Hartwig de Haen's letter ("Agency Seeks to Form World Food Standards," Nov. 14) unwittingly illustrates my point -- namely, the unscientific approach and lack of rigor of United Nations' institutions, programs and senior officials. Without offering a shred of evidence to bolster his assertions, he assures us that the U.N. is committed "to the contribution of biotechnology to eradicating world hunger," and to "developing standards for foods on the basis of scientific evidence and risk analysis."

The facts argue otherwise.

Like trying to build a bridge or an airplane using the incorrect value of the Greek letter "pi," when the basic assumptions that underlie a project are flawed, everything that follows is distorted. A long-standing scientific consensus and 30 years of experiments confirm that gene-splicing technology and its products are not, in fact, distinct categories amenable to generalization; gene-splicing techniques are essentially an extension, or refinement, of earlier, less precise, less predictable techniques to accomplish genetic improvement -- not unlike the improvement of automobiles' performance and safety with radial tires and disk brakes.

But the U.N.'s deliberations -- including those under the imprimatur of Codex (a creature of WHO and FAO) -- continue to defy science by devising burdensome new regulatory requirements and procedures that apply only to the pseudo-category of foods from gene-spliced organisms. This turns the logic of regulation on its head: In the U.N.'s distorted world of regulatory oversight, there is an inverse relationship between degree of regulation and risk. The result is vastly inflated R&D costs and diminished diffusion of superior techniques and products -- especially to poorer countries, which need them desperately.

It is easy to declare support for the U.N.'s Millennium Development Goals. What's harder is to resist activists' placing anti-scientific, politically motivated obstacles in the way of meeting them. At this, the U.N. and Mr. de Haen are failing miserably.

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