From: Mary Needham [mneedham@iamerica.net]
Sent: Thursday, February 08, 2001 4:09 PM
To: fdadockets@oc.fda.gov
Subject: Re: dockets OON-1396 and OOD 1598 - GEF

 FDA Commissioner Dockets Management Branch
 (HFA 305) Food and Drug Administration 5630 Fisher's Lane,
 Room. 1061 Rockville MD 20852

Dear FDA Commissioner:

I am one of thousands of ordinary consumers very upset about the
proposed relaxation of labeling requirements for genetically engineered
foods.
One of the freedoms of choice should be that we are entitiled to know
what we are eating.  I would choose NOT to consume GE foods.  Many large
companies obviously are pressuring you to make it possible for them to
disguise GE foods in what the rest of us buy unknowingly.

 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.

 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) They are labeled to ensure consumers¹ right-to-know;
 2) The biotechnology corporations that produce them are held
responsible for any harm they may cause.
 3) Independent safety testing demonstrates they have no harmful effects
on human health or the environment after about 20 years of use!

. Voluntary  labeling unfairly reverses the financial burden onto
producers who do not  use GEFs. Mandatory labeling is essential for the
traceability of GEF  products throughout the food supply for health
professionals. Mandatory  labeling also protects overseas markets for
farmers. FDA must require  MANDATORY labeling of GEFs.

 FDA's proposed rule is unlikely to provide the public with adequate
information on GEFs for independent review. The FDA notes that producers
of GEFs may claim that any such information,  including the premarket
notification,  is trade secret or confidential business information
subject to exemption  from public disclosure requirements.  FDA must
require full disclosure.

 I will not think anything less than mandatory safety testing,
labeling,  pre-market environmental review, and full disclosure are
appropriate. All GEFs should be  taken off supermarket shelves until
these are established.  I do not want to eat them, and I don't want them
camouflaged in things I do choose to eat.
--
Mary Needham
President
Reserve Technology Inst.
2610A Dunlavy
Houston, TX 77006
Tel: 713-521-7979
Fax: 713-521-3607
Websites: rti-hou.com
          fpso-subsea.com
Email: mneedham@iamerica.net