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October 24, 2000
President William Jefferson Clinton
The White House
1600 Pennsylvania Avenue NW
Washington, DC 20500
Dear President Clinton,
We appreciate your involvement in the growing
concerns about an unapproved variety of genetically engineered corn
that has contaminated the human food supply. A number of food
companies have recently withdrawn several products over concerns that
StarLink, a genetically engineered crop approved only for animal
feed, has contaminated their corn supply. Some of the nation's
largest food makers are facing production problems due to their
inability to find uncontaminated corn.
When a Kraft Foods product was found
contaminated with StarLink corn, the company took responsible action
by voluntarily recalling the product. Later, when the Food and Drug
Administration confirmed the positive test result, the agency ordered
a Class II recall. FDA defines a class II recall as "a situation in
which use of, or exposure to, a violative product may cause temporary
or medically reversible adverse health consequences or where the
probability of serious adverse health consequences is remote."
We are very concerned about recent reports
suggesting that foods now found to be contaminated with StarLink may
be treated differently than the Kraft product. According to press
reports, a "solution" to the problem of StarLink contamination now
being considered by government officials is to exempt StarLink from
the requirement for a tolerance, for food as well as feed uses. This
would allow an unlimited amount of StarLink corn in the food supply.
It would be unacceptable to approve this genetically engineered
product in the human food supply simply for the convenience of
industry. Any such action would show a troubling disregard for
consumer protection that could only further erode consumers'
confidence in our regulatory system for biotechnology products.
The biotechnology industry was permitted to
sell StarLink to farmers on the condition that systems were in place
to insure that the corn was used only for animal feed or industrial
use. Mounting evidence shows that many farmers were unaware of the
restrictions when sold StarLink seed. StarLink seed bags and seed
contracts apparently confirm that many farmers were not informed of
the restrictions agreed to by industry. As a result, StarLink corn
has pervasively contaminated the food supply.
The industry must not now be rewarded for
violating the law by an after-the-fact approval of a potentially
dangerous product.
Scientists have concerns that StarLink corn
could trigger potentially dangerous allergic responses in people.
There is no known history of human dietary exposure to the Cry9C
protein produced in StarLink corn. Moreover, the concentration of
this protein in StarLink seeds is up to 100 times that of the Cry
proteins found in other engineered corn varieties. The Environmental
Protection Agency's (EPA's) review of StarLink found that many of the
allergenicity data submitted on StarLink were "either inconclusive or
indicate that Cry9C exhibits some characteristics of known
allergens." There is no known safe level of allergens in food, as
some scientists warned EPA just last Friday.
We urgently request your swift and decisive
action to insure that EPA does not retroactively approve StarLink
corn for human consumption, and to see that FDA takes no action to
set tolerance or action levels for Starlink corn. We also ask that
you use your influence to insure that biotechnology companies that
violate the law are held accountable for losses suffered by farmers
and food producers.
Science, not political expedience, should be
the basis for regulatory action. We look forward to your leadership
in this urgent matter.
Sincerely,
John Passacantando, Executive Director
Greenpeace USA
Margaret Mellon, Director of the Food and
Environment Program
Union of Concerned Scientists
Jean Halloran, Director
Consumer Policy Institute/Consumers
Union
Andrew Kimbrell, Executive Director
Center for Food Safety
Laurel Hopwood, Chair, Genetic Engineering
Committee
Sierra Club
Rebecca Goldburg, Senior Scientist
Environmental Defense
Larry Bohlen, Director, Health &
Environment Programs
Friends of the Earth
Bill Christison, Executive Director
National Family Farm Coalition
Richard Caplan, Environmental Advocate
State Public Interest Research Groups (State PIRGs)
Ellen Hickey, Program Director
Pesticide Action Network North America
Phil Clapp, President
National Environmental Trust
Niel Ritchie, National Organizer
Institute for Agriculture and Trade Policy
CC: Vice-President Albert Gore
Dr. Jane Henney, Commissioner, Food and Drug Administration
Carol Browner, Chief Administrator, Environmental Protection Agency
Dan Glickman, Secretary, U.S. Department of Agriculture
