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More on Pew The opinion piece by Henry I. Miller and Gregory Conko seriously misrepresents my views and the product of my research in the area of allergenicity of genetically modified food.1,2 It is absurd to equate the shifts in protein composition that are possible with "conventional" plant breeding with those that can occur via biotechnology. It has become evident that biotechnology does confer a higher probability of introducing novel traits into food than conventional plant breeding and, in fact, this is how many of the potential benefits of biotechnology will be realized. If there is a price to be paid in additional regulation, and I think that there clearly is, then we need to make sure that such regulation is scientifically based. The report I coauthored is intended to shed light on one area where the federal research agenda needs to be strengthened to support this new technology. Allergenicity is one of the traits that regulators at the US Environmental Protection Agency and Food and Drug Administration assess in biotechnology foods. In fact, in 2000, the National Research Council recommended that "priority should be given to the development of improved methodology for identifying potential allergens in pest- protected plants, specifically, the development of tests with human immune-system endpoints and of more reliable animal models." Shortly after publication of this report, Starlink® corn, not intended for [human] consumption because EPA was unable to assess its allergenicity, wound up in the US food supply and in global commerce, creating enormous disruptions. Despite the NRC recommendation and the lesson of Starlink, last year nine federal agencies or institutes funded only 33 food allergy research projects totaling between $4.2 and $7 million. These funds are spread thin, and only recently has coordination among federal agencies begun. The report in no way attempted to address the question of risks of genetically modified food on the market. Moreover, it has never been my position that the technology should be "stultified" in any way. In fact, it is my opinion that rigorous government review and safety assessments are the best guarantor that biotechnology will be accepted by the public and will flourish in the market. During more than five years when I served as assistant administrator for the EPA, I was responsible for so-called Plant Incorporated Protectants, foods genetically modified to express pesticidal proteins. As a regulator, I attempted to make decisions based on evidence regarding safety. The proof is in the pudding; while at EPA, I approved the first such products to come into commercial development worldwide. The disruption that resulted from the Starlink episode exemplifies why it is important to strengthen the basis for food allergy assessment.4 Despite some speed bumps along the way, I continue to feel that this technology is indeed a wonderful one that shows much promise. Lynn R. Goldman, MD, MPH Professor Environmental Health Sciences Johns Hopkins School of Public Health 615 N. Wolfe St., Room W8511 Baltimore, MD 20815 References 1. H.I. Miller, G. Conko "Pew on biotech? Pugh!" The Scientist, 16[14]:12, July 8, 2002. 2. L. Bucchini, L.R. Goldman, "A snapshot of federal research on food allergy: Implications for genetically modified food," June 2002, available online at www.pewagbiotech.org/research/allergy.pdf. 3. National Research Council, Genetically Modified Pest-Protected Plants: Science and Regulation, Washington, DC: National Academy Press, 2000. 4. L. Bucchini, L.R. Goldman, "Starlink corn: a risk analysis," Environmental Health Perspectives, 110[1]:5-13, 2002.

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