APPENDIX 13
Memorandum submitted by the United States
Department of Agriculture (S 19)
I am writing to comment in connection with the
current discussions in the Agriculture Committee of the House
of Commons on several important issues, including biotechnology,
animal welfare, and the use of growth promoters in beef.
On the surface, each of these issues appears
unrelated. However, there is an important commonality between
them: the roles and responsibilities of both the public and private
sectors. In each instance, government has the responsibility to
ensure a safe food supply. Private citizens can then exercise
product choice in the market.
The U.S. Government maintains a clear distinction
between food safety and food marketing issues. Its role is to
determine that all choices given to consumers are equally safe,
and to ensure that there are no misleading or false labelling
statements or health claims. We strongly believe that regulatory
decisions regarding foods should be based on rigorous, scientific
risk assessments of the products presented to consumers. Factors
that are related to "consumer preference", such as production
methods, socio-economic factors, and ethical or religious preferences,
must be addressed through the marketplace. This "arms-length"
regulatory process serves to prevent consumer confusion and maintain
consumer confidence in the ability of government regulators to
guarantee a safe and wholesome food supply. Governments should
avoid involvement in issues affecting marketing of a product beyond
the determination of product safety.
The basis for a market is consumer choice. Clearly,
there are consumers who place differing degrees of importance
on production methods and product inputs. The U.S. food market
is an excellent example. There are thousands of products available
to meet consumer desires, whether they are organic products, "free
range" animal products, products that cater to a particular
religious or ethical system (kosher foods, for example), and products
that do not contain GMO's. These products exist not because the
U.S. Government forced their creation, but because consumers have
expressed a desire to buy them. The U.S. Government applies the
same food safety principles to each, in order to guarantee the
safety of all products, irrespective of their content or production
method.
The key objective in this entire process is
guaranteeing food safety and consumer confidence. When the government
tries to interpret consumer demand and regulate access to products
based on non-scientific assessments, it can lead to confusion
and an overall reduction in confidence in the food safety system.
In addition, a regulatory system that encompasses non-scientific
factors can lead to political disputes between countries, as countries
try to justify trade barriers for virtually any reason.
14 December 1999
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