or toxic reactions are virtually impossible to trace to the
hidden ingredients in the GMO food. How could one know, for instance, that
Brazil nut genes are contained within soy beans unless it is labeled?

At present the only way a consumer in the United States can be assured that
an apple is purely an apple is to buy certified organically grown food.
Every country in the European Union requires the labeling of GMO foods. More
than a dozen other countries have similar regulation, such as Japan,
Australia, New Zealand, and Brazil. I believe we have the right to know what
is in our food. Labeling GMOs is the least that should be done to protect
consumers.

Thank you,

John Hagen-Brenner
6956 Deveron Ridge Road
West Hills, CA  91301
USA