From: Tim/Barbara Murray [barbtim@mindspring.com]
Sent: Monday, March 26, 2001 12:31 PM
To: fdadockets@oc.fda.gov

Dear FDA,
    I have strong opposition to the lack of safety inspections, testing,
 
and consumer protections that are being allowed to occur in the area
of Genetic Engineering (GE).  I thought you were supposed to be
the watchdog of health and safety for the consumer.  With these
new rules it certainly appears to me otherwise.  In what other
area would you ever permit such risks of unknown dangers to
be approved  without adequate testing and labeling.  It is unthinkable
that you would not set much stronger safe guards.  Here are some
of my specific suggestions (below).  Please take my comments to
your governing board. I speak for a number of my friends and
colleagues. Thank you for your attention to this matter.
 
                                    Sincerely yours,
 
                                   Rev.Barbara Murray
 
 1..  You must require mandatory pre-market comprehensive
  environmental review of proposed GE products and hybrids..
Unlike any other kind of previously known, conventional pollutants,
  where a given amount of pollutant causes a limited amount
  of damage, a small number of mutant genes could start a
  population explosion and reproduce forever, causing irreversible,
  unlimited and irreparable damage. Witness the runaway
spread of AIDS, because the threat was initally underestimated..
Can anyone in authority, responsibly and honestly, attest that they are
safe
with certainty?  Of course not. I would not want that onus on me.
Do you?
 
2,  You must require mandatory pre-market, long-term health
  testing. GE products could be toxic, cause allergic
  responses, have lower nutritional value, and compromise
  immune responses in consumers. You have a long and
illustrious history of thoroughly testing unknown commodites
before allowing them to be released on unknowing and
unwitting consumers.  Why should GE products be different?
 
3.  You must require mandatory labeling of GE products.
  Without mandatory labeling, neither consumers nor health
  professionals will know if an allergic or toxic reaction
  was the result of a genetically engineered food or not.  Consumers
  would be deprived of the critical knowledge needed to hold
  food producers accountable and liable should any of these
new products be later found to be hazardous to our health.
 
4.  Introduction of GE foods, etc., as a standard practice
is an extremely massive change affecting probably everyone
and likely to be irreversible, with permanent consequences
(whatever they are) to everyone, now & forever.  It's not
an issue to be just blithely rubber stamped with "approval".
 
5.  It's time for you to re-examine your conflicts of interest with some
 
of the GE industries, etc., which you should be regulating much more
  carefully.. Some of your past employees have been allowed to
  work for 'GE' biotech companies, then work for you writing the very
  regulatory rules on that company's product, then return to work for
the same company again.  At a minimum, this is a dubious business
practice, for you of all agencies who should operate above reproach.
I'm told that 92% of FDA advisory committee meetings had at least
one person attending who was allowed to make rulings in spite of
some type of  conflict of interest. While I admit that such dual
loyalties
are not in themselves necessarily harmful to the public interest, I must
 
say that I have been disappointed to hear of your proposed positions
in the GE controversy and of your standards of decision making.
 
This could be a positive, turning point for you as an agency if you
choose to seize this opportunity to self-police and revise these
questionable practices.  Please set the record straight, and please
do the right thing in these upcoming hearings and rulings on GE
that will determine our health and safety and that of our children
for generations to come.  We're counting on you to realize the
very real seriousness of this threat and take appropriate action..