From: Steve Leibowitz [Steve_Leibowitz@payformance.com] Sent: Tuesday, March 20, 2001 1:35 PM To: 'fdadockets@oc.fda.gov' Subject: subject re: dockets .00N-1396 and 00D-1598 Dear FDA Commissioner, I am not arrogant. I do not claim to be an expert in GMO's (genetically modified organisms). I would not want to tell any one person or any group of people that a particular GMO is harmless or not to people or the environment. However, I have lived long enough and observed enought to see a pattern. Scientists enthused by the science, businessmen greedy for a profit, and regulatory agencies co-opted by the industries they supposedly regulate abandoning the role of protecting the public. In other words, I have seen arrogance on the part of those who embrace the new thing only to find out later that it was destructive. Look in the archives of the newspapers. There were ads for radioactive water that will cure kidney disorders. (Researchers can't find any of these people to study; the're all dead!) Now there is evidence that the original Salk vaccine was contaminated with monkey virus that may be a cause of cancer. What about DDT? What about the Monarch butterfly? What about Starlink? It is arrogant to claim that we know all the side-effects of all of the current and future GMOs. Under the circumstances, we should leave the choice of taking the risk, up to the consumer. Freedom of choice is an American principle. Label the product and let each individual be informed and retain the right to decide. The proposed Food and Drug Administration (FDA) regulations fail to require labels or safety tests on genetically engineered (GE) food. The new rules continue to deny Americans the right to know what is in our food, while protecting the economic interests of biotech corporations. Labeling GE foods would protect the public from potential hazardous health effects such as food allergies and toxicity that can only be traced if GE foods can be identified. By refusing to require both labeling and mandatory pre-market safety testing of foods, the FDA puts consumer's health at risk, ignores possible environmental hazards, and fails to satisfy the overwhelming desire of American consumers to exercise freedom of choice in the marketplace. It is not enough to require that firms simply notify you of their intent to market a food produced with genetic engineering; this is no substitute for thorough pre-market safety testing. The proposed "voluntary labeling" guidelines will do nothing to inform consumers of the presence of genetically engineered ingredients in their food, because biotech companies and food manufacturers have vehemently opposed labeling in the past and will not voluntarily label their foods in the future. Therefore, I urge you to keep all genetically engineered ingredients and crops off the market until independent safety testing demonstrates they have no harmful effects on human health or the environment. All GMO must be labeled to preserve each citizen's right-to-know and and decide for him/her self. The biotechnology corporations that produce them must be held responsible for any disaster they may cause. (And there is certain to be more. Do you want that on your conscience?)