From: Peter T. Hogarth [peter.hogarth@mindspring.com]
Sent: Saturday, March 24, 2001 3:08 PM
To: fdadockets@oc.fda.gov
Subject: Docket 00N-1396 & Docket 00D-1598

To the Food and Drug Administration:

I am deeply disturbed by the deficiencies in proposed rulemaking regarding genetically engineered foods.  My understanding of the proposed rules is as follows:

1. They do not require mandatory pre-market safety testing.
2. They do not require pre-market environmental review.
3. They do not require mandatory labeling of GE foods
4. They restrict voluntary labeling of non-GE foods.
5. They fail to ensure public access to adequate information for independent review.

The minimum acceptable rules would 
 
1. Require mandatory pre-market safety testing.
2. Require mandatory pre-market environmental review.
3. Require mandatory labeling of GE foods
4. Not restrict voluntary labeling of non-GE foods, as long as the claims are truthful.
5. Ensure public access to adequate information for independent review.

Of these items the single most essential is number 4, followed closely by number 3.  If the government is unwilling to do its duty in proactively regulating these potentially dangerous products, at least it is obligated to permit citizens to make their own informed choices.
 
Although the scientific arguments in favor of these restrictions on uncontrolled and irreversible modifications to the biosphere are overwhelming, they are being overridden by commercial interests that are shortsighted and extremely destructive.  Even if this were not the case, it is a matter of principle that citizens have a right to be informed about the products that they are buying and are involuntarily exposed to; this overrides the mercantile interests.
 
Peter T. Hogarth
321 Jamestown RD
Pittsboro, NC 27312