NATIONAL CAMPAIGN FOR SUSTAINABLE AGRICULTURE
URGENT ACTION ALERT (3/15/04)

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Tell USDA that Contamination of our Food Supply is Unacceptable! 
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PLEASE SUBMIT PUBLIC COMMENTS TO USDA BY TUESDAY, MARCH 23. 

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 on the agency’s web
pages.. The USDA allows interested parties to comment on this important
issue, so please take action this week. 

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 sample comments (below) to your networks,
your friends and family. A formatted, downloadable version of this alert
and sample comments can be found at
http://www.sustainableagriculture.net/alertsMain.php.

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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@aphis.usda.gov, and include "Docket No. 03-031-2"
in the subject line. The comment deadline is MARCH 23, 2004. 

You can also submit comments via postal mail (send an original and three
copies) to:

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

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. 


* * Sample comments * *

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 Sir or Madam:

Thank you for the opportunity to comment on USDA Docket No. 03-031-2
regarding the environmental impact statement you are 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. 

I am 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.

I am 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.

Thank you for taking these concerns into consideration. 

Sincerely,

________________________________________________________________________________
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. 
________________________________________________________________________________

National Campaign for Sustainable Agriculture
P.O. Box 396, Pine Bush, NY 12566
Tel: (845) 361-5201, Fax: (845) 361-5204
Email: Campaign@sustainableagriculture.net
www.SustainableAgriculture.net


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Is Building a Burger Manufacturing a Product?
By Congressman James E. Clyburn (D-SC)
Black Commentator

Thursday 14 March 2004

Many Americans remember the old McDonald’s commercial that had us all hungry for “two all-beef
patties, special sauce, lettuce, cheese, pickles, and onions on a sesame seed bun.” When you felt
compelled to purchase one of those concoctions, did you feel as though you had just bought a product
similar to the factory-produced computer that sits on your desktop? Or the desk it sits upon? The Bush
Administration seems to think you should. 

The President sent his new Economic Report to Congress last month, and buried among the 417
pages was the Administration’s query about reclassifying fast food workers as manufacturing positions.
The New York Times reports the White House drew a box for emphasis around the section that
laments the current system of classifying jobs “is not straightforward.” The report went on to ask,
“When a fast-food restaurant sells a hamburger, for example, is it providing a ‘service’ or is it combining
inputs to ‘manufacture’ a product?” According to the Administration’s logic, fast food production is the
equivalent of producing an automobile or manufacturing a computer. 

It seems, however, that there is a more logical explanation as to why this Administration would like to
add burgeoning fast food industry jobs into the dwindling manufacturing column. It is a good
old-fashioned shell game. 

This President has been under fire from news commentators and presidential aspirants for the growing
number of manufacturing job losses we are experiencing in this country. And exit polling of those voting
in recent primaries indicated that jobs were their top priority, and rightly so. 

The day after the President gave his annual State of the Union Address, his wished for “bump” was
usurped by headlines similar to the one which appeared in a South Carolina newspaper that decried
three straight years of job losses in the State. According to the accompanying article this is the first
time South Carolina has experienced such a fate since the Great Depression, better known to those of
us who came of age in the 40’s and 50’s as “Hoover Days.” South Carolina has lost 15,000
manufacturing jobs in the last year alone. Our textile industry has dwindled to around 60,000, less than
half its force a decade ago. The headlines are equally bleak across the country. 

Combining that all-beef patty, special sauce, lettuce, cheese, pickles, and onions on a sesame seed
bun may require a form of production, but it doesn’t constitute a product. Would Mr. Bush differentiate
between the fast food employees who make the sandwiches and those who ring up the orders? How
about between the ones who cook the French or “freedom” fries and the ones who “bust” the tables?
That sandwich may be as popular as a BMW but it is not assembled in a factory and shipped to
outlets, creating jobs for truck drivers, railroad employees and air and sea workers. For most
Americans, a trip to a fast food establishment is an abbreviated visit to a full-service restaurant. What
can we expect to see next, the job of making a Singapore Sling reclassified to one of manufacturing? 

Just as that jingle sticks in the American consciousness, the mass exodus of job losses is having a
similar impression on this nation’s people. I have high regards and great respect for those who work in
fast food restaurants, but instead of looking for ways to cook the books to create the illusion that the
valuable services they render are a form of manufacturing jobs, this President ought to spend more time
and energy creating more meaningful jobs and protecting those that already exist.