To put Henry Miller's views into perspective, he told the New York Times (January 25, 2001) in its report on how Monsanto gained "astonishing" control over the regulation of its own industry, through the Environmental Protection Agency, the Department of Agriculture and the Food and Drug Administration, "In this area, the U.S. government agencies have done exactly what big agribusiness has asked them to do and told them to do."

Miller was in a position to know. He was in charge of biotechnology issues for the Food and Drug Administration from 1979 to 1994. Yet, according to Miller, Monsanto blew its domination of the regulatory system by encouraging agencies like the FDA to introduce too much oversight and regulation. The result? "Food biotech is dead," declared Miller. "The potential now is an infinitesimal fraction of what most observers had hoped it would be."
http://www.thecampaign.org/education/brochure_nytimes.htm

If that was Miller's analysis of the laisser faire US situation, it's easy to see how he would view Europe (item 3). This, after all, is someone who argues that the biotech industry should be subjected to no especial regulatory conditions whatsoever when bringing its products to market as those products, in Miller's view, are inherently safer and more predictable than non-genetically engineered products.

His co-author Greg Conko is the co-founder of Prakash's AgBioWorld campaign.

1.Brussels right to be cautious of GM foods
2.GM-free, like all food taboos, is a matter of taste
3.Brussels' bad science will cost the world dear: By CONKO and MILLER
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1.Brussels right to be cautious of GM foods
By Dr Patricia Elliott
Financial Times, August 18, 2003, Monday USA Edition 2
LETTERS TO THE EDITOR

Sir,

"Brussels' bad science will cost the world dear", claim Henry Miller and Gregory Conko (August 14).

Their exposition of the advantages of genetically modified crop technology is itself an example of "bad science".

Repeated assertions about the risks being minimal and the benefits "legion" are all too common and ought to be supported by properly conducted and peer-reviewed research work. Can the authors quote any survey that has been carried out to determine the affects of any GM product on human health?

The apparent absence of evidence is of no value unless an exposed population has been properly investigated.

The precautionary principle, properly applied, as it has been in the field of drug therapy, is an essential tool needed to protect us from both commercial exploitation and from well-meaning enthusiasts.

We are fortunate in Europe that we now have protective legislation. History has many examples of the tragic results of unprotected exposure to new technology and new chemicals - tragic results that have also had an economic cost: the costs of treatment and, in many cases, the costs of damages.

Patricia Elliott, Saffron Walden, Essex
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2.GM-free, like all food taboos, is a matter of taste
By John C. English
Financial Times, August 18, 2003, Monday USA Edition 2
LETTERS TO THE EDITOR

Sir,

I am sure I am not alone among your readers in finding the Europe- bashing of the type seen in the article by Henry Miller and Gregory Conko rather tedious ("Brussels' bad science will cost the world dear", August 14).

The most significant factor in the genetic modification debate is people's concern about what they eat. But since when have rituals and taboos related to food had any relationship to science?

There is no basis for saying that meat from animals killed using the methods prescribed by Islam and Judaism is nutritionally any better than that slaughtered in other ways. Perhaps more to the point, there is no evidence that kosher food is nutritionally preferable to non-kosher food. But the US food industry seems quite capable of separating kosher from non-kosher food at limited cost, and I do not hear any complaints from the food industry or others about the lack of scientific justification.

We hear a lot these days about presentation and spin, but maybe, rather than talking about "GM-free" food, we should call it "European Kosher" and require that such food be certified with an appropriate symbol on the label. Jews are not required to eat kosher, nor are Europeans required to eat GM Free, but many wish to have the option.

Surely the American way is to give them that option if they pay for it. As a resident of the US it seems to me that the use of the "precautionary principle" in the collection of the US blood supply is a more serious short-run problem than its use in relation to the European food supply. The approach of the US authorities means that people like myself, who have spent more than six months during the past 15 years in the UK, are not acceptable as a source of blood, even though there is no scientific evidence that bovine spongiform encephalopathy can be carried in blood. Many others are rejected for other "precautionary" reasons, and the result is a serious crisis in blood supplies and frantic calls for more donors.

If Miller and Conko are really concerned about policies based on "bad science" that "cost the world dear", they should be focusing on energy and global warming. The US government's purblind refusal to take steps to address this problem is a national scandal. Where is the Hoover Institution when it is needed?

John C. English, Bethesda,
August 17, 2003
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3.Brussels' bad science will cost the world dear:
By GREGORY CONKO and HENRY MILLER
Financial Times, August 14, 2003, Thursday

http://search.ft.com/search/article.html?id=030814000909&query=Brussels%27+b
ad+science+will+cost+the+world+dear&vsc_appId=totalSearch&state=Form

Regulatory officials in the European Union seem to be ignorant of the rule of holes: when you are in one, stop digging. Numerous analyses over the past two decades have documented Europe's declining competitiveness in agricultural biotechnology - the use of genetic modification to improve plants, animals and micro-organisms. Recently, for example, the European Commission's Joint Research Centre reported that two-thirds of large European companies that had been involved in developing GM crops had cancelled substantial projects since 1998. Yet the EU seems determined, through its unscientific, unwise and unproductive approach to regulation, to let the sector fall further behind.

At the root of the problem is the EU's adherence to the so-called "precautionary principle", which holds that as long as the evidence about a product, technology or activity is in any way incomplete, it should be prohibited or, at the least, heavily regulated. This in turn is based on the false assumption that little harm comes from delaying the introduction of new products and technologies.

The principle exaggerates the potential drawbacks of new products and underestimates their benefits. The decision-making process it dictates is intentionally weighted against new technologies even after they have been cautiously examined.

Literally thousands of laboratory, greenhouse and field studies show the risks of GM plants and foods to be minimal, while their benefits - in terms of increased yields and reduced pesticide use - are legion.  Future increases in their use would improve human nutrition and, by reducing pressure on land and water, protect fragile ecosystems.

But the precautionary principle stands in the way. It forces us to ignore proven benefits in a costly effort to eliminate hypothetical risks that are small or easily manageable. Thus, in 1998, the highest French court invoked the principle when it suspended commercialisation of three GM corn varieties, even though the French government had already endorsed approval of those same varieties at EU level. Similarly, in 2000, Germany rescinded the licence for field testing a GM corn variety just one day before the agriculture ministry was due to approve it for commercial cultivation.

The list of bizarre and baseless actions by European regulators goes on and on. Even the Commission's own research implies that this has little to do with protecting consumers or the environment. Last year, it reviewed the 17 years of risk assessment research it had funded - 81 projects by more than 400 multinational research groups, costing about Euros 70m (Dollars 79m) - and concluded that GM organisms are "probably . . . safer than conventional plants and foods" for both the environment and human consumption.

The precautionary principle purports to be a useful method for decision- making in situations of uncertainty. In practice, however, it serves as an excuse for imposing arbitrary restrictions, often transparently motivated by protectionism, on new technology. The results of this approach are plain in the EU's labelling and traceability regime, which makes it prohibitively expensive and complicated for growers of GM crops to comply with the rules. The ultimate outcome will be to replace a de facto moratorium with insuperable regulatory obstacles.

In view of the moribund state of GM research and development in the EU, its only viable strategy may be to poison the well - that is, to make sure that GM technology fails everywhere, and that no competitor remains viable. European attempts to secure acceptance of the precautionary principle in international agreements and treaties are a good start.

In the interest of human rights, economic justice and free markets, we need global regulatory policies that make scientific sense and that lead to greater productivity and consumer choice. By promoting the precautionary principle, and by exporting their own version of unscientific and inconsistent regulation, EU politicians are doing us all a grave disservice. The only winners will be the Brussels bureaucrats who will enjoy additional power, and the anti-science activists who will have succeeded in erecting yet another barrier to a superior technology. The biggest losers will be consumers, who will be denied access to safer, more nutritious and more affordable food.

Henry Miller is a fellow at Stanford University's Hoover Institution. Gregory Conko is director of food safety policy at the Competitive Enterprise Institute, Washington