FW: ACTION ALERT: GENETICALLY ENGINEERED ORGANISMS

[Guest guest]

WESTON A. PRICE FOUNDATION

ACTION ALERT

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=78157:2563226. 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.

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ACTION #1:

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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=78158:2563226.

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ACTION #2:

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Send comments to the Animal and Plant Health Inspection Service (APHIS) of

the USDA: regulations@..., 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

westonaprice_contact@...

www.westonaprice.org

202 333-HEAL

Suze Fisher

Lapdog Design, Inc.

Web Design & Development

http://members.bellatlantic.net/~vze3shjg

Weston A. Price Foundation Chapter Leader, Mid Coast Maine

http://www.westonaprice.org

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“The diet-heart idea (the idea that saturated fats and cholesterol cause

heart disease) is the greatest scientific deception of our times.” --

Mann, MD, former Professor of Medicine and Biochemistry at Vanderbilt

University, Tennessee; heart disease researcher.

The International Network of Cholesterol Skeptics

<http://www.thincs.org>

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