August 27, 2007
Docket No. APHIS-2006-0112
Regulatory Analysis and Development, PPD, APHIS
4700 River Road Unit 118
Riverdale, MD 20737-1238
Regarding Docket No. APHIS-2006-0112
As the nation’s largest consumer-owned retail grocery chain, we urge you to prohibit the outdoor cultivation of genetically modified food crops designed to produce pharmaceutical and industrial chemicals.
This is a matter of immediate and grave concern in Washington state, where the Canadian company SemBioSys is seeking a permit to grow safflower engineered with human genes to produce experimental insulin. Nowhere in the USDA’s Environmental Impact Statement is there any recognition that safflower is a favorite food of birds and that Washington state is in the migratory path. It is not in the interest of our state or national economy for a foreign company to externalize the risks of its experiments upon our residents. Such an experiment is prohibited in SemBioSys’s own country of Canada.
We understand you have authority under the Plant Protection Act to declare such pharmaceutical crops illegal here, too. Doing so would protect our agricultural export market as well as public health and our nation’s food security — indeed, our very national security.
Our experiences with Starlink corn in 2000 and ProdiGene’s soybeans in 2002 demonstrates that our food production systems are vulnerable at many points to contamination by experimental pharmaceutical crop genes — from cross-pollination or physical mixing during seed production, planting and growing, harvest, storage and transport. Our farmers, food processors and taxpayers still are paying the price in lost export markets, beyond the tens of millions that it cost to mitigate the initial recalls.
These untested, unproven pharmaceutical/industrial crops also could well be biologically active at very low concentrations and harmful to people and animals that accidentally ingest them in contaminated food and feed. The theoretical benefits of these crops are wholly speculative. Not one plant-based pharmaceutical has been approved for human consumption despite more than a decade of promises.
We urge you to work with the Food and Drug Administration and support current technologies that can safely produce needed drugs and industrial chemicals in closed, contained systems.
If biotech companies want to produce plant-based drugs, they should follow the lead of Dow AgroSciences, which won approval of a chicken vaccine produced by tobacco cells contained in a steel tank. Cell cultures are a proven way to generate pharmaceuticals under controlled conditions — without the risk of contaminating our food with experimental drugs.
Chief Executive Officer