text:
May 3, 2001
By Fax and Regular Mail
Dockets Management Branch (HFA-305)
Food and Drug Administration
5630 Fishers Lane, R
Re: Comments on Docket Number 00N-1396, Premarket Notice Concerning Bioengineered Foods.
The Center for Science in the Public Interest ("CSPI")(1) submits these comments on the
Food and Drug Administrations ("FDA") proposed rule entitled "Premarket Notice Concerning
Bioengineered Foods" ("PBN Rule").(2) The proposed PBN Rule, which we generally support, is a
useful, though modest, improvement over the current voluntary consultation process. We urge
FDA to make more sweeping changes in its regulations.
1. A Mandatory Approval Process Will Safeguard the Food Supply and Bolster Public Confidence.
FDA should review and approve the safety of every genetically engineered food before it
is marketed. The public deserves a fair, transparent, mandatory premarket approval or
certification process, including an opportunity for meaningful public input. Only a mandatory
premarket approval process will maximally safeguard the food supply and bolster public
confidence in the safety of genetically engineered foods. The proposed PBN Rule, which is a
mandatory consultation process for all genetically engineered foods, will not inspire maximum
public confidence in the safety of this powerful new technology.
There are several reasons why FDA should institute a mandatory approval process for
genetically engineered foods.(3) First, this is a relatively new technology for producing food and
one cannot currently predict what products will be produced and whether they will be safe. In
fact, FDA acknowledges throughout the proposed PBN Rule that genetic engineering is a special
technique for producing foods that requires greater regulatory scrutiny than the current voluntary
process.(4) Second, both USDA and EPA have mandatory approval processes before the
genetically engineered plants that they regulate can be released into the environment. Those
processes, which have formal opportunities for public input, attempt to protect our environment.
Surely, all food, not just food with a pesticidal product, deserves a complete and open process to
review the safety of that food. Third, the burden on industry from a mandatory approval process
would be minimal. In most cases, developers must already ensure that their genetically
engineered food is safe by conducting numerous scientific studies and tests. A mandatory
approval process could be completed within a time period similar to the proposed PBN Rule.
Fourth, a mandatory approval process would harmonize the safety review of genetically
engineered foods in the U.S. with what occurs for identical foods introduced into commerce in
Europe and other countries elsewhere around the globe. Finally, a mandatory stamp of approval
from FDA for each genetically engineered food will significantly bolster public confidence, in
the U.S. and abroad, in this technology and its products. Without mandatory approval, U.S.
consumers might wonder why foreign governments, but not the U.S. government, review and
approve genetically engineered foods.
CSPI recommends that in a mandatory approval process, the testing and information
requirements for genetically engineered food products should be based on their potential for
causing harm. Specific factors that should be considered in deciding the testing and information
requirements might include the characteristics of the donor species, the gene transferred into it,
the organism of the transferred gene, whether the transferred gene came from a closely related
species, whether the donor organism is a traditional food where the transferred gene is expressed
in the consumed part of the donor plant, and whether the transferred gene is derived from a
organism that is known to cause allergenic reactions.
Finally, any mandatory approval system needs to be transparent and allow for
involvement by the public. FDA should establish for every application to market a genetically
engineered food a docket that contains all the non-confidential information in the application, all
additional information received by the agency (whether from the company or other party),
documentation of the substance of any telephone calls or meetings between FDA and the
company or other parties, and all FDA documents pertaining to the food, including the agencys
final decision and related materials.(5) FDA should publish a Federal Register notice announcing
the receipt of an application and provide ample opportunity for public comments to the agency
well before its final decision. Upon completion of its review, FDA should publish a notice in the
Federal Register announcing the agencys final decision. The notice should summarize the
agencys finding, rationale, and supporting information.
If FDA believes that it does not have the statutory authority to require a mandatory
approval process for genetically engineered foods, it should seek such authority from Congress.
2. Transparency of the PBN Process.
CSPI supports all aspects of the proposed PBN Rule that make the information submitted
by the developers and the agency review process available to the public in a transparent manner.
In particular, CSPI supports the following provisions in the PBN Rule(6): (1) 21 CFR § 192.10 ©
and (d), which state that most presubmission-consultations information would not be confidential
and would be made available to the public; (2) 21 CFR § 192.10(I), which states that FDA will
establish an administrative file for the consultation and place specific materials in that file for
public access; (3) 21 CFR § 192.40, which sets forth the rules for disclosure of the PBN and
FDAs methods of providing the information to the public; (4) 21 CFR § 192.20(b), which
requires a redacted copy of any PBN submission that clearly identifies the location and
approximate size of any information claimed as confidential; and (5) 21 CFR § 192.40(e), which
states that FDA will make easily available to the public the text of any letter issued by the agency
under § 192.30 © and the agencys completed evaluation of the PBN. With those provisions in
the final rule, the public would have increased confidence in FDAs review process because it
would have access to virtually all information in both the voluntary consultation and the PBN
review process. That will enable anyone to independently evaluate both the data submitted and
FDAs analysis of that data.
CSPI suggests several additional steps that should be considered in order to have a truly
transparent process. First, section 192.10, which governs the proposed presubmission
consultation process, includes specific regulations that establish an administrative file for the
consultation (§ 192.10(I)), yet there is no similar regulation for the PBN process (§ 192.40
discusses public disclosure but does not discuss what would be in the administrative file). The
PBN Rule should specify that an administrative file would be established that would include the
PBN, any additional written materials or correspondence from the notifier, any correspondence
from FDA to the notifier, documentation of any requests from FDA for additional information
needed by FDA, and a memorandum of each meeting, e-mail, significant telephone call, or other
communication between FDA and the notifier during FDAs review process. Similar to the
voluntary consultation process, the public should be provided with all documents transmitted
between the notifier and FDA throughout the review process. Second, under the proposed PBN
process, the public would have access to the PBN only when it has been filed by FDA. To have a
truly transparent process, the public should have access to any initial PBN submission, even if it
was deficient, and any documentation of what FDA has told the notifier is missing under Section
192.30(a)(2). Finally, as explained in more detail below, FDA should make available to the
public the notifiers justification of any confidentiality claim and FDAs decision on those
3. Public Involvement in the PBN Process.
Even if FDA does not propose a mandatory approval process, the proposed PBN Rule
should invite the public to submit comments on the PBN at any point during the 120-day review
process. FDA states in the preamble to the PBN Rule that the PBN process would ensure that
"market entry decisions by the industry are made consistently and in full compliance with the
law." Clearly, any relevant information from the public on this issue, such as scientific data on
the allergenicity of a protein coded for by a particular transferred gene, would be helpful to
FDAs review of the genetically engineered food. FDA, in safeguarding the food supply, needs
to review ALL relevant data about a particular genetically engineered food, not just information
from the notifier. Therefore, FDA should allow for the submission of information by the public
relevant to the FDA review of the genetically engineered food.
4. Confidential Business Information Claims.
CSPI appreciates the attempt by FDA to balance the rights of the public to obtain
information in the hands of the government with the rights of a notifier to safeguard truly
confidential business information. CSPI agrees with FDAs statements that, in most cases, the
fact that a notifier is consulting with FDA about a genetically engineered food and the PBN
submissions would not be deemed confidential. As stated by FDA, most presubmission
consultations and PBNs would occur subsequent to or simultaneously with approval processes at
either USDA or EPA, both of which involve processes where some of the specifics about the
genetically engineered food have already been made available to the public. In addition, CSPI
agrees that it should be the burden of the notifier to explain why the consultation itself (§ 192.10)
or specific information in the PBN (§ 192.25(a)(4)) should not be disclosed. CSPI recommends,
however, that the final rule preamble state that general claims that information is a trade secret
without specific substantiation would be rejected as inadequate and that any confidentiality claim
must specifically address each particular piece of information being claimed confidential.
Finally, CSPI agrees with the provisions of the PBN Rule that require the notifier to submit
redacted versions of their submissions. That will allow the public access to as much information
as is allowed by law.
One issue that the current PBN Rule does not address, however, is public access to the
notifiers confidentiality claim and any FDA decision on that claim. That information (with
redactions where necessary) should be made available to the public so that it could evaluate the
validity of the notifiers claim and analyze whether FDA had acted within the law. The public
has certain rights under the Freedom of Information Act but it would be unable to ensure that
those rights had not been compromised without access to the notifiers explanation about why its
information was confidential. Therefore, FDA should state in the final rule that if any
information was deemed confidential, FDA would make available in the administrative file the
notifiers documents supporting its claim and FDAs decision regarding that claim.
5. Allergenicity of Genetically Engineered Foods.
Several places in the PBN Rule address the allergenicity of genetically engineered foods.
First, Section 192.25(f)(4) requires the PBN to include "a discussion of the available data or
other information that address the potential that a protein introduced into the food will be an
allergen." CSPI believes that that requirement is too general and that for foods containing genes
from an organism that causes allergic reactions, either the petition should document that a gene
that codes for an allergen was not incorporated into the engineered organism or thorough
allergenicity testing should be required. Second, FDA states on page 14 of the preamble that
even with appropriate labeling, certain genetically engineered foods containing an unexpected
allergen would probably be considered adulterated within the meaning of section 402(a)(1) of the
Act. CSPI urges FDA to state that all genetically engineered foods into which an allergen has
been introduced are adulterated and prohibited from being marketed. CSPI can find no reason to
allow on the market a genetically engineered food into which a new allergen has been introduced.
Finally, FDA states that it is developing guidance for evaluating the potential allergenicity of
proteins introduced into genetically engineered foods based on a conference held in 1994. A
guidance document on this subject would be extremely useful. It should be based, however, on
the most current scientific information about allergenicity, whether or not that information was
presented at the FDA, EPA, and USDA joint conference in 1994. For example, FDA should
review EPAs recent (2000) SAP reports on allergenicity that modify, in some cases, the weight-of-evidence approach suggested by the 1994 conference.
6. Data and Safety Testing Requirements for Genetically Engineered Foods
In the proposed PBN Rule (and the current voluntary consultation process), FDA has not
provided any details about what specific data and safety testing are needed for genetically
engineered plants. While CSPI agrees with the need for a case-by-case evaluation of genetically
engineered foods, detailed data and testing requirements are necessary for the PBN review. The
currently used decision tree from 1992 provides a basis for the circumstances for when data may
be needed but does not describe specific testing protocols. FDA should elaborate on the specific
data and testing requirements, either in the regulations themselves, the preamble to the
regulations, or in guidance that accompanies the regulations.
Section 192.25 (f)(5), which is a catch-all provision for additional safety data on other
classes of substances that might be introduced into a food, also needs additional elaboration.
While FDAs decision trees from 1992 and other guidance address the introduction of genes
whose intended effect involves proteins, fats, carbohydrates, or micronutrients, there is no
decision tree or guidance for other compounds, such as hormones, secondary metabolites, or the
hundreds of other chemicals that might be engineered into a food. Many of these compounds
have complex biological activity in humans and animals and scientists knowledge about their
health effects, especially long term, is limited. FDA should elaborate on how genetically
engineered products that effect secondary metabolites will be treated under the regulation and
what data and testing will be required.
7. Addressing Unintended Effects from Genetically Engineered Foods.
In the preamble to the PBN Rule, FDA states that one reason for requiring a PBN is that it
is more likely that future genetically engineered foods may have unintended effects, particularly
from multiple gene introductions. It is unclear what FDAs basis is for that demarcation between
engineering of single and multiple genes. While multiple genes might have a higher probability
of unintended effects, there is no reason to believe that a single gene would not alter metabolic
pathways or cause mutations. FDA should ensure that it addresses unintended effects in all
genetically engineered foods, not just multiple gene introductions. Similarly, the preamble states
that rDNA and conventional breeding methods have a ". . . similar potential for unintended
effects . . ." (pg. 18). While several papers and reports have discussed unintended effects
resulting from rDNA and other methods of plant breeding, we are not aware of any attempts to
determine whether the frequency of such effects is higher or lower in rDNA crops. If FDA is
aware of such comparisons, it would be helpful to make them known. If such studies do not
exist, it would be prudent, as suggested by the NAS in its 2000 report, to give significant scrutiny
to the safety implications of unintended effects in all transgenic crops.
The proposed regulations, as written, do not require any information from the notifier
about unintended effects. Section 192.25 requires providing only toxicity and antinutrient
information for naturally occurring known substances. FDA needs to set forth the types of
testing that must be done to address unintended effects and when the different tests should be
performed. In general, FDA should consider requiring whole-food toxicity testing for all
genetically engineered foods where possible.(7) We urge FDA to commission an NAS study by
toxicologists and allergists to recommend details of a tiered testing scheme.
8. The FDA Response to a PBN (§ 192.30 (d)).
Section 192.30 (d), which addresses how FDA will respond to a PBN, needs to be
strengthened and clarified. Sections 192.30 (d)(1) and (2) need to explicitly state that marketing
of a genetically engineered food prior to FDAs completion of a review is prohibited. The
current language that FDA "expects" the food not to be marketed is ambiguous and may be
unenforceable. In addition, when FDA determines that the PBN does not provide a basis for
concluding that the genetically engineered food is safe or otherwise in compliance with
applicable law (§ 192.30 (d)(2)), FDA should be required to specify why it reached that
Section 192.30 (d)(3) should be revised to affirmatively approve the genetically
engineered food as being as safe as its conventional counterpart. An affirmative statement would
be much more helpful to the company and the public than a statement that the agency does not
have any questions regarding the notifiers view that the food is safe. At a minimum, however,
FDAs response to the notifier under §192.30 (d)(3) should set forth in detail the basis for FDAs
conclusion that it has no questions at this time.
FDA should modify § 192.30 (d) to add a fifth possible response to a PBN. That
response option would state that "the agency has no questions regarding the notifiers view that
the genetically engineered food is safe but that the following conditions stated in this letter need
to be met to comply with all applicable requirements." For example, if a genetically engineered
food requires a different name (e.g. high oleic soybean oil) or a specific label statement, that
condition should be specified in the final response from FDA to the notifier. That is particularly
important because, in most cases, the notifier will be the developer of the genetically engineered
food, not the manufacturer of the final food product that will be labeled and sold to the general
public. Thus, any use conditions need to be specifically identified in the final letter so that all
users of that food are aware of any conditions needed to comply with applicable law.
Finally, the rule should clarify what happens if, after the 120-day review period, FDA
responds that it is extending the evaluation for another 120 days as allowed by § 192.30 (d)(1).
At the end of the new 120-day period, could FDA again respond using § 192.30 (d)(1) and get
another 120-day extension or must FDA only choose among the other options in the regulations?
9. Methods for Detecting Genetically Engineered Food.
The PBN Rule should require that the PBN include methods by which the genetically
engineered food could be detected. At a minimum, a testing method for the presence of the DNA
of the transformation event and/or the protein from the introduced gene should be part of a PBN.
PCR or ELISA are two detection methods currently available to the industry to develop the
testing protocols for any PBN requirement.
10. Split Approvals
The PBN Rule, as currently written, would allow a genetically engineered food to be
marketed for animals but not for humans. The StarLink corn problem this past year has
demonstrated, however, that it can be difficult to segregate and prevent contamination from a
food approved only for animal use but that is eaten by both humans and animals. Therefore,
FDA should clearly state whether genetically engineered foods would be allowed for only animal
use and under what conditions. Except for foods that are only eaten by animals (such as hay),
CSPI believes that genetically engineered foods that humans might eat should not be marketed
only for animals.
11. Comments on Specific Sections of the Regulations.
Definition of "Notifier," § 192.1(c).
Although the definition of "Notifier" states that it can be anyone responsible for
development, distribution, importation or sale of the bioengineered food, the regulations are
written as if the "notifier" is the developer. No one other than the developer would have the
information required to be submitted in the PBN. In addition, if every manufacturer of a product
that contained a genetically engineered ingredient was required to submit a PBN, FDA would
receive far more than the 20 PBNs a year FDA predicted it would receive if the rule is finalized.
CSPI agrees that the developer is the most appropriate person to submit the PBN. CSPI does not
agree, however, with the discussion by FDA on page 40 of the preamble about the notifiers
responsibility to ensure that labeling of the food be appropriate as required by sections 201(n)
and 403 of the Act. To the extent that an affirmative label is required for the genetically
modified food (e.g., that the food is an allergen or that it should be called a specific name in the
ingredient list), the developer should be responsible for proposing a proper label and conveying
that information to the users of the particular food. The ultimate responsibility for the labeling of
a food under the Act, however, should fall upon the manufacturer of the product that is sold to
consumers. Therefore, the preamble should clarify that the company marketing a product to the
consumer is ultimately responsible for an accurate label designation.
The definition of "notifier" specifically includes an importer, yet nowhere in the
preamble is there is an explicit statement that imported foods that contain genetically engineered
ingredients are required to go through the PBN process. It is essential that imported foods that
are genetically engineered undergo premarket review, and the rule should state this explicitly.
Comment on § 192.5.
CSPI believes that the exemption from submitting a PBN set forth in § 192.5 (a) should
be modified to address situations where the level of expression of the intentionally modified trait
may vary in different genetic backgrounds. If the level of expression of the intentionally
modified trait is greater in a subsequent variety of the crop than the levels in the plant line that
represents the transformation event that was reviewed by FDA, then the subsequent variety
should not be exempted from submitting a PBN. These levels should be determined in the new
varieties under the same growing conditions as were required for the original submission. The
developers will likely have this information (at least on a phenotypic level) because it will have
implications for crop properties.
Additionally, there are insufficient data concerning similarities or differences in
unexpected transgene effects on expression of indigenous genes in different varieties of the same
crop to justify an exemption at this time. While similarities between varieties suggest that such
effects should be more predictable than for separate transformation events, there is little data to
support this contention. To the contrary, there are some data suggesting that transgenes may
effect gene expression in different varieties of the same crop in dramatically different ways(8).
On the other hand it would be impractical and unnecessary to require safety unique data
for each new variety that a transgene is bred into by traditional means. Therefore, FDA should
develop an intermediate policy of examining the first several such varieties under its criteria for
establishing substantial equivalence, in order to ensure that possibly adverse unexpected changes
have not occurred. If such testing of several varieties shows no adverse changes, or such changes
become predictable based on these tests, no further varieties would need to be tested.
Comment on § 192.25(b).
Section 192.25(b) requires a synopsis of the bioengineered food and is virtually identical
to the Section 192.10(f)(3) synopsis suggested in a voluntary presubmission consultation. The
preamble on page 42 states that the PBN synopsis should include the same information as the
presubmission consultation. CSPI recommends that FDA make clear that the PBN synopsis
required under section 192.25(b) should be the most complete and accurate information at the
time of the submission and need not be identical to the information submitted in the
presubmission consultation. In many instances, the presubmission consultation would require
the notifier to collect additional information about the genetically engineered food and the results
of the presubmission consultation should be reflected in the synopsis submitted in the PBN.
Comment on § 192.25 (d) (3).
CSPI recommends that FDA specify additional information about the transformation
event that must be provided. In particular, the submission should state whether the
transformation occurs in the nuclear genome or an organellar genome (presumably chloroplast),
the position of the gene insertions in the genome of the transformed plant and whether it is
inserted in a gene, and what is the sequence of the added genetic material of the actual
transformation event (as opposed to just the vector and gene(s) sequence prior to transformation).
Genome or organelle location is important, in part, to assess the likelihood of possible
contamination by pollen of surrounding crops (e.g., organic), since chloroplast transformation
may greatly reduce or eliminate the likelihood of pollen contamination. The sequence of the
transformation event is important because sequence changes can occur during transformation,
and even single nucleotide or amino acid changes can result in functional changes in the resulting
protein, such as changes in stability or allergenicity. It is also important to determine post-translational processing of proteins in characterizing the transformation event, especially if
toxicity testing in animals is required. Sequencing of the transformation event may be routinely
performed by currently available methods.
Comment on § 192.25 (e) and (f).
In these sections, FDA requires information in the PBN on newly inserted genes that
encode resistance to an antibiotic and on the potential that a protein introduced into the food will
be an allergen. The regulations, however, state that the notifier contact FDA to find out what is
the agencys current view of what is necessary. Thus, these provisions are too vague and provide
no basis for the public to determine if the PBN meets with FDA requirements. In our view, there
is sufficient knowledge about these subjects to specify with more detail what is required in a
PBN on these topics. For example, in vitro tests for properties correlated with food allergenicity
are currently done for all genetically engineered foods and should be part of the PBN. At a
minimum, however, if FDA will not specify what needs to be provided with the PBN in these
regulations, they should write detailed written guidance that is public on these topics. Those
guidance should include specific testing requirements based on the current state of the science
and could be modified as the science and the agencys thinking changes.
Section 192.25(f) should also be modified to provide the notifier with guidance about the
growth conditions, developmental states of the plant, and tissues of the crop that should be tested
to determine the levels of expression. The levels of expression may vary considerably depending
on those parameters.
Finally, there is a consensus among scientists that genetically engineered foods can be
developed for marketing without antibiotic-resistance genes. Thus, the preamble to the PBN
Rule should discourage the use of antibiotic-resistance markers.
Comment on § 192.25(g).
In order to select a comparable food and justify that selection, a notifier will usually need
to make a selection among several different foods. To properly analyze whether the particular
food selected is the correct one for the comparison, it would be helpful to FDA and the public to
understand which foods were not selected as comparable and why. Therefore, FDA should
specify in the rule that the justification of which particular food is selected for the comparison
should include a discussion of what other similar foods were considered as comparable and why
they were not selected.
In § 192.25 (g)(3), the regulations require comparing the bioengineered food with the
whole food for levels of nutrients, toxicants, and antinutrients. CSPI believes that the
comparison should involve not just the whole food but also compare the toxicants and
antinutrients of the whole plant. Genes for toxicants and antinutrients that are not normally in
the edible portion, but are found in other tissues of the plant, might be activated by the
transformation event. Such toxicants, even if not consumed by people, might adversely affect
animals and other creatures in the environment.
Comment on § 192.30
As currently written, this regulation only allows FDA to identify missing information
before the PBN has been filed. CSPI would assume that there would be situations in which
FDAs initial review of the PBN would suggest that it was complete, but that when FDA
proceeded with its evaluation, it determined that either information was missing or additional
information is needed. Therefore, this regulation should clarify that FDA has the authority to
determine that the PBN is not complete and missing information at any time during the 120-day
review period.
Comment on § 192.30(a) and (b).
As stated above, FDA should make available to the public documentation of what is
missing from a submitted PBN (§ 192.30 (a)(2)) and the letter informing the notifier that the
PBN has been filed.
12. Transition to PBN Rule.
For voluntary consultations that are pending on the date any final PBN Rule takes effect,
the companies involved in those consultations should be required to submit a PBN and comply
with the rule. The final rule should allow, however, that if the information provided to FDA
under the voluntary consultation is identical to what is needed under the final rule, FDA will
consider the existing submissions to be the PBN for that food. Requiring any pending
consultation to submit a PBN should not be burdensome since most of the same information
should have been submitted to FDA under the voluntary consultation. Submitting a PBN need
not delay review of a genetically engineered food because if the consultation was almost
complete, there is nothing in the PBN Rule that prevents FDA from expediting its review and
sending its letter to the company in less than 120 days. In addition, for any voluntary
consultations that occur between the publishing of a final rule and the effective date of that rule,
FDA should make it clear that those submissions would be treated pursuant to the public access
procedures set forth in Section 192.10.
CSPI appreciates this opportunity to submit comments on the PBN Rule. CSPI
understands that FDA has worked hard to address engineered foods under its statutory authority
and hopes that in the coming months FDA seriously consider a mandatory approval process. If
FDA would like additional information from CSPI about these comments, we would be happy to
meet with you at your convenience.
Gregory Jaffe
Co-Director, Biotechnology Project
Center for Science in the Public Interest
202-332-9110, Ext. 369
1. CSPI is a nonprofit education and advocacy organization that focuses on improving the
safety and nutritional quality of our food supply and on reducing the damage caused by alcoholic
beverages. CSPI seeks to promote health through educating the public about nutrition and
alcohol; it represents citizens interests before legislative, regulatory, and judicial bodies; and it
works to ensure advances in science are used for the public good.CSPI is supported by the more
than 900,000 member-subscribers to its Nutrition Action Healthletter, through foundation grants,
and through sales of educational materials. CSPI receives no funding from industry or the
federal government.
2. For the remainder of this comment, "PBN Rule" refers to the proposed rule and "PBN"
refers to the premarket biotechnology notice required under Section 192.25.
3. FDA can institute a mandatory approval process based on the same statutory authority
that legally supports the PBN Rule. These authorities include Sections 701(a), 301, 402, 403,
and 409 of the Federal Food, Drug and Cosmetic Act.
4. Throughout the preamble to the PBN Rule, FDA discusses the need for additional
scrutiny of genetically engineered foods. For example, on page 6, FDA acknowledges that
"rDNA technology continues to evolve and it is not possible for the agency to anticipate all of the
novel scientific and regulatory issues that may arise as the number and types of foods developed
using this technology expands." FDA also states that there is a greater potential for these foods
to contain substances that are food additives (pg. 12) and that with the increased introduction of
multiple genes in future genetically engineered plants, "unintended effects may be more
common." (pg. 16). Finally, FDA states that future genetically engineered crops will include not
just agronomic changes to crops but modifications intended to change the food itself and "thus
would be more likely than in the past to raise regulatory issues falling under FDAs purview."
(pg. 20). All of these observations by FDA about future genetically engineered plants support the
need for a mandatory approval process to ensure a safe food supply.
5. The proposed rule is silent about what information other than the PBN that will be
made public in the official docket for the mandatory review process whereas the proposed rule is
specific about what will be made public for the voluntary consultation under § 192.10. If FDA is
going to include documentation of any meetings, all correspondence between FDA and the
company or other parties, and all FDA documents pertaining to the food in a public docket, the
final rule should state that.
6. Since proposed Sections 192 and 592 are identical in content, this comment letter will
only refer to Section 192. However, all comments stated in this letter equally apply to Section
7. CSPI recognizes that whole food testing is not always possible, such as when the food
has poor nutritional or antinutritional qualities for the test animals. CSPI also recognizes that the
results from such testing are not always useful since, for example, exaggerated exposure cannot
usually be accomplished. However, until more information is available about unknown toxicants
in crop plants, whole-food testing could be a useful insurance policy that could yield useful
additional information to assess a foods safety.
8. For example see M. Osusky et al. (2000) Transgenic plants expressing cationic peptide
chimeras exhibit broad-spectrum resistance to phytopathogens. Nature Biotechnology, 18, 1162-1166. This paper does not involve transfer of a transgene between varieties by traditional
breeding, but still address this issue because very different phenotypes resulted in the different
varieties due to unexpected interactions between the transgene and genetic background
independent of the transformation event.


text:
April first is coming soon. Here are some harmless PC tricks you can play on spouses, friends, co-workers, or even your boss if you're brave enough. Try them on your computer first so you know how to do them quickly.
Make all of their desktop icons disappear
This can be done in as little as two or three seconds. You can restore their icons just as quickly.
- If you can't see any portion of the desktop, hit WINDOWS+D to minimize all windows. See this modifier keys article if you're not sure how to use the WINDOWS key.
- Right click in a blank area on the desktop (where there are no windows).
- A menu will appear. Place the mouse over the "View" menu option ("Arrange Icons By" in Windows XP).
- A submenu will appear. The "Show Desktop Icons" menu item will have a check mark next to it. Click it. Their icons will disappear.
- If you hit WINDOWS+D in step 1, hit it again to un-minimize their windows.
After the prank, simply right click the desktop and click "View" | "Show Desktop Items" again. Their icons will appear again.
Turn their display upside-down or sideways
This will only work if they have the right display adapter. You can find out simply by trying it. See this modifier keys article if you're not sure how to use the CTRL and ALT keys.
- If you hit CTRL+ALT+DOWNARROW their display will be upside-down.
- If you hit CTRL+ALT+LEFTARROW their display will be turned to the left side.
- If you hit CTRL+ALT+RIGHTARROW their display will be turned to the right side.
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The band teams up with NASA to launch "Up in the Air," from the forthcoming album "Love Lust Faith + Dreams." Read more
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Huawei W2 Windows Phone goes on sale in China for 999 Yuan ($163)
After years of struggles Windows Phones might have finally found their market niche – cheap, sub-$200 smartphones.
It's not what Microsoft, Nokia and other OEMs who tried Windows Phone expected, but that's where some traction is.
We got the first glimpse of interest in cheap Windows Phones with the release of $250 Nokia Lumia 620, and saw the real growth in Nokia Lumia shipments after $180 Lumia 520 launched in April. By all accounts, 520 is still doing a brisk business around the world, making Nokia a dominant Windows Phone OEM with 2/3s platform market share.
With its worldwide ambitions, Huawei also wants a piece of Windows Phone market, and now is entering the game with a handset that's even cheaper than Lumia 520. Yesterday they started selling Ascend W2 Windows Phone for 999 Yuan ($163) in China.
Huawei Ascend W2 comes equipped with:
- 4.3" 480×800 IPS display
- 3G TD-SCDMA connectivity
- 1.4 GHz Qualcomm MSM8230 1.4GHz dual-core CPU
- 5 megapixel camera
- 8GB of ROM, micro-SD card support
With specs comparable to Lumia 520, W2 has a chance to sell in pretty good volumes, further enhancing Windows Phone position as the 3d ecosystem, cheap alternative to mid-range Androids and iPhones.
Is it where Microsoft wants their mobile OS to be? Most certainly not. But with Windows Phone hardware support capabilities perpetually a generation behind Android, that's what they can get right now. Some unit volumes, with which comes increase in developer interest and more apps.
And, who knows, if Windows Phone is finally able to support quad-core CPUs and bigger 1080p displays before the end of this year, maybe Nokia and other OEMs may finally get some respectable volumes with better and more lucrative smartphones, too.


text:
I write this slightly off topic tale having just gotten home from my 11 hours in my concealed handgun license test. As excited as I am that I managed to actually score well on the range test using a semiautomatic despite one mixup (I hate external safeties even more now...), there is a bigger story to tell here.
My instructor was a 59 year old grandmother of four whom I shall respectfully refer to as "Vivi". This is not her real name, for I did not ask permission to tell her story, nor is she the type to want your pity.
Vivi is someone I strangely identified with. She's over double my age, female, and a South Texas girl. Her passions in life are her grandchildren and making beautiful letter art. You should see the certificate she gave me and the other members of the class who successfully passed the tests. It is jaw droppingly beautiful and I am having it framed.
We do have two things in common. For one we both feel very strongly about human rights, and we are talk about the right to responsible self defense a lot. For another, her passion in life is not guns even though she is a licensed concealed handgun permit instructor. My main passion in life isn't guns either.
Around a time when I was 15 or 16 years old, Vivi and her husband were sued by a new neighbor. Their new neighbor had just bought all of the land surrounding them and had moved onto it.
Soon, their neighbor filed a lawsuit against the firing range because she claimed it was dangerous and noisy and had no business operating. And the gun control extremists and whackjobs came out of the woodwork.
What these geniuses came up with is that any outdoor firing range should reside on 1000 acres of private land, and should meet every specification of the NRA handbook.
First of all, a family owned firing range barely makes money most of the time. Second of all, the specifications they were demanding be met were written for other types of facilities very unlike the one that Vivi and her husband have built literally with their own hands.
This was an attempt by gun control advocates to close down every firing range in the State of Texas. The head of Texas Against Gun Violence (better known as Texans Who Oppose Civil Rights) spoke out against the range.
Vivi, whose passion in life is letter art, fought this lawsuit with every fiber of her being.
It would have been so much easier to close the range, let the gun control lobby win, and sell the land and start over again somewhere else. But Vivi knew that wasn't right.
Vivi thought that future gun owners should have a place to safely learn how to use thier tools when they grew up. Vivi realized that the gun control lobby was using this as means to erode public knowledge of firearms and more importantly firearm safety.
Vivi and her husband fought this. And they won. The NRA revised its range manual, the regulations never passed, and the law was even revised to keep it from happening again.
But the price was steep. The liberal gun hating justices rules that since there was no noise ordnance in that county, then the range owners should have to pay the plaintiff $250,000 in legal damages.
Vivi lost her home. Vivi lost everything that she and her husband had worked so hard for all in the name of protecting my rights.
Thank God for people like Vivi and her husband. They are just glad they had this chance to win a victory for human rights.
She could not tell the story however without a tear in her eye. You never would hear a story like hers on any news station. No reporters showed up to broadcast their tale over the airwaves. But those same reporters can take the time to spread lies about guns and their owners.
Raped women, people murdered in their own homes, and grandmothers who have lost everything they ever had. This is gun control at its best.


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Former Atlantic coach Johnson to take over Taylor boys basketball program
Published: Friday, May 24, 2013 at 10:58 p.m.
Last Modified: Friday, May 24, 2013 at 11:05 p.m.
Taylor principal Ron Pagano said Friday that Jimmy Johnson will be the Wildcats' new boys basketball coach.
Pagano said he made the move to hire Johnson — the former coach at Atlantic — on Friday. Johnson went 89-42 in five seasons at Atlantic. He stepped down prior to last season.
Johnson replaces Mike Sims, who stepped down earlier this month, Pagano said.
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text:
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text:
Journey to Nyx – Blue Cards
Yes, Theros block is now complete. Now we have to start getting into the swing for Block constructed and we need to start thinking about the future when Return to Ravnica block rotates in October. To do this we need to grind through the reviewing of the cards that are going to force our draft picks, change up our current decks, and maybe even start some brewing gears moving around.
Now it's time for us to look at the Blue cards.
Aerial Formation – U – Instant – C – Strive – Aerial Formation cost 2U more to cast for each target beyond the first. Any number of target creatures each get +1/+1 and gain flying until end of turn. For a combat trick the effect is great but the strive cost is just two high to make it super effective. Best you'll get out of this is that you'll jump two dudes with it, maybe three.
Battlefield Thaumaturge – 1U – Creature – Human Wizard – R – Each instant and sorcery spell you cast cost 1 less to cast for each creature it targets. Heroic – Whenever you cast a spell that targets Battlefield Thaumaturge, Battlefield Thaumaturge gains hexproof until end of turn. 2/1. It's the one card that makes Heroic and Strive work in limited. Still, this plus Launch the Fleet might make for a new UW Aggro in Standard post rotation.
Cloaked Siren – 3U – Creature – Siren – C – Flash. Flying. 3/2. It's a beater and a surprise blocker for Limited.
Countermand – Four drop mill counter spell, yeah, it's jank for Limited.
Crystalline Nautilus - 2U - Enchantmen Creature - Nautilus - U - Bestow 3UU. When Crystalline Nautilus becomes the target of a spell or ability, sacrifice it. Enchanted creature gets +4/+4 and has "When this creature becomes the target of a spell or ability, sacrifice it." 4/4. Sometimes you just need a 4/4 beater. Getting it for just three mana means it has to have this kind of a draw back.
Dakra Mystic – U – Creature – Merfolk Wizard – U – U, tap: Each player reveals the top card of his or her library. You may put the revealed cards into their owner's graveyards. If you don't, each player draws a card. 1/1. This is a skill tester if I have ever seen one. Granted with the scry effects this just leads to mind games. When my opponent scries and leaves the card does he want me to really mill it, or is he hoping I'll let him draw the card. This really pushes leveled thinking plans and Jedi mind tricks.
Daring Thief – 2U – Creature – Human Rogue – R – Inspired – Whenever Daring Thief becomes untapped, you may exchange control of target nonland permanent you control and target permanent an opponent controls that shares a card type with it. 2/3. I can see this finding a combo if I have a token maker. Also with all the enchantements this can get so one-sided. Say I gave you control of the pump enchantment on my creature and you give me your god, deal?
Dictate of Kruphix - 1UU - Enchantment - R - Flash. At the beginning of each player's draw step, that player draws an additional card. Oh, Emrakul, they printed that? Need one for my group hug commander deck. The fact this has flash just might be enough for it to be a Standard card so that you make it so you get the first draw with it. Granted, I don't think we are going to see much of it until after Underworld Connections rotates in October.
Font of Fortunes – 1U – Enchantment – C – 1U, sacrifice Font of Fortunes: Draw two cards. This cycle all kind of suck but they are good way to trigger constillation and build devotion. Still two cards for four mana isn't bad in Limted and you can crack this on turn three after keeping up counter mana.
Godhunter Octopus – 5U – Creature – Octopus – C – Godhunter Octopus cant' attack unless defending player controls an enchantment or an enchanted permanent. 5/5. So in the world fo fatties with attacking drawbacks, this has to be the least negative one. Of course in Theros block Limited your opponent is going to have an enchantment or enchanted creature so you are going to be able to use this to bash face.
Hour of Need – 2U – Instant – U – Strive – Hour of Need costs 1U more to cast for each target beyond the first. Exile any number of target creatures. For each creature exiled this way, its controller put a 4/4 blue Sphinx creature token with flying onto the battlefield. Limited all-star here. This is just the combat trick that blue wants to cast. Chumb block some dorks and before damage replace those dorks with an army of 4/4 fliers you can attack with next turn. Totally awesome in Limited.
Hurbris – 1U – Instant – C – Return target creature and all Auras attached to it to their owner's hands. Yup, good removal for Limted to deal with Voltrons.
Hypnotic Siren – U – Enchantment Creature – Siren – R – Bestow 5UU. Flying. You control enchanted creature. Enchanted creature gets +1/+1 and has flying. 1/1. So it's a Limited card, but still what a card. Nice way to mind control other creatures or just jump your own. I also like that it teaches that you can bestow creatures you don't control for profit.
Interpret the Signs – 5U – Sorcery – U – Scry 3, then reveal the top card of your library. Draw cards equal to that card's converted mana cost. It's a draw spell for Limited and Commander. Kind of want to put this in a Jhoria deck and scry into fatties and bombs to suspend.
Kiora's Dismissal – U – Instant – U – Strive – Kiora's Dismissal costs U more to cast for each target beyond the first. Return any number of target enchantments to their owner's hands. Another awesome bounce effect for Limited to get past bestow dorks.
Pin to the Earth – 1U – Enchantment – Aura – C – Enchant creature. Enchanted creature gets -6/-0. Good nerf enchantment to make a beater into a wall in Limited.
Polymorphous Rush – 2U – Instant – R – Strive – Polymorphous Rush cost 1U – more to cast for each target beyond the first. Choose a creature on the battlefield. Any number of target creatures you control each become a copy of that creature until end of turn. A card I feel will become part of U/B Heroics. Awesome card for Limited that can turn all your small dorks into beaters while triggering heroic abilities.
Pull from the Deep – 2UU – Sorcery – U – Return up to one target instant card and up to one target sorcery card from your graveyard to your hand. Exile Pull from the Deep. Not bad, in Limited this is nuts. Cast this late to pull more tricks back for the next turn. Good card is good.
Riptide Chimera – 2U – Enchantment Creature – Chimera – U – Flying. At the beginning of your upkeep, return an enchantment you control to its owner's hand. ¾. Well, Kiora, I want four of them. I'm sure in Limited I'll have enchantments to bounce. Even better would be a one-drop bestow dork that I can enchant this with just before I attack on turns four to GG.
Rise of Eagles – 4UU – Sorcery – C – Put two 2/2 blue Bird enchantment creature tokens with flying onto the battlefield. Scry 1. Lols, this is so flavorful Having a bad game, ust show your opponent a pair of bird and scry 1. Still too pricy for anything but Limited and Commander.
Sage of Hours - 1U - Creature - Human Wizard - M - Heroic - Whenever you cast a spell that targets Sage of Hours, put a +1/+1 counter on it. Remove all +1/+1 counters from Sage of Hours: For each five counters removed this way, take an extra turn after this one. This is so epic in Limited and might just be good enough for some random Commander brews. It's a super fun card but that means it's never going to see competitive play. Granted, this is just going to be a fun card to play around with in fun decks.
Scourge of Fleets - 5UU - Creature - Kraken - R - When Scourge of Fleets enters the battlefield, return each creature your opponents control with toughness X or less to its owner's hand, where X is the number of Islands you control. 6/6. Calling it now, this is the bomb in Limited, Standard, and Block. Sure it's a card that forces you into mono-blue, but it's also a card that can bring mono-blue back into the final feature matches once more also want to alter this to look like the Falcon and Space Slug.
Sigiled Starfish - 1U - Creature - Starfish - C - Tap: Scry 1. 0/3. An awesome draft pick and a good two-drop filler for Sealed deck. An 0/3 is good from gumming up the ground and you just tap to scry after it has done it's job blocking.
Thassa's Devourer – 4U – Enchantment Creature – Elemental – C – Constellation – Whenever Thassa's Devourer or another enchantment enters the battlefield under your control, target player puts the top two cards of his or her library into his or her graveyard. 2/6. No! Don't draft mill! Just don't. This is just a filler 5 drop for a sealed bestow deck.
Thassa'a Ire – U – Enchantment – U – 3U: You may tap or untap target creature. Sure, I'll cast this in Sealed decks just to bait enchantment removal. In Draft, I might play it as well for a tap-down effect if I'm short on removal.
Triton Cavalry – 3U – Creature – Merfolk Soldier – U – Heroic – Whenever you cast a spell that targets Triton Cavalry, you may return target enchantment to its owner's hand. 2/4. Limited enchantment bouncer is very limited.
Triton Shorestalker – U – Creature – Merfolk Rogue – C – Triton Shorestalker can't be blocked. 1/1. The dream one-drop for blue based bestow decks in Limited.
War-Wing Siren – 2U – Creature – Siren Soldier – C – Flying. Heroic – Whenever you cast a spell that targets War-Wing Siren, put a +1/+1 counter on War-Wing Siren. 1/3. The dream three-drop for blue based bestow/heroic decks in Limited.
Whitewater Naiads - 3UU - Enchantment Creature - Nymph - U - Constellation - Whenever Whitewater Naiads or another enchantment enters the battlefield under your control, target creature can't be blocked this turn. 4/4. I really think we are going to see some of the Constellation cards end up in some Standard and Block decks, but I feel this is too slow outside of Limited. Still dropping this the turn after a blue god so this turns on that gods devotion will be epic in Limited.
Over all I have to say that while blue doesn't have much huge effects for the current Standard, but there are hopes for next season. Some kind of UW Strive deck might show up, and UB heroes gets some toys. Still, I'll be happy to draft some blue cards over the next few months. I wonder what black has to offer, that's my cue to get moving on to the next article. See you next time.
This has been...
Jeffrey Carmichael II
KDPfenthing on MTGO
https://twitter.com/fenthing on Twitter


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Sep 10
Posts: 67
richarderp says:
[This Topic has been modified by the Author]
Jun 08
Posts: 3625
soniadevereux says:
Oh thats is a real bummer for everyone! i wasnt going but I like to watch it.
Horses - if God made anything more beautiful, he kept it for himself. ~Author Unknown
Oct 07
Posts: 1472
dollymix says:
gutted, gutted, gutted, gutted, gutted, gutted, gutted, gutted, gutted
Get the picture?
I was supposed to be going from Thurs-Mon and was taking photos for a regional managazine. I was also camping with a group of friends and had a massive party arranged for Friday night. Soooooo disappointed.
However, the safety or horses and riders is paramount so I think they made the right decision.
Did I mention that I am gutted???
Apr 11
Posts: 556
Rosebudd says:
quite gutting really! :(
wasnt going i like to watch it.. went last year, was so good. Now they've cancelled, the weather will probably pick up now!
Mar 10
Posts: 3273
greyandbay says:
Yeah, heard it on the radio earlier - wasn't gong, but I do like watching it.
But I can't say I'm surprised, the ground must be saturated, and after a few horses have been round it would be sooo slippery, even if it stays dry from now on it would still be wet underneath.
It must be so disappointing and frustrating for the riders, but on the other hand if they'd carried on, how many would have pulled out?
The outside of a horse is good for the inside of a man - Winston Churchill
will definitley go next year Richard. It's just so disappointing isn't it? But I do think thye have made the right decision.
I was going to book Chatsworth for next weekend, but from my experience, it is wet there generally as a rule so if weather continues maybe they will be next to cancel? Will look forward to Bramham in June now instead...plus all the smaller BE events I toddle off to....you just can't beat badminton
[This Reply has been modified by the Author]
Mar 09
Posts: 4392
abbieandfiona says:
It is disappointing however its also very sensible living not far from Badminton and the weather we have had it would have been so unsafe to hold it.
Jul 11
Posts: 884
DuffyDuck says:
Alls I can say is I'm glad I didn't fork out nearly 700 for camping, euro tunnel, petrol, food and tickets ahaha!!
Oct 08
Posts: 487
Leo2980 says:
I won some tickets to the showjumping on Monday, really gutted its been cancelled. However, I am not that far away from Badminton and if their ground is anything like mine, I can well understand it!!
Courage is being scared to death - but saddling up anyway!
This photo was in the Telegraph Sport section this morning.....
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text: It is a dry day after Christmas and sunny too. Temperatures are in the 30s and near average for this time of year. The average high is in the middle 30s. There is a warming trend in the forecast for Friday and Saturday. Highs will be in the 40s for the next couple of days. Our next weather system arrives on Sunday. This will bring us a chance for a light rain/snow mix. A few snow showers are possible through Monday and more cold air is on the way for next week.


text:
How to build your own Bluetooth "handgun" headset
While Apple sells 1 million iPhone 3G units and 10 million app store downloads over the next weekend again, what could you be doing at home? If you've run out of ideas, here's one. How about you build your own Bluetooth headset?
And not just any Bluetooth headset, but a Bluetooth handun headset. You know, a BT headset that's shaped like a rifle, but is actually that, a BT headset?
If for some reason you find this mod interesting, just make sure you have ample amount of time in your hands, and a bit of patience.
Ready your Jabra Bluetooth headset for disassembly, and be prepared to get creative. Full instructions are available at the link below.
Read Instructables Via Engadget Mobile


text: George E. Laundria, 68, of West Hartford, husband of the late Harriett (Dinovellis) Laundria died Thursday (February 14, 2008), at home. Born in Winsted he was the son of the late Mary (Marek) Laundria Gorman. He was a retired manager of A.C. Peterson Farms, West Hartford retiring after more than 40 years of service. He was a U.S. Army veteran. He was a devout member of Our Lady of Sorrows Church, Hartford. He was a member of the Teamsters Union and loved to golf with his brother. George enjoyed refinishing furniture, his vegetable garden and was an avid Red Sox fan. He is survived by three brothers; Joseph Laundria of East Windsor, Frank Laundria and his wife Alma of East Hartford and John Gorman and his wife Sandy of East Granby, two sisters and brothers-in-law, Joyce and Charles LeCourt of Troutman, NC and Maxine and Kris Kaszubowski of East Windsor, several nieces, nephews, great nieces and great nephews, two brothers-in-law Andrew Manzi and Peter Dinovellis and his wife Beth and two sisters-in-law, Sharon Laundria and Mary Ann Gorsline. He is also survived by his very cherished friend, Mary Anne (O'Connor) Salemi of Haddam. The funeral is Wednesday at 9 a.m. from the D'Esopo Funeral Chapel, 277 Folly Brook Blvd. Wethersfield with a Mass of Christian Burial at 10 a.m. in Our Lady of Sorrows Church, 79 New Park Ave., Hartford. Burial will be in Mt. St. Benedict Cemetery, Bloomfield with full military honors. The family will receive relatives and friends on Tuesday from 4 - 8 p.m. at the funeral home. Memorial contributions may be made to Our Lady of Sorrows Church, Hartford. For on-line expressions of sympathy please visit www.desopo.com


text:
ZF2-496: Attached documents to message objects are corrupt
See http://zend-framework-community.634137.n4.nabble.com/… and this IRC log (23rd August):
{quote} : jurians: I was lookinag at your mail attachment issue. What's interesting is that Zend\Mime, functionally, hasn't changed between ZF1 and ZF2. The only difference is how messages work. I'm guessing there's some difference in how ZF1's mail class did attachments -- in ZF2, I'm simply saying that if we get a Mime\Message as the body to use it.
: jurians: I'll see if I can track it down quickly; if not, it may need to wait for a bugfix release.
: jurians: interesting. In ZF1, Zend_Mail extended Zend_Mime_Message. I'm stymied; no clue why it's not working in ZF1. Only thing I can think of is that Zend_Mail_Transport_Abstract was doing the part assembly (aggregating headers, boundaries, and content), and that Mime\Message doesn't do that naturally. {quote}
Task: attach a document (example a pdf) to the mail message and send it via the transport layer Expected result: attachment can be opened in an email client Actual result: attachment is corrupt and cannot be openend.
Similar code in Zend Framework 1 worked as expected and since then not much changed in the Zend\Mime part.
Example code to reproduce in ZF2:
$text = new Mime\Part('Hello world');
$text->type = 'text/plain';
$html = new Mime\Part('
Hello world
$html->type = 'text/html';
$data = file_get_contents('/path/to/my/file.pdf');
$pdf = new Mime\Part($data);
$pdf->type = 'application/pdf';
$pdf->filename = 'My File.pdf';
$pdf->disposition = Mime\Mime::DISPOSITION_ATTACHMENT;
$body = new Mime\Message;
$body->setParts(array($text, $html, $pdf));
$message = new Message;
$message->addTo('some@example', 'John Doe');
Found a work-a-round for this, the pdf is encoded '8bit'. If you add encoding as 'quoted-printable' or 'base64' the attachment will work.
$pdf->encoding = 'quoted-printable';
I suspect that ZF1 was making messages quoted-printable by default.
I have experimented with base64 encoded mime types, but my guess was to encode it myself.
$data = file_get_contents('/path/to/my/file.pdf');
$data = base64_encode($data);
$pdf = new Mime\Part($data);
$pdf->type = 'application/pdf';
$pdf->filename = 'My File.pdf';
$pdf->encoding = Mime\Mime::ENCODING_BASE64;
$pdf->disposition = Mime\Mime::DISPOSITION_ATTACHMENT;
With the comment of Koen I suspect I don't need to encode the data myself. Because I switched to Swift Mailer, it's quite some work to revert it: in the next week I will test this without a base64_encode() from myself.
This issue has been closed on Jira and moved to GitHub for issue tracking. To continue following the resolution of this issues, please visit: https://github.com/zendframework/zf2/issues/2540


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text: An Introduction to HR Metrics RecertificationSHRM: 14.75 PDCsHRCI: 14.75 (Business Management and Strategy credit) Competencies Competencies Business Acumen Critical Evaluation HR Expertise (HR Knowledge) Program OverviewLearn how to effectively use analytics to support your organization's goals and provide decision-makers with greater insight into workforce-related considerations. Explore how to properly align human capital analytics with business and HR strategies and to leverage data to build and deliver workforce and HR metrics to improve results. font> Program Objectives Align workforce metrics with business strategy, goals and objectives. Align HR metrics with critical HR objectives and initiatives. Determine the right data to collect. Build and execute your implementation plan. Get management and stakeholder support and involvement. Delivery Methods Modified to meet your needs 2–day Onsite Program Customizable Program Contact us today!E-mail:email@example.com Phone:+1-703-535-6496Request additional information Instructor Led Seminars Classroom (Face to Face) ADVERTISING LINKS


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Five minutes with Coach Otz: Season-opener preview
Chris Williams
After an exhibition victory over Minnesota, the Cyclones will open the 2012-13 season with a home contest vs. Southern on Friday night.
To look back at hot topics from the exhibition and ahead to Friday's opener, I recently sat down with Iowa State's associate head coach T.J. Otzelberger. Enjoy this Cyclone Fanatic exclusive.


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Emerging from farmland, Therme in Bavaria is surprisingly vast.
Water, water - everywhere,
Built recently, this is the ultimate baden or bath envisioned by ancient Romans.
Therme means thermal waters. Here the facilities extend to saunas, soaking pools, and massage. Stroll among 15 different saunas, each offering a unique setting for sweat.
Nature's energy has created spring water with a constitutional and healthy effect for your whole body. The special water comes originally from a depth of 1,100 m and has been untouched for more than 10,000 years.
Grant yourself the luxury of an extra bonus for your health in one of the four enriched pools of vital energy: brine, sulphur, calcium and lithium, iodine and selenium. Bath salts from the Dead Sea enhance one pool.
Resting for 10 minutes is said to relieve rheumatism, boosts your circulation and immune system. The trace element lithium affects your emotional balance and stimulates mental productivity.
Hot tubs, steam chambers, solariums, a Kneipp parcours, infra-red loungers and rooms of colour therapy are additional highlights in the thermal water. One area is exclusively natural: no swimming suits.
The thermal paradise is surrounded by a manmade lake (no swimming permitted). On the beach you will find the 'hottest spot' with the heat of 95° Celsius – the original 'beach sauna.' Relax in a lovely 'herbal sauna' with the smell of different herbs, enjoy a special fragrance in the 'Finnish log cabin,' or take a hot break in the 'gallery sauna.'
The smell of fresh bread enhances the 'Backhäusle' and inhale special aroma fragrances in the hot 'Kelo-Stadl.' In the lovingly designed 'meditation-sauna' guests relax while watching real colourful Koi carp in an aquarium. The 'Alhambra' gleams by the uniqueness of architecture, while the 'blue grotto' shines in a warm blue atmosphere
Refreshment for your water-weary body comes from two restaurants. And a bar built into the pools.
Admission to this water world is divided among saunas and soaks. Average cost is $25.
Located near the health resort Bad Worishofen, home of Kneipp nature treatments, Therme is a pleasant place to take the waters.


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Scott Turow: Welcome To the Law, One Ls!
With law school underway, we realize we've been remiss in not welcoming the latest batch of legal chickadees to our mad, mad world. To atone for this gaffe, we asked lawyer/authors for advice and reflections on the One L year. We loved the responses, so the next six items today will be nuggets from six noted lawyer/authors. We hope they're helpful, entertaining and — most of all — inspire you to share your own memories and pearls of wisdom.
Scott Turow needs little introduction. The Law Blog did a Q&A with the Sonnenschein partner last year upon the release of his latest, "Limitations." Thirty years ago he published "One L," his classic autobiographical account of his first year at Harvard Law. "One L" still sells roughly 30,000 copies a year in paperback, according to the author. Here's Turow's pithy advice, which was emailed to us last night:
Remember that law school is not lawyer school — it's about more and less. Enjoy it if you can. And if you can't, there is a bigger playing field out there.
If that leaves you wanting more, here's Turow's opening from "One L":
It is Monday morning, and when I walk into the central building, I can feel my stomach clench. For the next five days I will assume that I am somewhat less intelligent than anyone around me. At most moments I'll suspect that the privilege I enjoy was conferred as some kind of peculiar hoax. I will be certain that no matter what I do, I will not do it well enough; and when I fail, I know that I will burn with shame. By Friday my nerves will be so brittle from sleeplessness and pressure and intellectual fatigue that I will not be certain I can make it through the day. After years off, I have begun to smoke cigarettes again; lately, I seem to be drinking a little every night. I do not have the time to read a novel or a magazine, and I am so far removed from the news of world events that I often feel as if I've fallen off the dark side of the planet. I am distracted at most times and have difficulty keeping up a conversation, even with my wife. At random instants, I am likely to be stricken with acute feelings of panic, depression, indefinite need, and the pep talks and irony I practice on myself only seem to make it worse.
I am a law student in my first year at the law, and there are many moments when I am simply a mess.


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Im wondering what is the best way to password protect individual files or folders? I am working with peoples personal details and need to secure the currently unprotected files. I was thinking of using something like TrueCrypt but am unsure if this would still protect the files from access while the folder is mounted etc.....any help or advise would be greatly appreciated!
When a truecrypt volume is mounted, any program can read the data. Truecrypt encryption is transparent to programs.
If you really want to encrypt individual files, you could use a program such as PGP


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Verizon Samsung Ativ Odyssey specs unveiled, still no word on its launch date
Samsung launched its first Windows Phone 8 handset, the Ativ S, last month – although only in some markets. The company's second WP8 offering, the Ativ Odyssey, was also supposed to be released last month. As you probably already know, that didn't happen – and Verizon (the only carrier to sell the Odyssey) didn't say when customers should expect to find the device in stores.
Until we hear something official regarding the launch date of Odyssey, WP Central has managed to obtain a list of specs for the handset – comparing it to Nokia's Lumia 822 and the high-end HTC 8X. Both the Lumia 822 and HTC 8X are already available at Verizon.
The Odyssey features a 4 inch Super AMOLED display with 800 x 480 pixels, LTE and global connectivity, 5MP rear camera with 1080p video recording, 1.2MP front-facing camera, dual-core 1.5GHz Qualcomm Snapdragon processor, 1GB of RAM, 8GB of internal memory, MicroSD card support, and a 2,100 mAh battery. Measuring 122 x 63 x 11 mm, the handset is smaller than Nokia's and HTC's devices.
When it finally arrives, the Samsung Ativ Odyssey is probably going to be free on contract, just like the Nokia Lumia 822 currently is at Verizon (while the HTC 8X costs $99.99). But that remains to be seen.


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Living with A-Fib
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It's only been two weeks for me, but I can't shake the fear. I'm scared to do anything. The drugs I take keep me from driving, so my husband has to take me to work. I'm scared of having another episode, so I don't like to be away from home for long. I'm afraid to travel. I'm afraid to drink decaf coffee or a glass of wine.
Those of you who have lived with A-Fib for a while, is there a time when you came back to center? Got back to the gym? Got back out on a boat? Felt joy?
Posted on 12/29/06, 12:19 pm
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Hi Jea d, The first thing you need to know is afib won't kill you. Next you learn to live with it. There are a few things you can do to help it along. You can google a list of triggers for afib but the most common triggers are coffee, tea, decaf also on both, alcohol, chocolate, MSG, a lot of additives and preservatives, stress and anxiety, losing weight too fast, too much sun on a hot humid day, pushing or shoveling snow, straining yourself.
Hydrogenated fats > Saturated fat including animal fat and coconut (palm oil)pro inflammatory products Exercise after eating
Getting very cold
Dehydration Sugar spikes and crashes
Getting overheated (sauna) Sleep disturbance- takes extra care if you must do shift-work
Sleep apnea High altitude
Deep diving Getting sick-flu, food poisoning, malaria, etc.
Effort before recovery from illness High output (more than normal training)
Taking on tasks which will overtax one Helping someone move, build something; put the boat away etc.
Ballistic (burst of energy) sports Heavy weightlifting
Competition High heart rate
Gerd (acid reflux) Bowel disturbance
Anger High stress Sedentary life Adrenaline
Dental freezing with adrenaline Alcohol Tabasco
Aspartame (diet pop etc.) MSG see "truth in labeling "
These are all things to avoid but not everyone has too. You need to figure out what type of afib you have? I also belong to a Yahoo group for afib called,
www.afibsupport.com This is a 2000 plus group and you can gain a lot of information form the group. It is not a chat like this group but more sharing information only.
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I've lived with a-fib for 20 years. It was mis-diagnosed for 15 of those years as anxiety-related palpitations. I know how paralyzing the fear can be, but you are not going to die from a-fib. you might feel like you want to sometimes, just to make it stop, but you really can carry on... even while in the middle of an episode. You'll have to learn to pace yourself and get enough rest and not to push too hard when you DO feel good. My cardiologist said that wine was fine... just make sure to keep getting your coumadin level checked. Best of luck.
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I just joined this group and how are you doing today? Hope you found your comfort zone in living with AF
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just joined...and want to send Blessing to everyone...
I recently had my second event and it shook me up more than the first. I think it is mind over matter but I am constantly checking my pulse,
My treatment is metropolol(sp) and Warfarin...they seem to be working. I come out of A -fib sponteneously and this second event was shorter than the first.
My triggers seem to be the most common, caffeine or acohol...
The doctor is positive about my condition because I respond so well the the most basic medicines...but as Jea_d has said it is not an easy feeling or better said concern to get used to.
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I had my first a-fib in May of 2006. I have 2 flaps on one of my valve instead of 3 and now that I am 60 it is effecting the blood flow. Went on Tropol and was doing fine until Feb of this year. My primary doctor put me on thyroid medicine and within a week I was having big problems. The second a-flib was shorter but much worse than the first. My cardo dr increase tropol to 100mg and added cartia 180mg.
I was taking it with milk which also gave me problems. I stopped the milk and within days I am back to me and working out in gym and gaining confidence to live my life as before. Yes anything extreme does cause me to feel the heart beat faster and I just slow down or rest. Hope this is helpful.
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the exercise thing has a big question mark for me. even though the two events I had seemed to have coffee or alcohol involved this second event also had an increase in exercise. I was working out on the eliptical machine and walking 3 miles a day for a few days before this second event.
The doctor does not consider a target heart rate of 130bpm to be too much but of course if I have an issue 'don't do that'!
we will be taking a long vacation this year through Yellowstone, Tahoe and Yosemite. there will be some activiity above 8,000 ft. The doctor does not consider this risky...so we will see. My sister in law will be with us. She is a cardiac nurse.
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Hey Gang,
Need feedback. What I don't get is that I've had afib for 30 plus years undiagnosed and now on Cartia and Lopressor and Coumadin. As I read everyone's posts it seems NO drug stops or really helps. I'm trying to figure out why my doc gives me meds other than Coumadin. Coumadin makes sense becasue of stroke prevention. Apparently my reading everyone, the other two don't do the trick. Am I right?
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My afib started in January 07. I felt exactly the same way you did. We were scheduled to go on a cruise (4 day) and I was terrified! I went anyway and everything was fine. I have stayed away from caffeine but have an occasional glass of wine. Also, I've gone back to the gym and now exercise regularly and feel much better.
I think if you realize you are not alone in this, that there are a lot of others out there just like you who are living AND doing OK with it, then you will be able to get on with your life. Just take it slow at first but don't give up doing the fun things in life and don't let this rule your life. You're on the meds, so that should help.
Hope you're doing better now!
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I have had two afib "events" since January. a nurse told me I am one of the fortunate one, that I do not have these events more often...I exercise daily, 3 mile walk and 40 minutes on the eliptical machine and no problems, feel better every day.
but I would like to know how often do you all have them?
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Since January, I have had three events. Two of which I had to go to the ER, the other I was able to get out of myself. My medication was changed after the last event (a month ago) so hopefully this will help.
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Welcome to Tom's Kitchen—Homemade at its best!
Since 1974, Tom's Kitchen has served the best quality homemade food at reasonable prices! Breakfast, lunch and dinner, we continue the proud tradition of home cooking that is known throughout the Conyngham Valley: to prepare the most delicious foods made from scratch in our own immaculate kitchens, from recipes passed down through our family since the 1800s.
Breakfast, Lunch, Dinner and Banquets too!
Breakfast, Lunch and Dinner, Tom's Kitchen is known for its family-friendly prices and delicious meals!
We have Take-Out, too!
Sweet tooth? Take home a Tom's homemade cake, pie, rice pudding, apple dumplings and more!
Celebrations Start Here!
Our banquet room seats up to 100, surrounded in a country setting, complete with antiques and fireplace. You and your guests enjoy homemade cooking at its finest with sit down or buffet service.
All About Us
Open daily 7:00 a.m. to 8:00 p.m.
Contact Us and Find Us
|656 Rt. 93
Sugarloaf, PA 18249
|From Rt. 80 or Rt. 81, take exit for Rt. 93


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The University of Arkansas at Monticello has awarded a Leadership Scholarship to Emily England of Stuttgart, according to Mary Whiting, director of admisions at UAM.
The Leadership Scholarship includes partial tuition and is awarded for a maximum of eight semesters, excluding summer terms.
Emily England is the daughter of Wesley England and Jason and Sherry Young. Her high school activities include FFA, FBLA, DECA, Key Club, Spanish Club, the Bird Banner, Parliamentary Procedures team and Farm Business Management team.
Location, ST | website.com