From: Kai Druhl [kdruhl@lisco.com]
Sent: Saturday, March 31, 2001 10:11 AM
To: fdadockets@oc.fda.gov
Subject: Docket 00N-1396 & Docket 00D-1598

 We strongly oppose the proposed rules, which:

* Do not require mandatory pre-market safety testing
* Do not require pre-market environmental review
* Do not require mandatory labeling of GE foods
* Restrict voluntary labeling of non-GE foods
* Require a mere letter of notification prior to the 
  marketing of a GE food
* Fail to ensure public access to adequate information 
  for independent review
* Are supported by industry and opposed by consumer groups.

With respect to the topics of these dockets, we ask that:

* The FDA must require mandatory pre-market comprehensive 
  environmental review. Unlike conventional pollutants, 
  where a given amount of pollutant causes a limited amount 
  of damage, a small number of mutant genes could have a 
  population explosion and reproduce forever, causing 
  unlimited and irreparable damage.

* The FDA must require mandatory pre-market long-term health 
  testing. GE products could be toxic, cause allergic 
  responses, have lower nutritional value, and compromise 
  immune responses in consumers.

* The FDA must require mandatory labeling of GE products. 
  Without mandatory labeling, neither consumers nor health 
  professionals will know if an allergic or toxic reaction 
  was the result of a genetically engineered food. Consumers 
  would be deprived of the critical knowledge needed to hold 
  food producers liable should any of these novel products 
  be hazardous.

* The FDA must end its cozy relationship with the industries
  it purports to be regulating. People have been allowed to 
  work for a biotech company, then work for the FDA writing the 
  regulatory rules on that company's product, then go back to
  working for the company.  Ninety-two percent of FDA advisory 
  committee meetings had at least one conflict of interest.


Sincerely

Kai Druhl
Julie Druhl
2006 North B Street
Fairfield, IA 52556