From: Bryan Burns [burnsb@astro.temple.edu]
Sent: Tuesday, February 13, 2001 1:48 PM
To: fdadockets@oc.fda.gov
Subject: re: dockets . 00N-1396 and 00D-1598

Dear Commissioner Henney,

I am taking the opportunity to write you during the open comments period 
to express my dismay that the proposed regulations regarding Genetically 
Modified Foods do not require that such products be clearly labelled.  I 
have concerns about how this can affect people on strict diets, for 
health or religious reasons, as well as simply the public's assumed 
right-to-know about what they choose to put into their bodies. None of  
the above parties are well served by a continued lack of pertinent 
information.

Naturally, large agribusiness and grocery concerns are reticent to see 
labelling that they fear will cut into their profits or marketability. 
Likely those same groups were also resistant to nutritional labelling on 
foods as well. Yet the overall impact of nutritional information has 
been positive without crippling these industries. People continue to buy 
potato chips and Big Macs in large numbers despite the prominently 
placed information about fat grams, sodium, sugar, and calories. But for 
those who have a need to be aware of such items, this labelling has 
proven invaluable by giving them better knowledge to make informed 
decisions that best suit their own health and lifestyle requirements. 
Surely this would be the case with GM foods as well. Individuals who 
choose price and convenience will continue to dominate the marketplace 
for years to come. One need only look at the growing but still tiny 
organic produce market for confirmation of that.

I believe that the first priority of a government organization such as 
FDA is to inform and protect citizens. That reason alone should be 
sufficient to warrant mandatory labelling. However, I believe the case 
can also be strongly made that those agricultural products not 
containing GM foods are being put at a distinct disadvantage on the 
world market as other developed nations strengthen their labelling 
requirements. Our share will continue to decline in first-world 
countries without such labelling.

Lastly, I think that FDA should take a proactive position with regard to 
the type and content of labelling. Many industry professionals believe 
that consumer demand will eventually force companies  to self-label, as 
was the case with 'dolphin-free' tuna. As one would expect, industry 
would likely want something incredibly benign while consumer and 
environmental advocates would prefer something akin to the 
skull-and-crossbones. FDA has an opportunity and an obligation to set 
the standard for a label that provides full disclosure without being 
threatening.

Thank you for your time and consideration.

Best regards,

Bryan P. Burns
326 West Durham Street
Philadelphia, PA  19119