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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
View the PDF
August 6th, 2019
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
View CFS Comments
View the Sign-On Letter (47 Organizations)
November 16th, 2017
CFS Comments to FDA re: Agricultural Biotechnology Education and Outreach Initiatives
View Comments
October 30th, 2017
CFS comments on the Arkansas State Plant Board's Proposal to Restrict Dicamba Use
View Comments
June 19th, 2017
Comments from CFS, FOE and allies to FDA regarding the oversight of GE animals (Docket No. FDA-2008-D-0394-0279)
View Comments
June 19th, 2017
Comments from CFS and allied groups regarding new GMO regulations (Docket APHIS-2015-0057)
View Comments
October 12th, 2016
CFS Comments to the EPA Science Advisory Panel on the Carcinogenicity of Glyphosate (Docket EPA-HQ-OPP-2016-0385)
Download CFS Comments
August 10th, 2016
CFS Comments to the National Research Council Committee on "Future Biotechnology Products and Opportunities to Enhance the Capabilities of the Biotechnology Regulatory Systems"
View Comments
August 3rd, 2016
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.
View Comments
August 2nd, 2016
Comments on "Pesticides; Draft Guidance for Pesticide Registrants on Herbicide Resistance Management Labeling, Education, Training, and Stewardship"
View Comments
June 2nd, 2016
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.
View Comments
November 13th, 2015
Comments from 39 farm, environmental, consumer and fishing organizations urging better oversight of biotechnology (Docket No. FDA-2015-N-3403)
View Letter
November 13th, 2015
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
View the PDF
October 19th, 2015
CFS, Groups Submit Letter in Support for California Prop 65 Glyphosate Listing
View the PDF
July 1st, 2015
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
View Comments
June 22nd, 2015
Comments from CFS, Nearly 40 Other Groups Regarding Potential Changes to APHIS Biotechnology Regulations (Docket No. APHIS-2015-0036)
View the PDF
October 10th, 2014
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
Legal Comments
Science Comments I
Science Comments II
August 18th, 2014
Comments on the Agricultural Worker Protection Standard Revisions; Proposed Rule, Docket ID # EPA-HQ-OPP-2011-0184
View Comments
July 30th, 2014
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
View Comments
July 9th, 2014
CFS Statement to the Subcommittee's Hearing on the Societal Benefits of Biotechnology
View the PDF
June 30th, 2014
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)
View Comments
June 30th, 2014
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)
View Comments
June 30th, 2014
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
View the PDF
June 30th, 2014
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
View the PDF
March 25th, 2014
CFS Comments on Docket number USTR-2014-0005 Concerning Proposed Public Interest Trade Advisory Committee
View Comments
March 11th, 2014
CFS comments to USDA regarding Dow Chemical's 2,4-D resistant, genetically engineered corn and soybeans
View Legal Comments
View Science Comments I
View Science Comments II
March 4th, 2014
CFS comments regarding USDA's Federal Register Notice on "Enhancing Agricultural Coexistence" between organic, conventional and genetically engineered crops.
View Comments
February 20th, 2014
Comments from CFS and allies on the Trans-Atlantic Free Trade Agreement (TAFTA), "TAFTA as Monsanto's Plan B: A Backdoor to Genetically Modified Food"
View Comments
December 16th, 2013
CFS comments to USDA opposing approval of genetically engineered "Arctic" apples
View the PDF
December 3rd, 2013
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)
View the PDF
November 4th, 2013
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
View the PDF
October 31st, 2013
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
View the PDF
September 23rd, 2013
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
View the PDF
September 11th, 2013
Letter to Senate leadership from CFS and more than 120 organizations strongly opposing inclusion of the "Monsanto Protection Act" in the FY14 continuing resolution
View the PDF
May 10th, 2013
CFS comments to the US Trade Representative concerning the proposed Transatlantic Trade and investment Partnership (TTIP), Docket No. USTR-2013-0019)
View the PDF
April 29th, 2013
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)
View the PDF
April 29th, 2013
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)
Science Comments
Legal Comments
April 29th, 2013
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)
View the PDF
March 19th, 2013
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
View PDF
February 13th, 2013
CFS comments to EPA on the registration review of 2,4-D
View the PDF
January 25th, 2013
CFS science comments on Proposed Rule that "Amends control area and regulations for growing Brassica spp.  and Raphanus spp. in Willamette Valley" in Oregon
View the PDF
January 18th, 2013
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
View Legal Comments
View Science Comments
October 31st, 2012
CFS comments to Oregon Dept. of Agriculture re: rescinding restrictions on canola cultivation in the Willamette Valley
View the PDF
September 21st, 2012
CFS comments to EPA on Notice of Receipt of Application to Register New Use of Dicamba on Monsanto's Dicamba Resistant MON 87708 Soybean
View the PDF
September 21st, 2012
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
View Comments
September 11th, 2012
CFS comments to USDA on 2,4-D and glufosinate-resistant soybeans
View Legal Comments
View Science Comments
September 11th, 2012
CFS comments to USDA opposing deregulation of Bayer's isoxaflutole-resistant soybean
CFS comments to USDA opposing deregulation of Bayer's isoxaflutole-resistant soybean
August 23rd, 2012
CFS Comments to the USDA Advisory Committee on Biotechnology and 21st Century Agriculture: Compensation is Not Protection from GE Contamination
View the PDF
July 9th, 2012
CFS Comments on Final Environmental Impact Statement for Genetically Engineered Glyphosate Tolerant Sugar Beets
View the PDF
June 22nd, 2012
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
View the Letter
June 22nd, 2012
CFS comments to EPA on registration of 2,4-D for 2,4-D-resistant corn and soy
View the PDF
April 27th, 2012
CFS files legal, scientific, and member comments to USDA opposing the deregulation of Dow's 2,4-D resistant, genetically engineered corn.
CFS Legal Comments
CFS Science Comments I
CFS Science Comments II
Letter signed by 144 organizations
Letter signed by 35 scientists, physicians, nurses and health professionals
December 13th, 2011
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
View the PDF
December 13th, 2011
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
View the PDF
December 13th, 2011
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
View the PDF
December 13th, 2011
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
View the PDF
December 13th, 2011
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
View the PDF
May 2nd, 2011
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.
View the PDF
January 24th, 2011
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
View the PDF
December 6th, 2010
Science Comments II: Center for Food Safety comments to USDA APHIS opposing partial deregulation and commercialization of genetically engineered sugar beets
View the PDF
December 6th, 2010
Science Comments: Center for Food Safety comments to USDA APHIS opposing partial deregulation and commercialization of genetically engineered sugar beets
View the PDF
December 6th, 2010
Legal Comments: Center for Food Safety comments to USDA APHIS opposing partial deregulation and commercialization of genetically engineered sugar beets
View the PDF
June 7th, 2010
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.
View the PDF
March 3rd, 2010
CFS scientific comments on deregulation of GE alfalfa
View the PDF
March 3rd, 2010
CFS comments to USDA on deregulation of GE alfalfa
View the PDF
March 3rd, 2010
Letter to USDA opposing deregulation of GE alfalfa from 300 farmers, organic producers and NGOs
View the PDF
September 21st, 2009
Comments to EPA on the Registration of Glyphosate
View Comments
March 20th, 2009
Diverse Farmer And Public Interest Groups Urge Usda To Freeze Approvals Of Genetically Engineered Crops
View the PDF
February 6th, 2009
CFS comments to USDA APHIS opposing deregulation of Pioneer's corn genetically engineered for resistance to two herbicides
View the PDF
January 20th, 2009
CFS comments to USDA APHIS on proposed new GE corn engineered for ethanol production
View the PDF
November 24th, 2008
CFS comments to USDA APHIS on proposed new regulations for genetically engineered and pharmaceutical crops
View the PDF
November 3rd, 2008
CFS comments to USDA Opposing Deregulation of GE Papayas on the Mainland
View the PDF
August 18th, 2008
CFS comments to USDA Opposing Deregulation of Bayer's GE, glyphosate-tolerant cotton
View the PDF
February 12th, 2008
CFS comments opposing deregulation of Monsanto's new 'stacked' Bt corn variety
View the PDF
February 11th, 2008
CFS comments to USDA on EIS scoping document regarding GE alfalfa
View the PDF
December 4th, 2007
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
View the PDF
September 21st, 2007
CFS comments to the Department of Justice opposing the merger between Monsanto and Delta Pine Land
View the PDF
September 11th, 2007
CFS comments to USDA on the agency's draft programmatic environmental impact statement regarding the introduction and regulation of genetically engineered crops
View the PDF
July 23rd, 2007
CFS comments to USDA opposing a proposed filed trial of safflower genetically engineered to produce experimental human insulin.
View the PDF
July 17th, 2007
CFS comments to the EPA on proposed exemption for viral coat proteins
View the PDF
June 27th, 2007
CFS asks Kansas water officials to consider the effects of Ventria's biopharm rice and deny state water permits
View the PDF
June 19th, 2007
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
View the PDF
June 13th, 2007
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)
View the PDF
April 6th, 2007
CFS comments to USDA on Monsanto's petition to deregulate a new variety of Roundup Ready soybeans.
View the PDF
March 30th, 2007
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
View the PDF
March 9th, 2007
CFS comments to USDA on Syngenta's petition to deregulate a new variety of bt corn.
View the PDF
March 7th, 2007
CFS comments to USDA opposing the planting of GE Safflower, genetically engineered with a carp growth hormone
View the PDF
October 10th, 2006
CFS comments to USDA APHIS on Bayer's petition to deregulate its genetically engineered LL601 rice found to have illegally contaminated the food supply
View the PDF
October 10th, 2006
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
View the PDF
September 21st, 2006
CFS comments to the Oregon Department of Agriculture, Biopharm Ad Hoc Committee on state regulation of genetically engineered pharmaceutical, or 'Biopharm' crops.
View the PDF
July 17th, 2006
CFS comments to APHIS opposing deregulation of genetically engineered plums the first temperate GE tree.
View the PDF
March 22nd, 2006
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
View the PDF
March 22nd, 2006
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
View the PDF
March 22nd, 2006
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
View the PDF
March 22nd, 2006
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
View the PDF
March 15th, 2006
CFS comments to USDA/APHIS concerning weaknesses in its Environmental Assessment of a field trial for transgenic tall fescue and Italian ryegrass.
View the PDF
February 7th, 2006
CFS statement on WTO Ruling on U.S. E.U. biotech food dispute
View the PDF
February 6th, 2006
Joint statement by 15 non-profit organizations on the forthcoming WTO decision in the U.S. E.U. food dispute
View the PDF
June 2nd, 2005
Comments to USDA opposing granting of permit for Ventria biopharmaceutical rice in North Carolina due to contamination concerns
View the PDF
March 24th, 2005
Comments to USDA opposing granting of permit for Ventria biopharmaceutical rice in Missouri due to contamination concerns.
View the PDF
March 17th, 2005
Letter to USDA requesting the rejection of Ventria's three applications to plant pharmaceutical rice in Missouri.
View the PDF
March 1st, 2005
Comments to EPA opposing registration of new Bt for corn rootworm that may be allergenic and has properties similar to Starlink.
View the PDF
January 24th, 2005
Comments to USDA/APHIS Regarding Environmental Assessment of Genetically Engineered Alfalfa
View the PDF
December 20th, 2004
Comments to USDA/APHIS Regarding Environmental Assessment of Genetically Engineered Sugarbeets
View the PDF
October 25th, 2004
Comments to USDA/APHIS Regarding Proposed Environmental Impact Statement on Genetically Engineered Bentgrass
View the PDF
October 20th, 2004
CFS Response to PlantPharma's (IALS) Comments Regarding CFS's July 21, 2004 Report on Pharmaceutical Rice in California: Potential Risks
View the PDF
July 26th, 2004
A Look at the Unintended Effects of Genetic Engineering Food Crops
View the PDF
April 13th, 2004
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
View the PDF
April 13th, 2004
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
View the PDF
April 2nd, 2004
Comments to the Office of the US Trade Representative regarding the WTO/EU dispute
View the PDF
March 4th, 2004
Comments to the USDA on a petition submitted by the Monsanto Company and Scotts Company for approval of genetically engineered bentgrass
View the PDF
February 26th, 2004
Comments at APHIS Stakeholder discussion series on their upcoming Environmental Impact Statement and revised plant biotechnology regulations
View the PDF
November 14th, 2002
CFS seeks immediate government release of documents concerning the contamination of food crops with genetically engineered pharmaceutical corn
View the PDF
May 13th, 2002
Comments on U.S. Department of Agriculture's inadequate environmental assessments of Monsanto's 'Insect Resistant Corn Line MON 863'
View the PDF
April 15th, 2002
Comments on U.S. Department of Agriculture's inadequate environmental assessments of Aventis' 'TOPAS 19/2' canola
View the PDF
April 15th, 2002
Comments on U.S. Department of Agriculture's inadequate environmental assessments of Monsanto's 'GT 200' canola
View the PDF
April 15th, 2002
Comments on U.S. Department of Agriculture's inadequate environmental assessments of Aventis' 'MS1 and RF1/RF2' canola
View the PDF
February 28th, 2001
Comments on how U.S. Department of Agriculture can best facilitate the marketing of grains, oilseeds, fruits, vegetables and nuts
November 27th, 2000
Comments concerning the Environmental Protection Agency's assessment of scientific information concerning Aventis Cropscience's StarLink corn
View the PDF
Genetically Modified (GM) Crops and Pesticide Use
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Comments to FDA on Proposed Voluntary Guidance for Early Safety Testing
View the PDF
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