Biotechnology Project
Center for Science in the Public Interest
 Letter to EPA opposing “Revolving Door” appointments

February 22, 2001
Hon. Christine Todd Whitman
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, DC 20460

Dear Administrator Whitman:

We are troubled by reports that you are considering appointing to top positions, including Deputy Administrator and Assistant Administrator for Prevention, Pesticides, and Toxic Substances, individuals with substantial previous ties to agricultural biotechnology companies. As you know, biotechnology is a highly controversial issue and an area in which the EPA must be, and be perceived as being, completely objective and impartial. Even in cases in which an individual is highly qualified for the position, a real or perceived conflict of interest would further decrease public confidence in the agency and its regulation of biotechnology. Also, controversy concerning the regulation of agricultural biotechnology has resulted in a huge loss of trade in genetically engineered crops. Appointment of anyone with ties to the regulated industry would only exacerbate tensions with our trading partners.

We commend President Bush’s oft-stated goal of adhering to high ethical standards. Appointing high-level officials with real or perceived conflicts of interest, in the regulation of agricultural biotechnology or other matters, would be contrary to those goals. Though appointees with conflicts might recuse themselves from decisions related to biotechnology, such a solution would diminish the value of those employees and would be unlikely to quell legitimate doubts about the broader influence of such an individual on EPA's biotechnology policy.

Therefore, we urge you not to appoint individuals with conflicts of interest concerning biotechnology or other issues over which they would preside. Qualified individuals without such conflicts can surely be found.



Michael F. Jacobson, Ph.D.
Executive Director
Center for Science in the Public Interest
1220 L St. N.W., Suite 300
Washington, D.C. 20005
202-332-9110 Ext 377
on behalf of:   Carol Tucker Foreman
Distinguished Fellow and Director
of the Food Policy Institute
Consumer Federation of America
1424 16th Street, N.W.
Washington, D.C. 20036

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