To whom it may concern:
The undersigned organizations appreciate this opportunity to provide comments to the Food and Drug Administration (FDA) on the proposed Agricultural Biotechnology Education and Outreach Initiative (FDA-2017-N-5991). Our organizations represent the entire value-chain in the food system and ensure that the United States continues to be the world leader in providing safe and affordable food.
The Agricultural Biotechnology Education and Outreach Initiative calls upon the FDA to work with the U.S. Department of Agriculture (USDA) to provide education and outreach to the public on agricultural biotechnology and food and animal feed ingredients derived from biotechnology. Sixty-six food and agricultural organizations, several also joining these comments, supported this initiative1 to help the public better understand science- and fact-based information about agricultural biotechnology. We believe this initiative, to which Congress appropriated $3 million, is critical and long overdue because of the tremendous amount of misinformation about agricultural biotechnology in the public domain. For too long, stakeholders in the value-chain, from seed to plate, have had to defend the thoroughness and safety of the regulatory system without the addition of the trusted government voice.
Formal rulemaking will soon begin for the National Bioengineered Food Disclosure Standard2 (“Disclosure Standard”), a marketing standard that has nothing to do with the safety of bioengineered food. However, on the internet and in social media, the opponents of agricultural biotechnology continue to malign the safety of advanced methods of food production.3 Therefore, the Agricultural Biotechnology Education and Outreach Initiative is necessary and timely to provide consumers with scientific information about agricultural biotechnology.
We urge FDA and USDA to focus this program on 1) educating the public about the safety of agricultural biotechnology and the stringent regulatory approval process and 2) educating the public on the benefits of agricultural biotechnology to the environment and throughout the value-chain.
Government agencies should defend the safety of products approved through the strict regulatory approval process known as the Coordinated Framework between the FDA, USDA, and Environmental Protection Agency (EPA).
FDA is seeking comments on three questions:
1. What are the specific topics, questions, or other information that consumers would find most useful, and why?
We believe that consumers are interested in information about the safety and benefits of bioengineered food and farming methods that utilize bioengineered seeds. 4, 5 In addition, Consumers would benefit from a greater understanding of what GMO’s are67, the regulatory process, environmental benefits, and the role of technology within the modern agricultural system.
2. Currently, how and from where do consumers most often receive information on this subject?
Increasingly, consumers obtain information from social media in the form of headlines, infographics and short tweets. Short-form communication about complex topics is a challenge but a number of industry and stakeholder groups are engaged in online and social media efforts to educate consumers about food, farming and technology.8 3. How can FDA (in coordination with USDA) best reach consumers with science-based educational information on this subject?
In our experience, consumers want their concerns addressed in a respectful, easy to understand manner. GMO Answers has engaged the public through the use of infographics and videos.9 A Fresh Look was recently launched to show what farmers, moms and scientists say about farming methods that utilize bioengineered seeds.10 As consumers continue to seek information online, we recommend that the government, as a trusted and reliable source of information, meet the consumers where they are and provide information online and in social media.
The United States is the world leader in agricultural productivity in large part due to our use of agricultural biotechnology. We strongly support efforts by FDA and USDA to help the public better understand the science of agricultural biotechnology, to alleviate any concerns about the safety of the technology, impart confidence in the U.S. regulatory system, and discuss the associated benefits.
We appreciate the opportunity to respond to the specific questions posed by FDA and look forward to continuing to work with FDA and USDA to ensure that the United States remains the world leader in agricultural innovation.
American Farm Bureau Federation
American Feed Industry Association
American Seed Trade Association
American Sugarbeet Growers Association
Biotechnology Innovation Organization (BIO)
Corn Refiners Association
National Association of State Departments of Agriculture
National Cotton Council
National Milk Producers Federation
7 http://afreshlook.org/defining... 8 The Council for Biotechnology/GMO Answers; Crop Life International – A Seed Story: Plant Biotechnology in Focus and Plant Biotechnology Benefits webpage; The International Food Information Council – including “A Useful Guide to Understanding GMOs” and “Food Biotechnology: A Communicator's Guide to Improving Understanding”; U.S. Farmers & Ranchers Alliance Food Dialogues; Center for Food Integrity Best Food Facts; Peel Back the Label; A Fresh Look; The International Service for the Acquisition of Agri-biotech Applications (ISAAA)