Steve Savage: “How The USDA Unwittingly Aids EWGs Pesticide Disinformation Campaign”

A guest post by agricultural scientist Steve Savage, 
proprietor of Applied Mythology
(This post first appeared on Applied Mythology 6/19/2012)

Each year, the Agricultural Marketing Service of the USDA (USDA-AMS) conducts an extensive sampling and analysis of items from the actual US food supply to determine what, if any, pesticide residues are present at the consumer level.  This information is published each year, and the actual raw data is also available for download.  The data for 2010 was just recently released.

What Does The Data Actually Tell Us?

For 2010, as for preceding years, the data demonstrates is that pesticide residues are only present at very low levels, usually dramatically below the conservative ‘tolerances’ set during the risk analysis by the EPA.  This is quite remarkable considering that pesticide use on crops depends on many thousands of independent decisions by many thousands of individual farmers both in the US and in dozens of countries from which we import food.

This year the USDA provided several summaries in an effort to be clear about what they have found.  In this years press release one finds the following, unambiguous statements:

The 2010 PDP report confirms that food does not pose a safety concern 
based upon pesticide residues.  
 
 
Statement from the EPA ‘The data confirms EPA’s success in phasing- out pesticides used in children’s food for safer pesticides and pest control techniques.  The very small amounts of pesticide residues found in the baby food samples were well below levels that are harmful to children.’  
  
Statement from FDA: ‘Based on the PDP data from this report, parents and 
caregivers can continue to feed infants their regular baby foods without being concerned about 
the possible presence of unlawful pesticide chemical residues.’ 

Statement from the USDA: ‘Age-old advice remains the same: eat more fruits and vegetables and wash them before you do so.  Health and nutrition experts encourage the consumption of fruits and vegetables in every meal as part of a healthy diet…’

Unambiguously positive assessments like this can also be found in the main data summary, the ‘What Consumers Should Know‘ highlights, and in the ‘Questions and Answers‘ link.

What Does The Press Tell Us?

As a typical example, CNN starts with the headline, ‘Watch out for the 2012 Dirty Dozen,’ and continues, ‘Apples and celery are still agricultures dirtiest pieces of produce according to the Environmental Working Groups annual ‘Dirty Dozen’ report.’  Its version of the baby food findings are, ‘For the first time this year, the USDA also collected data on pesticide residue in baby food, finding many of the studies samples to be contaminated with organophosphate pesticides.’

How can CNN report something so radically different than what the USDA said?  They simply are repeating what the Environmental Working Group has said in its press release of 6/19 and make no effort to compare it with the official document.

HuffPost Healthy Living starts with the headline, ‘Dirty Dozen: EWG Reveals List of Pesticide-Heavy Fruits and Veggies.’  Nowhere in this article is there even a reference to what the USDA, EPA and FDA said about the data.  It simply passes along the EWG interpretation as if it were gospel. 

This is the mainstream media.  You can well imagine what is said on various organic and Food Movement sites and blogs.

In contrast, Jon Hamilton writing for an NPR blog uses the headline, ‘Why you shouldnt panic about pesticide in produce.’  Jon notes that the EWG sends a ‘mixed message,’ saying ‘you should be concerned about pesticide residues in fruits and vegetables, but not so concerned that you stop eating these foods.’  Rather than simply parroting EWG, this writer demonstrates some journalistic mettle by interviewing a scientist at McGill University who can provide some perspective.  He also demonstrates that he read at least some of the USDA documentation by quoting specific numbers on apples and the non-alarm assessment for the baby food data.  Such efforts at balance are unfortunately rare.

Why Does The EWG’s Version Get So Much Attention vs The USDA’s?

Although sensationalism, low journalistic standards, and limited scientific background are certainly involved in the largely uncritical magnification of the EWGs message by the press (and particularly the blogosphere), Im afraid that UDSA-AMS is partially to blame.  Dont get me wrong, they do a rigorous collection and analysis of the data.  They are extremely clear in what they conclude with sound reasoning.  They are definitely transparent and unbiased in their presentation.  What what USDA does not do is provide a summary version of the data that is easily digestible by ordinary readers, including typical members of the press.  EWG provides a simple list with a one dimensional ranking.  It is a gross and misleading simplification, but that makes it easy to relay as if it was a real analysis.  Unfortunately, the summaries that the USDA presents are extremely detailed, extremely long, and not easy to interpret even for someone who wants to.  Let me explain.

A Document That I Doubt Many People Really Read and Digest

The annual summary document for each years PDP data is huge, in the range of 200 pages as a pdf (it is hard to tell, the appendices are numbered independently).  It starts with 28 pages of background on methodology and summary of sample types etc.  Then there are 9 pages of a historical appendix.  Finally the actual data begins in a 77 page appendix, but this is organized by chemical – nothing that most people would even begin to relate to.  For each chemical there is no information about whether that product is something toxic or not, nor is there information on any other dimension of its environmental profile.  To get that, someone would have to search for an MSDS and maybe an EPA RED – none of which are easy for any layman to interpret.  All this table lists are the number of samples, the number and percent of ‘detections,’  the range of those detections in PPM, the LOD (limit of detection), and the EPA tolerance (an extremely conservative level set by an elaborate risk analysis). Most people would have no idea what to do with those numbers.  In fact they show that the vast majority of ‘pesticide detections’ are at levels well below the tolerances, but it is tedious to do the comparisons by eye and there is nothing in the table to give the message of how far below any level of concern the vast majority of samples are actually shown to be.  Im not surprised that no independent journalistic interpretation of these data occur.

Below the chemical-by-chemical summary there are dozens of pages summarizing commodities other than fruits and vegetables.  That is followed by an appendix J which unhelpfully simply compares the ‘percent detections’ for imported and domestic samples (a summary level as seriously unhelpful as that by the EWG).

Finally, at the very end of this huge document there is a crop-by-crop summary with the same data columns as for each chemical (#samples, #detections…) which has the same tedious requirement to compare detections and tolerance that are all usually numbers to several decimal points.  I have never seen anyone in the press do much if anything with this data set.

What Does This Report Need?

To be fair, USDA-AMS has amassed such a huge body of data.  It is difficult to summarize it in a way that is intuitively meaningful.  Their bottom line conclusion, ‘produce is safe,’ is a perfectly valid, but some visual representation could go a long way towards getting that message across.  I acknowledge that this is difficult.  I have made some attempts to do so in the past.  I plan to do so again with this years data, but that will take time.  The same would be true for even an ambitious reporter, while simply reporting what the EWG says allows less ambitious reporters to keep up with the instant news cycle.

A Mountain of Data

It is a wonderful thing that the USDA makes the effort to analyze so many samples of so many crops and looks for so many different chemicals.  The downside is that this generates a database that is beyond what most of us even know how to process.  The file that one can download with the raw data has been getting bigger every year and has now reached 85MB.  Im used to dealing with large files, but none of my ordinary software can deal this this.  Ive gotten my son to write a program in RUBY to parse the data and only give me the tiny fraction which contains ‘detections’ and discard the millions of rows of data that effectively say, ‘we didnt find this chemical in this sample.’  Im going to ask him to modify the program this year with some additional summaries.  

When and if I get this done, I plan to make this available to anyone interested in doing an actually meaningful analysis of the data and to explore ways to present it graphically in ways that can compete with the egregiously trivialized ‘analysis’ done by EWG.  

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

Produce stand image from Steve Savage

(Via Steve Savage Applied Mythology.)

Steve Savage: “A Rational Analysis of the USDA Pesticide Residue Data”

A guest post by agricultural scientist Steve Savage, 
proprietor of Applied Mythology
(This post first appeared on Sustainablog 6/15/11)

NewImage

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”

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

 

Topographic map of the state of California.

The Golden State

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

Labeling for a Known Hazard

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

Labeling For Lack of Safety Studies

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

…for good reason.

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

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

Labeling Because Other Countries Require It

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

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

nutrition label

Nutrition facts. Source: FDA.

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

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

Labeling As A Way To Track The Effects of GMO Foods

An exceptional proposition

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

Labeling To Allow Some Consumers To Avoid GMO Foods

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

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

Labeling to Allow Consumers to Intentionally Choose Biotech Improved Foods

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

Conclusion

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

(Via Biofortified.)

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

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

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

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

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

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

 

 

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

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

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

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

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

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

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

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

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

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

Credits:

Corn combine image from bohnsack

ship image from 62518797@NO4

Train image from RoyLuck

Silos image from spiesteleviv

“(Via Steve Savage Applied Mythology.)

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

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

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

Labeling for a Known Hazard

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

Labeling For Lack of Safety Studies

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

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

Labeling Because Other Countries Require It

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

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

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

Labeling As A Way To Track The Effects of GMO Foods

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

Labeling To Allow Some Consumers To Avoid GMO Foods

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

Labeling to Allow Consumers to Intentionally Choose Biotech Improved Foods

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

Conclusion

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

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

Classic California License Plate from WoodysWorld1778

(Via Steve Savage Applied Mythology.)

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

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

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

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

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

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

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

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

This Is Your Global Food Supply On Climate Change

I think that Steve Savage expresses the climate change connection about right. We won’t know for twenty years if the 2012 weather extremes are expressing a climate change signal. Regardless, the extremes are signaling how important it is to make the global food supply more robust under the stress of combined extremes of heat and drought.  Here’s a snippet from Dr. Savage:

OK, I’m going to go out on a limb and say that I think that this year’s climate extremes are linked to human-caused climate change.  We might not really have the definitive answer on whether that is true for 20 years, but I would like nothing better than to be proven wrong about the linkage I’m making today.  From a global food supply perspective, the effects of weather on 2012 food production is problematic no matter what its cause.  As bad as it seems, it might just be a ‘shot over the bow’ relative to what me might expect in the future. The unfilled corn cob pictured above is a relatively decent example of what the US corn crop is yielding this year.

How Hot Is It?

This isn’t just about low rainfall.  There is a recent graph about temperature extremes on the NOAA (National Oceanic and Atmospheric Agency) site that is striking. The 2012 difference from average is off the chart!

 

When it is both hot and dry, our dominant, rain-fed crops suffer the most.

Please do read Steve’s complete analysis.

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.

The face of climate change should be the poor (not polar bears)

Steve Savage’s latest on global food prices led Steve to emphasize that technology is our primary tool to double food production by 2050. That essential tool is being fought by rich and powerful NGO’s and by the wealthy European states. Here’s a snippet from “Should “Charismatic Megafauna” be the “Face” of Climate Change“:

Unfortunately, there is continued resistance to “GMO” crops even after 13 years and billions of acres of safe implementation. Of course if we fail to grow enough food, it won’t be the risk-averse, affluent people of Europe and Japan that will suffer. Even though their own farms are less productive than they could be, they will be able to afford to import food at prices that put it out of reach for the poor. They may also continue to be able to block other countries from growing GMO wheat or rice without suffering much for it, but the suffering will occur somewhere else. I highly recommend Robert Paarlberg’s book, “Starved for Science” which documents how European influence has influenced agricultural policy in Africa to reflect the precautionary leanings of their former colonial masters rather than what is needed to feed poor people.

This is why a polar bear is not an appropriate image of what will happen if we don’t respond properly to the challenge of climate change. We need to envision hunger, starvation, political instability, and mass migration. Climate change consequence needs a human face.

Steve’s book recommendation is available in a Kindle edition: Starved for Science: How Biotechnology Is Being Kept Out of Africa. I just ordered for our iPads. UPDATE: Paarlberg’s book is truly excellent. I’ve already sent a Kindle gift book to a UK friend.

Polar Bear photo from Flickrfavorite.