From: Michael Reid [msreid@ucdavis.edu]
Sent: Thursday, February 01, 2001 7:34 PM
To: fdadockets@oc.fda.gov
Cc: action201@sustainableagriculture.net
Subject: Docket No. 00N-1396 & Docket No. 00D-1598 - Genetically
Engineered Foods

To whom it may concern

The National Campaign for Sustainable Agriculture is spearheading a campaign
to protest the new rules on genetically engineered foods.  In my reading of
their arguments, it seems that they are ignoring the substantial testing
that is required of such foods, and are working not for, but against
sustainable agriculture.  The value of the precise and directed engineering
of crops and animals by the new biology to consumers, producers and the
environment have been documented in studies by the National Academy of
Sciences and in a report to the House Science Committee.

They argue that FDA must require mandatory pre-market safety testing,
suggesting that GE foods could be toxic, could cause allergic responses,
could have lower nutritional value, and could compromise immune responses in
consumers.  They ignore the fact that many foods presently on the market
(peanuts for example) are markedly toxic and allergenic to some consumers.
They also fail to note the marked reduction in fumonisin levels in products
synthesized from BT corn.

They argue, without any evidence, that GE crops and foods could cause
irreparable damage to the environment.  This technology is in its infancy,
but already the use of GE crops has reduced pesticide application over
millions of acres in North America.

They suggest that the FDA must require mandatory labeling of GE foods,
suggesting that without mandatory labeling, neither consumers nor health
professionals will know if an allergic or toxic reaction was the result of a
genetically engineered food. They also allege that consumers will also be
deprived of the critical knowledge they need to hold food producers liable
should any of these novel foods prove hazardous.  Neither of these claims is
credible, since reactions to such foods would immediately followed (as for
any other food product) by rapid identification of the cause of toxicity.
The Odwalla juice issue is a good example of how quickly the cause of a
food-borne illness can be identified.

They finally allege that the notification policy is an insult to consumers,
and irresponsibly ignores strong scientific evidence of numerous potential
health and environmental risks of GE foods.   But neither they, not any of
the other critics of GE foods has produced any scientifically credible
evidence of any such risks.

The FDA is to be commended for employing measured strategies to ensure the
safety of the food supply without the draconian regulations and labelling
requirements sought by a fringe minority who seem less interested in the
safety of the food supply than in making political capital.

Sincerely,


Michael Reid
Professor and Program Leader
Agricultural Productivity
Division of Agricultural & Natural Resources
University of California