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Author Topic: Petition Seeking Mandatory Labeling of Genetically Engineered Foods  (Read 5304 times)

Description: (USA) - Non-big8 concerns?

Offline LinksEtc

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I'm just sharing this here in case anybody is interested. 

www.regulations.gov
ID FDA-2011-P-0723
"PETITION SEEKING MANDATORY LABELING FOR GENETICALLY ENGINEERED FOODS"

I remember reading a while back in the book "Food Allergies for Dummies" about the "Brazil nut soybean debacle".  I know the Big8 USA allergens have to be labeled, but I am concerned about the safety of genetically engineered foods for those with non-big8 allergies.

--------------------------

FDA does not seem to be considering the safety for those of us with non-big8 allergies.

http://www.fda.gov/ohrms/dockets/dailys/02/Jan02/011102/00d-1598_let0001_vol476.pdf

(Please forgive any typos in the below quote ... there was an error copying the text.)

Quote
Fortunately, we know a lot about the foods that do trigger allergic reactions. About 90 percent of all
food allergies in the United States are caused by cow’s milk, eggs, fish and shellfish, tree nuts, wheat,
and legumes, especially peanuts and soybeans.

To be cautious, FDA has specifically focused on allergy issues. Under the law and FDAs biotech
food policy, companies must tell consumers on the food label when a product includes a gene from
one of the common allergy-causing foods unless it can show that the protein produced by the added
gene does not make the food cause allergies.


--------------------------

I'm not sure how concerned I should be.  I know we've had a couple discussions about modified foods at FAS.
 
« Last Edit: November 01, 2011, 03:34:03 PM by LinksEtc »

Offline CMdeux

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Re: PETITION SEEKING MANDATORY LABELING FOR GENETICALLY ENGINEERED FOODS
« Reply #1 on: October 31, 2011, 01:09:23 PM »
Thanks!

I'm pretty comfortable with the regulatory process on this one as it exists, honestly.  JMO.


It isn't that it can't be a reason for concern-- obviously, it can-- but that there are so many OTHER gaping holes in the safety net for those with FA that this is something of a red herring IMO.

GMO's are much more heavily vetted in every imaginable way than anything 'conventionally' or 'organically' produced...

and really, how much do we know about what gets sprayed, dusted, or dip-coated onto our food as it is?

Fining agents and oils are exempt, and FALCPA only covers the top 8 even in exclusion of that... USDA products aren't regulated w.r.t. FA at all.

None of that will change with GMO regulation... and the data about allergenicity is already a requirement for the FDA approval process... which is why some GMO efforts have been abandoned.  Because any time there are markers for allergenicity (a protein that is extraordinarily pH and heat stable, for example, or is protease-resistant), that generally leads to a redesign to avoid the issue.  It always has.

I could go on.

But in short, I see this kind of effort as a giant waste of energy and resources for people wanting to be activists for better and safer food labeling. 

If people object to the technology on philosophical grounds, fine.  But the safety issues aren't really the giant unknown that they are frequently portrayed to be, and there are BIGGER FISH TO FRY in the FA-food-safety department.

Again, just my opinion, but it's one based on understanding the technology involved in creating GMO's, as opposed to that in conventional ag and selective breeding.  I am far more afraid of food processing than I am of genetic engineering.
 
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Offline LinksEtc

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Re: PETITION SEEKING MANDATORY LABELING FOR GENETICALLY ENGINEERED FOODS
« Reply #2 on: October 31, 2011, 01:16:36 PM »
Thanks CM, I always value your opinion!

I may comment briefly on this, but it is definitely not my main fish to fry!

Offline CMdeux

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Re: PETITION SEEKING MANDATORY LABELING FOR GENETICALLY ENGINEERED FOODS
« Reply #3 on: October 31, 2011, 01:45:41 PM »
 :yes:

Honestly, if I were to get BIG changes that I desperately want-- those would expand FALCPA-style coverage to be inclusive of the top 12 the way it is in parts of the EU...

and they would need to CLOSE the loopholes of oils, highly refined ingredients, drugs, cosmetics, and agricultural products.  That's my dream.

Oh-- and some kind of mandate about divulging shared lines and production facilities at the very least-- upon demand, if not on packaging itself. 

I'll bet I'm not getting any of that for Christmas, though. ;)

     
My worry about efforts like the one in the above petition is that they are fundamentally guided by a notion (scientifically incorrect, probably) that "all this Frankenfood" is what is causing food allergy incidence to rise in the first place...
there is literally NO evidence (in spite of looking for it) that this is so... and again, literally no mechanistic reason why it should be true in the first place, besides which, it draws much-needed research $$ from other basic research which COULD be helping our community. 

But what is actually true isn't necessarily all that important.  The allergen issues are "plausible" here because they are theoretically possible.  It becomes about using us as poster children for a particular agenda.    Which I really don't like even if I agreed with the underlying philosophy, (which I don't).  Today is the day, OFFICIALLY, that the UN has designated 7b day.  I'm not sure that we can feed that many people (nevermind the 10b that the planet is likely to be home to in 35 years) without biotechnology-- at least not without completely destroying every inch of land biome on it in order to farm without the edge that it provides us.  Anyway.  I digress.  I'm not inherently "pro" on the issue. I simply object to framing it as an allergy concern.

  I don't feel like it's right to use the LTFA community's very real concerns about food and twist them to serve an unrelated agenda.  It also runs the VERY real risk of conflating LTFA with those people who will swear up and down that their "highly allergic" family member has "no problem at all with raw/organic/natural {allergen.}" <blink-blink>  Those people probably ought to be flogged, IMO, for the invidious impact on families like ours in the courts of public opinion.


"Natural" food allergens are still going to be a huge problem after the people behind efforts like this have gone back to their free range eggs and organic peanut butter.  <sigh>  I'm afraid I see them as shamelessly opportunistic zealots rather than useful partners.


With that, I'll shut up about it, though.   :footinmouth:

I certainly don't have any objection to people voicing their views and concerns to the FDA and other regulators.  Higher visibility surrounding LTFA is almost certainly a good thing overall.
Resistance isn't futile.  It's voltage divided by current. 

Western U.S.

twinturbo

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Re: PETITION SEEKING MANDATORY LABELING FOR GENETICALLY ENGINEERED FOODS
« Reply #4 on: November 01, 2011, 07:20:02 AM »
Most people don't realize that any sort of selective breeding is genetic modification. That started with agriculture. I think most people have this idea it's a mad scientist on the payroll at an insidious corporation. A lot of times it's trying to get a specific shade of flower or making a crop more hearty or resistant to improve harvest in impoverished areas.

Offline ajasfolks2

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Re: Petition Seeking Mandatory Labeling of Genetically Engineered Foods
« Reply #5 on: November 04, 2011, 02:37:20 AM »
Just putting this link here -- don't recall having ever seen this site, but thought it was very interesting!


Food Allergy Research and Resource Program

Quote
FARRP was established in 1995 as a cooperative venture between the University of Nebraska and seven founding industry charter members.  Today, FARRP has more than 50 member companies, more than one dozen staff members and several graduate students.  FARRP has two primary missions:

Mission 1
Develop and provide the food industry with credible information, expert opinions, tools, and services relating to allergenic foods.

Mission 2
Develop and provide the agricultural biotechnology industry with credible information, expert opinions, tools, and services relating to novel foods and food ingredients including genetically modified products.

FARRP takes a comprehensive approach working with and collaborating with research institutions, governmental authorities, consumer groups, and scientific societies around the globe to share our experience and knowledge to improve the safety of food products for consumers with food allergies and sensitivities.


http://farrp.unl.edu/home

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Offline LinksEtc

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Re: PETITION SEEKING MANDATORY LABELING FOR GENETICALLY ENGINEERED FOODS
« Reply #6 on: November 05, 2011, 09:45:19 AM »
Most people don't realize that any sort of selective breeding is genetic modification.

The thing is with selective breeding, you're not going to find completely unexpected genetic material in a food.  When it comes down to it, a banana would be a banana would be a banana.  If I have a food allergy to something different than a banana, I'm not expecting that allergen to be inside a banana once peeled.

It can be said that the non-big8 don't have to be labeled now with regular food, so they shouldn't with modified food.  However, imo, GE changes the rules of the "game" so I think they should have a responsibility to label for any allergen.

If it's no big deal, they shouldn't have a problem making it formal and telling me that they will label if there are health concerns regarding any known allergen.

Offline CMdeux

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Re: Petition Seeking Mandatory Labeling of Genetically Engineered Foods
« Reply #7 on: November 05, 2011, 10:54:37 AM »
Actually, you can.

It isn't that a banana isn't going to be a banana...


but what if... um...  you could select for a banana that was FROST-resistant?  That way it could be grown in non-equatorial regions... might be good for preserving rainforest, reducing shipping costs, etc. 

Well, the BIOTECH method would use a very specific gene that impacts (probably) the frost-resistance of the plant, perhaps by including a gene from another plant that IS highly frost-resistant....  The gene product of the modification would, at a minimum, be extremely well understood and bear known characteristics.  As a protein, I mean.  A known allergen would NOT be used for this purpose, and furthermore, suspected ones aren't either-- and by that, I mean that anything that rings alarm bells for having high allergenic liability (heat and protease resistance among other things.)  Well, so what about if the newly introduced
Before-market testing would be done to compare (carefully) the 'control' specimen to the GM one in terms of OTHER protein components.  After all, nobody wants to eat a banana that tastes like kale.  Well, okay, maybe a few people might...  but anyway.  My point is that alterations in the plant's NATIVE proteins would actually be monitored and considered in the development of a GM food crop.  Compare that to the means of developing a non-GM crop with the desired properties...

The NON-biotech method would look for specimens that responded in the desired manner, and might consider what other species could be used to "cross" with the banana.  Not being a botanist by training, I have no idea just HOW promiscuous banana trees are, but some plants are HIGHLY so, and others not much.  This method uses Darwinian pressure to produce the desired traits.  In an empirical sense, though-- so that process of checking to investigate alterations in native protein production doesn't really happen in this instance, because it isn't happening in the same kinds of programs.  Of course, that doesn't mean that you can't turn ON previously silent genes.  Genes which might well produce allergens-- or might begin producing them in quantities necessary for them to become priority allergens, even.

For an example of what I'm trying to say, here-- look at Quorn.  Okay, it's a mushroom.  Well, sort of.  It's definitely NOT GM.  Is it 'safe' from an allergenicity standpoint?  Should be as safe as mushrooms, yes?

But it apparently is not.
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Offline Arkadia

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Re: PETITION SEEKING MANDATORY LABELING FOR GENETICALLY ENGINEERED FOODS
« Reply #8 on: November 05, 2011, 11:24:48 AM »
Most people don't realize that any sort of selective breeding is genetic modification. That started with agriculture. I think most people have this idea it's a mad scientist on the payroll at an insidious corporation. A lot of times it's trying to get a specific shade of flower or making a crop more hearty or resistant to improve harvest in impoverished areas.

You couldn't feed seven billion people without it. Plagues, Disease, and Pestilence are expected, and natural outcomes in the agriculture otherwise. <shrug>

They are a natural reset. Otherwise, we wouldn't have SEVEN BILLION people on this planet.

While not exactly a parallel, vaccination is a type of GMO.

to a degree, we've taken natural selection out of the population (famine, vaccination, fertility management, selective reduction, health care technology, etc.) It has to be put back in somewhere. Ensuring a food supply, however "inferior" in the eyes of some, is one of those steps.

I think we can agree, the extent of population culling, otherwise, wouldn't be an exceptable outcome for the majority of us, myself included.
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Offline LinksEtc

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Re: Petition Seeking Mandatory Labeling of Genetically Engineered Foods
« Reply #9 on: November 05, 2011, 11:37:58 AM »
I think I see what you're saying CM, but aren't there some things that wouldn't naturally be able to "mix" without GE?

It's not that I can't see the benefits of GE.

I guess I'm just somewhat concerned that this is going to eventually introduce additional difficulties for those with non-big8 allergies.
« Last Edit: November 05, 2011, 11:39:34 AM by LinksEtc »

Offline CMdeux

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Re: Petition Seeking Mandatory Labeling of Genetically Engineered Foods
« Reply #10 on: November 05, 2011, 12:13:29 PM »
It probably is.

No question.  But it's probably dwarfed by the other inevitable problems looming.

But the risks, in my opinion (and in that of most scientists who are familiar with the molecular biology techniques and what they can-- and cannot-- do relative to the other strategy of "pressuring" species and cross-breeding) are not really much altered from conventional agriculture and selective breeding.

As for 'there are some things that can't mix'  um.... well, no.  Not really.  Pretty much anything is possible-- EVENTUALLY.  The one exception might be some of the black smoker vent organisms (from which Taq polymerase is derived... just as a FYI aside), since they seem to have a differing metabolism entirely from other life forms on the planet.

After all, look at how many different types of potato exist.  The wild type is virtually unrecognizable among them.

Now, it takes time to develop all those different varieties, certainly...

but what GM opponents are arguing, when you get right down to it, is that 'wheat' is somehow a 'better' thing from an allergy standpoint (relative to, say... SPELT...) than GM soy is relative to natural soybeans.

I just don't think that there is much validity to that argument through the lense of allergens.  ANY protein can be an allergen-- and probably IS, to someone, somewhere.  At least with GM technology, there is a CONSCIOUS attempt to avoid introduction of anything that seems likely to be a food allergen.  That is untrue of conventionally selected crops.  It's ironic, but GM technology probably makes things SAFER from an allergen standpoint than the other way around.

There are people who are allergic to pretty much all the members of the grass family.  Should we require products containing millet and sorghum to note that these are domesticated varieties which have been produced by hybridization with other members of the larger family of plants?  New varieties are developed all the time... and look at the headaches it causes all of us to find the new "it" ingredient and have to wonder... WTH  is that??!!     (E.g. shea ten years ago, a variety of tropical seeds and fruits now.)

Even among peanut allergic patients, there are functional differences in WHICH protein which individual is allergic to.  Same with milk and egg, and no reason to think that it doesn't also hold true for the rest of the top 8 (or 10 or 12).  Altering the expression level even through conventional methods definitely manipulates (albeit unintentionally) the protein expression in a plant (or other organism).

This is why I'm FAR less concerned with GM foods than I am with the co-processing that happens in the food system the way it exists now.

It's also why I (personally) do not support efforts like this.  Because I feel that it overlooks very real problems in our food chain and placates the large group of people that are emotionally invested in being anti-technology, rather than basing their stance on actual science.   As noted previously, my own reluctance is that I feel that it robs the FA community of very much needed credibility of we lend our voices to anti-GM rhetoric, even a little.

I feel so strongly about this, in fact, that I've repeatedly spoken out AGAINST this particular talking point IRL.  If anti-GMO folks want to pursue their agenda, that's fine.  It is constitutionally protected free speech, after all, even if it doesn't have the scientific validity that they would like to claim.  But they MAY NOT co-opt my family as poster children in their efforts.  Make no mistake, insistence on GMO labeling isn't going to lead to ANYTHING but demonization of GM foods, and that is exactly what the underlying agenda is here.

  My family?  We have real problems with food-- we don't need to borrow theoretical ones.  This is, in my estimation, like being carried along by a mob that storms the hospital, finally produces a genuine 'patient' and angrily shouts for care-- and then cheers robustly at a cute bandaid on an uninjured fingertip.  Personally, as that patient, I'd like it better if someone would look at a sucking chest wound rather than telling me that I needed protection for that fingertip.  The mob isn't really interested in my problems, and they are a noisy distraction when it comes to the real issue.

If that makes sense. 
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Western U.S.

twinturbo

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Re: Petition Seeking Mandatory Labeling of Genetically Engineered Foods
« Reply #11 on: November 05, 2011, 01:11:31 PM »
^+1

Quote
The one exception might be some of the black smoker vent organisms (from which Taq polymerase is derived... just as a FYI aside), since they seem to have a differing metabolism entirely from other life forms on the planet.

I saw that! Astrobiologists have been going on deep sea expeditions to theorize that some of those organisms are more closely adapted to environs on other planets than our own surface.
« Last Edit: November 05, 2011, 01:21:12 PM by twinturbo »

Offline CMdeux

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Re: Petition Seeking Mandatory Labeling of Genetically Engineered Foods
« Reply #12 on: November 05, 2011, 01:46:32 PM »
I'd be okay with GMO labeling if (and it's a big if)


there were simultaneously;

a) better scientific literacy on the subject (in other words, if the word "frankenfood" quits getting tossed around and/or people start noting how ridiculous it is to differentiate between a surgical gene insertion and the sledgehammer methods of conventional plant breeding) 


b) there were REAL transparency in the use of foodstuffs from top to bottom in the food chain.  This means that if someone calls a food manufacturer (and hey-- having a phone number on all packaging might be a GREAT start, even) that consumer SHOULD, legitimately, be able to ask about co-processing of ANY other foodstuff, ask about SOURCING of any ingredient, and get answers that are honest and forthcoming.  I wish that it weren't like pulling teeth to get information.

c) finally, we need to apply the SAME standard to conventionally produced foodstuffs.  So if I want to know what a particular ingredient might, in a genetic sense, be related to-- I should have a way to find that out.


If that includes GM ingredients, so be it, and people who care enough can make all of the phone calls they want to investigate. Of course, I can't really USE the information unless I have a complete profile that tells me exactly which gene products I have an allergy to, and it also doesn't reveal which gene products are PRESENT in the conventional crops, because it just isn't known in most cases.
 

The numbers of FA people actually harmed by undisclosed cross-contamination in restaurants and food processing are MANY orders of magnitude higher than the numbers of FA people who are theoretically vulnerable via GM of food crops or, for that matter, by "emerging" food allergens produced conventionally.  Though to be fair, I predict that the latter is the greater threat.

  There are several examples that I'm aware of in which a GMO under development was redesigned or scrapped because of allergen concerns-- even theoretical allergen concerns.  GM foods have to pass through a series of regulatory hurdles that conventional varieties do not, so the risks are probably about equal even in the most critical evaluation of their safety.


Sorry.  It's just that I find this kind of thing MADDENING.  Neo-Luddism for its own sake shouldn't be driving things by masquerading as other concerns and by manipulating the masses with unfounded fear... but that seems to be how it has been working. 

Risk evaluation places a disproportionate danger on things which are alien, mysterious or poorly understood.  This is why people fear airplanes but not automobiles, even though this is directly counter to the actual risks involved.  It's because they KNOW how a car is operated, but the forces that keep an aircraft aloft aren't as widely understood.  Ergo, it is completely understandable that people FEAR biotech-produced foods and medicines more than they do conventionally-produced ones.  But that doesn't make the fear a rational one, necessarily.  Suspicion of the unknown is a hard-wired human trait; it's what kept us alive as a species and allowed there to be 7bn of us on the planet to begin with.  So it isn't that I'm saying it shouldn't be that way.  It's just that if we allow it to rule our decision making the way we did when we lived in small tribal groups during the Ice Age, we're going to have a lot of problems maintaining this population...

or not, as Ark pointed out.   ;)

Again, I'm not "pro" anything here, I just understand the science so that GM crop development isn't an unknown for me personally.  I feel the same way about 'natural' pesticides and herbicides versus synthetic ones, food irradiation, etc.    There are things to be fearful about in technology, but if pharmacology in the past 100 years has taught us ANYTHING about the law of unintended consequences, the thing that truly stands out to me is that EMPIRICALLY driven development of crops, drugs, and medical practice is often fraught with MORE pitfalls than the high tech, basic-research driven version.  Consider a drug that targets a particular condition.  Do you want the one that is plant-derived, "all-natural" and causes an unknown plethora of side effects because while it "works" to treat "problem Z" it isn't really clear HOW it works... or, for that matter, exactly how "problem Z" happens in the first place?  Well, yeah-- maybe... if it's that or 'incredibly painful imminent death" then probably so.  But if you have a choice between a drug that targets 99% of one enzyme's activity (the target) and 30%-60% of seven OTHERS (unintended targets)... versus a deliberately designed drug that targets 75% of the target AND NOTHING ELSE, which one seems like the 'better' drug?  The SAFER drug?

Of course-- it's the one with the greater precision.  The one that does only what we were hoping, and nothing else. Of course, that doesn't mean that a drug class can't still have unintended effects, particularly long-term ones. But that's true of BOTH of those hypothetical drugs.   But 100 years ago, many laypersons would have chosen an herbal preparation over a synthetic, simply on the basis of familiarity.  Nevermind that the 'natural' version might come with liver toxicity that the refined versions didn't.  <sigh>

Same thing is true in plant genetics.  There are gene linkages when you begin talking about traits produced by or selected for using conventional breeding.  Crop scientists may not care what 'secondary' traits come as a package deal with a desirable one, as long as they don't affect the commercial status of the crop...  but that doesn't mean that they won't turn out to be important to someone, somewhere.  People with PKU and other metabolic disorders have some skin in this game, too.

We've been accelerating the crop development timeline as human beings for not-too-many generations of people.  I'm going to seriously LMAO if it turns out that GM foods weren't the problem with increasing atopy and autoimmune disorders, and that something that happened back in Luther Burbank's day is.   Funnier still if it turns out to be something like a "natural" pesticide like Rotenone, which has only been in TRULY wide use since the 'green' revolution of the 1980's and a return to a scaled up verison of organic ag in the 90's. 

We're operating under the assumption that the familiar is safe.  It is NOT, nor is it all well-defined.  If the argument is about the speed with which GM can accomplish what conventional breeding takes more time to do... well, that's probably a red herring as well.  We're saying that pressuring organisms at a rate 100X (as we have for the past 10K years or so) is fine, selective breeding at even 1000X the rate of human evolution (as in the 20th century) is okay... but that a rate which is 104X isn't, in that case.

  It might be true (it's what the Paleo-diet folks certainly claim, anyway)... but if it is, then we're right back to pre-agricultural revolution foodstuffs.  At that point, we've got a much, MUCH bigger problem than labeling things that might turn out to be food allergens to someone somewhere, because we're going to have to use low-yield and pest-prone varieties and not everyone is going to be eating.

Again, I know that I'm soapboxing a little.  It's just really hard for me not to try to explain this in the scientific terms.  Sorry.   :footinmouth:
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Offline Arkadia

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Re: Petition Seeking Mandatory Labeling of Genetically Engineered Foods
« Reply #13 on: November 05, 2011, 02:03:25 PM »
It's just that if we allow it to rule our decision making the way we did when we lived in small tribal groups during the Ice Age, we're going to have a lot of problems maintaining this population...

or not, as Ark pointed out.   ;)


wait until society has to choose between corn production for a food source vs. for one of ethanol production. Because it's coming, if not already here. Grain embargos are going to get interesting....
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Offline LinksEtc

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Re: Petition Seeking Mandatory Labeling of Genetically Engineered Foods
« Reply #14 on: November 05, 2011, 02:36:12 PM »
Again, I know that I'm soapboxing a little.  It's just really hard for me not to try to explain this in the scientific terms.  Sorry.   :footinmouth:

I really appreciate your explanation CM ... it helps me to understand the issue better   :yes: