2003N-0573 Draft Animal Cloning Risk Assessment
FDA Comment Number : EC816
Submitter : Dr. Darlene Schanfald Date & Time: 01/04/2007 10:01:47
Organization : Dr. Darlene Schanfald
Category : Individual Consumer
Issue Areas/Comments
I oppose the introduction of cloned animals into the human food system. We have a toxic, unsafe food system in the U.S. Agencies seem incapable and unwilling to protect citizens. FDA says it lacks authority and can only negotiate and advise once they've approved a food or process. FDA is losing personnel. FDA inspectors are not allowed to inspect, except what the industry allows them to observe. U.S. food gets riskier and riskier to eat. Animal production in this country has typically been unclean and now more and more unskilled labor are being hired so they can be paid less and threatened with jail and deportation if they talk about the filth and unsafe practices in the food factories.

Cloned animals are a fairly new phenomenon. The animals are typically unhealthy. You can manipulate any data when you use "risk assessment." Risk Assessment does not guarantee safety; it guarantees illness and death, only limiting the numbers that can succumb to the risk. Risk Assessment needs to be replaced with the Precautionary Principle, denying a product if there is a chance of harm. There is in this instance and allowing cloned animals/offspring into the human food chain is putting the public in harm's way.

You state, "Cloning poses no unique risks to animal health when compared to other assisted reproductive technologies currently in use in U.S. agriculture." That's only saying that these animals will be mistreated as are all other farmed animals used for the food system.

You state, "The proposed plan outlines measures that FDA might take to address the risks that cloning poses to animals involved in the cloning process." "Might take" is no guarantee, especially since you have no authority but to advise.

You state, "One such measure could be that the agency would work with scientific and professional societies with expertise in animal health and reproduction to develop a set of care standards for animals involved in the cloning process. Although the agency does not have authority to address the ethics of animal cloning, the proposed risk management plan does state that FDA plans to continue to provide scientific expertise to interested parties working on these issues." And you would do this with less and less FDA personnel?! This posture is nothing more than FDA approving something and then dismissing any responsibility.

You state the offspring, not the clones themselves will be introduced into the food system. This is likely not so. Older clones will be dispensed with through the food chain.

Humans are not so dependent on meat that they need more, and they certainly do not need to be guinea pigs for this industry. You do not know, and can not know, due to the short time of this type of food production, the long term affects on humans. Only time would tell, when it is too late.

You must disallow cloned animals/offsprings into the human food system.