Docket Management
Docket: 02D-0324 - Draft Guid.: Drugs, Biologics & Medical Devices Derived from Bioengineered Plants
Comment Number: EC -101

Accepted - Volume 9

Comment Record
Commentor Ms. Haley Nicholson Date/Time 2003-02-10 03:04:00
Organization Ecopledge
Category Other

Comments for FDA General
1. General Comments To whom it may concern: I am writing to comment on DOCKET NO. O2D-0324. Experts agree that contamination of food crops with biopharm traits is inevitable, especially since cross-pollinating corn is the favorite plant and as acreage increases from small pilot trials to large commercial plantings. Look at the ProdiGene incidents in NE and IA. Some of the compounds presently being grown in corn have known human health effects, but have not been tested. Many more are kept secret by government and industry as confidential business information. Some companies want to extract the biopharmaceutical, then put the crop residue into the food and feed chain. So if extraction isn't complete, we're talking drug residues in the food supply. Farmers will suffer as contamination episodes ruin export markets, and the use of pesticides on biopharm plants raises the very real risk of pesticide residues in drugs. More stringent regulation is not the answer -- banning biopharming, at least in food crops and in the open air -- is. There are many contained, controlled, proven as well as newer alternatives to open- air biopharming for any drugs that are really needed. Yours truly, Haley Nicholson Baker Hall Room 143 Boulder, CO. 80310

EC -101