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Policy Comments
October 9th, 2019
Summary of Center for Food Safety's Science Comments to EPA on Monsanto's Request to Register Dicamba Herbicide for Use on Monsanto's Dicamba-Resistant MON 87708 Soybean
Comments from CFS and Allies to USDA Regarding Proposed Rule on Movement of Certain Genetically Engineered Organisms, 7 CFR Parts 340 and 372, Docket No. APHIS-2018-0034
CFS Comments to the National Research Council Committee on "Future Biotechnology Products and Opportunities to Enhance the Capabilities of the Biotechnology Regulatory Systems"
CFS urges EPA to deny Monsanto's petition to permit spraying of the herbicide dicamba on GE dicamba-resistant soybeans and cotton, due to harms to human health, the environment, and farmer welfare.
Invited Comments to the National Research Council Committee on "Future Biotechnology Products and Opportunities to Enhance the Capabilities of the Biotechnology Regulatory System." By Doug Gurian-Sherman, Ph.D.
CFS comments on the Office of Science and Technology Policy's notice and request for information on Clarifying Current Roles and Responsibilities Described in the Coordinated Framework for the Regulation of Biotechnology
Comments from CFS on the preliminary plant pest risk assessment and draft environmental assessment of zea mays event MON 8741 genetically engineered for protection against corn rootworm and resistance to glyphosate
CFS Comments to USDA's Animal and Plant Health Inspection Service on the Agency's draft Environmental Impact Statement on Monsanto Petitions (10-188-01p and 12185-01p) for Determinations of Nonregulated Status for Dicamba-Resistant Soybean and Cotton Varieties
Comments on USPTO's Guidance on the Proposed Procedure For Subject Matter Eligibility Analysis Of Claims Reciting Or Involving Laws Of Nature/Natural Principles, Natural Phenomena, And/Or Natural Products
CFS Comments to EPA on EPA's Proposed Registration of Enlist Duo Herbicide Containing 2,4D and Glyphosate for New Uses on Herbicide-Tolerant Corn and Soybean (Docket No. EPA-HQ-OPP-2014-0195)
Comments to USDA/APHIS on Plant Pest Risk Assessment and Environmental Assessment for Determination of Nonregulated Status of Potatoes Genetically Engineered for Reduced Browning and Reduced Acrylamide (Docket No. APHIS-2012-0067)
CFS Comments to EPA on EPA's Proposed Registration of Enlist Duo Herbicide Containing 2,4-D and Glyphosate for New Uses on Herbicide-Tolerant Corn and Soybean
CFS Legal Comments to EPA on EPA's Proposed Registration of Enlist Duo Herbicide Containing 2,4- D and Glyphosate for New Uses on Herbicide-Tolerant Corn and Soybean
CFS comments regarding USDA's Federal Register Notice on "Enhancing Agricultural Coexistence" between organic, conventional and genetically engineered crops.
CFS comments to the FIFRA Scientific Advisory Panel on the scientific uncertainties associated with corn rootworm resistance moitoring for GE, Bt corn Plant Incorporated Pesticides (Docket No. EPA-HQ-OPP-2013-0490)
CFS letter to FDA urging the agency to decline a District Court request to define the marketing label "natural" without a public comment process or excluding GE foods
CFS letter to Farm Bill conferees urging passage of a Farm Bill that protects pollinators, organic farmers and our ability to safeguard public health and the environment
Joint letter to Oregon Governor Kitzhaber opposing the inclusion of the local seed and food preemption bill (SB 633) in the PERS/tax reform package up for consideration by the legislature in the special session
Letter to Senate leadership from CFS and more than 120 organizations strongly opposing inclusion of the "Monsanto Protection Act" in the FY14 continuing resolution
Comments to aphis on petition for determination of nonregulated status of soybean genetically engineered for resistance to hppd inhibitor herbicides (Docket No. APHIS-2012-0090)
CFS Comments to USDA APHIS on Draft Environmental Assessment and Draft Plant Pest Risk Assessment for Dupont-Pioneer Petition for Determination of Nonregulated Status of Insect Resistant and Herbicide Resistant Pioneer Maize (Docket No. APHIS-2012-0026)
Comments to aphis on petition for determination of nonregulated status of cotton genetically engineered for resistance to the herbicides dicamba and glufosinate (Docket No. APHIS-2012-0090)
CFS comments to the National Organic Standards Board regarding antibiotics in apple and pear growing, sugar beet fiber, excluded methods and genetic engineering, among other issues
CFS comments to EPA on Application to Register New Use of Dicamba on Dicamba and Glufosinate Resistant MON 87701 Cotton, and to Establish Tolerances for Residues of Dicamba in Cottonseed and Cotton Gin Byproducts
Summary of Center for Food Safety's Science Comments to EPA on Monsanto's Request to Register Dicamba Herbicide for Use on Monsanto's Dicamba-Resistant MON 87708 Soybean
Letter to EPA from seventy health scientists urging the Agency to reject Dow Chemical’s application for commercial sale of 2,4-D resistant corn and soybeans
Legal Comments: CFS files legal, scientific, and member comments to USDA on the Agency's draft Environmental Impact Statement on Monsanto's genetically engineered, Roundup Ready sugar beets
Science Comments II: CFS files legal, scientific, and member comments to USDA on the Agency's draft Environmental Impact Statement on Monsanto's genetically engineered, Roundup Ready sugar beets
Appendix: CFS files legal, scientific, and member comments to USDA on the Agency's draft Environmental Impact Statement on Monsanto's genetically engineered, Roundup Ready sugar beets
CFS files legal, scientific, and member comments to USDA on the Agency's draft Environmental Impact Statement on Monsanto's genetically engineered, Roundup Ready sugar beets
Science comments: CFS files legal, scientific, and member comments to USDA on the Agency's draft Environmental Impact Statement on Monsanto's genetically engineered, Roundup Ready sugar beets
CFS Science Policy Analyst Bill Freese has over a decade of experience engaging the USDA, EPA and FDA on dozens of different GE crops and GE crop regulatory matters. In 2004, he teamed up with the distinguished Salk Institute cell biologist Dr. Dave Schubert to publish a peer-reviewed critique of the US regulatory system for GE crops.
CFS open letter to U.S. Department of Agriculture (USDA) Secretary Tom Vilsack and other key Agencies requesting that the USDA carefully reconsider, based on sound science, the full range of impacts that would ensue from the commercial planting of genetically engineered (GE) Roundup Ready (RR) alfalfa
Science Comments II: Center for Food Safety comments to USDA APHIS opposing partial deregulation and commercialization of genetically engineered sugar beets
Science Comments: Center for Food Safety comments to USDA APHIS opposing partial deregulation and commercialization of genetically engineered sugar beets
Legal Comments: Center for Food Safety comments to USDA APHIS opposing partial deregulation and commercialization of genetically engineered sugar beets
CFS comments to the USDA's Agriculture and Food Research Initiative (AFRI) of the National Institute for Food and Agriculture (NIFA) on agricultural research funding.
CFS comments to USDA on the Agency's Environmental Assessment regarding Dupont's 'GAT' soybeans' a new genetically engineered soybean tolerant to two different classes of herbicides: glycines (i.e. glyphosate) and ALS inhibitors
CFS comments to USDA on the agency's draft programmatic environmental impact statement regarding the introduction and regulation of genetically engineered crops
Farm Bill Could Hamstring State Food Safety Agencies. Consumer, Environmental, Farmer and Animal Welfare Groups Protest Clause that Wipes Out State and Local Authority on Meat, Poultry, Biotechnology
CFS comments to the Environmental Protection Agency on proposed revisions to regulations on crops genetically engineered to produce pesticides or insecticides (plant incorporated protectants, or PIPs)
CFS comments to USDA-APHIS opposing approval of Ventria Bioscience's proposal to plant 3,200 acres of pharmaceutical rice genetically engineered to express human proteins in Kansas
CFS comments to USDA APHIS on Bayer's petition to deregulate its genetically engineered LL601 rice found to have illegally contaminated the food supply
Supplemental Comments: CFS comments to USDA APHIS on Bayer's petition to deregulate its genetically engineered LL601 rice found to have illegally contaminated the food supply
CFS comments to the Oregon Department of Agriculture, Biopharm Ad Hoc Committee on state regulation of genetically engineered pharmaceutical, or 'Biopharm' crops.
CFS, along with numerous environmental organizations and state officials, comments to Congress in opposition to the National Uniformity for Food Act.: Letter from Environmental Coalition
CFS, along with numerous environmental organizations and state officials, comments to Congress in opposition to the National Uniformity for Food Act.: Letter from Assoc. of Food and Drug Officials
CFS, along with numerous environmental organizations and state officials, comments to Congress in opposition to the National Uniformity for Food Act.: Letter from 39 State Attorneys General
CFS, along with numerous environmental organizations and state officials, comments to Congress in opposition to the National Uniformity for Food Act.: Letter from Nat'l Assoc. of State Depts. of Agriculture
ICTA Comments: Comments to Animal and Plant Health Inspection Service (APHIS) in regard to its preparation for an Environmental Impact Statement (EIS) on the regulation of certain genetically engineered organisms
Comments to Animal and Plant Health Inspection Service (APHIS) in regard to its preparation for an Environmental Impact Statement (EIS) on the regulation of certain genetically engineered organisms
