By Dr. Gregg B. Feigelson
July 18, 1997
Dr. Barbara A. DeBuono
New York State Commissioner of Health
Via FAX Transmission: 518-474-5450
Dear Dr. DeBuono:
I am very concerned about your department's involvement
with activities initiated by the NYS Department of Environmental
Conservation concerning the live capture of wild Canada geese for
slaughter. It is eminently clear that since such actions are as
unpopular as they are cruel, the NYS DEC has decided to implement
a false charity public relations gimmick: distribution of the dead
geese to the needy, homeless, and elderly -- a segment of society
for which, at least superficially, the general public has sympathy.
The needy and disenfranchised must not only be protected from the
physiological harm that might result from ingesting "food" from
an unregulated source, but they also need protection from a clear
case of premeditated socio-economic discrimination. I ask that
your department reject out-of-hand any attempt to distribute the
flesh of these dead geese.
It is peculiar that the wildlife division of the
NYS DEC would voluntarily commit resources to oversee the slaughter
of geese and the testing of their flesh for toxic chemicals. Such
activities bear no relation to their overall mission and tend to
imply ulterior motives. While these suspicious circumstances prompt
legitimate concern over the validity of the data generated, there
are issues of interpretation that also must be addressed. With
due respect, I must point out that it would be completely irresponsible
to determine the safety of consuming geese based on established
thresholds. Scientists have recently begun to challenge these "acceptable
levels" and in many cases determined that such levels are
orders of magnitude too high.
Further, it is particularly important
to note that such standards were not designed to predict margins
of safety for those whose overall health deviates substantially
from "average": the groups targeted to receive the flesh
(e.g. the needy, homeless, very young, the elderly and combinations
thereof). Thus, since there are no sound scientific standards to
which the toxic substance testing data can be compared, there can
be no legitimate grounds to claim that wild geese are safe for
these individuals to consume. I take for granted that your agency
shares my belief that all law abiding citizens of New York State,
regardless of age, race or economic status deserve protection from
exploitation; especially from state agencies who are looking for
distractions to their agendas of destruction.
By not allowing the
NYS DEC to create a dangerous double-standard of food safety,
a low standard for the needy and a higher one for those who can afford
it, your department will have the opportunity to confirm our
beliefs. I ask that the New York State Department of Health
not become a party to the unethical public relations maneuvers of
Department of Environmental Conservation (Bureau of Wildlife).
Please reject their efforts to hide the evidence of their actions
in the bowels of our state's most vulnerable.
Sincerely, Gregg B. Feigelson, Ph.D.