From: Jeff Siegel [jeffsiegel@compuserve.com] Sent: Monday, March 26, 2001 3:12 PM To: fdadockets@oc.fda.gov Subject: Comments on Dockets 00D-1598 and 00N-1396 -- GM Food Labelling Dear FDA, I’m extremely concerned about dockets 00D-1598 and 00N-1396 and how they can lead to endangering American’s safety by failing to require safety testing foods containing genetically modified (GM) ingredients and how they can end up denying Americans the right to know what they are eating by not requiring the clear identification of GM ingredients on labels. SAFETY TESTING GM foods must be thoroughly tested prior to approving them for human consumption because genetic manipulation is a very complex and too little understood science. Just because a gene works one way in one organism doesn’t mean that it will work the same way in another organism – especially if species lines are crossed or even worse, when genes are shared between things as diverse as plants and animals. You can, in a way, compare genetic code to computer code – both are sets of instructions to be carried out – and both are very complex. Computer software (operating systems and applications) is the most complex thing created by man. Although it is created by man, note how many problems and unpredictable behaviors are encountered on a daily basis – even on software that is extensively tested by armies of company employees and volunteer customers (“beta testers’). When was the last time you had your computer lock up or a program work in an unexpected manner? Bugs, software errors, are often unintentional adverse side effects that result due to an incomplete understanding of thousands, and even millions, of lines of computer code. The most complex software we have today is child’s play compared to genetic code – and yet we continually have problems with software. If we haven’t adequately mastered software, how can anybody expect humans to master the manipulation of genetic code? Programmers can create and issue software “patches” to correct for errors, but once a genetic problem has been created the things it affects can’t be “patched” or corrected – the damage has been done and possibly can’t be eradicated. The inherent dangers of genetic engineering demand thorough and unbiased testing. MANDATORY LABELING OF FOODS CONTAINING GM INGREDIENTS It is chilling to hear that you are considering denying the American public from knowing what’s in the food they eat. I can think of NO REASON to deny Americans the right to know what’s in their food. If GM foods are totally safe, as the biotech industry believes, then why do they want to prevent the mandatory identification of foods containing their products? Biotech companies, based on the assumption that their products are absolutely safe, are arguing for no mandatory labeling because they fear lost sales when “uninformed” consumers with “irrational fears of GM products” avoid products labeled as containing GM ingredients. The biotech firms are trying to get the government, by preventing the mandatory labeling of products containing GM ingredients, to enable the GM companies to not have to publicly defend the safety of their products or educate the public on the presumed safety of GM products. The FDA required the Nutrition Information labels to ensure consumers could make educated choices regarding the foods they buy – why would the FDA not want to enable consumers to make educated choices with respect to foods containing GM ingredients. Note that any mandatory GM ingredient identification must be clear and unambiguous. The bottom line – Americans have the right to know what they are eating. Jeff Siegel 209 S. Walnut St. Wilmore, KY 40390-1325 859-858-2444