Letter from The Project to Label Gene-Altered Food to the US Dept. of Agriculture regarding the creation of a national organic standard. The letter objects to the inclusion of gene-altered food in the category of organic food.

Eileen S. Stommes, Deputy Administrator
Room 4007 South, P.O.Box 96456
Washington, DC 20090-6456
Re: TMD94-00-2
Dear Ms. Stommes,
There are two constituencies to whom you have a direct responsibility in this matter. Their first concerns are your first concerns.
Your number one constituency is American farmers, the men and women who created you and continue to support your agency's existence. You are the U.S. Department of Agriculture.
The future income and welfare of American farmers are directly related to your decision in this matter. Do you remember Alar? That was your mistake. This docket issue should not become another Alar.
In the Alar incident, all apple growers were hurt when consumers learned that the alar used by some apple growers was dangerous for children. Children were exposed to excessive levels of alar because of their low body weight and high applesauce consumption. It was a risk you could have avoided.
In the future, all American farmers will be exposed to the same risk that apple growers were exposed to. You are the only agency responsible for protecting them. The alar event demonstrates what you and everyone else knows...the public is very anxious about the safety of the food supply and will react vigorously and unpredictably to perceived risks.
What can you do to protect farmers from future alar-like events?
You could conduct a public education campaign about food safety, you could develop quick response teams, anticipate specific problem areas, and label foods so that consumers know which products to worry about.
Each of these options bears directly on your decision in this docket matter.
Would public education work? Frankly, your credibility is low after the recent e-coli bacterial meat problems and will be lower if you make the wrong decision about the regulations regarding "organic food". It won't just be low, you will in fact be ridiculed.
Quick response teams, anticipation of high risk areas? The nature of the food supply is its great diversity with more than a million independent producers and tens of thousand of species in the pipeline. There is no rational anticipation of problems. Problems arise because they can't be anticipated by people of goodwill. You are always
stuck responding to food supply problems after the fact.
You can only respond after the press has frightened the already-skittish public. Ineluctably you will always be too late.
The only answer, a solution that I believe is your obligation, is to "partition" the food risk problem. If you know that purple foods pose a greater risk than other colors then you make sure that purple foods become unambiguous. Label rhubarb as "purple". Then when a "purple" problem arises people won't stop eating red apples, red beets or other food that might be mistaken for purple foods. Partition the problem by using labels to separate categories that encompass different levels of risk.
You know, we all know, that genetically engineered foods are new, and that food safety risks are higher in this category than in most others. It is therefore morally imperative that you label genetically engineered food as different from other foods. You need to do this for many decades into the future, while this type of food is novel.
You must do this to protect all the farmers who do not grow genetically engineered crops. The first opportunity that presents itself to you, for doing this, is to use the label "organic" to exclude genetically engineered foods. Take that first step on behalf of your farmer constituency, now.
Your second constituency is the tens of thousands of employees of your agency and their families. Their interest is in working for a respectable employer. Your responsibility to them is to avoid public shame and humiliation for your agency, as best you can. The docket issue under consideration opens you up to public ridicule, if you make the wrong choice.
We, the public, the press and your employees, know that the popular meaning of the term "organic food" does not include genetically engineered food. The popular term "organic food" embodies in its meaning a rejection of industrial improvements in the food supply. That popular meaning blatantly excludes genetically engineered crops. Corn with an inserted cluster of bird genes and soy beans with inserted fish genes are not considered "organic food".
A wrong decision on this issue will make the U.S.D.A. a laughable agency and will consequently make the everyday of work of each employee of your agency a humiliating experience.
The correct decision for you to make, the decision that reflects the needs of your two prime constituencies (farmers and employees), is to reject genetically engineered food from the category "organic food".
MIchael Phillips, Director
The Project to Label Gene-Altered Food is a non-profit grass roots organization founded in 1993 to lobby and educate.
April 1998