From: Center for Food Safety [action@foodsafetynow.org] Sent: Wednesday, April 04, 2001 12:58 AM To: FDA Commissioner Cc: president@whitehouse.gov; vice.president@whitehouse.gov; fdadockets@oc.fda.gov; fdadockets@oc.fda.gov Subject: Oppose the New FDA Regulations on GE Foods! To: Dockets Management Branch (HFA-305) Food and Drug Administration 5630 Fishers Lane, Rm 1061 Rockville MD 20852 Comments pursuant to: Docket #00N-1396 Premarket Notice Concerning Bioengineered Foods Docket #00D-1598 Voluntary Labeling Guidance Submitted by: David J. Engel Executive Director, Midwest Organic Services Association (MOSA) Program Director, WI Chapter #1 Organic Crop Improvement Association (WI OCIA#1) 53063 McManus Rd Soldiers Grove WI 54655 email: dengel@mwt.net Comments: I have been the Executive Director of MOSA since its inception in March, 1999, and the Program Director of WI OCIA#1 since its inception in 1988. My wife--a holistic veterinarian--and I have also milked 40-50 Jersey cows during this time period (25-30 cows prior to 1988), while also cropping approximately 200 tillable acres with 50+acres of pasture. We have always farmed organically since 1977 when we first bought a farm. We are on this present farm here in rural Soldiers Grove WI, since 1981, and we got certified here in July, 1988. I have served in various positions in the organic industry, in addition to my employment above, including being on the OCIA International Certification Committee, 1990-94; President of OCIA Intl, 1994-95; Chair of the Organic Trade Association's Quality Assurance Council's Certification Committee, 1999-01; Member of the OTA's Organic Certifier's Council Steering Committee, 2000-01. My personal comments below are made with the above background and understanding, 1 • The FDA must REQUIRE mandatory premarket safety testing of all genetically engineered food , as to date this has not been done. Genetically engineered foods have caused and could cause allergic reactions; have lowered and could lower the nutritional value of both feedstuffs and food; and could weaken immune responses in consumers, as well as expose consumers to antibiotic resistant virus strains. 2 • The FDA must REQUIRE mandatory pre-market environmental review, as it is surely not our wisdom which is allowing us to see, experience and then ignore such ‘canary signs' as dead Monarch butterflies (two different studies in NY and IA), dead lacewings (Scotland), dead rodents (GE potato experiment in England), as well as the geese in Illinois that will not eat GE beans, but will eat conventional beans right next to the GE beans. It is one thing to have atrazine in a well and to have to clean it up, primarily through further non-use of atrazine. It is quite another to have GE bacteria, for example, released into the environment and be replicated ad infinitum without sufficient testing or understanding the very real, potential dangers of or damage caused by such bacteria. Life will out, and we need to allow life to express itself as Mother Nature has guided us. 3 • The FDA must REQUIRE mandatory labeling of GE foods, in order to simply provide concerned consumers with the choice to choose if they want to purchase food made with GE products. Without labeling, no one will be able to exercise this right of the consumer to purchase what they want. Fully 70-80% of processed (and some unprocessed) foods in America right now have some level of GE background to them. Without labeling, we cannot tell what foods are not GE. 4 • The pre-market”Notification” policy is outrageous, as it basically reaffirms the FDA's 1992 Policy on GE foods, and this in the face of almost 10 years of increasing evidence of the dangers and damages that GE foods and their production have on the land, people and animals. The 1992 Policy blithely opined that ‘GE foods are not substantially different' than normal foods, therefore no testing or regulatory oversight needs to be done. I disagreed then (rBgH came in shortly after this ruling, though the US is the only major industrial country in the world to date that has allowed the use of rBgH) and I disagree now, and the more so, given the above examples of what has happened, and the daily new danger/damage signs that are extant. In sum, it very much appears that the exigencies of corporations' greed to market product without the hindrance of testing or labeling is winning the day over peoples' right to know what food they are eating or what possible negative effects this food is having on both us and our world. For the sake of God and people and animals and the environment, please put in place common sense protocol that will ensure that the greater good is looked after so that all GE products must be tested and labeled, and so that environmental assessment is done to determine long-term effects of introducing GE products into our environment. Surveys reveal the overwhelming desire of people to have this testing and labeling. You are responsible to the greater good of the people first, not corporations. I am sharing the song below in closing, and pray that the public good be done. Thank you for your time and consideration. Tho' It Was Small, It Caught My Eye.... Tho it was small it caught my eye, it made me say, “Now I wonder why.... Is this happening, I really wonder, what it is that has been done here?” Just a butterfly dead on its knees, just one tho a Monarch, if you please He'd eaten the pollen of the Bt corn, and now he looked so forlorn But the experts say, “Well, we mustn't worry, one or two butterflies, well, we mustn't hurry And react as tho there's a problem now, after all he could'a hit a windshield somehow Ah, those experts can say so many things, ‘cuz it is easy to talk and the money talk brings Is nice and desirable, at least it seems so, and anyway every butterfly has to go And for fifty years things have come and gone, and many are wondering what's going on There's still DDT and the harm it's done, and in many ways Mother Nature is still on the run Well, if a word to the wise is sufficient, we'd better get smart and start to take a hint At least we'd better start to listen, and watch out where it is we're pissin' One butterfly today, oh so what, I too would not worry or hurry, but.... If that little bit of GMO can make an insect dead, even if it's in a lab, even if it's injected Then is it worth the risk to us, why would we not hesitate and wanna make a fuss I think we need to be concerned, ‘cuz you can't cross a bridge that has been burned I think we need to have precaution....and maybe even a little party like they had in Boston... Yes, everything here is intertwined, from the people to the land to the sky we find So many many interconnections, it's a wonder and what's more upon closer inspection All God's children have a place in the choir, some sing low and some sing higher And maybe we should try to take better care of...these little butterflies and ‘preciate their love Tho it was small it caught my eye, made me say, “Now, I wonder why......” David J. Engel Soldiers Grove WI 608-734-3273 David Engel 53063 McManus Rd Soldiers Grove, WI, 54655 CC: The President Vice President Dick Cheney FDA Dockets Management [Docket No. 00N-1396] Senator Herb Kohl Senator Russell D. Feingold Representative Tammy Baldwin Representative Ron KindFDA Dockets Management [Docket No. 00D-1598] To the recipient -- this fax/email message has come to you via the Center for Food Safety web site -- a public tool for providing input on food safety issues. The user/site visitor had complete control over editing the content of this message. Thus, the opinions expressed in this message are not necessarily those of CFS or its parent organization, ICTA. Please contact CFS at (202)547-9359 or email office@centerforfoodsafety.org with any questions. Thank you. ___________________________________________________________________________ This letter was composed at www.foodsafetynow.org, a web site maintained by: The Center for Food Safety, 666 Pennsylvania Ave, SE, Suite 302 Washington, DC 20003 PH: (202)547-9359 Fax: (202)547-9429 Email: office@centerforfoodsafety.org web: www.centerforfoodsafety.org