Action Alert: From The Cornucopia Institute

Rescue Local/Organic Farming in the Food Safety Bill!

Urgent—Call your Senator Today

Next week, as early as Tuesday, April 13, the U.S. Senate is expected to vote on a sweeping overhaul of federal food safety law – S. 510. The House food safety bill passed last year (HR 2749) included several measures that threaten small-scale organic producers, including a registration fee of $500 and blanket application of complicated monitoring and traceability standards -- regardless of one's farm size.

There's no doubt that industrial agriculture needs better oversight. But, family-scale local and organic farms are probably the safest in the nation -- they are part of the solution, not part of the problem -- and need to be protected!

Now is your chance, as a supporter of sustainable family farming, to help fix these problems! Senator Tester (D-MT), a certified organic farmer himself, is proposing an amendment to S. 510 that would exempt small-scale farmers and food processors from the most burdensome regulations.

We need your help TODAY, please call your U.S. Senators in support of these proposals.

The vast majority of recent food safety scandals in the U.S. -- E. coli on fresh spinach, melamine in dairy products, Salmonella in peanut butter -- were all linked to industrial agribusiness practices, and these large-scale operations clearly warrant more federal food safety oversight and strict enforcement action. What is NOT needed is a "one-size-fits-all" approach that poses unfair costs and onerous reporting on local and organic farmers.

Safer, healthier food options provided by local, organic, and sustainable farmers should not be punished for their responsible work with expensive and complicated new rules. These rules may make industrialized food production safer, but offer no real food safety gains to consumers of local and organic foods. Small-scale operations are already subject to adequate regulation by local and state agencies. Smaller farm size inherently poses less risk (they are almost always owner-operated), and direct marketing also offers consumers better quality food with more transparency and accountability -- and easy traceability.

Taking Action is Easy:

Call your Senators today, and tell them that you support Senator Tester's amendment to S. 510.

To reach your state's Senators,

1. Search his/her phone number online: http://www.senate.gov/general/contact_information/senators_cfm.cfm

2. Or call the Capitol Switchboard at (202) 224-3121.

Sample Talking Points:

Specific talking points you can share with your Senators from Tester's proposed amendment to S. 510 include:

1) With respect to the hazard analysis and risk-based preventive controls, add the following new section to Section 103:

(l) EXEMPTION FOR CERTAIN FACILITIES – This section shall not apply to a facility for a year if the average annual adjusted gross income of such facility for the previous three-year period was less than $500,000.

2) With respect to traceability, add the following new section to Section 204:

(f) EXEMPTION FOR CERTAIN FACILITIES – The traceback and recordkeeping requirements under this section shall not apply to a facility for a year if the adjusted gross income of such facility for the previous year was less than $500,000.

With respect to the produce standards, add the following new section to Section 105:

(g) EXCEPTION FOR DIRECT MARKET FARMS – This section shall not apply to farms whose annual value of sales of food products directly to consumers, hotels, restaurants, or institutions exceeds the annual value of sales of food products to all other buyers.

Thanks for your support of organic, local and sustainable farmers!

The full action alert can be viewed at: http://www.cornucopia.org/2010/04/action-alert-rescue-localorganic-farming-in-the-food-safety-bill/#more-2770



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Offshore Oil Drilling Community Forum

The coast of California is now vulnerable to new off shore drilling. Environment California and Surfrider Foundation are holding a community meeting in Santa Monica on March 17 to talk about this threat and what we can do to protect our beaches.

The meeting is from 7-8 pm, at:

Santa Monica Library, Fairview Branch
2101 Ocean Park Boulevard
Santa Monica, CA 90405

To RSVP to the event go to: http://www.environmentcalifornia.org/action/oceans/la-forum?id4=ES

Success! New USDA Rules Establish Strong Organic Standards for Pasture and Livestock

A big thank you to all of our members who took the time to write to the White House to express your concern, and to urge the President to support truly organic dairy farming practices. Thanks to your efforts organic dairy can continue with meaningful pasture and grazing rules that support the true ethics of organic farming.

From The Cornucopia Institute:
On behalf of the organic family farmers in this country I want to thank and recognize the co-op community. I can't think of a more important ally in this 10-year struggle that has resulted in the Obama administration setting up to crack down on the abuse from factory farms in organic dairy.

This is a big victory and I hope that you and your members will take pride in your important contributions,
Mark Kastel
Codirector
The Cornucopia Institute

Read the full Press Release here: http://www.cornucopia.org/2010/02/new-usda-rules-establish-strong-organic-standards-for-pasture-and-livestock/

Contact the White House - Don't Let Lobbyists Weaken New Organic Dairy Standards

From the Cornucopia Institute:

Farmers and consumers concerned with the integrity of organic dairy farming need to contact the White House (IMMEDIATELY) and urge the President to support a strong pending standard governing organic livestock and dairy management practices.

The White House's Office of Management and Budget (OMB) is nearing the end of its critical review of proposed new regulations clarifying the requirement that dairy cows and other ruminants consume a meaningful amount of feed from pasture and grazing. Powerful factory farm interests opposed to the rule - who want to continue to principally confine animals in feedlot style operations - have privately met with OMB officials and are seeking to weaken the new rule.

Click here to visit the Cornucopia Institute's website, find out how to contact the White House and read more: www.cornucopia.org

Tell the USDA You Care about GE Contamination of Organic Food!

In 2006, the Center for Food Safety (CFS) sued the Department of Agriculture (USDA) for its illegal approval of Monsanto's genetically engineered (GE) Roundup Ready alfalfa. The federal courts sided with CFS and banned GE alfalfa until the USDA fully analyzed the impacts of the plant on the environment, farmers, and the public in a rigorous analysis known as an environmental impact statement (or EIS). USDA released its draft EIS on December 14, 2009 and their preliminary determination is to once again deregulate GE alfalfa without any limitations or protections for farmers or the environment, claiming that there is no evidence that consumers care about GE contamination of organic foods! A 60-day comment period is open until February 16, 2010.

Please take the time to visit the Center for Food Safety's website to voice your opinion on genetically engineered foods.

Go here: http://ga3.org/campaign/alfalfaEIS

Food Safety Bill--A threat to small/organic farms--your voice is needed

From the Cornucopia Institute:
Action Alert

Senate Bill 510: FDA Food Safety Modernization Act

Tell the Senate committee not to threaten quality organic and local food production

Act now! Contact your senator Today!
Our food safety system is broken. Industrialized food production gives rise to serious food safety problems, and our government's ability to regulate corporate agribusiness must be strengthened -- without harming small-scale and organic family farmers.

Bills in Congress propose to give more authority to the Food and Drug Administration to regulate for food safety, inspect food processing facilities, and order mandatory recalls. The House passed its own food safety bill in July. The Senate's bill is in committee and scheduled for a mark-up (committee vote) today

Allowing the FDA to crack down on corporate food producers that threaten our citizenry's health is a step in the right direction -- as long as legislation contains protections for small-scale, organic and local food systems. Small farms could be forced out of business by increasing costs for record-keeping, testing and other measures they will not be able to comply with. These are our country's safest farms -- part of the solution, not part of the problem!

Now is the time to contact Senate committee members (especially if one is from your state) that will make changes to the bill on November 18. Our message is: Senate Bill 510 must contain protections for small-scale and organic family farms.

Please call as many committee members as you have time for!
Take Action Today – Call Senate Committee Members
See the list below for Senators on the Health, Education, Labor and Pensions (HELP) Committee. Please call or fax their office, ask to speak with the aide in charge of food safety issues, and share the concerns of the small-scale and organic farming community with them.

List of Senate HELP Committee Members

Senator Phone
Democrats
Tom Harkin (IA) - 202-224-3254
Chris Dodd (CT) - 202-224-2823
Barbara Mikulski (MD) - 202-224-4654
Jeff Bingaman (NM) - 202-224-5521
Patty Murray (WA) - 202-224-2621
Jack Reed (RI) - 202-224-4642
Bernie Sanders (VT) - 202-224-5141
Sherrod Brown (OH) - 202-224-2315
Bob Casey (PA) - 202-224-6324
Kay Hagan (NC) - 202-224-6342
Jeff Merkley (OR) - 202-224-3753
Al Franken (MN) - 202-224-5641
Michael Bennet (CO) - 202-224-5852


Republicans
Mike Enzi (WY) - 202-224-3424
Judd Gregg (NH) - 202-224-3324
Lamar Alexander (TN) - 202-224-4944
Richard Burr (NC) - 202-224-3154
Johnny Isakson (GA) - 202-224-3643
Orrin Hatch (UT) - 202-224-5251
Pat Roberts (KS) - 202-224-4774
Tom Coburn (OK) - 202-224-5754
Lisa Murkowski (AK) - 202-224-6665

Help the Center for Food Safety

If you're never heard of them before, the Center for Food Safety is an organization that works to protect public health and the environment by promoting organic and sustainable food production practices and lobbying against harmful technologies and companies.

They do a lot of good work and we as a co-op rely on them to alert us to issues and news. They are in the middle of their fall donation funds drive, and they have a short but interesting video of Vandana Shiva, an amazing speaker, on their donation page. Its worth checking out even if you don't wish to donate. Also if food safety is something you're interested in its worth signing up for their e-mail updates which is free.

Check it out (takes you to another website) https://secure.ga3.org/03/FFF_Shiva!

Tell USDA: Keep Nanotech OUT of Organic!

From the the Center for Food Safety's True Food Network website:

USDA's National Organic Standards Board (NOSB) is voting on whether nanotechnology should be banned from use in Organic products. Thanks to your overwhelming outcry in May 2009 the Board's initial recommendation is to keep nanotech out of organic entirely. Now, we need your help again to make sure USDA holds the line! The critical vote on the Board's final recommendation will be held in Washington D.C. on Nov 3.

Nanotechnology is contrary to Organic Principles and could further entrench industrial/chemical agriculture and industrial food as our dominant paradigm, to the detriment of public health and the environment. Tell NOSB to ensure the integrity of Organic on this issue by voting that USDA ban nanotechnology as an excluded method.

Read more and take action now (takes you to True Food Network website)

Proposed Federal Rules Could Competitively Injure Small, Local and Organic Fresh Market Produce Growers

From the Cornucopia Institute:

USDA Schedules Public Hearings to Obtain Citizens' Concerns and Suggestions

The "Leafy Green Marketing Agreement," which requires producers to follow a set of rules (metrics) in the name of food safety, has already shown to be injurious for the environment, biodiversity, and organic growers in California. The USDA is now considering a similar "Leafy Green Marketing Agreement" that would extend beyond California and Arizona to cover the entire United States-let's help make this rule work for growers of all sizes!

The USDA has scheduled a series of hearing sessions, around the country, inviting you to this perfect opportunity to share your concerns and suggestions.

Click here to read the full article and the schedule.

Aakk! Plastic

BYOB (Bring Your Own Bag)

H.R. 875

The National Cooperative Grocers Association (NCGA) has done some research on H.R. 875 and the following is what they had to say.

The dilemma of how to regulate food safety in a way that prevents problems caused by industrialized agriculture but doesn't wipe out small diversified farms is not new and is not easily solved. And as almost constant food safety problems reveals the dirty truth about the way much of our food is produced, processed, and distributed, it's a dilemma we need to have serious discussion about.

Most consumers never thought they had to worry about peanut butter and this latest food safety scandal has captured public attention for good reason - a CEO who knowingly shipped contaminated food, a plant with holes in the roof and serious pest problems, and years of state and federal regulators failing to intervene.

It's no surprise that Congress is under pressure to act and multiple food safety bills have been introduced.

Two of the bills are about traceability for food (S.425 and H.R. 814). These present real issues for small producers who could be forced to bear the cost of expensive tracking technology and recordkeeping.

The other bills address what FDA can do to regulate food.

A lot of attention has been focused on a bill introduced by Rep. Rosa DeLauro (H.R. 875), the Food Safety Modernization Act. And a lot of what is being said about the bill is misleading.

Here are a few things that H.R. 875 DOES do:

- It addresses the most critical flaw in the structure of FDA by splitting it into 2 new agencies - one devoted to food safety and the other devoted to drugs and medical devices.
- It increases inspection of food processing plants, basing the frequency of inspection on the risk of the product being produced - but it does NOT make plants pay any registration fees or user fees.
- It does extend food safety agency authority to food production on farms, requiring farms to write a food safety plan and consider the critical points on that farm where food safety problems are likely to occur.
- It requires imported food to meet the same standards as food produced in the U.S.

And just as importantly, here are a few things that H.R. 875 does NOT do:

- It does not cover foods regulated by the USDA (beef, pork, poultry, lamb, catfish.)
- It does not establish a mandatory animal identification system.
- It does not regulate backyard gardens.
- It does not regulate seed.
- It does not call for new regulations for farmers markets or direct marketing arrangements.
- It does not apply to food that does not enter interstate commerce (food that is sold across state lines).
- It does not mandate any specific type of traceability for FDA-regulated foods (the bill does instruct a new food safety agency to improve traceability of foods, but specifically says that recordkeeping can be done electronically or on paper.)

Several of the things not found in the DeLauro can be found in other bills - like H.R. 814, the Tracing and Recalling Agricultural Contamination Everywhere Act, which calls for a mandatory animal identification system, or H.R. 759, the Food And Drug Administration Globalization Act, which overhauls the entire structure of FDA. H.R. 759 is more likely to move through Congress than H.R. 875. And H.R. 759 contains several provisions that could cause problems for small farms and food processors:

- It extends traceability recordkeeping requirements that currently apply only to food processors to farms and restaurants - and requires that recordkeeping be done electronically.
- It calls for standard lot numbers to be used in food production.
- It requires food processing plants to pay a registration fee to FDA to fund the agency's inspection efforts.
- It instructs FDA to establish production standards for fruits and vegetables and to establish Good Agricultural Practices for produce.

There is plenty of evidence that one-size-fits-all regulation only tends to work for one size of agriculture - the largest industrialized operations. That's why it is important to let members of Congress know how food safety proposals will impact the conservation, organic, and sustainable practices that make diversified, organic, and direct market producers different from agribusiness. And the work doesn't stop there - if Congress passes any of these bills, the FDA will have to develop rules and regulations to implement the law, a process that we can't afford to ignore.

But simply shooting down any attempt to fix our broken food safety system is not an approach that works for consumers, who are faced with a food supply that is putting them at risk and regulators who lack the authority to do much about it.

You can read the full text of any of these bills at http://thomas.loc.gov.

If you'd like to send a message to your representative about how you feel or for more information please visit www.organicconsumers.org or http://capwiz.com/grassrootsnetroots/issues/alert/?alertid=12878056

Your choice of TP really is important

I used to chuckle when I went to the grocery store at the sheer volume of TP choices. There seems to be every possible variation of recycled content, length, strength and ply available. I used to stare at the wall of glossy packets weighting price over absorbency, amused that I had to actually put thought into what toilet tissue to get.

Well it turns out that our choice of TP really is important. According to the good folks at Greenpeace, TP from made from virgin forests is responsible for untold amounts of environmental devastation.

To read a really good article on this visit www.guardian.co.uk

To learn more about Greenpeace's campaign and to download a pocket guide see www.greenpeace.org

Tell Mars and Hershey's to sign the Non-GM Beet Sugar Registry

As a Valentine to Consumers, 73 Companies Pledge Not to Use Sugar from Monsanto's Roundup Ready Sugar Beets - Tell Hershey's and Mars to Sign!

Today the Center for Food Safety, along with environmental and corporate watchdog groups, launched the Non-Genetically Modified (GM) Beet Sugar Registry, documenting commitments from over seventy grocery chains and food producers including Organic Valley not to use or sell GM beet sugar. This call to halt the introduction of GM sugar beets into the food supply comes on the heels of public outcry over mercury contamination of our nation's dominant sweetener - high fructose corn syrup - and on the eve of the year's sweetest holiday - Valentine's Day.

By signing on to the Registry, companies:
* Pledge to not support the introduction of sugar from GM sugar beets;
* Pledge to avoid, wherever possible, using GM beet sugar in their products;
* Pledge to ask the sugar beet industry to not introduce GM beet sugar into our nation's food supply

Companies have rejected GM sugar beets not only because they have not been proven safe but also because the EPA had increased allowable levels of herbicide residues on GM sugar beet roots by up to 5,000 percent when USDA approved the crop for planting. This action was taken at the request of Monsanto, the sole manufacturer of GM Roundup Ready sugar beets. Extracted from the roots of the GM sugar beet plant, this type of sugar will be used in processed food and sold, unlabeled, to consumers beginning this year. The Registry website is a place where people can go to identify and support those companies that choose to publicly renounce the use of GM beet sugar.

In 2001, Hershey's and Mars announced that they would not use GM beet sugar, but both companies have been noticeably silent on the issue ever since. Members like you have sent more than a hundred thousand letters to food companies asking them to publicly refuse to use GM sugar in their products - let's tell Hershey's and M&M Mars to show us the love this year!

Tell Hershey's and Mars to Kiss GM Sugar Goodbye! Send your Valentine to Hershey's and Mars urging the companies to publicly reject the use of GM sugar in their chocolates and other sweets.

To learn more visit truefoodnow.org

To see a list of companies see: www.seedsofdeception.com

USDA Gives Preliminary Approval to New Pesticide-Promoting GE Corn Variety

From the Center for Food Safety: "USDA's Animal and Plant Health Inspection Service (APHIS) has given preliminary approval to the first of a new generation of pesticide-promoting, genetically engineered crops designed to survive spraying with multiple herbicides. This GE corn variety was developed by DuPont subsidiary Pioneer Hi-Bred International to tolerate applications of glyphosate (the active ingredient in Roundup) and acetolactate synthase-inhibiting herbicides (ALS inhibitors). This latest petition to deregulate a new, untested, and complex GE crop poses food safety, environmental, and agronomic concerns that were not adequately evaluated by the Bush Administration's USDA."

To read more about this and to take action please visit the Center for Food Safety website at: http://ga3.org/campaign/PioneerCorn

The New Secretary of Agriculture

Former Iowa Governor Tom Vilsack has been appointed by President-elect Obama to head up the USDA. The Organic Consumers Association (OCA) has a lot to say about this appointment. They say "his overall record is one of aiding and abetting Concentrated Animal Feeding Operations (CAFOs) or factory farms and promoting genetically engineered crops and animal cloning." Tom Vilsack is also a strong supporter of ethanol as an alternative fuel. If you agree with the OCA, you can join their petition to oppose the appointment of Former Iowa Governor Tom Vilsack here.

Slow Food

Every heard of Slow Food USA? From their website: "Slow Food is an idea, a way of living and a way of eating. It is a global, grassroots movement with thousands of members around the world that links the pleasure of food with a commitment to community and the environment." They also have a blog and on their blog today they are urging their readers to speak and let President Elect Obama know who they think the future Secretary of Agriculture should be. Read their post & speak up too here!

Also don't forget, post a comment below before December 15th and be entered into our Holiday Giveaway for a chance to win a co-op gift card for $100!

The Winner will be announced on this blog on December 16th so be sure to check back to see if you won!

Stand Up for Small Organic Farmers ... Contact USDA!

From the Cornucopia Institute:

Organic Stakeholders Demand Democracy from the USDA
Take Action: New Rules Could Force Organic Family Livestock Farmers Out of Business

After eight years of political debate, legal wrangling and protests within the organic community the USDA on October 23 finally published a draft rule intended to clamp down on giant factory farms milking thousands of cows that have been abusing the spirit and letter of federal organic law by primarily confining their cattle to feedlots.

The USDA could have made minor regulatory language changes to the current rule that would have clarified and forced the grazing of cattle. Instead, the USDA completely rewrote the complicated organic livestock standards without input from the organic community or the National Organic Standards Board. And they have given the organic community-farmers, consumers, retailers and processors-just 60 days to digest the sweeping changes and submit comments to government regulators.

Unfortunately, it has taken the groups that represent organic farmers over 30 days just to understand the true meaning of the complex USDA draft rule and to develop the many needed and major revisions. While the draft rule that the USDA presented would effectively clamp down on factory farm scofflaws, it would also probably put out of business the majority of all family-scale livestock farmers in the United States. This is unacceptable.

The groups Cornucopia has collaborated with will seek additional input and distribute a number of suggested changes to the entire organic community shortly. But with the election, the end of fall harvest, Thanksgiving, and the build-up to Christmas, all falling within the 60-day time window for public comment, we believe we simply need more time to share these changes with all organic stakeholders.

A high percentage of organic farmers in the country, maybe 30% (including Amish families), do not typically use e-mail. It is imperative that all stakeholders have a chance to have a voice.

Please send a message to USDA Secretary Ed Schafer (agsec@usda.gov) asking him to extend the public comment period by 30 days!

Your message does not have to be long or complicated. Merely saying that in order to protect the rights of all organic stakeholders we respectfully request a 30 day extension to the public comment period relating to organic livestock. In your message, be sure to note the docket number for this proposal: Docket No. AMS-TM-06-0198; TM-05-14.

The Cornucopia Institute will soon supply all of our members and others in the community with a full analysis and recommendations that will help stakeholders submit informed and focused comments in support of family farmers and organic integrity. We hope to send this out by early December-but the crush of holiday mail will slow the receipt of this critical information for many. The current deadline for comments is December 23. The recommended 30-day extension would move that date to January 23.

In the meantime, the following documents are available on the Cornucopia Institute's www.cornucopia.org at the USDA Pasture/Livestock Rulemaking link. On this page you will find:

1. A sample letter asking the USDA to extend of the public comment period from 60 to 90 days.

2. The official USDA announcement of rulemaking including analysis as printed in the Federal Register.

3. The proposed USDA draft pasture/livestock rule.

4. A preliminary draft of the recommended livestock rule language from a consortium of public interest groups representing organic farmers and consumers, including The Cornucopia Institute and FOOD Farmers (available within the next day).

In addition, there are four public listening sessions being sponsored by the USDA to gather input on the proposed new rule. They are scheduled for:

* Tuesday, December 2
1:30-4:30 p.m.
Organic Valley Family of Farms Headquarters
One Organic Way
LaFarge, WI 54639

* Thursday, December 4
1:30-4:30 p.m.
California State University - Chico
University Farm Pavillion
311 Nicholas C. Schouten Lane
Chico, CA 95928

* Monday, December 8
1:30 - 4:30 p.m.
Extension Research Facility, 6500 Amarillo Boulevard West
Amarillo, TX

* Thursday Dec. 11
9:30AM - 12:30 PM
The Family Center of Gap
835 Houston Run Drive, Suite 200
Gap PA 17527

And the state of Montana is also holding a listening session. That will be held:

* Friday, December 5
6:30 PM.
Holiday Inn
5 E Baxter Ln
Bozeman, MT 59715

Please stay tuned for more information from us. It is incredibly important that we get this rule right as the future of so many ethical organic livestock producers, and access to legitimately produced organic food products, are at stake.

FDA's Latest Threat to Dietary Supplements Defies the Dietary Supplement Health and Education Act

The American Association for Health Freedom (AAHF) and its international affiliate, the Alliance for Natural Health (ANH) are calling attention to the some serious changes the FDA is making to policy that will affect dietary supplements. Read the press release on the AAHF website at www.healthfreedom.net!

President-Elect Obama: Please Support Organic Food & Farming

The purity and availability of local, organic food is something that we know is very important to our member-owners.

The election of Barack Obama brings a possibly once-in-a-lifetime opportunity to significantly shift the focus of our national agricultural policy away from the Monsantos and "Big Agriculture" companies of the world to sustainable, family farms and organic agriculture. We need to make our voices heard to encourage Obama to keep that in mind in making his choice for Secretary of Agriculture and how he drives agricultural policy.

Please consider signing the petition from the OCA (Organic Consumer Association) to President-Elect Obama.

Just go to http://salsa.democracyinaction.org/o/642/petition.jsp?petition_KEY=1737 and fill in the form.

The OCA website is a great resource for all kinds of information, organic news, activism, sustainability, and much more. Right now there's a really great interview of Michael Pollan on thier site. Check it out! www.organicconsumers.org

GE Animals: Coming to a Supermarket Near You?

Genetically engineered animals may be heading to your local supermarket faster than you think. Though creating animals in a lab sounds like science fiction, it's happening right now: Genetically engineered super salmon, which grow twice as fast as normal farmed salmon, goats engineered with spider genes to produce silk in their milk, and pigs engineered with mouse and bacterial DNA to improve digestion.

The Food and Drug Administration (FDA) is currently accepting public comments on its draft guidance for the commercialization of such GE animals, opening the way for grocery stores to sell food made from genetically engineered animals. And the agency is proposing that these products be sold to you without your knowledge.

The jury is still out on whether food from these animals is safe for humans or the environment. And the ethics of such changes have yet to be considered. In fact, FDA says the ethics of engineering animals for food production cannot even be considered in its decision-making!

FDA says they will conduct a safety review before these foods can be sold for human consumption. But consumers won't know if they're buying food from genetically engineered animals, because the agency is refusing to require labeling - robbing us of our right to know what's in our food.

The FDA draft guidance would treat genetically engineered animals under its new animal drug provisions. While the new guidance would require a long-overdue review process, the proposed FDA rules are seriously flawed. While regulating genetically engineered animals through the more rigorous "new animal drug" provisions is good news - meaning each new GE animal would have to get FDA approval before going to market, like new drugs do - the secrecy inherent in our current drug approval process is bad news for consumers. In addition, FDA's limited review will only be for efficiency of the GE process, the safety of the GE process on the animal, and will not require extensive testing of the foods derived from such animals. Moreover, the review will not cover environmental issues like impacts to wildlife or biodiversity.

Under this draft, the public cannot know if the review of a product met the highest scientific standards until after its approval, and then they cannot avoid the product in the marketplace because it is not labeled. The FDA feels it deserves the public's trust, but refuses to give us the tools to verify that it is doing its job fairly and adequately.

What's worse, FDA is not proposing actual regulations, but rather a non-binding "guidance" document that continues the anti-regulatory shift of risk from those producing genetically engineered animals and foods to those consuming them.

The public comment period is only open until November 18th - Please, tell FDA to ban the use of such animals for food. If any such animals are to be considered, FDA must require labeling of food products from all genetically engineered animals, an open, transparent, and participatory review process of any such genetically engineered animals, and include a meaningful consideration of the ethical implications and environmental impacts of genetically engineering animals.

Your voice should be heard on this issue. The docket number for it is FDA-2008-D-0394.

To comment on this go to http://www.regulations.gov click on one of the "add comment" (looks like a yellow speech balloon) and fill in the form.

Or go to http://ga3.org/campaign/GEanimals.