In comments submitted to the Food and Drug Administration last week, IDFA urged the agency to maintain the current moratorium on the sale of milk and milk products from cloned animals and their progeny until FDA has implemented new safeguards to ensure consumer acceptance of these products. In its comments, IDFA warns that introducing milk from cloned cows into the food supply could cause milk consumption to drop as much as 15%, causing a serious public health concern and economic strain on the government's dairy support systems, unless these safeguards are in place.
"Consumer research by IDFA and others shows that a lack of consumer acceptance of cloning is not simply an issue of preferences or popular opinion, but a legitimate scientific and public health concern, because of its likely effect on consumption patterns of milk and other dairy products," the comments state. "Any decrease in dairy consumption would run directly counter to the 2005 Dietary Guidelines for Americans, which recommend an increase in dairy consumption to achieve necessary levels of calcium and other essential nutrients for the U.S. population."
IDFA submitted its comments in response to the FDA draft Animal Cloning Risk Assessment, Proposed Risk Management Plan and Draft Guidance for Industry, which were released last December. The comment period, which had been extended one month, ended May 3. As of last week, FDA's website acknowledged that the agency had received over 9,000 comments, although some news reports have put the final number at 118,000 or more, with many reportedly coming in at the eleventh hour.
In its comments, IDFA acknowledges that it would be an unusual departure from the agency's traditional approach to consider consumer acceptance in its decision-making process. The issue of cloning, however, raises unique circumstances and calls for a different approach.
Federal dollars are also at stake in this decision, according to IDFA. In the comments, IDFA urges FDA to prepare a full cost-benefit analysis of its decision before allowing milk products from cloned cows and their progeny into the food supply. If consumers do not accept the technology and dairy product sales drop as a result, the government's dairy farmer support programs could become much more costly to taxpayers. International trade of dairy products could also be negatively affected, the comments state.
IDFA recommends several additional action steps that would enhance consumer acceptance and nutritional health, including expanding the Risk Assessment to consider all the potential dietary changes that could occur, establishing a regulatory review process for the safety of food from cloned animals, creating a risk management plan that assures uniform standards for the cloning process, and developing voluntary labeling guidelines specifically for cloning.
In conclusion, the comments stress the need to keep the moratorium in place until FDA has considered and implemented these recommendations.
"Given the potentially devastating public health and economic consequences, it is especially incumbent on FDA to take the time to 'get it right,'" the comments state.
Members may read IDFA's comments here.