March 23, 2004

NOTICE FOR COMMENTS TO USDA ON GENETICALLY ENGINEERED ORGANISMS

PLEASE SUBMIT PUBLIC COMMENTS TO USDA
BY APRIL 13, 2004.

WHAT'S AT STAKE: USDA has issued a wide-ranging request for comments on its approach to regulating genetically engineered crops and animals. This request may be preliminary to significant changes in federal biotech regulations. The comments currently being solicited will directly affect the range of issues to be considered in future regulatory proposals. A large response is urgently needed, telling USDA that genetic engineering in agriculture must be much more stringently regulated to prevent unintended spread into the environment and the food supply.

BACKGROUND: USDA's Animal and Plant Health Inspection Service (APHIS) is currently seeking public comments on, "Issues regarding possible regulatory changes with the potential to affect the quality of the human environment." The agency is advising the public that it intends to consider changes in its regulation of biotech organisms. In doing so, it will prepare an Environmental Impact Statement to evaluate any proposed changes. Therefore, the agency is seeking comments on what issues should be covered in the Environmental Impact Statement. In particular, it is asking about including (or exempting) biotech crops from its definition of "noxious weeds." The call for comments was issued in the January 23 Federal Register (pgs. 3271-3272) and can be viewed at http://mailhost.groundspring.org/cgi-bin/t.pl?id=78158:2564042. The USDA allows interested parties to comment on this important issue, so please take action by April 13.

This comes as recent research highlights the risks and pervasiveness of contamination of conventional crops with genetically engineered (GE) traits. National Academy of Sciences report found that containment of GE crops could not be guaranteed under the present system, and that the spread of genes from GE plants poses potential environmental harm. In addition, a report published last month by the Union of Concerned Scientists (UCS) found widespread contamination of conventional seeds with GE contaminants.

Instead of seeking to control the contamination of the food supply, USDA is considering tolerating the presence of transgenic DNA in conventional varieties of seed. This could result in the agency skipping any human health and environmental review of these GE varieties before they end up in the food supply. To make matters worse, some of the GE contaminants could come from plants engineered to produce pharmaceutical drugs and industrial chemicals, products never intended for the human food supply.

ACTION #1:

Please circulate this alert and the Foundations’ submission (below) to your networks, your friends and family. A formatted, downloadable version of this alert can be found at http://mailhost.groundspring.org/cgi-bin/t.pl?id=78158:2564042.

ACTION #2:

Send comments to the Animal and Plant Health Inspection Service (APHIS) of the USDA: , and include "Docket No. 03-031-2" in the subject line of your e-mail. The comment deadline is APRIL 13, 2004. This is actually an extension granted last week by the USDA from the original due date of March 23, 2004.

Comments should not be identical form letters, but instead individually drafted comments that touch on the same points. Below are the main highlights you should include in your own words. Include the reasons why these outcomes are important (e.g., your concerns about food contamination, superweeds, loss of markets, etc.), and why it matters to you (e.g., as a consumer, as a farmer, etc.).

KEY POINTS FOR APHIS COMMENTS
(Docket No. 03-031-2)

*USDA-APHIS should revise its regulations for genetically engineered organisms, and should stringently regulate all such organisms as "plant pests" under the Plant Protection Act (7 U.S. Code 7701-7772). USDA-APHIS should exercise the fullest extent of its authority to ensure rigid containment of all genetically engineered organisms, and to prevent any unintended release of such organisms.

*All genetically engineered plants or plant products should be regulated as "noxious weeds." All such plants and plant products can and do cause economic and agronomic damage to other crops and livestock.

*Unintended spread of any genetically engineered organism into the environment or food supply-chain, at any level, is unacceptable. There should not be any tolerance or exemptions for "low-level" presence in food, feed or seed, of genetically engineered organisms or traits.

*Genetically engineered production of pharmaceuticals or industrial chemicals, in crops used for food or animal feed, should be prohibited. Open-air testing of any genetically engineered pharmaceuticals or industrial chemicals should be prohibited.

*Permit conditions for approval of any genetically engineered organism under APHIS' authority must include proof that no transgenic material will migrate into other living organisms. Conditional approvals should not be granted; all safety and environmental issues should be resolved prior to commercialization.

Many thanks to the Center for Food Safety and the National Campaign, Genetic Engineering in Agriculture Committee for crafting the information contained in this action alert.

* * Actual Comments Provided by the Weston A. Price Foundation* *

Please use all or parts of this document as you see fit.

Docket No. 03-031-2
Regulatory Analysis and Development
PPD, APHIS, Station 3C71
4700 River Road, Unit 118
Riverdale, MD 20737-1238

RE: Docket No. 03-031-2

Dear Mr./Ms.:

Thank you for the opportunity to comment on USDA Docket No. 03-031-2 regarding the environmental impact statement APHIS is in the process of developing for genetically engineered crops and organisms.

New evidence shows that contamination of non-genetically engineered (GE) crops with DNA from genetically engineered organisms is becoming an increasingly serious problem in this country. The National Research Council recently presented the USDA with a report addressing the need for biological confinement of genetically engineered Organisms. Additionally, the Union of Concerned Scientists, an independent nonprofit alliance of more than 100,000 concerned citizens and scientists, just released a report demonstrating the pervasiveness of contamination in US supplies of non-GE corn, soybean and canola seeds.

It would be irresponsible for the USDA to ignore these recent findings and continue to allow outdoor plantings of genetically engineered crops, especially those engineered to produce pharmaceutical drugs and industrial chemicals. If open-air plantings of these "biopharm" crops are allowed, contamination of the food supply is inevitable.

Food crops are increasingly used to produce pharmaceuticals and drugs, including cytokines known to suppress the immune system, induce sickness and central nervous system toxicity; interferon alpha, reported to cause dementia, neurotoxicity and mood and cognitive side effects; vaccines; and viral sequences such as the 'spike' protein gene of the pig coronavirus, in the same family as the SARS virus linked to the current epidemic. The glycoprotein gene gp120 of the AIDS virus HIV-1, incorporated into GM maize as a ‘cheap, edible oral vaccine’, serves as yet another biological time-bomb, as it can interfere with the immune system and recombine with viruses and bacteria to generate new and unpredictable pathogens.

Since 1991 over 300 open-field trials of "pharma" crops have taken place around the world. In California, for example, GE rice containing human genes has been grown for drug production. Pharmaceutical wheat, corn and barley are also being developed in the US, France and Canada.

In Texas 500,000 bushels of soy beans destined for human consumption were contaminated with genes from maize genetically modified by the U.S. firm Prodigene in order to create a vaccine for a stomach disease afflicting pigs. A major concern is that GE firms are using commodity food crops for pharmaceutical production.

The Foundation is aware that the USDA is considering allowing unapproved varieties of genetically engineered organisms to enter the food supply by exempting from regulation the occurrence of low levels of these varieties. It would be negligent for the USDA to allow varieties unapproved for human consumption to enter the food supply.

Health issues of GM crops have not been adequately researched. There have been no properly controlled clinical trials looking at the effects of short- or long-term ingestion of GM foods by humans. We have three broad health concerns:

Allergic Reactions
Genetic modification frequently uses proteins from organisms that have never before been an integral part of the human food chain. Hence, GM food may cause unforeseen allergic reactions - particularly among children. Allergens could be transferred from foods to which people are allergic to foods they think are safe. When a new food is introduced, it takes five to six years before any allergies are recognized.

In 2000 GE `StarLink' maize was found in taco shells being sold for human consumption in the US - even though the maize had only been approved for animal feed. StarLink is modified to contain a toxin that could be a human allergen; it is heat stable and does not break down in gastric acid - characteristics shared by many allergens.

Antibiotic resistance
Genetic modification could also make disease-causing bacteria resistant to antibiotics. This could lead to potentially uncontrollable epidemics. Antibiotic-resistance genes are used as `markers' in GM crops to identify which plant cells have successfully incorporated the desired foreign genes during modification.

A 2002 study commissioned by Britain’s Food Standards Agency (FSA) showed that antibiotic-resistance marker genes from GM foods can make their way into human gut bacteria after just one meal. Two years previously, the British Medical Association had warned: "The risk to human health from antibiotic resistance developing in micro-organisms is one of the major public health threats that will be faced in the 21st century."

Transgenic DNA and Cancer
Transgenic DNA is known to survive digestion in the gut and to jump into the genome of mammalian cells, raising the possibility for triggering cancer. The possibility cannot be excluded that feeding GM products such as maize to animals also carries risks, not just for the animals but also for human beings consuming the animal products.

Determinations

The Weston A. Price Foundation is requesting that the following four determinations be included in the Environmental Impact Statement:

1. There should be no open-air plantings of "biopharm crops", crops engineered to produce pharmaceutical drugs and industrial chemicals.

2. "Biopharm crops" should not be engineered into food crops.

3. There should be no exemptions for the occurrence of low levels of unapproved varieties in the food supply.

4. There must be regulations in place to ensure that all GE crops are appropriately monitored.

In addition, all genetically engineered plants or plant products should be regulated as "noxious weeds." All such plants and plant products can and do cause economic and agronomic damage to other crops and livestock.

USDA-APHIS should revise its regulations for genetically engineered organisms, and should stringently regulate all such organisms as "plant pests" under the Plant Protection Act (7 U.S. Code 7701-7772).
USDA-APHIS should exercise the fullest extent of its authority to ensure rigid containment of all genetically engineered organisms, and to prevent any unintended release of such organisms.

Permit conditions for approval of any genetically engineered organism under APHIS' authority must include proof that no transgenic material will migrate into other living organisms. Conditional approvals should not be granted; all safety and environmental issues should be resolved prior to commercialization.

GE crops may also reduce the diversity of plant life by contaminating their wild relatives and indigenous crop varieties in areas where the crops evolved. Widespread GE contamination of conventional maize has already been detected in Mexico. In Europe, contamination of wild relatives of oilseed rape and sugar beet is considered inevitable if GE commercialization goes ahead. The same applies to wild relatives of rice in Asia.

If wildlife is harmed "unexpectedly" (i.e., without that harm having officially been predicted), and an official risk assessment had not previously decided that GE crops were safe, it is the state and society that will have to pay for putting things right - if this is possible.

Thank you for your consideration of our concerns.

Sincerely yours,

Bill Sanda
Director of Public Affairs
Weston A. price Foundation

www.westonaprice.org
202 333-HEAL

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This page was posted on 03/25/04