From: Mitchell M. May [mmay@lasal.net]
Sent: Monday, March 26, 2001 11:27 AM
To: fdadockets@oc.fda.gov
Subject: Docket 00N-1396 & Docket 00D-1598

Dear FDA,

As both a consumer (and parent of two) as well as a scientist with my
training in experimental research design, I am very concerned by what
appears to be the highly skewed position the FDA is taking when it comes to
your proposed position and labeling with GE items.  From an unbiased science
point of view (what other kind of science should there be) the FDA's
position on GE foods in particular would never be accepted in any research
program I have ever been a part of, and any "scientist" one who took such a
premature position as the FDA has, would be severely reprimanded for showing
a bias prior to proper studies, controls, and controls being demonstrated.
With such severely deficient and insufficient studies on introducing GE
foods into the human food chain, it is without proper and adequate knowledge
and without precedent in this current age of science that such a widespread
introduction into the human food chain should be allowed.

I remain very hopeful that the potential promises of GE foods will indeed be
realized for the needs of our developing world.  However, we must be certain
we fully understand and can control all the aspects of the GE process and
all the possible ramifications of it.  It is extremely concerning that we
are far from understanding the entirety of letting GE foods into the food
chain, and yet there has been an "extra allowance" in the FDA supporting
their release without the science any where near complete.  Unfortunately,
of course everyone assumes a political and economic bias that would allow
such to occur, how else is one to view this, given no other lobby or
interest would ever be granted such a premature release.

If this is going to be your position, then it is totally irresponsible on
the other side to not let consumers have complete and full information for
them to make up their own mind as to whether they wish to consume GE foods
or not.  Consumers have a right and the FDA has a mandate to give full and
unbiased facts to consumers as to whether that food or product has or does
not have GE factors within it.  It is not for the FDA to decide what
consumers should and should not know, any withholding of such information
can only be for some bias or position, any of which is unethical.  Even if
consumers make a decision to not purchase GE based on their own bias,
misinformation or bad science, that is not for the FDA or any other
government body to interfere with, that is the right of the consumer alone.

You must as a bare minimum both require all GE containing foods to be
labeled as such and likewise to allow all foods not containing GE to be
labeled as such. Your reasoning that companies not be allowed to label foods
as non-GE is clearly stretching logic and is again a bias that leads one
back to economic interests and not science or the will of the public.  What
is there to fear in giving people the choice, why are you intent on
controlling information and not allowing the public to decide for
themselves.

You are shooting yourselves in the foot as the public sees the FDA as taking
sides in this debate, and if the FDA is to retain any credibility it must
require solid and sufficient science regarding GE foods and it must  allow
the public to be fully informed on what GE foods they are purchasing and
feeding their families.  I  am concerned that GE foods will actually have a
huge set back if they are jammed down the peoples throat and not dealt with
full disclosure and integrity.

Sincerely,

Mitchell M. May, Ph.D.