From: Sarah Divelbiss [sdivelbiss@sssnet.com] Sent: Thursday, March 29, 2001 12:38 AM To: fdadockets@oc.fda.gov Subject: dockets 00N-1396 and 00D-1598 Dear FDA Commissioner Henney, I WANT LABELING!!!!!!!!!!! As a consumer, a citizen and a taxpayer, I want my views about the above-named dockets to be known. The proposed Food and Drug Administration (FDA) regulations fail to require labels or safety tests on genetically engineered (GE) food. The new rules continue to deny Americans the right to know what is in our food, while protecting the economic interests of biotech corporations. Labeling GE foods would protect the public from potential hazardous health effects such as food allergies and toxicity that can only be traced if GE foods can be identified. By refusing to require both labeling and mandatory pre-market safety testing of foods, the FDA puts consumer's health at risk, ignores possible environmental hazards, and fails to satisfy the overwhelming desire of American consumers to exercise freedom of choice in the marketplace. I want genetically engineered (GE) food, or products that contain them, to be labeled as such. I want to know which ingredients are GE in the products that contain GE ingredients. I want what is best for my family. I am not convinced that GE food is best for my family. As a result, I would like to avoid GE food when possible. The best way for me to know that a food is GE, is for that food to be labeled as such. With out required labeling of GE foods, I am placed at a disadvantage when in the grocery store. If I know that a particular company uses GE foods (I have a partial list from a consumer organization), but the products are not labeled, I cannot differentiate between GE products and non-GE products. Hence, I will choose to avoid ALL products from companies who are known to use GE foods. And who is to say that the list I have in my posession is factual. Companies that use GE foods should be required to label their foods as such. To put the burden of proof on companies that do not use GE products is not acceptable. I have noticed that organic foods are labeled "organic". Some even have a logo saying "no GMO's". Is this required by law? Regardless of the answer, I suspect they are labeled so that consumers can spot them more easily, and since organic is generally a desirable label, so consumers can buy them more easily. Now, if I believe what I read on the websites of companies who benefit from GE, there are no known problems with consuming GE foods. According to the FDA website, while many people who support labeling of GE foods have suggested possible problems, no problems have been proven to exist. Two questions immediately come to my mind: 1) if GE foods are so great, benign, no related health problems, shouldn't the companies that are selling them be shouting from the mountaintops "eat this food!!! it is GE!!! it is great for you!!!"? Companies should be clamoring for the right to place labeling on their product, proudly displaying "contains GE ingredients", or "this food was grown using GE technology". Why aren't they? 2) Have the possible problems that people have suggested or anticipated been disproven? Shouldn't we wait until adequate testing is done to determine if GE foods are safe? Why should the consumer have the burden of proof? We make no profit on buying or not buying the product. It is obvious how we benefit if our suggested problems are proven (labeling, get to know what we are buying to eat). It is obvious how a company benefits by not having to label (save the almighty dollar, not spend money on testing) If a company wants to sell GE foods, prove to me that it is safe. Why does Monsanto Corporation have their meeting catered with organic foods when they are leading the charge of GE, pesticides, etc.? Speaking of Monsanto, I read with interest their FAQ section. In answer to the question about safey of GE foods, the answer was (and I paraphrase) ..the FDA says it is okay to use GE foods. The FDA says GE foods are safe to consume. QUESTION: if the foods are not tested by the FDA, where does the FDA get its info that the GE foods are safe??????? The logic behind that does not exist. It is shameful that such a huge company with so much money is allowed to manipulate the food I eat and not have to answer to it, explain it or least of all, simply label it as such ---not natural, genetically modified. One more point which I would like to touch on. Organic foods are the only thing safe to eat if one is attempting to avoid GE foods. I have heard that the Federal definition of organic will be expanded to allow GE foods to be labeled organic. I feel that this is a slap in the face to the people who are striving to be kind to the earth in their actions. It is misleading to consumers. It is wrong. I hope that this will never happen. Please do not allow these regulations to stand as is. Labeling of products containing GE materials should be required by law, immediately. Companies should also be required to publish a list of all foods/plants/seeds/other products(clothing, cosmetics etc.) which contain GE foods. This information should be made available to the public in newspapers, on the web, etc. Failure to comply should result in major fines. It is simply not okay for labeling to be optional. It is not okay for taxpayers, the citizens, the country to bear the brunt of more experimentation because the experimenters have a huge pile of money that they share with Washington. It is not enough to require that firms simply notify you of their intent to market a food produced with genetic engineering; this is no substitute for thorough pre-market safety testing. The proposed "voluntary labeling" guidelines will do nothing to inform consumers of the presence of genetically engineered ingredients in their food, because biotech companies and food manufacturers have vehemently opposed labeling in the past and will not voluntarily label their foods in the future. Therefore, I urge you to keep all genetically engineered ingredients and crops off the market unless or until: 1) Independent safety testing demonstrates they have no harmful effects on human health or the environment; 2) They are labeled to ensure consumers right-to-know; and 3) The biotechnology corporations that produce them are held responsible for any harms they may cause. I WANT LABELING!!!!!! Sincerely, Sarah Divelbiss