From: HilaryBrad@aol.com
Sent: Monday, March 26, 2001 10:11 AM
To: fdadockets@oc.fda.gov
Subject: Docket 00N-1396 & Docket 00D-1598
To whom it may concern at the FDA 

I understand that genetically modified foods are under discussion again.   
If the guardians of our health are too closly aligned to corporate interests 
only the short term good of those food industries will be served.  My email 
is intended to add to the public commentary you have invited: 

* The precautionary approach is an imperative: 
      The FDA should 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. 

The following elements of the proposed rules are unacceptable because they: 

* Do not yet require mandatory pre-market safety testing 
* Do not yet require pre-market environmental review 
* Do not yet require mandatory labeling of GE foods 
* Continue to restrict voluntary labeling of non-GE foods 
* Continue to only 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 


Hilary Bradbury, Ph.D 
Assistant Professor 
Case Western Reserve University 
Department of Organizational Behavior 
Weatherhead School of Management 
Cleveland OH, 44106 

TEL:   216 368 0070 
FAX : 216 368 4785 
hxb22@po.cwru.edu 
http://weatherhead.cwru.edu/bradbury/