Docket 99N-4282: GE and GMO Foods and FDA Regulation
From: Lorna Salzman
Date: January 13, 2000
Re: Docket 99N-4282: GE and GMO Foods and FDA Regulation
Present FDA authority over genetically modified foods and their components is insufficient to either inform or protect consumers and the general public because of inadequate research and testing. Therefore, FDA should require full, accurate comprehensible labelling of all foods that contain genetically modified ingredients or which have been produced using recombinant genetic techniques or methods. FDAs assertion of "substantial equivalence" has no basis in science precisely because no long-term testing has been performed by any independent body to substantiate this assertion. FDA should adopt the principle that such products or ingredients are hazardous until proven safe,not the reverse.
Because such GE and GMO foods and food ingredients lack such experimental evidence of long-term safety, they are on a par with many of the so-called folk remedies and health supplements over which the FDA has itself expressed concern. Accordingly, it is absolutely vital to the protection of public health and safety that independent verifiable long-term testing be performed BEFORE the marketing of such GE and GMO foods is allowed, and that if there is any doubt, unresolved issue, conflict, uncertainty or indication of potential hazard, such products be withheld from the market until and unless their safety is impartially proven. Interim protection can be provided, to a degree, by a requirement of labelling but in the long term such products should be banned until proven safe by impartial tests whose protocols and experimenters are publicly known.
The public also needs the assurances that any regulatory, testing, oversight or consultative body is not only independent and represents all stakeholders but that its findings be readily accessible to the general public on a regular basis and through means that are easily accessible via libraries, schools, the news media, on line, etc.