Docket Management
Docket: 00D-1598 - Voluntary Labeling Indicating Whether Foods Have Been Developed Using Bioengineering
Comment Number: EC -180

Accepted - Volume 31

Comment Record
Commentor Mr. matthew smuts Date/Time 2001-02-25 16:03:48
Organization citizen
Category Individual

Comments for FDA General
Questions
1. General Comments Docket Management Docket: 00N-1396 - Premarket Notice Concerning Bioengineered Foods Comment Number: EC-97 Comment Record Commentor Mr. Matthew Smuts Date/Time 2001-02-25 15:59:01 Organization citizen Category Individual Comments for FDA General Questions 1. General Comments I am exteremely concerned about the introduction of bioengineered foods into the food supply. Primarily I don't understand what the need for such foods is. I believe it is mostly for the benefit of corporations. These may include agribusiness operations which are looking for ways to grow food in the extremely adverse conditions of overfertilized and overpesticized soils as well as ship food long distances without damage to the product (a noble cause but perhaps we should reexamine the need for food to be shippe such long distance in the first place). Another example might be a company which attempts to patent certain bioengineered foods to corner the market on that particular crop ( or at least make farmers reliant on them for production). I could give more details but I will gety to the point. I believe that the transfer of genes between organisms which would otherwise never occur is extremely risky in terms of future effects upon the future supply of food as well as on the greater environment. We simply know too little about how htese products will react with the larger environment once released. Furthermore once they are released we have no way of recalling them if we discover later that they have adverse effects. Perhaps this is beyond the jurisdiction of the FDA but I noticed in your proposed regulations that you include environmental impacts and EPA status as part of the consultation process. While I commend their inclusion I would be interested to see how much weight these factors carry in the final approval process. Because of the nature of the risks to the greater environment involved I think that a whole new set of standards must be developed. We have already seen in the case of the monarch butterfly how these genetic alterations can have unintended consequences on flora and fauna. What if we affect other organisms upon which plant srely for pollination, nutrient availability, etc. are adversely affected. This could pose a threat to the food supply as a whole. Again these may not be directly under the jurisdiction of the FDA but they do effect the food supply which the FDA proposes to regulate. I fear that there may be unintended consequences for humans as well. In this regard I STRONGLY ENCOURAGE THE MANDATORY LABELING OF BIOENGINEERED FOODS. This will at least give people the choice (until GMO's enter the rest of the food chain...unintentionally) I think an example from the agricultural field may have relevance here. Integrated Pest Management is a process whereby the least toxic/invasive methods are used FIRST to control pests. Thereafter, IF NECESSARY, increasingly more toxic/invasive methods are tried. Heavy use of pesticides is not used unless absolutely necessary. In the context of GMO's we must ask ourselves whether they are necessary and what problems we are trying to solve with them. If it's malnutrition why not find more effective ways to trandport food and nutritional supplements to where they're needed. If production, perhaps we must look at what is already produced, and wasted, and discern why we need more production (for the benefit of a few large megalopolies?). We should not resort to altering the genetic structure of organisms which nature has spent MILLIONS OF YEARS developing unless it is a last resort. I implore you to seriously question their use at all and at the very least make it so individuals such as myself can make informed decisions as to whether or not we wish to support such endeavors.




EC -180