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October 29, 2000


Labeling & anti-corporate behavior; Non-Molecular


In response to two recent postings (greatly abbreviated below) I have the
following to offer.
1.) I think Andrew Apel is right about the risk of labeling "GM free", but
what about voluntary labeling "guaranteed to contain flavor-enhancing (or
some other benefit) GMO products"? How can the anti's object to that? The
novelty alone would sell such a product, and if it's good, the buyer will
come back. The catch is, there has to be some benefit to the final
consumer. I brought this up a while ago but got no nibbles.

2.) Elizabeth Whelan's diagnosis of anti-corporate agenda underlying
Greenpeace's anti-biotech agenda is not limited to the UK. As anyone who
has read several of Jeremy Rifkin's books will agree, his master plan is
to rid the world of the root of all evil--the American-based multinational
corporations. From this goal he has not budged in over 20 years of
publishing. Most scientists can't get past the aggravating sound bites to
understand his main agenda. Biotech is his most convenient and powerful
weapon at present. Before biotech Rifkin used the decline of union jobs,
nuclear power, and the bicentenniel celebration as hooks to incite
socioeconomic revolution. I say this with some authority, having read all
his books cover to cover. They spell out the master plan quite
clearly...everything except how to make New York City disappear.
Andrew Apel
There is one very big reason for opposing food labeling, mandatory or
voluntary. As we all know, from the recent news, activists are running
around everywhere testing foods for GM content. In such a climate, any
food company with a "GM Free" label, mandatory or not, risks an expensive
recall and a class-action lawsuit. .........

Elizabeth M. Whelan (ACSH) WROTE: The answer here appears to be that what
fuels the anti-biotech sentiment,at least among the movement's leadership,
is not health and environmental concerns, but political and ideological
ones. ...... they would reject the food (and let people starve) rather
than to do business with large American profit-making institutions.
Mary Ellen Jones, Ph.D.
Virginia Polytechnic Institute and State University PPWS Glade Rd.
Research Facility Blacksburg, Virginia 24061-0330 office: 540-231-8073

Subj: Response to Drew Kershen's Request for Information
From: "Henry I. Miller"

The following reference has much of the information you requested:

Goodman RM et al. Gene Transfer in Crop Improvement. Science 1987; 236:
48-54. It is particularly useful because it describes wide crosses --
crafted by PRE-RECOMBINANT DNA techniques -- that have given rise to
organisms that do not and cannot arise in nature (unlike Kershen's
examples of the nectarine, a mutant peach, and the tangelo, a
tangerine-grapefruit hybrid). (These data give the lie to claims that
recombinant DNA manipulations that move genes across "natural breeding
barriers" have no precedents and constitute a technological disjunction.)
These wide crosses are "transgenic" by any reasonable scientific
definition and may be considered "non-molecular transgenics," while
organisms crafted with recombinant DNA techniques that contain
trans-species DNAs are "molecular transgenics."

See also the following excerpt from Chapter 1 of Miller, Henry I., "Policy
Controversy in Biotechnology: An Insider's View," R.G. Landes Co.
[rglandes@rglandes.com], 1997.


Then there is the agricultural "green revolution" which has dramatically
increased human longevity and improved the quality of life in developing
countries. The green revolution might be viewed as the culmination of a
long quest begun by ancient agriculturists who attempted to cultivate and
domesticate wild plants. With the rediscovery in 1900 of Gregor Mendel's
concepts of inheritance, plant breeders ushered in the era of scientific
application of genetic principles to crop improvement. Twentieth century
plant breeding, even before the advent of rDNA methods, sought ways to
take advantage of useful genes and gradually has found a wider and wider
range of plant species and genera on which to draw. Breeders first
achieved interspecies hybridization, transferring genes between different,
but related species. Eventually, plant geneticists found ways to perform
even wider crosses between members of different genera. The offspring of
such crosses normally are not viable because the resulting embryo has an
abnormal endosperm. With the development of tissue culture techniques,
however, the hybrid embryo could be provided conditions similar to those
supplied in early development by the normal endosperm and maternal
tissues. Crops resulting from such "wide crosses" are commonly grown and
marketed in the U.S. and elsewhere. They include familiar and widely used
varieties of tomato, potato, corn, oat, sugarbeet, bread and durum wheat,
rice, and pumpkin.

Recombinant DNA techniques have refined these methods by enabling plant
breeders to identify and transfer single genes encoding specific traits of
interest. They can now readily move selected and well characterized
genetic material from any source in nature, greatly increasing the
diversity of useful genes and germplasm available for crop improvement. In
addition, safety assessment of plants is enhanced by the greater precision
and predictability of rDNA techniques.

Myth Two: Novel and Dangerous Organisms will be Created. Does the
introduction of a single gene or several genes, judged against the
background of tens or hundreds of thousands of the host organism's own
genes, create a "novel" organism? Could the introduction of a single gene
from a known pathogen convert an otherwise benign organism into a
pathogen? These questions have been widely debated and answered, as
reflected by the NAS, NRC and other groups described in the following

How novel is a corn plant with a newly-inserted gene for a Bacillus
thuringiensis endotoxin which confers endogenous protection against
European corn borer? It is, after all, still a corn plant. How novel is
the laboratory bacterium Escherichia coli (E. coli) K-12 with a
newly-inserted gene for human alpha interferon? It only varies from the
unmodified strain in one gene. Does a tomato plant become pathogenic (or
give rise to novel pathogenic recombinants) after insertion of a small
amount of well characterized DNA from Agrobacterium tumefaciens, a known
plant pathogen?

Consider, first, whether genetic recombination, itself, is of concern. It
has already been established that people have for millennia engaged in
genetic recombination in the production of domesticated microbes, plants,
and animals. But the impact and importance of these genetic changes pale
in comparison with what occurs in nature. Innumerable recombinations
between related and unrelated organisms have occurred by several
mechanisms.8 Sexual reproduction randomly combines genes from two parents
in the offspring, which then has a unique set of genes to pass along to
the next generation. In the gut, decomposing corpses, and infected wounds,
bacteria take up naked mammalian DNA, albeit inefficiently, when they
encounter disintegrating cells. Over the past million years and longer,
mammalian-bacterial genetic hybrids have appeared, been tested by
competition within bacterial populations and by environmental stresses,
and have been conserved or discarded by natural selection. Genetic
hybridization also has been rampant among fungi, viruses, and plants.

Similar to the wide crosses in plants described above, certain kinds of
gene transfers thought until recently to be impossible in nature because
of phylogenetic distances are now known to occur. Brisson-Noel et al have
demonstrated that a gene (or genes) for erythromycin resistance was
transferred between the gram-negative bacterium Campylobacter and
unrelated gram-positive bacteria.9 In recent laboratory experiments, it
was demonstrated that gene transfer can occur between E. coli and
streptomyces10 or yeast,11 and that the crown gall disease in plants
results from a natural transfer of DNA from Agrobacterium to plant cells.
In fact, knowledge of the nature of this mechanism led to the development
of an effective means of transferring selected genes into plants using
Agrobacterium DNA.12

Evolutionary studies provide data relevant to the issue of the "novelty"
of molecular chimeras created by rDNA gene-splicing. Does the transfer of
a moth gene into a squash affect the "squashness" or transfer "mothness"
to the new hybrid? The sequencing of various genomes during the past
decade has revealed that nature has been remarkably conservative about
maintaining and using effective molecules as they evolved. Nearly
identical DNA sequences and biochemical pathways are found in different
species, across genera, and even across phylogenetic kingdoms. Scanning
the sequence of the E. coli genome, for example, reveals gene sequences
that are virtually identical to those in a variety of organisms, ranging
from other bacteria to plants, insects and humans.13 With such broad
conservation and "sharing" of genes in nature, debates over the
proprietary nature of "human," "plant," and "bacterial" genes and over the
"novelty" of a squash plant that contains a moth gene become moot.

9. Brisson-Noel A, Arthur M, Courvalin P. Evidence of natural gene
transfer from gram-positive cocci to Escherichia coli. J. Bacteriol. 1988
170:1739. 10. Mazodier P, Petter R, Thompson C. Intergeneric conjugation
between Escherichia coli and Streptomyces species. J. Bacteriol. 1989;
171:3583 11. Heinemann JA, Sprague Jr GG. Bacterial conjugative plasmids
mobilize DNA transfer between bacteria and yeast. Nature 1989; 340:205.
12. Nester EW, Gordon MP, Amasino RM, et al. Crown gall: A molecular and
physiological analysis. Annu. Rev. Plant Physiol. 1984; 35:387-413. 13.
Takemoto K., Yano M, Akiyama et al. GenoBase 1.1 Escherichia Coli, March

>From: "Kershen, Drew L" < Subject: Request for
information on trans-species organisms

Subj: Lord Melchett: The payoff & the hypocrisy
From: Andura Smetacek

Well, now we know. After a vigorous few years attacking biotechnology,
hiring anti-GMO/pro-organic "marketing campaigners," and spreading fear
about conventional foods to help create a market for "organic" products,
Lord Melchett is leaving Greenpeace to go to work for organic industry
retail leader Iceland Foods.

Consider the outcry and the claims of pay-offs from activists were an NGO
leader who supports biotechnology (like Jimmy Carter or Norman Borlaug) to
become a paid consultant to Novartis, or God-forbid, Monsanto or
Aventis... Yet not a peep from them or the media with the good Lord's new
found employment.

Yet anyone who takes a dime from for research or even philanthropy from
the biotech industry is immediately cast as "tainted, bought or biased" by
activists and the media alike. Any pro-biotech group is always noted in
the media as "industry funded" yet Greenpeace and the other activists are
rarely characterized as such (although they receive big $$ and inkind
support from companies like Ben & Jerry's and others who market their
products as organic or natural).

However, the other aspects of Lord Melchett's "retirement" reveal an even
great hypocricy and conflict of interest. According to the Mirror
Newspaper his family farm is "now ready to fully convert to organic

Now ready? Lest we forget his admonissions to Monsanto's CEO Bob Shapiro
last year that Greenpeace would not consider working with Monsanto to
resolve their differences until Monsanto converted their efforts 100% to
organic farming.

Yet at that time, it seems that Melchett was not following his own advice
on even one percent of his land.

As reported in the Farmers Weekly (March 19, 1999) Melchett's 800 acres in
north-west Norfolk were not farmed organically at all. Indeed, Melchett
acknowledged this fact, according to a letter from him in response to that
article (April 2, 1999), noting that he was only then in the process of
converting about 30 percent of his fields (none yet converted). One can
reasonably assume that since the conversion process takes three years that
all of Lord Melchett's farm is still "non-organic" today.

His reasoning: the price and market for organic was not sufficient to
justify conversion, but as soon as those prices went up he'd make the

So Melchett helped create that market and increased prices through his
fear campaigns. Now complete, he can "retire" to his consultancy with the
food retailers whose pockets he's helped to line and to increase his
profits from his (soon to be) organic farm holdings.

Nice work if you can get it. Use tax-deductible donations (and government
funds) to create a better market for your own financial interests by
creating unfounded fears around your competitors products. It is no wonder
that the government of Canada has removed Greenpeace's "non-profit" tax
status noting their financial interests to their various shakedown

The Scotsman reports this week that a leading member of the organic
advocacy is now calling for increased studies into organic agriculture.
Specifically, David Atkinson told the Sir Maitland Mackie memorial lecture
now that their is big enough public support for organic agriculture
research is needed to reinforce the market and viability.

The lesson for biotechnology supporters. Next time hire the likes of
Greenpeace first to get the public support to support your product by
scaring the pants off them about your competitors... Then you can start
thinking about the actual research to prove your own product is safe and

It seems that money the biotechnology industry and governments spent over
the past 20 or so years on testing and research would have been much
better spent with some well-placed pay-offs to Greenpeace and a good
public relations campaign.

Genetically altered foods gets roasted at Ithaca forum:
Experts participate in modified-foods debate


The Ithaca Journal Monday, October 30, 2000

While occasionally sprinkled with humor, a discussion of genetically
modified foods among six panelists at Ithaca College on Sunday frequently
reached the boiling point.

The panelists, nearly all internationally known experts, converged on the
college for an inaugural taping of a student-produced television program
called "Ithaca Forum."

For nearly three hours, in front of a 200-person studio audience, they
debated almost every aspect of genetically modified foods -- foods that
have had their genetic makeup altered through biotechnology to create
products like insect-resistant corn and vitamin-rich rice -- occasionally
using ears of corn to help illustrate their points.

Panelist Dr. Ralph Hardy, former president of the Boyce Thompson Institute
for Plant Research at Cornell University, said that genetically
engineering foods was essentially an extension of traditional plant
breeding methods.

But Dr. Vandana Shiva, a physicist and ecologist who wrote "Biopiracy: The
Plunder of Nature and Knowledge," disagreed.

"We are crossing boundaries in new ways and we have not developed
adequately the tools to understand the implications," she said.

The panelists also discussed whether genetically modified foods could help
feed a swelling world population. Dr. Philip Regal, an expert on the
biology of and potential risks from recombinant DNA organisms at the
University of Minnesota, called the claim that biotechnology would solve
the complex problem of world hunger "absurd."

"Clearly, this is not going to be the only solution," said Dr. C.S.
Prakash, director of the Center for Plant Biotechnology Research at
Tuskegee University. But he said that biotechnology could be a key
contributor to solving hunger problems, helping crops grow under otherwise
marginal conditions, increasing productivity and cutting down on disease.

Also participating on the panel were Tony Del Plato, coordinator of the
Safe Food Campaign/Organic Consumers Association in Ithaca, and Dr.
Anatole Krattiger of bioDevelopments LLC, which has helped bring
biotechnology to developing countries.

Assistant television-radio professor Anthony Tenczar, who created the
"Ithaca Forum" idea and produced Sunday's event with associate professor
Jill Swenson, said he hopes to eventually show an edited version of the
program on a local cable-access channel or on public television.

(from Agnet)
Thanks to Conrad Lichtenstein for alerting me
to this.

2000 Science Volume 290, Number 5491, pp. 457-459.

Karen A. Goldman, an Adjunct Professor of Law at the Georgetown University
Law Center, Washington, DC 20001, USA, and Assistant Counsel to the
Inspector General at the National Science Foundation (this article was not
written in the author's capacity as a government official. Any opinions,
findings, conclusions, or recommendations are those of the author and do
not necessarily represent the views of the Office of Inspector General or
the National Science Foundation), writes that bills proposing to amend the
U.S. Federal Food, Drug, and Cosmetic Act (FFDCA) to address the safety
and labeling of bioengineered foods have been introduced in both houses of
the U.S. Congress. The Genetically Engineered Food Safety Act (GEFSA)
would make all transgenic components of bioengineered foods subject to
premarket review as food additives (1). The Genetically Engineered Food
Right to Know Act (GEFRKA) would require labeling of food that "contains a
genetically engineered material, or was produced with a genetically
engineered material" (2). Goldman says that many aspects of these bills
are inconsistent with well-established principles of food regulation.

Food additives are defined in the FFDCA as substances that are intended to
become components of food, but are not "generally recognized as safe"
(GRAS) through laboratory testing or long-standing use in food (3).
Manufacturers must submit data on the technical effects and safety of food
additives to the Food and Drug Administration (FDA), and approval takes as
much as 6 years (4, 5). Goldman says the FDA has not generally
characterized transgenes and other bioengineered substances such as
proteins, carbohydrates, fats, or oils as food additives, because they are
ubiquitous in living organisms and comparable to substances in foods
already on the market and are therefore GRAS. However, if a bioengineered
substance is not GRAS, the FDA can regulate it as a food additive (6).
Indeed, the FDA approved bioengineered aminoglycoside
3'-phosphotransferase as a food additive (7). Goldman says that since
1994, the FDA has held more than 40 voluntary consultations with
manufacturers to assess many of the same factors that would be considered
in a safety evaluation required by the GEFSA, including possible
allergenicity, toxicity, and changes in nutrient levels (6, 9). The FDA
recently announced that it will propose regulations requiring
manufacturers to notify it of their plans to sell bioengineered foods at
least 120 days before marketing and to submit information that the FDA
would evaluate to determine whether additional regulatory steps should be
taken (8). The GEFSA would be unnecessarily burdensome, because it would
regulate all bioengineered components of foods as food additives,
regardless of qualities or composition.

In addition, says Goldman, the GEFSA is unnecessary, because most
transgenic components of food have been evaluated for safety by the
Environmental Protection Agency (EPA), under standards similar to those
for food additives. Because nearly all of today's transgenic crops are
either pest-resistant or herbicide-tolerant (10), the bioengineered
components of most crops have been evaluated for safety (11) under legal
standards that originally applied to pesticide chemicals and their inert
ingredients (12). Approval of pesticides and food additives is based on a
determination of reasonable certainty that no harm will result from
cumulative dietary exposure (12, 13). In addition, for pesticides the
safety determination must apply to sensitive subgroups such as infants and
children, as well as the general population (12). When evaluating
bioengineered plant-incorporated protectants (PIPs) (14), the EPA
generally considers the same factors that would be required by the GEFSA
for all bioengineered components, including allergenicity and toxicity (1,
15, 16).

The EPA, says Goldman, concluded that bioengineered PIPs are safe for
human consumption at any anticipated level of dietary exposure (11, 15,
17). Indeed, bioengineered PIPs such as Bt, an insecticidal protein
derived from Bacillus thuringiensis, offer a benefit by replacing riskier
chemical pesticides (18). On the basis of Bt's history of safe usage,
rapid degradation by simulated gastric fluid in vitro, lack of acute oral
toxicity in rodents, and lack of potential for allergenicity, the EPA
approved bioengineered variants of Bt for human consumption (15-17).
However, the EPA limited the approval of the Cry9C variant to use in
animal feed, because of inconclusive results in tests designed to assess
its potential allergenicity (19). Bioengineered enzymes that make plants
herbicide-tolerant have also been evaluated for food safety, because they
are considered inert ingredients of pesticides when used as selectable
markers for PIPs such as Bt (20). The EPA determined that the major
herbicide tolerance-conferring enzymes were not toxic to rodents, were
rapidly digested in a gastric environment, and showed no evidence of
allergenicity. Thus, the EPA approved them and concluded that no maximum
allowable level is necessary to protect the public health (21-23).

The EPA's evaluations of PIPs and their inert ingredients have affirmed
their safety. Moreover, says Goldman, the FDA's new premarket notification
policy should give the agency ample information to decide when transgenic
components of bioengineered foods should be regulated as food additives.
Although recent reports of taco shells containing a small percentage of
corn expressing the Cry9C variant of Bt (24) indicate that limited use in
feed should be permitted only if the segregation of such products can be
ensured, food additive review under the GEFSA would not have prevented
this contamination.

Indeed, the EPA's review of Cry9C was particularly thorough, including an
evaluation by a scientific advisory panel (25). Accordingly, premarket
approval of all bioengineered foods as food additives is unwarranted and
inconsistent with established principles of food regulation. Mandatory
labeling of bioengineered food proposed by the GEFRKA is, says Goldman,
inconsistent with the historical exemption of pesticides from labeling
requirements. Disclosure of chemical pesticide and fungicide residues in
food labels was largely eliminated during a 1960's controversy that
strongly resembles today's controversy over labeling (11). At that time,
the FFDCA required disclosure in retail food labels of the residues of
certain fungicides applied after harvest. The FDA supported this
disclosure on the basis of consumer "right-to-know." However, insecticides
and herbicides did not have to be disclosed because of the difficulty of
tracking their residues from the beginning of crop production (26-28).
Food industry and state agricultural and land-grant college officials
asserted that fungicide labeling was burdensome and impractical, that
detection methods for pesticide residues were inadequate, and that there
would be widespread violations of the FFDCA and criminal liability. Some
stores refused to accept produce treated with disputed fungicides, and
there was fear of widespread economic loss (28). Because of these
concerns, Congress amended the FFDCA to end mandatory disclosure of
fungicides (27, 29, 30). Mandatory labeling of bioengineered foods could
be more burdensome than disclosure of fungicides applied after harvest. It
would require segregating and tracking an inherent, minute component of
food through the entire chain of food production, including planting,
harvesting, shipping, processing, and retail sale. Goldman says it would
be perverse to require disclosure of bioengineered PIPs when no labeling
is required for chemical pesticides (11).

More generally, the labeling provisions of the GEFRKA are contrary to
well-established tenets of food labeling under the FFDCA. The FFDCA
requires that labeling be truthful and not misleading (31) and that it
reveal material facts relevant to the use of the product (32). In United
States v. 95 Barrels of ... Apple Cider Vinegar, the Supreme Court
interpreted "material facts" to be facts about composition, not method of
manufacture (33).

Similarly, genetic engineering, a method of manufacture, has not been
construed by the FDA as a material fact requiring labeling, just as other
plant breeding methods are not required to be disclosed (6). The FDA has
concluded that as a class, bioengineered foods cannot be distinguished
compositionally from foods developed by traditional methods, and thus do
not require labeling. However, if bioengineering produces a material
difference, for example, through the introduction of an allergen, toxin,
or novel component such as a sweet protein, labeling would be required
(6). Accordingly, the FDA recently required labeling of bioengineered
soybean and canola oils with altered fatty acid composition (9).

In Stauber v. Shalala, consumer advocates were unsuccessful in their
effort to force FDA to require labeling of milk produced with the use of
recombinant bovine somatotropin (rbST), because the milk is
compositionally indistinguishable from milk produced without the hormone
(34). The district court concluded that a labeling requirement based
solely on consumer demand to know the method of manufacture would violate
the FFDCA (34). The GEFRKA seeks to overrule Stauber v. Shalala by
requiring labeling of food derived from animals injected with genetically
engineered materials (2).

The GEFRKA may also violate the First Amendment commercial speech rights
of the manufacturers of bioengineered foods by requiring labeling in the
absence of health and safety concerns. In International Dairy Foods Assoc.
v. Amestoy, the Court of Appeals for the 2nd Circuit held that a Vermont
law requiring labeling of rbST-enhanced milk violated commercial speech
rights of the dairy manufacturers, because it imposed the equivalent of a
warning about method of manufacture, even though the composition of the
milk was unaffected (35). Consumer "right-to-know" was insufficient to
compel labeling in the absence of a substantial government interest, such
as health or safety concerns (35). By this reasoning, the labeling
requirement in the GEFRKA for any food that "contains a genetically
engineered material, or was produced with a genetically engineered
material," could also be held unconstitutional.

The GEFRKA would require labeling and tracking of bioengineered foods
regardless of whether the altered characteristics of the genetically
modified organism are detectable in the food (2). The GEFRKA would require
labeling of milk or meat derived from animals that have been fed
bioengineered foods, even though no evidence suggests that the milk or
meat would be distinguishable from that of animals fed traditional foods
(2, 25). As bioengineered corn and soybeans are widely used as animal feed
in the United States (36), this requirement could lead to the meaningless
labeling of most milk and meat. These labeling provisions are extreme even
as compared with those of the European Union, which does not require
labeling in the absence of detectable transgenic DNA or proteins (37).
Finally, says Goldman, a labeling requirement would not prevent
inadvertent contamination, as recently occurred with the Cry9C variant.

Goldman concludes that both the GEFSA and the GEFRKA are inconsistent with
basic principles of food regulation, as well as current scientific
knowledge about bioengineered foods. Laws addressing the safety and
labeling of bioengineered food, or the regulation of any new technology,
should be based on sound science.
References and Notes
1.H.R. 3883, 106th Cong. (2000); S. 2315, 106th Cong. (2000). 2.H.R. 3377,
106th Cong. (1999); S. 2080, 106th Cong. (2000). 3.21 U.S.C. § 321(s)
4.21 U.S.C. § 348 (1998).
5.Delays in the FDA's Food Additive Petition Process, Hearings Before the
Subcommittee on Human Resources and Intergovernmental Relations of the
House Committee on Government Reform and Oversight, 104th Cong. 16 (1995).
6.57 Fed. Reg. 22,984 (FDA 1992).
7.59 Fed. Reg. 26,700 (FDA 1994).
8.FDA, U.S. Department of Health and Human Services, HHS News, P00-10, 3
May, 2000.
9.L. Thompson, FDA Consumer 34, 18 (January-February 2000). 10.D. Ferber,
Science 286, 1662 (1999).
11.K. A. Goldman, Georgetown Int. Environ. Law Rev. 12, 717 (2000). 12.21
U.S.C. § 346a (1998).
13.21 C.F.R. § 170.3(i) (1999) (food additives). 14."Plant-incorporated
protectants" have been called "plant-pesticides," but the latter will be
renamed in new EPA regulations. 65 Fed. Reg. 55,929 (2000).
15.61 Fed. Reg. 40,340 (1996).
16.62 Fed. Reg. 17,720 (1997).
17.60 Fed. Reg. 21,725 (1995).
18.N. Smith, Subcommittee on Basic Research, Committee on Science, 106th
Cong., 2d Session, Seeds of Opportunity (Committee Print 2000). 19.63 Fed.
Reg. 28,258 (1998).
20.59 Fed. Reg. 60,496 (1994).
21.61 Fed. Reg. 40,338 (1996).
22.62 Fed. Reg. 52,505 (1997).
23.62 Fed. Reg. 17,717 (1997).
24.A. Pollack, New York Times, 23 September 2000, p. C1. 25.EPA, Cry9C
Food Allergenicity Assessment Background Document (2000).
www.epa.gov/scipoly/sap/2000/february/12-9.pdf 26.H.R. Rep. No. 85-2119
27.H.R. Rep. No. 86-1468 (1960).
28.Chemical Preservatives: Hearings on H.R. 9521 Before a Subcommittee of
the House Committee on Interstate and Foreign Commerce, 85th Cong. 118
29.21 U.S.C. § 343(k) (1994).
30.The only exception is a requirement for disclosure of residues of
pesticides applied after harvest on shipping (not retail) containers of
raw agricultural commodities. 21 U.S.C. § 343(l) (1994). 31.21 U.S.C. §
343(a)(1) (1994).
32.21 U.S.C. § 321(n) (1994).
33.265 U.S. 438 (1924).
34.895 F. Supp. 1178 (1995).
35.92 F.3d 67 (2d Cir. 1996).
36.Economic Research Service, U.S. Department of Agriculture, Biotech Corn
and Soybeans: Changing Markets and the Government's Role, 29 March 2000,
37.Commission Regulation (EC) No. 49/2000 of 10 January 2000, art. 1, 2000
O.J. (L 6/13).
38.Office of the Press Secretary, The White House, Clinton Administration
Agencies Announce Food and Agricultural Biotechnology Initiatives, 3 May
39.U.S. Department of Agriculture, release no. 0147.00, 4 May 2000.