From: Larry Zimmerman [larryz@mac.com]
Sent: Saturday, March 24, 2001 3:33 PM
To: fdadockets@oc.fda.gov
Subject: Docket 00N-1396 & Docket 00D-1598

I understand that the Food and Drug Administration is now accepting public
comment on its proposed new rules on genetically engineered (GE) foods.

I also understand that the proposed rules:

* Do not require mandatory pre-market safety testing
* Do not require pre-market environmental review
* Do not require mandatory labeling of GE foods
* Restrict voluntary labeling of non-GE foods
* Require a mere letter of notification prior to the marketing of a GE food
* Fail to ensure public access to adequate information for independent review
* Are a total give away to the biotech industry

I would like to think that a federal organization such as the FDA was 
beholden to the American people, and was formed to perform some 
function useful to the people. How naïve. How very wrong. Instead the 
FDA is totally controlled by the same industries it is supposed to be 
regulating. I wrote to express my irritation at your proposed rules 
for organic food. Thankfully, you realized you could not hoodwink 
people on that issue. But you have obviously learned nothing. It 
makes me very angry to see you doing your best to support an industry 
which has no concern whatsoever for the safety or well being of the 
people of this planet, or of the planet itself.

* The FDA must require mandatory pre-market comprehensive 
environmental review. Unlike conventional pollutants, where a given 
amount of pollutant causes a limited amount of damage, a small number 
of mutant genes could have a population explosion and reproduce 
forever, causing unlimited and irreparable damage. It has also been 
shown that these novel gene sequences can cross species barriers and 
cause unknowable changes to the environment. We can create Superfunds 
to clean up toxic wastes. Nothing whatsoever can be done to reverse 
the damage that GE will inevitably produce. It would only take one 
big GE mistake to destroy life on this planet. How can you be willing 
to take such risks?

* The FDA 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. 
People have already died, and thousands have been injured by GE 
products. Not disclosing such problems does not make them go away. 
You say there is no difference between GE foods and natural foods. 
The shills from the industry say that the safety of GE is well 
researched. There is no scientific basis for such ridiculous claims. 
It only goes to show that you have no understanding, or more likely 
choose not to understand the real implications of GE. Genetic 
engineering is not a science. It is a crap shoot. Something good 
could come out of it. It is far more likely that the results will be 
incredibly dangerous. The expression "a little knowledge is a 
dangerous thing"  applies to GE more than you care to believe.

* The FDA 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. Consumers would be deprived of the critical 
knowledge needed to hold food producers liable should any of these 
novel products be hazardous. You seem to think that by not talking 
about GE, no one will notice that it exists. You are unwilling to 
even let consumers make the choice. I resent being made a guinea pig 
to determine whether every new GE food that comes along is safe or 
not. It is already extremely difficult to find food that is not 
tainted by GE. You do not allow people to know about the dangers, and 
then say nobody cares. We very much care. And if you told people 
about GE you can be sure that the outcry would get you fired or in 
jail.

* The FDA must end its incestuous relationship with the industries it 
purports to be regulating. People have been allowed to work for a 
biotech company, then go work for the FDA for the sole purpose of 
writing the regulatory rules on that company's product, then go back 
to working for the company.  Ninety-two percent of FDA advisory 
committee meetings had at least one conflict of interest. Maybe you 
think that such practices are common, but they are wrong, immoral, 
and destroy what very little faith people have in government being 
able to act responsibly.

Please reconsider your proposed rules. They are bad rules. They are 
ill-considered. They are criminal.