Subject: Do Not Approve GE Pharmaceutical Production Protocols; Allow Public Comment
April 5, 2004
Dear Secretary Kawamura,
OTA urges you not to approve at this time any protocol for any agricultural product genetically engineered to produce pharmaceutical substances, specifically, at this time, the Ventria Biosciences pharmaceutical rice varieties.
The Organic Trade Association (OTA) is a membership-based organic business association with over 1400 members, representing all sectors of the organic industry throughout North America.
Allowing the open planting of agricultural products genetically engineered to produce pharmaceutical substances should be of grave concern not only for organic producers but for conventional agricultural producers as well. USDA is only beginning a process to produce an environmental impact statement for genetically engineered (GE) crops. Problems with contamination of neighboring crops have been widespread, both for wind-pollinated and self-pollinated plants. Gene transfer in open agricultural systems is still poorly understood, but it is clear that gene flow is common rather than rare. The potential for economic loss to both conventional and organic rice producers is great, as Japan and Europe both have strict requirements for food not to be contaminated with genetically engineered varieties.
Please allow a public comment period on these matters in order to gather pertinent data before making any decision.
Thank you very much.
Associate Policy Director, Organic Trade Association
P.O. Box 547, Greenfield, MA 01301
Phone: (413) 774-7511, ext. 14; Fax: (413) 774-6432
The Organic Trade Association is the membership-based organic business association representing all sectors of the organic industry throughout North America. OTA's mission is to encourage global sustainability through promoting and protecting the growth of diverse organic trade.