Jennie Schmidt: The Costs of GMO Labeling

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Jennie Schmidt is the proprietor of TheFoodieFarmer “Blogging about how your food gets from field to fork”. Jennie is very different from your typical Whole Foods customer, who has never set foot on a farm – she knows farming in depth. In particular she understands the supply chain – which is why she is especially qualified to write the captioned essay on what “right to know” really costs. This is the real deal, carefully researched, first-hand explanations of what is involved in establishing traceability of every ingredient that goes into food on your supermarket shelf. Read Jennie for the particulars. She closes with this summary:

Those who say GMO labeling won’t add to the consumer’s grocery bill need to go back to Economics 101 and some basic high school math.

True traceability in our food supply system will be hugely expensive.

Its likely that as a nation, we’d never capitalize all that infrastructure to achieve true traceability.

Which goes to the crux of the matter – this isn’t about labeling, as I cited in my last GMO blog, labeling is a means to an end. As noted by many activist groups, the ulterior motive behind labeling is not about a consumer’s right to know, it is about banning the technology.

Say NO to mandatory GMO labeling. Stand for science.

I liked Jennie’s essay so much that I posted the following comment:

Jennie – thanks heaps for taking the time to document some of the true costs that the “right to know” lobby wants to impose on consumers. I’m happy to see you already have a well-deserved pat on the back from Prof. Kevin Folta.

When we see such a “movement” promoting regulations that don’t make sense – that’s a good time to ask “who benefits?” If we follow the incentives we find there are a number of special-interests who are funding this campaign. David Tribe framed the smelly bedfellows as Big Quacka and Big Organic.

A concept from Public Choice economics that helps us understand how these hidden interests operate is called “Bootleggers and Baptists”. In your GMO labeling case the Bootleggers include Whole Foods and trial lawyers. Back in the CA Prop 37 fight I wrote a few posts on this concept, such as How California’s GMO Labeling Law Could Limit Your Food Choices and Hurt the Poor and Scott Andes: Why California’s GMO Labeling Proposition Should be Defeated.

The key idea is that the Bootleggers have learned that the best media reception is obtained by fronting the Baptists, preferably worried-looking moms holding their beautiful babies.

The Bottom Line: if you want to know about food and farming – talk to farmers, not to Greenpeace.

Should there be required labeling of GMOs?

Tyler Cowen has made a serious study of the food supply chain. So he offers some of the best critical thinking on Prop 37

Here is one on-the-mark take (of many):

…there have been more than 300 independent medical studies on the health and safety of genetically modified foods. The World Health Organization, the National Academy of Sciences, the American Medical Association and many others have reached the same determination that foods made using GM ingredients are safe, and in fact are substantially equivalent to conventional alternatives. As a result, the FDA does not require labels on foods with genetically modified ingredients because it acknowledges they may mislead consumers into thinking there could be adverse health effects, which has no basis in scientific evidence.

Or try the National Academy of Sciences from 2010:

Many U.S. farmers who grow genetically engineered (GE) crops are realizing substantial economic and environmental benefits — such as lower production costs, fewer pest problems, reduced use of pesticides, and better yields — compared with conventional crops, says a new report from the National Research Council.

Here is a good NYT summary Op-Ed on that report. There is not the scientific evidence for Mark Bittman’s recent evaluation that:

G.M.O.’s, to date, have neither become a panacea — far from it — nor created Frankenfoods, though by most estimates the evidence is far more damning than it is supportive.

It’s the tag there that is problematic. He doesn’t offer a citation, nor has he in past columns offered convincing material to back this evaluation (you can read here for a somewhat more detailed account from Bittman; it simply minimizes benefits and does not support “by most estimates the evidence is far more damning than it is supportive”). This earlier critique of Bittman is on the mark on virtually every point.

The standards of evidence being applied here are extremely weak. In that last Bittman link he wrote that:

…The surge in suicides among Indian farmers has been attributed by some, at least in part, to G.E. crops…

The link is to a sensationalistic Daily Mail (tabloid) story, yet that gets translated into “has been attributed by some.” In that story, the suicides were caused by indebtedness and supposedly the debts were in part caused by a desire by farmers to buy GMO crops. In comparable terms one could write that anything one spends money on could cause suicide through the medium of indebtedness.

By the way, the Wikipedia treatment gives some more detailed citations suggesting that GMO crops are not a significant cause of farmer suicides in India. The most careful study of the matterreports this:

We first show that there is no evidence in available data of a “resurgence” of farmer suicides in India in the last five years. Second, we find that Bt cotton technology has been very effective overall in India. However, the context in which Bt cotton was introduced has generated disappointing results in some particular districts and seasons. Third, our analysis clearly shows that Bt cotton is neither a necessary nor a sufficient condition for the occurrence of farmer suicides. In contrast, many other factors have likely played a prominent role.

I would in fact be more supportive of the GMO labeling idea if renowned food writers such as Bittman, and many others including left-wing economists, would come out and boldly proclaim the science about GMOs to their readers. Too often the tendency is to use a “I’ll try not to say anything literally incorrect, while insinuating there are big problems” method of scoring points against big agriculture. (Another common trope is to switch the discussion to “distribution” and to suggest, either explicitly or implicitly, that a net benefit technology such as GMOs is somehow unnecessary or undesirable; dare I utter the words “mood affiliation“?) GMO labeling is the one issue which has gained legal traction, so critics of “Big Ag” just can’t bring themselves to give it up.

Bittman’s whole column is about GMOs, but he gets at the important point only in his final sentence:

[With better information] We’d be able to make saner choices, and those choices would greatly affect Big Food’s ability to freely use genetically manipulated materials, an almost unlimited assortment of drugs and inhumane and environmentally destructive animal-production methods.

Overuse of antibiotics and animal treatment (both cruelty and environmental issues) — now those are two very real problems, backed by overwhelming scientific evidence. The fact that the California referendum is instead about GMOs — which have overwhelming scientific evidence for net benefit and minimal risks — is the real scandal.

It’s time that our most renowned food writers woke up to that difference. In the meantime, they are doing both us and themselves a deep disservice.

 

 

 

Small business under Proposition 37 (GMO labeling in California)

I do not think it is very well thought through.

Unless you are a trial lawyer or lobbyist — one of the designers/backers of prop 37. Then for you prop 37 is a sinecure, you kids to Stanford and Harvard and early retirement. Tyler Cowen:

I advise anyone who favors Proposition 37 to read the text of the law. It is full of bad ideas and questionable distinctions, many of which are not apparent from the more superficial descriptions of the proposal. Here is one of them:

Retailers (such as grocery stores) would be primarily responsible for complying with the measure by ensuring that their food products are correctly labeled. Products that are labeled as GE would be in ,compliance. For each product that is not labeled as GE, a retailer generally must be able to document why that product is exempt from labeling. There are two main ways in which a retailer could document that a product is exempt: (1) by obtaining a sworn statement from the provider of the product (such as a wholesaler) indicating that the product has not been intentionally or knowingly genetically engineered or (2) by receiving independent certification that the product does not contain GE ingredients. Other entities throughout the food supply chain (such as farmers and food manufacturers) may also be responsible for maintaining these records.

I call this the “how to kill off small farmers and retailers” provision. And what would it do to local farmers’ markets to have the burden of proof so shifted? Who is best situated to handle possible lawsuits or shakedown lawsuits? The larger corporations.

It is interesting to see what receives an exception from the labeling provisions: alcohol, restaurant food, and animal meats raised from genetically engineered crops. (Lobby much?) For varying reasons, those are some of the outputs most likely to be harmful to you or to the environment.

Prop. 37 also exempts milk, cheese, and meat and it exempts “small” amounts of transgenic material in foodstuffs. According to critics of the bill it exempts 2/3 or so of the food products which Californians consume.

I do not think it is very well thought through.

 

Will Overregulation In Europe Stymie Synthetic Biology?

I really liked this Forbes essay by Henry Miller & Drew Kershen. The topic is synthetic biology, but also useful is the history of the mis-regulation of genetic engineering. The authors conclude with this tidy summary of these mistakes:

(…) The future success of synthetic biology depends in large part on whether public policy toward its applications is well-crafted. Policymakers should learn from the regulatory missteps inflicted on genetic engineering that illustrate how choosing how choosing a flawed paradigm has critical implications for a technology.

Genetic engineers using increasingly powerful and precise tools and resources have achieved breakthroughs in a broad spectrum of fields, including agriculture, pharmaceuticals and diagnostics, in spite of the fact that thirty-five years ago, the U.S. National Institutes of Health adopted overly risk-averse guidelines for research using recombinant DNA, or ‘genetic engineering’ (also known as ‘genetic modification,’ or GM) techniques.

Their approach was based on what has proved to be an idiosyncratic and largely invalid set of assumptions that overestimated the novelty and potential risks associated with the process of gene transfer and from the recombinant DNA-modified organisms themselves. Those guidelines sent a powerful message that the scientific community and the federal government were taking the speculative, exaggerated risk scenarios seriously, a message that has affected – and afflicted — regulation worldwide ever since. Unwilling to diminish their bureaucratic empires, the U.S. EPA and Department of Agriculture have clung tenaciously to unscientific, burdensome, costly regulatory policies.

However, at least where non-corporate activities are concerned, from the supra-national to the local level, unnecessarily intrusive regulation may become harder to impose on synthetic biology. What will federal (USDA, EPA, and FDA) and other regulators do about garage-inventor synthetic biologists who produce and test novel plants and microorganisms? Will they try to subject these ‘made-from-scratch’ organisms to the same technique-focused, unscientific, excessively burdensome regulatory frameworks designed for recombinant DNA-modified organisms?

The European Union and the United Nations’ Cartagena Protocol on Biosafety face the same regulatory conundrum. At both, the regulation of genetic engineering is explicitly triggered by the process by which a plant is crafted rather than by the risk-related characteristics of the product, and the UK Research Councils analysis has expressed concern that the regulations for genetically engineered plants will likely also be applied to synthetic biology. With prototypical British understatement, the report said, ‘Currently there are some problems with the operation of the EU clearance processes, and this could act as a barrier to commercialization of certain synthetic biology products. The UK government is currently engaged in [revising] EU regulations with the aim of enabling more effective operations of the current regulatory system.’

Henry I. Miller, a physician and molecular biologist, is the Robert Wesson Fellow in Scientific Philosophy and Public Policy at Stanford University’s Hoover Institution. He was the founding director of the Office of Biotechnology at the FDA. Drew L. Kershen is the Earl Sneed Centennial Professor of Law (Emeritus), University of Oklahoma College of Law, in Norman, Okla.

(Via Henry Miller- Rationalist.)


Proposition 37 – California Food Labeling Initiative: Economic Implications for Farmers and the Food Industry if the Proposed Initiative were Adopted

There is a new paper by UC Davis professors Julian M. Alston and Daniel A. Sumner [PDF]. Particularly useful is Appendix C: Costs of Segregation, Monitoring, and Enforcement. We can only estimate these costs, but it is critically important that California voters learn how real-world agriculture works. If we could conduct a poll designed to test understanding of the process impact of this regulation, I will happily predict nearly zero correct responses.

Another valuable reference provides a quick overview of the farm gate to retail prices for organic premia: Table 3. Price Premia for Organic versus Non-organic Products in U.S. Markets.

The Executive Summary begins with this tidy summary:


A Costly Regulation with No Benefits.
Proposition 37, would impose significant costs on California’s food and agricultural industries, as well as consumers.

  •   Proposition 37 would cause food manufacturers and retailers to change the methods used to produce many of the foods Californians eat, and would make those foods more expensive. Among consumers, the burden would be greater on the poor who spend a larger share of their income on food.

  •   As well as imposing costs on consumers, and others in the food supply chain, Proposition 37 would be costly to farmers, including many California farmers who do not produce any genetically engineered (GE) commodities, because their products are often used as ingredients in foods that also contain ingredients from GE crops.

  •   Proposition 37 would impose about $1.2 billion in additional costs on California food processors to meet segregation, monitoring and certification costs.

  •   Proposition 37 would not provide any meaningful benefits, in the form of improved information, improved product safety, or an expanded range of choices for consumers. In fact Proposition 37 would reduce choices by driving some food products containing GE ingredients from the market.

  •   Imposing “unnatural” restrictions on the use of the word “natural” on food labels would mislead and confuse consumers because producers of farm commodities such as fruits, vegetables and tree nuts that are simply dried, roasted, juiced or otherwise lightly processed, in many instances on the farm, would be precluded from using the term “natural” on the product label. 

Lastly, it’s good to see full disclosure on the title page before the authors’ affiliations.

The work for this project was undertaken with partial funding support from No on 37. The views expressed are those of the authors, based on their analysis, and not attributable to any institution or organization with which they are affiliated or associated.

Steve Savage: “GMO Crops: To Label Or Not To Label”

A guest post by agricultural scientist Steve Savage, 
proprietor of Applied Mythology
(This post first appeared on BioFortified and Science 2.0)

 

Topographic map of the state of California.

The Golden State

This fall, California voters will be asked to vote on Proposition 37, a law which would require that all foods including ‘GMO Crop ingredients’ be labeled as such.   There are many reasons that this isn’t a good use of governmental authority for mandatory food labeling.  A look at historical logic and precedents for labeling, and at the misleading messages this initiative would foster, should inspire Californians to reject it at the ballot box.

Labeling for a Known Hazard

If a food is hazardous to some consumers, but not others(e.g. peanut allergy), then it makes sense to require that it be labeled to protect that minority.  If a food contains something generally hazardous, but difficult to immediately remove from the food supply, it makes sense to label those foods as well (e.g.trans-fats for which labeling was required after 2006).  If a particular GMO crop were to be found to be hazardous to certain people, or people in general, the appropriate response would to ban the use of that particular trait nationally, not to label it at a state level!No such hazard has been documented for dozens of biotech crops crop traits over 16 years of extensive commercialization, so ‘hazard’ has never been a reason to require labeling of a GMO crop.

Labeling For Lack of Safety Studies

The proponents of Proposition 37 argue that because the FDA does not require a set of specific human safety studies prior to commercialization, consumer need to be warned. Considering the diversity of biotech traits, it does not really make sense to specify a particular battery of safety studies.  They would really need to be varied on a trait-by-trait basis.

…for good reason.

The opponents of these crops imply that these foods are thus, untested when it comes to safety.  Nothing could be further from the truth.  Both the companies that produce the crops, and a wide range of independent researchers, have studied GMO crop safety for years.  Highly qualified scientific panels have reviewed those data and consistently concluded that these improved crops represent no unusual risk compared to crops improved by traditional methods.

Ironically, the largest single contributor to the pro-labeling effort is the Internet ‘health advisor,’Dr.Mercola whose $800,000 donation was funded by his thriving, natural supplement business.  There is very little regulatory oversight for that multi-billion dollar supplement industry in terms of required testing either human safety or product efficacy.  When it comes to safety testing, GMO crops are far more intensively scrutinized than something like Dr. Mercola’s supplements.

Labeling Because Other Countries Require It

One argument for requiring labeling has been that places like Europe, Japan and China do so. First of all, most of the ingredients in the US, human food supply that come from GMO crops (corn starch; high fructose corn syrup, soybean, cottonseed or canola oil…) have always been supplied from different crops in other regions (potato or rice starch, beet or cane sugar, sunflower, peanut or rapeseed oil…) so there are actually very few GMO labeled foods in those countries.  They import massive amounts of our GMO crops for animal feed, but that is not labeled.  Second of all, the scientific review panels in these other countries have come to the same conclusions as those in the US. They find no reason to doubt the overall safety of GMO-based foods.  It is just that politics trumps science in those political systems. That is certainly not something we should imitate.

Labeling Because It Is A Consumer’s ‘Right to Know.’

nutrition label

Nutrition facts. Source: FDA.

Bits of information do not actually become ‘knowledge’ unless they can be placed into a meaningful context. We have a historical example of this with the mandatory food composition labeling that has been required in the US since 1990.  The calorie, protein, fat, carbohydrate and vitamin content of foods could theoretically be useful information that consumers could ‘know.’  Unfortunately,when Congress passed the Nutrition Labeling and Education Act of 1990, it never actually funded the education part (imagine that).  For most consumers, the information on food products is not part of a functional knowledge-base that could guide their food decisions.  Instead, they are left to be influenced by the advertizing messages and ever-changing food fads that shape our‘marketing of non-existence’ food culture. Proposition 37 does not include any sort of official educational component. It would just mandate that a bit of information, ‘contains ingredients from crops modified by genetic engineering’ be attached to many foods.  The contextualization of that information will be heavily influenced, not by any sort of balanced presentation, but by a range of activist groups and marketers.

This will not be anything new as these groups have been flooding the internet with hyperbolic warnings for more than a decade.  One might think that there would be a statute-of-limitations on saying that ‘the sky is falling.’  It is not at all surprising that Mercola and others would like the opportunity to ramp up the level of societal fear with the help of the ‘information’ supplied by California law.  (By the way, Dr. Mercola has not just promoted fear of GMOs.  He has been a conduit for anti-vaccination activists and even for a ‘doctor’ with the theory that all cancers are fungal infections).

Labeling As A Way To Track The Effects of GMO Foods

An exceptional proposition

Another argument that Prop. 37 supporters make is that labeling will allow us to better track or detect any issues with these foods.  Other than the fact that there is no obvious mechanism for that to happen, there is another major problem with the argument. Foods purchased in restaurants would not be labeled under Prop 37 (nor would alcoholic beverages or organic products that happen to contain them). Considering that on average people eat about half of their meals out,and that many mostly eat out, this idea of tracking falls apart.  The other implication of this exemption is that the information on grocery items (which will be cast in a scary light by Mercola et al), will not be seen in restaurants, including those that serve fast food, fried in GMO vegetable oils and sweetened with GMO corn-based sweeteners. Making home meals sound scary and restaurant meals sound safer hardly sounds like a smart message to be sending to a population with an obesity problem.

Labeling To Allow Some Consumers To Avoid GMO Foods

Some people may never trust the scientific/regulatory consensus.  That is OK, but those folks don’t really don’t need to force mandatory labeling for everyone else.  They always have the option to buy Organic, which decided not to use GMO long before it was even an option.  These folks also always have the option to buy products that are sold as or even certified as non-GMO – something that is allowed already.  Anyone can also learn a few simple rules based on the limited number of crops that are GMO in the first place.

Here are the simple rules: If the product has ingredients that are derived from Corn, Soy, Cotton, Canola, or Sugar beets, just assume it is probably includes biotech varieties since farmers of those crops overwhelmingly choose those option.  Right now, the only fresh market GMO crops in the US are papayas from Hawaii (virus resistance developed by Cornell University that saved the crop), and some sweet corn. In the rare case of another biotech crop being added to this list, there is always plenty of official notice and press/blog coverage.

Labeling to Allow Consumers to Intentionally Choose Biotech Improved Foods

Within a few years there may be some biotech-based, non-browning apples on the market, but they will be voluntarily labeled as such because it is a positive consumer feature and because that value chain is amenable to full identity preservation down to the sticker on each fruit. This is the most logical form of GMO crop labeling, and there are no regulatory, legal, or practical barriers to such labels.

Conclusion

Mandatory food labeling should be reserved for well-documented public health needs and should be linked to viable public education efforts.  It shouldn’t be something designed to enrich fear-based marketers or to give people a false comparison between home-cooked and restaurant foods.

(Via Biofortified.)

Steve Savage: “6 More Reasons To Vote No On California Prop 37″

A guest post by agricultural scientist Steve Savage, 
proprietor of Applied Mythology
(This post first appeared on Applied Mythology 8/24/12)

I’ve posted a blog about why GMO labeling is basically illogical.  If you take the time to read the actual proposition, there are at least six more reasons that proposition 37 on the California ballot this fall is a really bad idea that voters should reject.  

1.    This is asking for something that is a great deal harder than it sounds.

Almost all GMO crops are commodity grains.  To understand what labeling these crop ingredients means means, think of a river.  When it rains, little rivulets of water begin to run off of the ground, and then combine into small creeks.  These combine to make streams that eventually combine to make a river. By the time the water is in the river, it is so mixed that you could never know which drop came from where. The commodity grain industry is much like that river.  Many fields are harvested using the same harvesters and grain wagons (see first image above). That grain then goes either to a growers silo or to a local elevator, which combines the harvest from many farms and fields.  

The grain is later moved in things like 110-car freight trains or giant barges or ships, which again mix various sources. Along that path, some of the grain is processed into ingredients for human food, while most of it goes to animal feed. 

 

 

Along this complex, but highly efficient path, there is so much mixing (‘co-mingling’ in grain-speak) that a question like, ‘did this come from a GMO or non-GMO field,’ is impossible to answer.  In all those steps, keeping GMO and non-GMO grain separate is inefficient (e.g. different harvesting equipment, partially filled trucks, dedicated bins, paperwork…).  That makes it costly.  It would also be very difficult to prevent a little bit of onetype of grain out of the other because a little can be left behind in a harvester, truck, bin, etc.  In theindustry that is known as ‘adventitious presence.’

The 0.5% threshold specified in the legal text of prop 37 would be highly problematic from a practical point of view. Considering that biotech traits are used in a very large percentages of the soybean, corn, canola and sugar beet crops, it makes much more sense to allow something that has been expensively segregated to be labeled ‘non-GMO,’as is already the case. 

2.    This initiative would create a field day for lawyers.  If this initiative is passed, anyone who wants to can take acompany to court if they think they are selling unlabeled GMO foods.  They don’t need to go to any governmentagency with oversight  – just straight to court.  There don’t have to be any damages in question.  The courts are also allowed to award the accusing party compensation for courtcosts and for the costs of investigating the food in the first place.  Given the practical challenges described above, this initiative would create a thriving litigation industry for exactly the kind of lawyers who wrote this proposition in the first place.

3.    This initiative would effectively restrict the use of the marketing term, ‘natural.’

Any foods which are even minimally processed (e.g. milling of wheat to make flour) cannot be marketed as ‘natural’ under this potential law unless they are either specifically tested for GMO status or come from a highly segregated channel complete with an audit trail and sworn affidavits.  That would even be true for foods made from crops that don’t even have commercial, biotech traits.  Thus, unless a food is certified Organic (specifically exempted in this initiative), it becomes expensive and legally risky to call it ‘Natural.’  Arguably, the marketing term ‘natural’ is over-used, but the answer to that isn’t to create an uneven playing field through a proposition that is promoted for a completely different reason.

4.    It will be virtually impossible to fix any unintended consequences of this law.  This initiative is designed to be difficult to change.  It says that if any part is stricken in the courts all the remaining sections are in force.  Even worse, it requires that any changes require a 2/3 majority in both houses of the legislature –something that is highly unlikely based on the extreme polarization of California politics.  If we pass this initiative, we will likely be stuck with it no matter what expected, or unanticipated problems it creates.

5.    This is another example of the California initiative system being gamed by special interests from out of state.  It is common for special interests to use the Californiainitiative system by paying people to collect signatures and then buying advertisements.  This has nothing to do with the original concept of a grass-roots, citizen-driven process.   In this case the major fundingcame from the notorious food-fear merchant, ‘Dr.’ Mercola, and also from some of the Organic food companies that employ distorted, negative descriptions of non-Organic food topromote their products.  It was also driven by activist lawyers who stand to gain financially.  The initiative is being promoted as a common sense requirement for consumer benefit.  Common sense should actually drive California voters to follow the money.

6.    It is worth asking, ‘why do farmers like these crops so much?’ There is a bit ofa spoiled child flavor to statements like, ‘hey, I’m the consumer so I shouldget any information that I want.’ We who actually depend on farmers for something as non-optional as foodshould at least ask, ‘why are GMO crops so overwhelmingly popular with any group of farmers with who has ever been given the opportunity to grow them?’  Farmers that manage to stay in business in that risk-laden enterprise do so by making rational economic decisions.  Biotech crops are something that has made good business sense for them, and by extension, a less costly and more reliable food supply for consumers.  If this initiative has the disruptive effect on the food system that its writers are hoping, we may discover the downsides of ignoring the interests of people on whom we depend.

 If you are a scientist, you can add your name to a petition against proposition 37 that has been organized by university and foundation researchers.  Its not just industry scientists (like myself), who are opposed to prop 37.  Its people who understand the science and its benefits.

You are welcome to comment here or to email me at savage.sd@gmail.com

Credits:

Corn combine image from bohnsack

ship image from 62518797@NO4

Train image from RoyLuck

Silos image from spiesteleviv

“(Via Steve Savage Applied Mythology.)

Steve Savage: “GMO Foods: To Label Or Not To Label?”

A guest post by agricultural scientist Steve Savage,
proprietor of Applied Mythology.
(This post first appeared on Science 2.0, 8/21/12)

This fall, California voters will be asked to vote on Proposition 37, a law which would require that all foods including ‘GMO Crop ingredients’ be labeled as such.   There are many reasons that this isn’t a good use of governmental authority for mandatory food labeling.  A look at historical logic and precedents for labeling, and at the misleading messages this initiative would foster, should inspire Californians to reject it at the ballot box.

Labeling for a Known Hazard

If a food is hazardous to some consumers, but not others (e.g. peanut allergy), then it makes sense to require that it be labeled to protect that minority.  If a food contains something generally hazardous, but difficult to immediately remove from the food supply, it makes sense to label those foods as well (e.g. trans-fats for which labeling was required after 2006).   If a particular GMO crop were to be found to be hazardous to certain people, or people in general, the appropriate response would to ban the use of that particular trait nationally, not to label it at a state level.  No such hazard has been documented for dozens of biotech crops crop traits over 16 years of extensive commercialization, so ‘hazard’ has never been a reason to require labeling of a GMO crop.

Labeling For Lack of Safety Studies

The proponents of Proposition 37 argue that because the FDA does not require a set of specific human safety studies prior to commercialization, consumer need to be warned. Considering the diversity of biotech traits, it does not really make sense to specify a particular battery of safety studies.  They would really need to be varied on a trait-by-trait basis.  The opponents of these crops imply that these foods are thus, untested when it comes to safety.  Nothing could be further from the truth.  Both the companies that produce the crops, and a wide range of independent researchers, have studied GMO crop safety for years.  Highly qualified scientific panels have reviewed those data and consistently concluded that these improved crops represent no unusual risk compared to crops improved by traditional methods. Indeed, ‘Nature’ seems to make similar genetic modifications.

Ironically, the largest single contributor to the pro-labeling effort is the internet ‘health advisor,’ Dr. Mercola whose $800,000 donation was funded by his thriving, natural supplement business.  There is very little regulatory oversight for that multi-billion dollar supplement industry in terms of required testing either human safety or product efficacy.  When it comes to safety testing, GMO crops are far more intensively scrutinized than something like Dr. Mercola’s supplements.

Labeling Because Other Countries Require It

One argument for requiring labeling has been that places like Europe, Japan and China do so.  First of all, most of the ingredients in the US, human food supply that come from GMO crops (corn starch; high fructose corn syrup, soybean, cotton seed or canola oil…) have always been supplied from different crops in other regions (potato or rice starch, beet or cane sugar, sunflower, peanut or rapeseed oil…) so there are actually very few GMO labeled foods in those countries.  They import massive amounts of our GMO crops for animal feed, but that is not labeled.  Second of all, the scientific review panels in these other countries have come to the same conclusions as those in the US.  They find no reason to doubt the overall safety of GMO-based foods.  It is just that politics trumps science in those political systems.  That is certainly not something we should imitate.

Labeling Because It Is A Consumer’s ‘Right to Know.’

Bits of information do not actually become ‘knowledge’ unless they can be placed into a meaningful context.  We have a historical example of this with the mandatory food composition labeling that has been required in the US since 1990.  The calorie, protein, fat, carbohydrate and vitamin content of foods could theoretically be useful information that consumers could ‘know.’  Unfortunately, when Congress passed the Nutrition Labeling and Education Act of 1990, it never actually funded the education part (imagine that).  For most consumers, the information on food products is not part of a functional knowledge-base that could guide their food decisions.  Instead, they are left to be influenced by the advertizing messages and ever-changing food fads that shape our ‘marketing of non-existence’ food culture.  Proposition 37 does not include any sort of official educational component,. It would just mandate that a bit of information, ‘contains ingredients from crops modified by genetic engineering’ be attached to many foods.  The contextualization of that information will be heavily influenced, not by any sort of balanced presentation, but by a range of activist groups, aggressive organic marketers, and fear-based marketers like Dr. Mercola.   This will not be anything new as these groups have been flooding the internet with hyperbolic warnings for more than a decade.  One might think that there would be a statute-of-limitations on saying that ‘the sky is falling.’  It is not at all surprising that Mercola and others would like the opportunity to ramp up the level of societal fear with the help of the ‘information’ supplied by California law.  (By the way, Dr. Mercola has not just promoted fear of GMOs.  He has been a conduit for anti-vaccination activists and even for a ‘doctor’ with the theory that all cancers are fungal infections.  His consistent message is, ‘Be afraid! Buy my products’).

Labeling As A Way To Track The Effects of GMO Foods

Another argument that Prop-37 supporters make is that labeling will allow us to better track or detect any issues with these foods.  Other than the fact that there is no obvious mechanism for that to happen, there is another major problem with the argument.  Foods purchased in restaurants would not be labeled under Prop-37.  Considering that on average people eat about half of their meals out, and that many mostly eat out, this idea of tracking falls apart.  The other implication of this exemption is that the information on grocery items (which will be cast in a scary light by Mercola et al), will not be seen in restaurants, including those that serve fast food, fried in GMO vegetable oils and sweetened with GMO corn-based sweeteners.  Making home meals sound scary and restaurant meals sound safer hardly sounds like a smart message to be sending to a population with an obesity problem.

Labeling To Allow Some Consumers To Avoid GMO Foods

Some people may never trust the scientific/regulatory consensus.  That is OK, but those folks don’t really don’t need to force mandatory labeling for everyone else.  They always have the option to buy Organic, which decided not to use GMO long before it was even an option.  These folks also always have the option to buy products that are sold as or even certified as non-GMO – something that is allowed already.  Anyone can also learn a few simple rules based on the limited number of crops that are GMO in the first place. Here are the simple rules: If the product has ingredients that are derived from Corn, Soy, Cotton, Canola, or Sugar beets, just assume it is probably includes biotech varieties since farmers of those crops overwhelmingly choose those option.  Right now, the only fresh market GMO crops in the US are papayas from Hawaii (virus resistance developed by Cornell University that saved the crop), and some sweet corn. In the rare case of another biotech crop being added to this list, there is always plenty of official notice and press/blog coverage.

Labeling to Allow Consumers to Intentionally Choose Biotech Improved Foods

Within a few years there may be some biotech-based, non-browning apples on the market, but they will be voluntarily labeled as such because it is a positive consumer feature and because that value chain is amenable to full identity preservation down to the sticker on each fruit.  This is the most logical form of GMO crop labeling, and there are no regulatory or legal barriers to such labels.

Conclusion

Mandatory food labeling should be reserved for well-documented public health needs and should be linked to viable public education efforts.  It shouldn’t be something designed to enrich fear-based marketers or to give people a false comparison of at home and restaurant foods.

You are welcome to comment here or to email me at savage.sd@gmail.com

Classic California License Plate from WoodysWorld1778

(Via Steve Savage Applied Mythology.)

Steve Savage: Do You Really Need to Buy Organic Foods To Avoid Pesticide Residues?

What I found disappointing about the Stanford study was the weakness of its analysis of differences in pesticide residues. 

I was delighted to find that Steve Savage had posted a well-researched critique  Do You Really Need to Buy Organic Foods To Avoid Pesticide Residues? of the meta-analysis “Are Organic Foods Safer or Healthier Than Conventional Alternatives?” The main-stream media didn’t get much further than the “Conclusion” paragraph of the press release

Conclusion: The published literature lacks strong evidence that organic foods are significantly more nutritious than conventional foods. Consumption of organic foods may reduce exposure to pesticide residues and antibiotic-resistant bacteria.

Every media reference I’ve encountered emphasizes the “…may reduce exposure to pesticide residues”. Does that mean “reduce exposure” from safe-and-totally-insignificant to…? Perhaps – but that really isn’t the focus of the Stanford paper – which is the nutritional vector. Steve’s introduction gets right to the implied pesticide risk that concerns me:

Last week, a meta-analysis from a highly credible, academic source (Stanford University, its medical school and nearby institutions), raised serious questions about the often-touted, nutritional advantage of organic food. They digested the contents of 237 peer reviewed articles comparing organic and conventional foods and diets. They concluded that “the published literature lacks strong evidence that organic foods are significantly more nutritious than conventional foods.” This drew a great deal of attention and organic advocate defense. Because even though Stanford is affectionately known by alums such as me as “the farm,” it is certainly no ag-school promoting the status quo. Instead, it enjoys a very strong reputation for research excellence. It isn’t easy to dismiss these findings.

Many commentators, confronted with the highly credible de-mythification of the nutritional advantage of organic, jumped to the paper’s slight evidence supporting a 30% reduction in exposure to pesticide residues as a way to justify paying extra for organic. Does the science really support that claim? No.

Please read Steve’s commentary with an open mind. If you are not completely persuaded, then for further reading may I suggest the B N Ames, M Profet, and L S Gold paper Dietary pesticides, which is an edited version of a chapter titled ‘Cancer Prevention and the Environmental Chemical Distraction‘, in the 2003 book Politicizing Science: the Alchemy of Policymaking. The Kindle edition is only $9.99, and a very good investment it is.

Scott Andes: Why California’s GMO Labeling Proposition Should be Defeated

I was planing to write an article on California Proposition 37. Now I don’t need to, because Scott Andes has done the job nicely with his essay at ITIF’s Innovation Files.

To frame the discussion we need prof. Kevin Folta’s tabulation of the available methods for altering the DNA of a plant. I recommend that you read Kevin’s article before continuing. Click the image for the full-size table:

Here are the ways that plants are genetically altered.  Note that all of them are acceptable to most people, despite having no idea what the heck is being changed, and the huge number of genes affected. 

Scott Andes explains that the activists promoting GMO labeling have no scientific basis – this is nothing like Trans-fat labeling. This is about politics. As David Tribe put it, this is about the financial interests of “Big Quacka and Big Organic“. And let us not forget the Trial Lawyers, which I discussed here: California proposition 37: Trial Lawyers, Bootleggers and Baptists

Here’s selected snippets from Scott Andes’ essay: 

This November, California voters will be asked to decide whether food that has been ‘genetically modified (GM)’ should come with a special GM label.  Proponents of proposition 37, or the ‘Right to Know’ initiative, argue that ‘in a democratic, free-market society, consumers get to make informed choices about what we eat and feed our families,’ i.e., a GM label will help consumers make informed choices. Sounds simple enough. What could possibly be the downside to a small label that presumably enables greater consumer decision making?

First, labels such as this are never about education and open consumer choice, but about limiting people’s interest in/exposure to? a harmful substance. Labels are one of many public policies that aim to ‘nudge’ consumer behavior away from a product. As Richard Thaler and Cass Sunstein outline in their well-known book Nudge, consumers are fickle, uncertain, and look for cues to make decisions. Thaler and Sunstein use the example of putting fruit first in cafeteria lines. Because people irrationally fill up their trays with things at the beginning of cafeteria lines, one way to ‘nudge’ people to eat healthy is to put healthy food first. Mandatory labels do the same thing. Cigarette labels do not exist to inform people that smoking leads to lung cancer—everyone knows that—they exist to nudge a consumer to think twice before purchasing a pack. The same thing goes for other mandatory labels such as Trans fat.

The question becomes, what makes an ingredient or food processing method warrant a label?  Obviously, there are many examples of products that are sold without detailed consumer information. Take generic brands. Beyond knowing a product is ‘canned tuna’ or ‘diced tomatoes’ consumers know little about the producing company or their method of production, yet we readily allow such products because they are cheaper and we are ensured that generics undergo the same health and safety requirements as name brands. Additional identifiers on generic goods add nothing  to informed decision making so we do not require them. Therefore, arguing, ‘consumers have a right to know,’ implies there is something about GMOs that make them more like Trans-fat than generic canned tuna. So what is the distinction?

The regulatory litmus test for mandatory labeling in the United States is the health impact of an ingredient. Nutritional content labeling helps consumers evaluate, for example, the number of calories and vitamins in a product while more explicit labels help consumers avoid unhealthy ingredients. Labels containing such useful, accurate information are required by law. Under the current regulatory framework, in order to justify a GMO label, GMOs would need to have different health or nutrition implications for humans than that of conventionally grown food.

While there are many ethical debates surrounding GMOs, one corner of the debate that science rightfully owns is whether or not GMOs have a unique health portfolio. The evidence clearly shows they do not. According to the Mayo Clinic, ‘A recent study examined the past 50 years’ worth of scientific articles about the nutrient content of organic and conventional foods. The researchers concluded that organically and conventionally produced foodstuffs are comparable in their nutrient content.’ The WHO states, ‘GM foods currently available on the international market have passed risk assessments and are not likely to present risks for human health. In addition, no effects on human health have been shown as a result of the consumption of such foods by the general population in the countries where they have been approved.’ And in a literature review for congress, the GAO writes, ‘To date, GM foods have proven to be no different from their conventional counterparts with respect to nutrients, allergens, or toxicity.’

If GMOs do not differ from conventional foods in terms of nutrition then why the call for a label? In part it’s because of a public misunderstanding that genetic engineering is creating unprecedented and novel organisms. As my colleague Val Giddings has noted, genetic manipulation is commonplace throughout the food system by conventional and organic farmers. What separates traditional transgenic methods  from genetic engineering is the use of recombinant DNA (rDNA) technology—a laboratory method of coordinating genetic material from multiple sources—to  confer beneficial traits to an organism. rDNA technologies are unique in that scientists can target one specific gene and monitor its impact on an organism, unlike traditional hybridization that blends two organisms in a completely unpredictable and largely uncontrollable grab-bag process.

The vastpreponderance of scientists agree that using GE rDNA techniques actually reduces the risk of surprises or undesirable results compared to traditional methods because through rDNA  one can actually see the genetic effects of a foreign gene, while traditional methods are only able to observe the phenotype implications (what a plant looks like). (…)

(…) Marchant, Cardineau, and Redick show in their book on GMO labeling that when the predicted cost of labeling is included in the questions, consumers overwhelmingly reject mandatory labels. More importantly, the reason so many consumers support labeling is because  believe GMOs are harmful. Responsible public policy should not promote this misconception but try to correct it. When cigarette labels were first debated most consumers believed they were unnecessary because people did not understand the health consequences of smoking.  Science was further along than public opinion. Similarly, with GMOs, science is ahead of public opinion.

{snip snip}

Definitely read the whole thing. Also be sure to read Hank Campbell The Mercenary Intent Behind Proposition 37′s GM Food Labeling