Proposed rules to regulate biopharms

May 9, 2003

Re: Docket # 03-031-1
Regulatory Analysis and Development
PPD, APHIS, Station 3C71
4700 River Road Unit 118
Riverdale, MD 20737-1238

Dear APHIS,

As a consumer-owned organization with 40,000 members, we strongly object to your proposed rules to regulate genetically engineered crops containing pharmaceutical drugs and industrial chemicals. The proposed rule to require a distance of only one mile between corn grown for food and corn containing pharmaceutical drugs would guarantee contamination of our food supply with experimental drugs.

The biotech companies already have a track record of snafus that's undermining the public's faith in genetic tinkering. The near miss with Prodigene's soybeans, genetically engineered with experimental drugs, is but one example. The contamination of food products with GE Starlink corn (not approved for human consumption) and the discovery by regulators that genetically mutated research pigs may have been making their way onto the nation's dinner tables are two additional examples in just the past three years. These examples alone have cost hundreds of millions of dollars, not to mention the losses from trade partners who will not accept GE imports.

We agree with the Grocery Manufacturers of America that "biopharms" (a.k.a "foodaceuticals") are a matter of "deep concern." We agree with the GMA in urging the federal government and biotech interests to direct its substantial research capabilities into investigating the use of nonfood vehicles for the development of pharmaceuticals.

We agree with the National Food Processors Association in urging you to halt planting gene-altered crops for pharmaceuticals. The risk is too high and it is not possible to achieve 100 percent containment of gene-altered pollen. It is known that GE corn pollen is genetically very "promiscuous" and that pollen drift has contaminated crops at least six miles away, documented by contamination of the Terra Prima farm in Texas years ago.

We urge that no food crops whatsoever should be genetically engineered to express pharmaceutical and industrial compounds. At the minimum, these biopharm crops should be restricted entirely to controlled indoor environments such as greenhouses. The more than 300 secret "foodaceutical" trials nationwide should be ended immediately.

Respectfully yours,

Tracy Wolpert, Chief Executive Officer
Randy Lee, Chief Financial Officer

PCC Natural Markets
4201 Roosevelt Way NE, Seattle, WA. 98105

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