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.)

Why labeling of GMOs is actually bad for people and the environment

This is a very well written argument – by David Zilberman, professor of agriculture and resource economics at UC Berkeley.

On November 6th, California voters will be asked to vote on a proposition about labeling of genetically modified (GM) products. On the surface this seems quite reasonable: people should have information about what they y consume. In my view, labeling requirements are appropriate when there is undisputed scientific evidence that a food component is damaging, which, for example, is the reason for warning labels on cigarettes. But with GMOs this is not the case. For example, a recent NRC report states that GMOs are as safe if not more safe than conventional food which is also consistent with most of the published research.

Many of the fruits and vegetables we eat are already modified as they have been generated through techniques such as selective breeding and hybridization of crops among others. The discovery of DNA and advances in modern molecular biology allow us to develop more refined and precise crop breeding techniques where we slightly modify existing varieties by adding a specific trait. Obviously, genetic engineering is in its infancy, and has already led to major developments in medicine. Even though it has been underutilized in agriculture, existing GMOs have had significant impact. The most popular traits address pest control (Bt varieties) and tolerance to herbicides (Round-up ready varieties). These traits have been adopted with corn and soybeans in the US, Brazil, and Argentina among others and also in cotton in India, China, and some developing countries. Studies show that GM varieties of cotton and corn in developing countries increased in per acre yield by more than 50%, and GMOs contributed significantly to the more than doubling of the production of soybeans.

The importance of GMOs has to be viewed within a global context. Population and income growth have led to increased demand for food and especially meat. Meat production is feed intensive. This and the introduction of biofuel has resulted in increased prices of agricultural commodities. When food becomes scarce (and expensive), it is the global poor that suffers most. Our calculations suggest that the magnitude of the impact of GMOs on reducing food commodity prices was the same or even bigger than biofuels had on increases of these prices (15-30% reduction in the price of corn and soybeans overall). Furthermore, the prices of cotton did not rise with the prices of other commodities in 2008 due to increased supply from the adoption of GMOs. If African nations and Europe would have adopted GMOs, current prices of food would have decreased significantly, and much of the suffering associated with the food shortages could have been avoided. Thus even in its early stages GMOs have made significant contributions to reducing food shortages and saving lives.

Adoption of GMOs is not only good for food commodity prices and the well being of the poor, it is also good for the environment. Adoption of herbicide tolerant varieties enabled transition to minimal tillage techniques, which reduced the GHG effect of agriculture equivalent to hundreds of thousands of cars annually. GMOs make it possible to produce food on less land, reducing the incentive of converting wild land into agricultural land. There is evidence that by replacing toxic chemicals in India and China, adoption of GMOs directly saved many lives. Reduction of exposure to pesticides and the resulting health effects has been a major cause for adoption in the US.

But what about Monsanto?

(…)

Read the whole thing.

 

California proposition 37: Trial Lawyers, Bootleggers and Baptists

“When I used to go and talk about Prop 65 when it was on the ballot, I would say the biggest beneficiaries would be lawyers. I think that goes double for Prop 37,” said Michele Corash, a environmental defense partner with Morrison & Foerster. — from The Recorder, Defense Lawyers Say Prop 37 Will Bring Bumper Crop of Litigation, 7/27/2012

Courtesy of Andrew Apel @AgBioEye, an excellent little article on the developing California proposition 37 train-wreck. Snippet: 

Proposition 37, which will be on the ballot this November, will all but guarantee payday after payday for trial lawyers in the Golden State. Also known as the Right to Know Genetically Engineering Food Act, the law would require labels on foods and beverages that include ingredients produced with biotechnology. Never mind that biotechnology can produce crops more resistant to disease or with greater yields. Oh, and they’ve been on the market for almost two decades, and there’s no credible evidence that biotech crops have produced even a case of sniffles in humans.

So who stands to benefit, other than dubious nutrition supplement peddlers? If you guessed trial lawyers, you win an organic cookie. They have already attacked food companies for using biotechnology in the past, so having the law in their favor will turn these seemingly frivolous cases into sure winners.

Never mind that biotech crops could change the world and avert the global food crisis; ignore the fact that biotech food has helped nations develop. The American Medical Association’s declaration that “there is no scientific justification for special labeling of bioengineered foods” is irrelevant to the debate, it seems. Facts don’t matter when there’s money to be made.

This should all sound familiar, because Prop 37 isn’t too many steps away from Proposition 65. It was a decade ago when we first noted the outrageous results of Prop 65—when French fries were under attack. It’s a rule that California has onlymade even worse over the years by adding more and more substances to the list.

So is it any surprise that the man who helped craft Prop 65 is leading the charge for Prop 37? Would you be any less surprised if he tried to deny the blatantly obvious similarities

Read the whole article – lots of potentially useful resources. I’ve not had time to do any checking on the article source: “Center for Consumer Freedom“. This group may be baptists fronting for other bootleggers. See Bruce Yandles Bootleggers and Baptists if you are not familiar with this economic analysis.

Some background on the other bootleggers hiding behind Prop 37. E.g.,

Quackwatch FDA Orders Dr. Joseph Mercola to Stop Illegal Claims, Mercola is biggest $$$ at $800,000. Mercola is a large anti-vaccine, organic, “natural stuff” moneymaker. They are part of the Big Organic lobby.

Station KCET is tracking prop 37 donors. The bootleggers were way in front on the funding last week (~3x the opposition who had only two small contributors). I’m happy to see some contributors coming along to oppose. The challenge here is that Prop 37 sounds harmless to people who don’t know anything about the food supply chain, and don’t appreciate the powers that are behind the sorts of propositions.

Steve Savage: What We Have NOT Recently Learned About Pesticide Risk

A few weeks ago, the readers of various ‘Food Movement’ and ‘Health’ blogs (and unfortunately some news sources) were treated to a major dose of fear mongering.  It had to do with an old agricultural fungicide that was tested at an extremely high, non-contextual dosage in a scientific study that looked at ‘chemical effects on epigenetic change.’  What the study demonstrated was interesting, but its interpretation in various circles has been completely out of context.  For example, self-described ‘Health Ranger,’ Mike Adams of Natural News started off with the headline: 

‘Red alert for humanity: Chemical damage can be inherited by offspring through unlimited generations’

Under the section heading, ‘Why chemicals threaten the future of the human species,’ Adams concludes:’  we are, in essence, ChemHumans, forever imprinted with the toxic burden of all the tens of thousands of synthetic chemicals we have foolishly unleashed onto our world, our environment and food supply’.   

What inspired this sort of ‘the sky is falling’ rant?  A classic failure to put a scientific finding into any sort of rational perspective.

(…)

Thus begins a typically robust analysis by Steve Savage, proprietor of the very suitably titled Applied Mythology. Steve’s “About me” reads:

Steve Savage is an agricultural scientist (plant pathology) with >30 years of experience in agricultural technology. He has worked for Colorado State University, DuPont (fungicide development), Mycogen (biocontrol development), and for the past 13 years as an independent. He also has a little vineyard in his back yard near San Diego. 

Fortunately for us he is willing to invest the time to educate us who are outsiders to the field. My recommendation is simply to get yourself over to Applied Mythology – every article I have read has been well worth my time. As soon as I have time I’ll be posting links to a few articles that were especially useful to me.

If you are still not motivated to join Steve’s readership, I will quote his tagline:

What if much that you think you know about agriculture, farming and food isn’t actually true? What if there are “myths” that have been intentionally and mostly unintentionally spread about these issues? What if the truth about these issues matters for the future of humanity? That is what this blog is about.

A perfect example is Its What You Know For Sure That Keeps You From Learning.

Genetically modified crops shrink farming’s pesticide footprint

Image: Genetically modified insect protected cotton on the left, next to a closely related conventional cotton variety on the right which is showing the damage from heavy insect feeding pressure. Greg Kauter, Courtesy of Australian Cotton Growers Research Association Inc, Narrabri, NSW.

There is a concise summary of the benefits of modern agriculture at The Conversation, by University of Melbourne scientists Richard Roush, and David Tribe:.

(…)

Recent news reports claim one in ten Australians believe the world will end on December 21, 2012, based largely on internet gossip about the meaning of ancient stone carvings from the Mayans of Central America. Such is the disturbing power of frightening myths to influence human belief.

No wonder modern apocalyptic mythology about agriculture, sinister stories about pesticides and assertions that genetic engineering of crops break a biological taboo find a very receptive audience, especially among those who don’t ever go to a modern farm.

In truth, there’s a lot to feel good about in the way modern agriculture is shaping up to the big challenges of the present – reducing carbon emissions, preventing soil erosion and minimising any environmental damage by herbicides and pesticides.

Helping the environment

One of the most significant crop management improvements in recent times has been the increasingly common practice of sowing seeds by direct drilling them into the stubble of the previous season’s crop. This approach forgoes a massive amount of soil tillage with the plough. Such minimum-tillage or no-tillage farming means that much less diesel oil is used in tractors and carbon levels can buildup in the soil rather than be released to the atmosphere.

It’s been estimated that the carbon emission savings from introduction of genetically engineered crops that encourage no-till farming are equivalent to removing 19.4 bn kilogram of carbon dioxide from the atmosphere worldwide. This is equal to the carbon emissions savings from removing 8.6 million cars from the road for one year.

Minimal tillage farming also has several other benefits, such as better moisture retention in the soil and reduction in soil erosion.

Modern crop genetic engineering has provided farmers with much better crop variety options for use in no-till farming. One of these is crops that are tolerant of the herbicide glyphosate. This is the most widely used types of GM crop. Glyphosate-tolerant crops include soya beans, canola, cotton and maize. Glyphosate has much lower environmental impact than chemicals such atrazine, which it replaces. Unlike atrazine, which is banned in the European Union, glyphosate is relatively rapidly degraded in the soil and does not easily leach into water run-off to river basins.

(…) Hopefully, readers will realise that most of the sinister prophesies circulating about  crop genetic engineering are as useful as the current myth that Mayan hieroglyphics say the world will end in December.

The authors were careful to head off the usual “corporate shill” comments by their complete transparency:

Richard Roush receives research funding from the Grains Research and Development Corporation.

Rick Roush has advised the US EPA on resistance management issues twice in the last 4 years. The US EPA requires a formal disclosure review process to identify any possible conflicts of interest, which Rick has passed. Rick does not work for, consult for, own shares in or receive funding from any private company that would benefit from this article, and has no relevant affiliations.

David Tribe does not work for, consult to, own shares in or receive funding from any company or organisation that would benefit from this article except the University of Melbourne, where he is paid for teaching research and community outreach by a standard salary arrangement with the University. He has no relevant affiliations that might entail a conflict of interest in scientific analysis.