Vicki - thanks for sharing these comments. The more the FDA gets of comment such as these the greater the chance they'll see the errors in the initial rules-making and make the changes necessary.
Dru et al - if you get this - thanks to you and your group as well for these excellent comments.
I have attached as well comments submitted recently to the FDA by the Wastenaw Food Policy Council. They were formulated by The Farmer Policy Action Team of the WFPC, major credit going to Farmer PAT member Daniel Poon.