From: Praxis [praxis@allegan.net] Sent: Saturday, March 24, 2001 11:07 AM To: fdadockets@oc.fda.gov Subject: Docket 00N-1396 & Docket 00D-1598 FDA Comissioner 3-22-01 Docket No. OON-1396/ OOD-1598 FDA Dockets Management Branch (HFA-305) Food ans Drug Administration 5630 Fischer Lane, Room 1061 Rockville, MD 20852 Dear Sir, Praxis provides solutions for pest and environmental management with emphasis on integrated biological control strategies rather than chemistry. We sell over 45 site specific Biotool Kit™ products tailored by our own proprietary biotechnology, Integrated Biological Cybernetics™. The biological components, natural life forms from various phyla in our Biotool Kit™ products, are not genetically engineered organisms. Praxis Biotool Kits™ are in compliance with the federally mandated Food Quality Protection Act (FQPA), State of Michigan rules and regulations regarding Integrated Pest Management (IPM), and meet all criteria for Ecologically Based Pest Management (EBPM) as recommended by the National Academy of Science. We offer safer, effective, low cost alternatives for the chemically sensitive (MCS) community. Praxis, is a pioneer in safer environmental management and biological pest control. We have won several special recognition and environmental awards for affordable, and easy to use alternatives to pesticides: including the Michigan Environmental Health Association (MEHA), Keep Michigan Beautiful (KMB), and from the Presidents Council on Sustainable Development (PCSD). Please visit our website for more information. http://www.praxis-ibc,com All of us at Praxis are gravely concerned about the development and use of genetically engineered foods and think they must be labeled. Gene escape has already occurred despite industry assurances that would never happen. Despite genetic engineering industry "safety" propaganda Americans have already died and been hospitalized from taking the GMO food supplement L-Tryptophane. Praxis has reported unexpect environmental consequences and non-target impacts on beneficial insects (Lady Bugs) to Mike Mendelson at the US EPA. We think all GMO’s should be tested for safety by the FDA, not industry or the land grant universities that have been coopted by industry grants and now represent a clear conflict of interests. Please place a moratorium on new products and do not renew the old ones until this testing takes place. Conventional breeding is not the same thing as genetic engineering. Human genes in a salmon, flounder genes in a strawberry is not something that happens in nature. The risk of new emerging virus, viroid, and prion diseases for both our crops, domestic animals and ourselves may be increased by this technology that does little to benefit the public good or the farmer. This corporate hijacking of food ownership turning it into intellectual property turns the farmers who grow it into share croppers on their own land. Test and label all GMO Food. Sincerely, Samuel DeFazio.