Good morning. My name is Lisa Katic, and I am the Director of Scientific and Nutrition Policy for the Grocery Manufacturers of America. I am pleased to be speaking today on behalf of GMA and its members.

GMA is the world's largest association of food, beverage and consumer product companies. Led by a board of 42 Chief Executive Officers, GMA speaks for food and consumer product manufacturers at the state, federal and international levels on legislative and regulatory issues. The organization applies legal, scientific and political expertise from its member companies to vital food, nutrition and public policy issues affecting the industry. One such issue, which we are addressing today, is modern food biotechnology. With U.S. sales of more than $450 billion, GMA members represent more than 90 percent of food, beverage and consumer products sold in the United States and employ more than 2.5 million workers in all 50 states.

My remarks today will focus generally on the public information issues raised by FDA in its Federal Register Notice, and specifically on the questions of what information consumers want to know about foods produced through modern biotechnology, and how to best provide them with that information.

What Consumers Want to Know

Let me begin by addressing the question of what consumers want to know about food produced through modern biotechnology. Studies conducted this summer and fall by the food industry show overwhelmingly that consumers want truthful, accurate information about the foods that they eat. GMA fully supports the ability of manufacturers to inform consumers about foods produced through modern biotechnology. Indeed, it has been our experience that when consumers are presented with balanced information regarding foods produced through modern biotechnology, they are excited about the benefits these foods can and will provide.

According to Thomas Hoban, a professor at North Carolina State University, between two-thirds and three-quarters of American respondents surveyed are positive about plant biotechnology. The most recent surveys showed that when consumers were provided with information about the benefits of genetic modification, 70 percent said they felt more positive and hopeful about the genetic modification of foods.

It is clear from our research that consumers want foods that can provide added health benefits. According to a survey conducted by the International Food Information Council, the vast majority (91%) of consumers say they would be interested in learning about foods that have added health benefits. Foods and ingredients developed through modern technology will offer real consumer benefits in the future. I will highlight just a few of the benefits that are currently available or are on the horizon:

• Fruits and vegetables that contain more beta carotene and vitamins C and E, which may help to reduce incidences of cancer and heart disease.

• Grains, fruits and vegetables that contain more nutrients, such as proteins, and have reduced fatty acid profiles.

• A new rice that will counter vitamin A deficiency, the leading cause of blindness in children in the developing world.

• Improved nutrients in strawberries, and vitamin?enhanced sweet potatoes and canola oil.

• Allergen-free rice and peanuts.

• Fruits and vegetables that ripen less quickly after they are picked, are more disease and insect resistant and have an increased tolerance to herbicides. Slower ripening fruits and vegetables have improved flavor and can remain fresh longer.

• Healthier cooking oils. Corn, soybeans, canola and other plants will be modified to reduce the saturated fat content of cooking oils derived from these crops.

• Better methods to identify and locate toxins, pathogens or contaminants in food.

In addition to nutritional benefits, foods produced through modern biotechnology can offer environmental benefits as well. For example, grains, fruits and vegetables containing pesticide-resistant and herbicide?tolerant characteristics can require fewer chemical applications. These more resilient plants can tolerate farmers' application of very specific herbicides for weed control, thus reducing the overall need for chemical applications and stress to our natural resources.

GMA Position Statement On Labeling Related To Biotechnology

GMA's Board of Directors recently approved a position statement strongly supporting the current FDA labeling policy with respect to foods or food ingredients derived through biotechnology. This means GMA supports the labeling of biotech foods where there is a significant compositional change, where the food is nutritionally different from its traditional counterpart, or where a potential allergen has been introduced.

The FDA labeling policy also allows for voluntary labeling statements that are truthful and not misleading, providing a comprehensive framework for consumer protection and choice.

Just as some consumers prefer "organic" foods, others may want to purchase foods that are not produced through modern biotechnology. Manufacturers should be able to satisfy these preferences and competitive markets will respond accordingly. Competition will deliver products and information that best satisfy consumer choice.

We support the right of manufacturers to make claims for their products, including claims about products made without the use of modern biotechnology, so long as they are truthful and non-misleading. It is important that such claims not mislead consumers about the composition, safety, or quality of the labeled product or any other product. We recommend that FDA develop criteria for claim accuracy and substantiation in relation to voluntary labeling of "non-biotech" foods or food ingredients.

How We Should Inform Consumers

The next question then is how to best provide accurate and adequate information about modern biotechnology to consumers. Some groups are urging FDA to mandate the disclosure of genetic techniques used in the development of a product, even if the food that results is equivalent to its traditional counterpart and even though it presents no demonstrated health or safety risk to people. These critics are not satisfied with FDA's current labeling policy and seek to mandate special new labeling requirements. Special mandatory labeling could mislead consumers into believing that foods produced through modern biotechnology are either "different" from conventional foods or present a risk or a potential risk -- even though FDA has determined that the food is safe. Such special labeling of foods modified through modern biotechnology could lead to the very kind of confusion that FDA has tried to keep out of labels.

A label cannot tell every consumer everything he or she might want to know about every product, because different consumers care about different things. If manufacturers tried to satisfy the tastes and preferences of every consumer, the amount of information that might be useful could fill an encyclopedia. Only a small fraction of this information can possibly fit on a label.

In addition, sources of information far better and more comprehensive than labels are readily available to consumers. Through focus groups and telephone surveys, consumers are telling the U.S. food industry that they are able to obtain information about food biotechnology from the news media, the Internet, food companies and academic experts. In fact, a new survey from the International Food Information Council found that 81 percent of American consumers agree that, rather than labeling products as containing biotech ingredients, "it would be better for food manufacturers, the government, health professionals and others to provide more details through toll-free phone numbers, brochures and web sites." These sources are more informative than the label because they provide the flexibility and forum to discuss issues in detail.

For example, GMA, along with the American Farm Bureau Federation, the Food Marketing Institute and more than 30 other organizations recently established the "Alliance for Better Foods" to provide fact-based information to consumers about food biotechnology. The Alliance includes farmers, processors, retailers, scientists, health professionals, medical experts, academicians, those committed to protecting the environment, those fighting world hunger, and those generally who support the development of biotechnology. The Alliance has developed a web site-- "www.betterfoods.org" -- and publications that address consumers' questions regarding foods produced through modern biotechnology. The web site also provides links to government agencies, including FDA, so that consumers can learn about the government's role in biotechnology.

FDA's Current Biotechnology Labeling Policy Should Not Be Modified

Let me conclude by stressing that GMA and its members strongly support FDA's existing science-based labeling policy with respect to foods and food ingredients derived from modern biotechnology. We believe that the FDA policy provides a comprehensive framework for consumer protection and choice and clearly serves the public interest. In a market system that values consumer choice as the engine of economic welfare, government regulation should protect consumers from real risks and help consumers make informed choices. A policy that raises unwarranted suspicion of research and development, as mandatory labeling of modern biotechnology could do, might deny the public the benefits of innovation. It would be unfortunate if misinformation and unfounded concerns deprive consumers of the information and the foods that they desire.

A sound labeling policy can and should recognize the rights of consumers to a safe and nutritious food supply, while facilitating consumer choice based on meaningful information about the product itself. By mandating only essential information, allowing voluntary claims about modern biotechnology, and demanding accuracy in all labeling, FDA's existing labeling policy has accomplished this goal.

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