| Dr. Applebaum went on to say that at the conclusion of the consultation process, before the food or ingredient is introduced into interstate commerce, the biotech company should file with FDA summary documentation to support the determination of safety for the biotech food and derivative ingredients. The NFPA believes this is a critical step, so that anyone interested can examine it. Most important is that the general public develops a higher level of comfort regarding the safety of biotech foods. The NFPA and its member companies strongly support the current FDA policy on labeling requirements for biotech foods and believes the policy is science-based and is designed to mandate any information on the food label that is material or of consequence to the consumer with respect to safety, health, composition and nutrition. The NFPA further supports the use of voluntary labeling of foods, whether or not they are produced through modern biotechnology. The NFPA has long supported voluntary label statements provided such statements are truthful, non-misleading and disclose the necessary required material facts. These voluntary label statements could include 'Biotech-free' or similar terminology, or, for balance, 'Contains biotech
ingredients.' In order to support any voluntary statements, the NFPA believes that three criteria must be met: First, a quantitatively based threshold should be established, especially for any 'free' claim. Such a threshold should be strict but technologically feasible. Second, every claim needs to be substantiated. For a biotech-related voluntary statement, the ability to substantiate identity preservation and other traceback procedures should be vital components. And third, most biotech-related label claims will need supplementary statements that place the claim in its proper context. NFPA believes supplementary statements are absolutely necessary to prevent potentially misleading claims. A supplemental statement should note that there are no significant differences between biotech and biotech-free versions of the same food.
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