From: rachel.fessenden@oberlin.edu Sent: Tuesday, February 06, 2001 11:26 AM To: fdadockets@oc.fda.gov Subject: Docket No. 00N-1396, and 00D-1598 Jane Henney Dockets Management Branch, Food and Drug Administration 5630 Fisher's Lane, Room 1061 Rockville, MD 20852 Dear Jane Henney, The new regulations and guidelines put forward by your agency on genetically engineered (GE) foods are a disappointment for American consumers. Despite overwhelming and consistent demand, your agency still fails to require comprehensive safety testing for GE foods. The notification policy ignores strong scientific evidence of numerous potential health and environmental risks of GE foods, and allows the current system of laissez-faire oversight to continue. GE foods were developed and released before the scientific community had much information about how they would affect people and the environment; today we know some of the potential dangers of them and are learning more all the time but the long term effects are essentially unkown. We do know that genetically engineered foods are a thriving business and companies will not do comprehensive saftey testing on their own. Unless your agency implements and enforces rigorous safety testing for GE foods, the public is at risk. As you know, genetically engineered foods can be toxic, cause allergic responses, have lower nutrition value, compromise immune responses in consumers, and cause irreparable damage to the environment. I was perhaps even more disappointed in your most recent stance on labeling. I am greatly opposed to your new "voluntary labeling" policy, which denies consumers a basic right to know. 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 will also be deprived of the critical knowledge they need to hold food producers liable should any of these foods prove hazardous. Labeling is particularly crucial to our democracy because of the lack of required safety testing and the fact that we still have no idea what the long term effects of genetically engineered foods will be. Contrary to the profit-driven motives of companies, citizens may wish to avoid GE foods until such time (if ever) that they are satisfied that GE foods are safe, rather than making use of them blindly and assuming they're safe until informed otherwise. And because there are ecological risks associated with genetically engineered crops, such as impacts on the soil ecosystem and non-target species like Monarch butterflies, consumers may want to avoid them. We need labeling to be able to make an educated decision. Without labeling we are deprived of our power to choose, to the extent possible, what risks we expose ourselves to and our democracy is therefore weakened. We must eat even when we don't know the GE status of our food, and so remain at the mercy of corporations producing potentially unsafe and ecologically damaging genetically produced foods. Your proposed rules ignore serious concerns, and appear to be a decision made to convenience industry at the expense of public health and the environment. I trust you will take my concerns into serious consideration. Sincerely, Rachel Fessenden OCMR Box 876 Oberlin, Ohio 44074