Bioengineered food disclosure is not a safety issue | Letters … – Iowa Farmer Today




The Coalition for Safe, Affordable Food … was actively engaged in support of the Bioengineered Food Disclosure Law, which calls for the establishment of a uniform national disclosure standard for bioengineered food and prevents a patchwork of state-by-state or other governmental subdivision food labeling requirements that would have driven up food costs for consumers.

The coalition has carefully studied the questions posed by USDA-AMS … The coalition’s responses are aimed at assisting USDA-AMS with fulfilling the multiple goals of the law, shared by the coalition, which include fostering consumers’ access to information about the food they eat; providing consumers with continued access to an abundant, safe, affordable and sustainable food supply; ensuring that farmers and ranchers have access to the technologies they need to feed a growing world population; providing food manufacturers with certainty in the supply chain; and respecting the strong scientific consensus on the safety of bioengineered food and, relatedly, preserving Congress’ intention that the agency implement a disclosure standard for marketing purposes, and not based on health, safety, or nutrition. …

“Conventional breeding” should encompass breeding methods that use the organism’s gene pool and other methods that enable efficient movement of native genes from un-adapted to elite organisms. As reflected in the bipartisan Senate report on the law, this approach is consistent with Congress’s direction that the USDA-AMS mandatory marketing disclosure program “be technology neutral and reflect technological changes over time.”

The concept of “conventional breeding” does not apply to most microorganisms, but many other forms of genetic modification have been applied to microbes for decades.

As is true of plants and animals, if the genetic modification could have been obtained by these well-established microbial genetic modification techniques, the resulting food product should not be subject to disclosure in the USDA-AMS mandatory marketing disclosure program. …

The law directs USDA-AMS to consider establishing consistency between the eventual National Bioengineered Food Disclosure Standard and the Organic Foods Production Act of 1990. The coalition supports consistency, where appropriate, to help reduce consumer confusion. …

USDA-AMS must acknowledge the clear statutory intent that food is not subject to the mandatory disclosure requirement solely because it is derived from animals fed bioengineered substances. …

When determining any threshold or amount of a bioengineered substance present in food that triggers mandatory disclosure, USDA-AMS should reinforce that the bioengineered food disclosure standard is a marketing standard, and not a health, safety or nutrition standard. In addition, the regulations should make clear that, whatever threshold or amount of a bioengineered substance triggers mandatory disclosure, voluntary disclosure below that level is permissible provided that the disclosure is truthful and not misleading. …

Although the mandatory disclosure standard is directed to marketing and not safety, health or nutrition, for consistency’s sake, the term “small food manufacturer” should be defined in the same way it is defined under the FDA’s Food Safety Modernization Act final rules, subject to notice and comment rulemaking, on preventive controls for human food, international adulteration of foods and sanitary transportation of foods. All three of these rules define a small business as “a business (including any subsidiaries and affiliates) employing fewer than 500 full-time equivalent employees.”


These comments are from remarks the Coalition for Safe, Affordable Food, representing 34 food and agriculture organizations, sent to the USDA Agricultural Marketing Service acting administrator regarding a proposed rule. The complete comments with the list of organizations is at http://bit.ly/2xgfQio.



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