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An Indian Smallholder Farmer Speaks Out: Allow Us to Embrace Biotechnology

Published October 14, 2012 Agriculture , Uncategorized Closed
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Sadly the fundraisers at Friends of the Earth will probably not read this editorial by Rajesh Kumar:

 My last visit to the United States changed the way I farm on the other side of the world.

In 2009, I traveled from India to Des Moines to attend the Global Farmers Roundtable, a project of Truth about Trade and Technology, held in conjunction with the World Food Prize. I met farmers from Iowa as well as Australia, Honduras, South Africa, and elsewhere. We learned about each other’s work, discussed common challenges and opportunities, and enjoyed some of the best sweet corn I’ve ever tasted.

When I returned to India, I worked with a group of local farmers to open a new sweet corn processing factory. The knowledge I gained in the United States made it possible. I’ll always be grateful to Iowa and the people I met at the Global Farmer Roundtable and World Food Prize for pointing us in the right direction.

I hope Indian farmers can imitate Iowa farmers in other ways as well. Most importantly, we must embrace biotechnology–or at least we must be allowed to embrace biotechnology. Right now, large forces and special interests are blocking the way. They must be stopped.

(…)

 Read the whole thing. And if you have a friend at FOE, then do what you can to get your friend to read and pass it upstairs.

The GM Corn Rat Study

Published September 21, 2012 Agriculture 1 Comment
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Neuroscientist Steven Novella examines the propaganda:

By all accounts this study looks like the perfect storm of ideologically motivated pseudoscience. French researchers Gilles-Eric Séralini at the University of Caen, who have a history of opposition to GM food, have published a highly dubious study allegedly linking consuming the GM corn or exposure to the roundup pesticide with increased risk of tumors and death. However:

In an unusual move, the research group did not allow reporters to seek outside comment on their paper before its publication in the peer-reviewed journal Food and Chemical Toxicology and presentation at a news conference in London.

So – they presented their controversial findings, which they consider “alarming,” but prohibited journalists from doing their job before presenting the results. That’s more than suspicious – I think it’s unethical. Transparency in science is critical, especially when that research has immediate implications for public safety and can have a profound effect on public opinion.

It is much easier to provoke fear than to reassure with careful analysis. It’s almost as if the researchers wanted an undiluted initial shock reaction to their research before the careful analysis could even take place.

But the internet moves fast these days, and that careful analysis is already beginning – leaving those news outlets who swallowed the press release in the dust. The New Scientist has an excellent analysis, based partly on a French blogger who has dissected the study. Problems already identified with the study include the following:

- The population of rats used have a high propensity for tumors.

- There were only 20 rats in the control group, and 80 in the exposure groups, an atypical asymmetry.

- The data reports that “some” of the test groups had a higher tumor incidence, while others did not – sounds suspiciously like cherry picking the data.

- The statistical analysis done by the team was atypical, characterized by nutrition researcher Tom Sanders as ”a statistical fishing trip,” while a more standard analysis was excluded.

- Exposure to GM corn or the herbicide Roundup had the same negative effects. It is inherently implausible (admittedly not impossible) for such distinct mechanisms to have the same effect.

- There was no dose response at all – which is a critical component of demonstrating a toxic effect.

- The researchers did not control for total amount of food consumed, or fungal contaminants, both of which increase tumors in this population of rat.

These are only the most obvious problems with the study – the kinds of things that journalists would have been told if they were allowed to show the study to other scientists before reporting on the study.

Frankly, if a journalist if given such a restriction I think they should either refuse to report on the study, or solely report about the odd restriction, or ignore the restriction and show it to other scientists anyway. The integrity of the science reporting process is more important than this one study or this one research group.

This group has a clear conflict of interest in that they have a history of strong opposition to GM foods and have published dubious researchin the past overcalling the risks of GM food. However, I do not believe that an apparent conflict of interest automatically condemns research, if the research is rigorous and transparent.

However, when you combine a conflict of interest (in this case a strong ideological bias) with questionable research methods and then squirrely dealings with the media, you have cause for concern.

Already the French government has ordered a probe into the possible safety concerns of GM corn. That seems like an overreaction to this one questionable study, but as long as they do an honest inquiry into the science the end result should be legitimate. I just hope they publicize the outcome of their investigation, even if negative, as much as the “alarming” research that provoked it.

Should there be required labeling of GMOs?

Published September 20, 2012 Agriculture , California Proposition 37 1 Comment
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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)

Published September 20, 2012 Agriculture , California Proposition 37 Closed
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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?

Published September 14, 2012 Agriculture , California Proposition 37 Closed
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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

Published September 14, 2012 Agriculture , California Proposition 37 Closed
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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: “A Rational Analysis of the USDA Pesticide Residue Data”

Published September 12, 2012 Agriculture 3 Comments
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A guest post by agricultural scientist Steve Savage, 
proprietor of Applied Mythology. 
(This post first appeared on Sustainablog 6/15/11)

Spraying pesticide in California

Image via Wikipedia

When the Environmental Working Group (EWG) makes its annual “Dirty Dozen List” of fruits and vegetables with pesticide residues, it does so without paying any attention to which chemicals were found or what level was detected. This is why it is so misleading.  To do the analysis properly does take a lot more “work” – it took me much of the last two days to do it.

First I had to download the raw data which comes as a 5.5 MB ZIP File that expands to a 83 MB text file.  My son wrote a little Ruby On Rails script that sifts through the millions of rows of data to find the 30,000 actual “detections” of pesticide residues that the USDA reported for 2009.  That list has the identity of the pesticide and its concentration in parts per million, billion or sometimes trillion.  Next, I searched for anMSDS for each of the 300 or so different chemicals to get the specific acute toxicity (this is usually in section eleven of each document).  The acute toxicity is expressed as an LD50 – the milligrams of chemical it would take per kilogram of body weight to kill 1/2 of the rats in a feeding study (Oral LD50).  These are publicly available documents which are usually easy to find except for old, discontinued pesticides and some of the metabolites.  Dividing the LD50 by the detected amount gives you the multiple of its own body weight that the rat would have to eat to reach a toxic dose.

An Example You Can Blame on McDonald’s

As an example, an old, extremely toxic pesticide, aldicarb (Temik) has an LD50 of 1 mg/kg.  This is exactly what you imagine when you hear the word, “pesticide.”  In one sample of fresh potatoes, the USDA scientists detected 0.01 mg/kg of aldicarb sulfoxide – a metabolite which is just as toxic as the aldicarb.  For the rats to die from eating such potatoes would require that they rapidly consume 90 times their own weight of those particular potatoes.   The most toxic potato sample had 1.5mg/kg of the aldicarb sulfoxide which means that the rates could die by eating just one times their own body weight.  A rat might be able to do that.

The EWG essentially treats every one of the 30,000 detections as equal in risk to these worst-case potato values.  Because most pesticides are far, far less toxic than aldicarb, the average residue found by the USDA on potatoes has a safety margin of 595,163.   The only reason that aldicarb is still used on potatoes (and it will be phased out soon), is that for purely brand protection reasons, MacDonald’s asked it’s fry suppliers not to give them any more GMO potatoes (they had been using them for several years, and they still cook them in GMO soybean oil and serve up GMO sodas with corn sweetener).  Still, McDonalds killed the Bt-potato.  That is why potato growers plant their potatoes into a furrow with granular aldicarb so that the roots pick up the insecticide for ~60 days, protecting them from the Colorado Potato Beetle.  Still, potatoes are in about the middle of the pack in terms of average safety margin.  Oranges have a safety factor of nearly 1.5 million.

Sweet corn, which makes the “Clean Fifteen” list for EWG is actually the crop with the lowest average safety margin (8,909).  This demonstrates the meaninglessness of the Dirty Dozen list.

Beyond Averages

Of course, averages can be misleading.  It is more instructive to look at the full distribution of results.  The graph below summarizes all the sample results for fruit crops.  For this graph, values on the right side of the graph represent extremely low risk while those to the left represent relatively higher risk.  As you can see, even though these crops had many pesticide residues, they almost all were present at vanishingly levels meaning extremely minor risk.  People just don’t eat one hundred, one thousand or several million times their body weight of one food in a sitting!

The same is true for vegetables.  The few residues detected on lettuce have safety margins in the million-fold range and the non-Organic lettuce was actually a little better than the Organic lettuce.  By this methodology potatoes and spinach come out the worst with some safety margins in the thousand range.  Still, the message from the real data is completely different than what one gets from the EWG’s “analysis.”

When the EWG list is reported by the unsophisticated media, they say things about it which are completely false.  For instance thirdage.com said, “The “dirty dozen” list of the twelve fruits and vegetables with the highest amount of pesticide residue was released Monday by the Environmental Working Group (EWG).”  That would be impossible because the EWG did not access the raw data which would be necessary to identify how “high” the residues actually were.  They say that cherries “dropped off the list” without mentioning that cherries were not even one of the crops tested in 2009.

So, what does the USDA data actually tell us?  That we should feel confident that the fruits and vegetables available in our markets are perfectly safe, and we should be consuming them in ever greater quantities to take advantage of all the cancer- and other disease-fighting chemicals they naturally contain.  It also tells us that the EWG should be ashamed of their list, print a full retraction, and refund their ill-gotten financial gains.

If anyone would like a copy of the processed data or graphs I would be happy to email it from savage.sd@gmail.com.  Also if anyone would like to improve on my collection of LD50 values that would be much appreciated.  My website is Applied Mythology.

Crop dusting image from wikimedia


sustainablog (http://s.tt/18H4H)

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

Published September 12, 2012 Agriculture , California Proposition 37 Closed
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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″

Published September 12, 2012 Agriculture , California Proposition 37 Closed
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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

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Corn combine image from bohnsack

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“(Via Steve Savage Applied Mythology.)

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

Published September 12, 2012 Agriculture , California Proposition 37 Closed
Tags: , , , ,

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.)

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