From: Center for Food Safety [action@foodsafetynow.org]
Sent: Wednesday, April 04, 2001 12:58 AM
To: FDA Commissioner
Cc: president@whitehouse.gov; vice.president@whitehouse.gov;
fdadockets@oc.fda.gov; fdadockets@oc.fda.gov
Subject: Oppose the New FDA Regulations on GE Foods!

To:
Dockets Management Branch (HFA-305)
Food and Drug Administration
5630 Fishers Lane, Rm 1061
Rockville MD 20852

Comments pursuant to:
Docket #00N-1396
Premarket Notice Concerning Bioengineered Foods

Docket #00D-1598
Voluntary Labeling Guidance

Submitted by:
David J. Engel 
Executive Director, Midwest Organic Services Association (MOSA)
Program Director, WI Chapter #1 Organic Crop Improvement Association (WI 
 OCIA#1)
53063 McManus Rd
Soldiers Grove WI 54655
email: dengel@mwt.net

Comments:
I have been the Executive Director of MOSA since its inception in March, 
1999, and the Program Director of WI OCIA#1 since its inception in 1988. 
My wife--a holistic veterinarian--and I have also milked 40-50 Jersey cows 
during this time period (25-30 cows prior to 1988), while also cropping 
approximately 200 tillable acres with 50+acres of pasture. We have always 
farmed organically since 1977 when we first bought a farm. We are on this 
present farm here in rural Soldiers Grove WI, since 1981, and we got 
certified here in July, 1988. 

I have served in various positions in the organic industry, in addition to 
my employment above, including being on the OCIA International 
Certification Committee, 1990-94; President of OCIA Intl, 1994-95; Chair 
of the Organic Trade Association's Quality Assurance Council's 
Certification Committee, 1999-01; Member of the OTA's Organic Certifier's 
Council Steering Committee, 2000-01.

My personal comments below are made with the above background and 
understanding,

1  The FDA must REQUIRE mandatory premarket safety testing of all 
genetically engineered food , as to date this has not been done. 
Genetically engineered foods have caused and could cause allergic 
reactions; have lowered and could lower the nutritional value of both 
feedstuffs and food; and could weaken immune responses in consumers, as 
well as expose consumers to antibiotic resistant virus strains.

2  The FDA must REQUIRE mandatory pre-market environmental review, as it 
is surely not our wisdom which is allowing us to see, experience and then 
ignore such canary signs' as dead Monarch butterflies (two different 
studies in NY and IA), dead lacewings (Scotland), dead rodents (GE potato 
experiment in England), as well as the geese in Illinois that will not eat 
GE beans, but will eat conventional beans right next to the GE beans. It 
is one thing to have atrazine in a well and to have to clean it up, 
primarily through further non-use of atrazine. It is quite another to have 
GE bacteria, for example, released into the environment and be replicated 
ad infinitum without sufficient testing or understanding the very real, 
potential dangers of or damage caused by such bacteria. Life will out, and 
we need to allow life to express itself as Mother Nature has guided us.

3  The FDA must REQUIRE mandatory labeling of GE  foods, in order to 
simply provide concerned consumers with the choice to choose if they want 
to purchase food made with GE products. Without labeling, no one will be 
able to exercise this right of the consumer to purchase what they want. 
Fully 70-80% of processed (and some unprocessed) foods in America right 
now have some level of GE background to them. Without labeling, we cannot 
tell what foods are not GE.
4  The pre-marketNotification policy is outrageous, as it basically 
reaffirms the FDA's 1992 Policy on GE foods, and this in the face of 
almost 10 years of increasing evidence of the dangers and damages that GE 
foods and their production have on the land, people and animals. The 1992 
Policy blithely opined that GE foods are not substantially different' 
than normal foods, therefore no testing or regulatory oversight needs to 
be done. I disagreed then (rBgH came in shortly after this ruling, though 
the US is the only major industrial country in the world to date that has 
allowed the use of rBgH) and I disagree now, and the more so, given the 
above examples of what has happened, and the daily new danger/damage signs 
that are extant. 

In sum, it very much appears that the exigencies of corporations' greed to 
market product without the hindrance of testing or labeling is winning the 
day over peoples' right to know what food they are eating or what possible 
negative effects this food is having on both us and our world. 

For the sake of God and people and animals and the environment, please put 
in place common sense protocol that will ensure that the greater good is 
looked after so that all GE products must be tested and labeled, and so 
that environmental assessment is done to determine long-term effects of 
introducing GE products into our environment. Surveys reveal the 
overwhelming desire of people to have this testing and labeling. You are 
responsible to the greater good of the people first, not corporations. I 
am sharing the song below in closing, and pray that the public good be 
done.

Thank you for your time and consideration.

        Tho' It Was Small, It Caught My Eye....    

Tho it was small it caught my eye, it made me say,  Now I wonder why....
Is this happening, I really wonder, what it is that has been done here?
Just a butterfly dead on its knees, just one tho a Monarch, if you please
He'd eaten the pollen of the Bt corn, and now he looked so forlorn

But the experts say, Well, we mustn't worry, one or two butterflies, 
well, we mustn't hurry
And react as tho there's a problem now, after all he could'a hit a 
windshield somehow
Ah, those experts can say so many things, cuz it is easy to talk and the 
money talk brings
Is nice and desirable, at least it seems so, and anyway every butterfly 
has to go

And for fifty years things have come and gone, and many are wondering 
what's going on
There's still DDT and the harm it's done, and in many ways Mother Nature 
is still on the run
Well, if a word to the wise is sufficient, we'd better get smart and start 
to take a hint
At least we'd better start to listen, and watch out where it is we're 
pissin'

One butterfly today, oh so what, I too would not worry or hurry, but....
If that little bit of GMO can make an insect dead, even if it's in a lab, 
even if it's injected
Then is it worth the risk to us, why would we not hesitate and wanna make 
a fuss
I think we need to be concerned, cuz you can't cross a bridge that has 
been burned
I think we need to have precaution....and maybe even a little party like 
they had in Boston...

Yes, everything here is intertwined, from the people to the land to the 
sky we find
So many many interconnections, it's a wonder and what's more upon closer 
inspection
All God's children have a place in the choir, some sing low and some sing 
higher
And maybe we should try to take better care of...these little butterflies 
and preciate their love

Tho it was small it caught my eye, made me say, Now, I wonder why......


David J. Engel
Soldiers Grove WI
608-734-3273



David Engel
53063 McManus Rd
Soldiers Grove, WI, 54655

CC: 
The President
Vice President Dick Cheney
FDA Dockets Management [Docket No. 00N-1396]
Senator Herb Kohl
Senator Russell D. Feingold
Representative Tammy Baldwin
Representative Ron KindFDA Dockets Management [Docket No. 00D-1598]


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