Analysis of Washington State GMO Labeling Initiative I-522

Background

Recently, supporters of the Washington State initiative I-522 submitted signatures to the Secretary of the State of Washington.  This initiative is designed to “establish mandatory labeling of foods produced through genetic engineering”. The official web site for the initiative support effort can be found at: ( labelitwa.org [EDIT 3/2/2013: Initiative supporters have put up a new WEB site at Yes on I522]) and the initiative text can be found at: (I-522 Text ). The author of I-522, Chris McManus (Chris McManus), is an advertising executive from Tacoma, Washington.  When asked about technical details of the initiative, he reportedly replied “Well, you know, I’m not a scientist.  I work in media. Those kinds of questions I’ll have to defer to later in the campaign.”  (McManus Quote ).  One would think that addressing such issues might be an important consideration before signing the petition, however, the process has now moved beyond that point.

The effort has strong support from the organic community, with the initiative itself having several sections devoted specifically to the promotion of organic production methods as well as the backing of large organic business and consumer interests such as Whole Foods Market Inc. (Wikipedia: Whole Foods Market & wholefoodsmarket.com ), PCC Natural Markets, the largest certified organic coop in United States, (Wikipedia: PCC Natural Markets  & pccnaturalmarkets.com),  and the non-profit advocacy group, The Organic Consumers Association (Wikipedia: Organic Consumers Association & organicconsumers.org ).  Several other smaller businesses with interests in organic production have also committed to supporting the measure (see for example Labelitwa Supporters ).Pike Street Market

Much of the initiative text is taken, sometimes verbatim, from the earlier 2012 initiative process in California, Proposition 37 .  While the similarity of the two initiatives is substantial, there are important differences.  Proposition 37, for example, contained language intended to regulate the use of the term “natural”.  That component of Proposition 37 was highly contentious and was possibly its weakest legal aspect (Legal Analysis of Proposition 37 ).  Such language has been dropped from I-522.  While the similarities of the Washington State initiative text may present many of the same legal issues already raised by Proposition 37, I-522 has its own unique language, which may initiate other challenges.  The similarities and differences of these proposals will be addressed as they occur below.

Taking a purely empirical view, labeling of genetically modified organisms provides little useful consumer health or safety information. GE products currently in the marketplace have proven safe in foods and animal feeds through use and testing. Environmentally, these products can have a good record of improvement over conventional production methods while maintaining the high yields and profits necessary for farmers.  These facts have been repeatedly demonstrated in the peer reviewed scientific literature, much of which is from independent sources, despite claims to the contrary (see Biofortified Genera for an extensive list).  The widespread acceptance of genetic engineering in the farming community is further evidence of the unique utility of these tools.  Farmers are not foolish and do not gamble on, or stick with, risky ventures where their livelihoods are at stake (see for example the opinion of farmer Brian Scott ).

Alternatively, some people may have ethical concerns such as intellectual property rights or corporate control over food supplies, and these could provide an impetus and societal pressure for mandating GE food product labels.  The text and labeling process proposed by I-522, however, are ill suited for informing consumers.  The vague labeling requirements of I-522 are designed to scare consumers away from GE products, not provide desirable information. Simultaneously, the law appears designed to strongly promote organic methods as an equal and preferred GE alternative. These unfounded biases, as well as the extensive exemptions incorporated into the law, remove any usefulness the labeling might have to consumers wishing to avoid GE products.

Executive Summary

1) The proposed label system is too vague and contains little useful information.  The supporting arguments suggest labeling could help consumers concerned with health, dietary, religious, environmental, and corporate control issues avoid GE products.  The actual labeling, however, does not guarantee any GE content will be present in the product.  The proposed labels are not required to specify what ingredients may be GE, nor the extent to which they may be present.  In addition, the law does not require testing for the presence of GE components.  Consumers wishing to discern between GE and non-GE products can already do so through existing, non-mandatory labeling designations provided by USDA Organic certification, or one of several private non-GE certification businesses.

2) Too many exemptions are granted to large agricultural and food industries.  These exemptions further reduce any usefulness of the labeling allowing producers and retailers of restaurant foods,  animal products, and alcoholic beverages among many others to serve customers GE products without informing them.

3)  The penalties for noncompliance are onerous, especially for small businesses.   The potential penalties will most likely lead larger national and global food producers to simply apply the most generic GE label to all their products.  They would likely be able to compensate for any negative consumer reaction to such labeling through their large volume of sales.  Smaller local producers, however, would be left with little choice but to either comply with a designation that has been demonized in the popular media or pursue costly alternatives such as USDA Organic or private non-GE certification.  Any business that intentionally avoids labeling must provide a sworn statements from their suppliers that their product is non-GE.  For smaller producers and retailers, this paper trail could present a cumbersome and expensive process to maintain.

4)  The State is required to enforce the law without additional resources.  The initiative does not stipulate or mandate additional funding sources for monitoring or enforcing compliance.  Given the current budgetary challenges faced by Washington State, it is unlikely new money will be allocated for labeling enforcement.  This will either entail poor enforcement of the law or a potential reduction of current Health and Safety services elsewhere in the State system.  Because any person may file a complaint and seek legal costs for alleged labeling violations (without evidence), a further burden will be placed on State courts and Health and Safety departments.  The law could lead to unnecessary legal actions at the expense of taxpayers and consumers.

5)  The labeling law requires the GE designation be conspicuously present on the front of the package or retailer’s display (for raw produce).  In doing so, the GE label would be removed and segregated from preexisting nutritional and health information.  Because GE products have been demonized in the popular media, this is likely to promote a negative perception to the consumer.  Forcing producers and retailers to prominently display such a label without justification will likely lead to a Constitutional First Amendment objection regarding compelled speech.

6)  The numerous arguments suggesting that Washington State’s organic production and international trade are threatened by GE production are unfounded.  Organic production has successfully coexisted alongside conventional and GE production for many years in the US.  Likewise, international trade in the presence of GE products has been successfully carried out for many years.  It is unlikely that the multi-million dollar agricultural export industry will require or depend on a state level labeling law that does not require product testing.  The commodity identities referenced in the initiative are already provided by national USDA Organic and private non-GE certifications.

NOTE: This analysis was provided on a voluntary basis and was not supported by any organizations, industry or otherwise.

The Washington Initiative Process

The State of Washington has two types of initiatives, “Initiatives to the People”, and “Initiatives to the Legislature”.  While the first type of initiative would go directly to a voter ballot, this initiative is of the second type.  That means, once the appropriate number of valid signatures is certified by the Secretary of the State of Washington (accomplished on 1/31/2013 ), the initiative will be submitted to the Legislature during their January 2013 session (currently slated for a 2/14/2013 hearing).  At that point, three things can happen (from:  participedia.net ):

• The Legislature can adopt the initiative as it has been proposed by the public and it then becomes law without a vote by the people.

• The Legislature can reject the proposed initiative or refuse to act on it and the initiative must be placed on the ballot for the state’s next general election.

• The Legislature can approve an amended version of the proposed initiative and, in this case, both the amended and the original versions of the bill will appear on the state’s next general election ballot.

It is not certain which path the State legislature will take, but it is most likely that option one, immediate acceptance, will not be taken.  The Washington legislature recently rejected two GE labeling attempts by members, see: Washington Bill 6298 & Washington Bill 2637 .  Of the remaining options, the second is the most probable as it is the common course for legislative initiatives.  The third option, however, would present an interesting circumstance where two similar versions appear on the same ballot and potentially lead to confusion in the voting booth.  It reasonable to assume that I-522 supporters would want to avoid this vote splitting possibility by preventing amendments to the initiative, although from a technical, scientific, and potentially legal standpoint, I believe it should be.

I-522 and Comments

Below the initiative is presented, section by section, with some comments and observations on these faults.  Each section is in blockquotes and my analysis is below. On the side, Frank N. Foode™ will help us out by pointing out whether each section was taken from Proposition 37 or not.  In this analysis, the terms genetically engineered (GE), genetically modified organism (GMO), and genetically modified (GM) are used interchangeably.  [Edit 3/7/2013: The term Genetic Engineering (GE) is used here and meant to be consistent with the definition provided in I-522, Section 2, Part 3a.  Previous references to Genetically Modified Organism (GMO) or Genetically Modified (GM) have been changed throughout to reflect this definition and nomenclature.  Exceptions are made in the cases of organization names, products, and quoted references.]

NEW SECTION. Sec. 1. The  people find that:

(1) Polls consistently show that the vast majority of the public, typically more than ninety percent, wants to know if their food was produced using genetic engineering. Without disclosure, consumers of genetically engineered food unknowingly may violate their own dietary and religious restrictions.

This section is intended to provide arguments in favor of the initiative and “inform the public”.  As will be seen, the statements here provide poor rationale for mandating labeling and often digress into promotional material for organic production methods or material meant to scare consumers and producers away from GE products.

This is true, polls have indicated a large percentage of survey respondents have a preference for labeling.  It is unlikely, however, that GE labeling in I-522 would prevent people from violating their dietary or religious restrictions.  Products that might fit these categories, such as vegetarian, vegan, gluten free, kosher, etc, are already labeled as such voluntarily for marketing reasons.  More to the point, a verified non-GE designation is already available to any food manufacturers who desire it (for example, The Non-GMO Project and Genetic ID ).  By definition, people concerned with these issues are already scrutinizing what they are consuming and the products containing GE ingredients are already well known.  Additionally, organic production in the US prohibits GE products. A consumer using the “USDA Organic” label designation can already avoid all GE products.  Furthermore, even if I-522 labeling was imposed, little information other than “genetically engineered” or “may be partially produced with genetic engineering” would be provided.  Genetic engineering is a process, not a thing.  Many attributes to food products or the systems that produce them can be addressed through genetic engineering.  The initiative, however, does not require the specific type of modification, or even the specific ingredient that has been modified, to be listed.  As written, the measure would tell the consumer no more about dietary or religious preferences than a label specifying “Organic” or “Natural”.   Hence, the vegetarian or vegan would not be informed whether an animal protein was incorporated in a product.  The Jewish customer would have no additional information telling them a porcine attribute was present.  I-522 does nothing to address dietary or religious restrictions.  It should also be noted that previous mandatory GE labeling efforts for religious reasons have failed to be upheld by the courts .  In addition, the Vatican and Islamic officials have both found no problems with GE products.

A short note on the effectiveness of labeling:  Studies examining existing labels for nutritional content have shown that they are consistently overlooked or ignored by consumers.  Although participants said they looked at nutritional labels, the same respondents failed to completely do so while purchasing products (University of Minnesota survey of consumers ).  GE labels are likely to suffer the same fate.  A study from Europe, where GE labeling is enforced, found consumers typically bought products labeled GE, even though they indicated that they would not [EDIT 3/18/2013: Additional survey information on GM label use: Do European Consumers Buy GM Foods? ].  The relationship between personal desire for labeling and the effectiveness of labeling is weak.

(2) Currently, there is no federal or state law that requires food producers to identify whether foods were produced using genetic engineering. At the same time, the United States Food and Drug Administration does not require safety studies of such foods. Unless these foods contain a known allergen, the United States food and drug administration does not require the developers of genetically engineered crops to consult with the agency. Consultations with the United States food and drug administration are entirely voluntary and the developers themselves may decide what information they may wish to provide.

This is true, no federal or state law for mandatory labeling of GE products exists at this time.  An effort to force the FDA to label GE products through federal law was signed by 1 million people, although the FDA decided against it (Just Label It ).  While this seems substantial, it should be recognized that this represents only an approximate 0.5% of all eligible voters  in the United States (2012) and is not an immediate mandate for labeling.  Additionally, mandatory GE labeling legislation introduced to the US Congress by Senators Bernie Sanders (I-VT) and Barbara Boxer (D-CA) failed to pass the US Senate in 2012.  [Edit 4/2/2013: The FDA actually supports voluntary labeling by industry and provides a guide for doing so.]

The implication of this I-522 statement regarding the FDA is that no testing of GE products is required and that the testing that is done is completely voluntary.  This is a misrepresentation of the truth.  While, the FDA itself is not mandated to assess GE safety, regulation of GE products in the United States is divided among various agencies and existing federal law:

The responsibility for regulatory oversight of these products is shared by three Federal agencies: the U.S. Department of Agriculture’ s Animal AND Plant Health Inspection Service(APHIS), the U.S. Environmental Protection Agency(EPA), AND the Department OF Health AND Human Services ‘ Food AND Drug Administration(FDA ).”   [Emphasis added].

Which agency is involved in the regulation process depends on the intended use of the product.  If food items are in question, the FDA has been involved.  During product evaluations, it is standard assessment protocol to test all intended food items for known allergens.  The FDA can and will request any and all information they deem necessary for assessment.  No GE product on the market has passed through less than two of the mentioned agencies .  This position statement by the author(s) of I-522 is disingenuous at best.  While many may view this process as inefficient and incomplete, mandatory labeling requested by I-522 will do nothing to improve the process nor will it induce the FDA to be involved in GE regulation.

It should also be noted here that the safety of crops developed through traditional breeding methods, is unregulated and completely voluntary, even though these have occasionally shown problems in the past, (see section (4) below).

(3) Mandatory identification of foods produced with genetic engineering can provide a critical method for tracking the potential health effects of consuming foods produced through genetic engineering.

It is hard to imagine how the labeling provided by I-522 could possibly help track a potential problem given that: 1) The required labeling has no specific information about the type of modification, nor the ingredient modified and 2) the extensive product exemptions to the required labeling (listed below) would severely confound any efforts to track a problem.  Because the proposed label is vague on which ingredient may be included, or even if a modified protein is present in the final processed product, it has no value for notification of allergic individuals at all.  If a known allergenic component were present, Federal law would already require it to be labeled separately.

Further, any product intended to be consumed in a restaurant, for example, would not require labeling.  By posing the supporting statement in this manner, the author is explicitly suggesting that GE products can and will have problems, despite the fact that no health problems have ever been found in the many years that people and animals around the world have consumed genetically modified food products. Simply put, the GE labeling information provided by I-522 cannot help track health problems.

(4) Consumers have the right to know whether the foods they purchase were produced with genetic engineering. The genetic engineering of plants and animals is an imprecise process and often causes unintended consequences. Mixing plant, animal, bacterial, and viral genes in combinations that cannot occur in nature produces results that are not always predictable or controllable, and can lead to adverse health or environmental consequences.

The “right to know” has been a debatable topic in GE labeling, dependent on perceived costs, benefits and risks.  The implication here, however, is that consumers have this right because the process of genetic modification is dangerous and uncontrollable.  All crop breeding techniques, including those used prior to GE, can lead to unintended results.  Relative to these traditional crop breeding techniques, however, GE methods are more precise and controlled.  Genetic engineering processes are very specific in the changes made, typically involving only one or two genes. [EDIT 3/19/2-13: Methods are now poised to become even more precise.]  Because specific genes are targeted, the functional changes are anticipated ahead of time. Traditional techniques, however, may use processes such as outcrossing of varieties or mutagenesis through irradiation and chemicals.  These methods induce simultaneous multiple changes in the genetic structure that are random in nature with unknown and unpredictable outcomes.  Traditional breeding programs on crop plants such as potato, celery and kiwi, for example, have resulted in unintended and harmful effects in the past.  [Edit 3/21/2013: New crops are regularly introduced to new markets with out testing and with unknown consequences.  See the cucamelon, for example].  Admittedly, GE methodologies, like all breeding methods, may occasionally produce undesirable traits, however, they are unlikely to reach the marketplace because they are heavily scrutinized and tested for adverse effects prior to release. [Edit 3/23/2013:  Kevin Folta has a nice comparison of plant improvement methods and their characteristics].

The mixing of plant, animal or viral/bacterial genes is actually quite common in nature.  The complete genome of a bacterium (Wolbachia), for example, has been found nested within the chromosomes of the common fruit fly, drosophila.  Viral components (endogenous retroviruses or ERVs) are commonly found in many vertebrates and can encompass a large proportion of their genetic code. Pea aphids have been shown to have acquired fungal genes  for coloration.  Snake genomic features have also been recently observed in cattle.  Such examples of horizontal transfer of genetic material across phylogenetic categories are numerous and considered by some to be an important mechanism in the natural process of evolution . There is no reason to expect or suspect that this process would necessarily create adverse health or environmental consequences more than any other type of genetic transfer processes .

(5) United States government scientists have stated that the artificial insertion of genetic material into plants, a technique unique to genetic engineering, can cause a variety of significant problems with plant foods. Such genetic engineering can increase the levels of known toxicants in foods and introduce new toxicants and health concerns.

Without a reference, it is unclear where this comes from.  The United States implements GE technology more than any other nation and private, academic and US government scientists broadly and openly support genetic engineering efforts.  Over the many years of GE use, globally and in the US, scientific investigation into potential toxicants or health concerns have all proved negative or been exposed in regulatory testing programs.  When problems have been identified, development of the products in question has ceased (see for example the example of Brazil nut genes introduced into soybean).  Scientists did recognize early on that the safety of this technology is important and should be monitored. Self imposed regulation and restrictions were set in place as early as 1988.  The implication of this statement that the GE process is uncontrolled and that scientists are generally unsupportive of GE is unfounded.

(6) Forty-nine countries, including Japan, South Korea, China, Australia, New Zealand, Thailand, Russia, the European Union member states, and other key United States trading partners, have laws mandating disclosure of genetically engineered foods on food labels. Many countries have restrictions or bans against foods produced with genetic engineering.

Many countries do implement GE labeling, although the number reported seems to vary from around 40 to as many as 61 (Proposition 37 reports 50 in a similar section).  Regardless of the number, the details of these labeling laws often differ from I-522.  In the European Union, for example, tolerance levels for unintended GE contents are set at 0.9% (EU GE Regulation ). While I-522 imposes this limit initially, it will eventually require a zero tolerance level after July 1st 2019, a practical impossibility.  Note that in I-522, this will apply even in cases of unintended GE use.  After this time, any errant producer or reseller, large or small, will be held accountable without a label.  Assuming that the detection abilities for genetic material will only increase with time, and that transfer of genetic material across phylogenetic constructs is quite liberal in nature, it virtually guaranteed that problematic genetic material will eventually be detectable in any product.  The zero tolerance aspect of this initiative creates a condition that is impossible for any producer, GE or not, to meet.

Several countries currently do restrict or ban GE products.  These restrictions, however, are not as complete as implied.  European Union members, for example, regularly approve and import GE products intended for animal feed.  Many of these countries also have both privately and publicly funded GE research programs (see, for example, the GE approval database).

Despite the intentions of this line of argument, the existence of laws outside of the State of Washington or the United States is a poor guide.  In most cases, other countries have imposed such laws based on widely criticized science, political pressure from groups opposed to GE technology, fear of corporate influence, or as a protection for their agricultural producers.

(7) No international agreements prohibit the mandatory identification of foods produced through genetic engineering.

This is currently true.  Regulations mandating labeling would impose no legal restrictions on export commodities.  Buyers, sellers and brokers for exported commodities, however, already contend with international laws regarding GE products.  Therefore, the existence of a labeling law, particularly one at the state level that does not require testing for genetically modified components, would have no impact on international trade.

(8) Numerous foreign markets with restrictions against foods produced through genetic engineering have restricted imports of United States crops due to concerns about genetic engineering. Some foreign markets are choosing to purchase agricultural products from countries other than the United States because genetically engineered crops are not identified in the United States, making it impossible for buyers to distinguish what does or does not meet their national labeling laws or restrictions, rendering United States’ products less desirable. Trade losses are estimated at billions of dollars. Mandatory identification of foods produced with genetic engineering can be a critical method for preserving the economic value of exports to markets with restrictions and prohibitions against genetic engineering.

As mentioned above, restrictions and bans have not prevented these countries from importing GE products.  GE animal feeds (primarily soybean) are openly sought by many countries, including the European Union.  For commodities intended for human consumption, it is unlikely that a State level regulation will influence international trade.  Buyers and exporters of such items are likely to certify the quality and contents of the products they handle themselves.  The ‘mandatory identification’ referred to above would be provided by the buyers and exporters testing the materials themselves for the security of their business transactions.  The billions of dollars in trade implied would not be casually gambled on a State mandated label that does not even require testing for GE content.  State level labeling is not now, and would not be in the future, critical to preserving economic value.  The initiative is intended for Washington State consumers, not international markets.  This statement goes beyond the intended scope of the initiative.

(9) Industry data shows foods identified as produced without genetic engineering, including conventional foods identified this way, are the fastest growing label claim. Consumers have a right to an informed choice at the point of sale.

This is an odd claim to make in an initiative pleading for mandatory labeling.  If true (no reference is given), and voluntary use of such labels is so popular, why should the State make them mandatory?  Why impose regulation where it is not needed?  This statement implies that any consumers ‘right to know’ is already being addressed by producers without the need for further regulation and that the ability to distinguish GE/non-GE products from one another already exists.

(10) Farmers from a wheat growing region of the state have gathered more than two thousand six hundred signatures on a petition demanding mandatory disclosure for crops produced with genetic engineering. The farmers are concerned they will lose their wheat export markets if genetically engineered wheat is approved.

This is clearly a play by the author(s) to gain voter traction in Central and Eastern Washington where there are large farming operations (Wheat, Potato, Onion, and Apples).  These regions of Washington State are historically  conservative and often heavily influenced by Libertarian and Tea Party politics that would not be expected to support an initiative that imposes expanded government regulation on growers, producers and retailers.  The case is not closed regarding labeling, however.  The agricultural sector in Washington is keenly aware of negative public perceptions.  Washington State apple growers, for example, suffered large financial losses in the 1970’s after a scare concerning a plant growth regulator, Alar.  Potato growers were also preemptively frightened away from GE potatoes after activist groups pressured fast food and processing companies into banning GE products.   This supporting statement seems designed to leverage the fears and sensitivities of Washington growers and marketers towards the initiative.  Support, however, would be damaging to growers in the long run.  Diseases such as late blight in potato and fire blight in apples are a continuing problem for which conventional control measures are few.  Genetic modification techniques, however, offer hope for both potato and apple.

The effects of mandatory State labeling on export markets is not clear.  As stated earlier, it is unlikely that buyers and exporters would rely on a State level labeling requirement for product quality assurance, especially when the measure does not mandate product testing.  Furthermore, clearly labeled non-GE, organic grains are already sold and promoted as such for sale within and outside of Washington State with no problems (see: Bluebird Grain Farms or Organic grains in Washington , for example).  Initiative I-522 will do nothing to enhance the market size or value for Washington State commodities.   Additionally, there are indications that some farmers elsewhere have no interest in mandatory labeling, despite the claims made in the initiative. [EDIT 3/2/2013: Contrary to the claim in the initiative, Washington Wheat Growers have now come out against labeling.]

(11) Agriculture is Washington’s number one employer and wheat is Washington’s number two export crop, second only to goods and services produced by the Boeing company, and ahead of Microsoft, which ranks third.

This is a continued attempt to portray the farming community as threatened without justification as to how a State level labeling law would influence multinational export trade.  See 10) above.  This is at odds with the experience of other farmers across the United States who have found that the use of GE products has helped strengthen and secure their economic positions.  There is no reason to imply otherwise other than to frighten voters into supporting the measure.

(12) Preserving the identity, quality, and reliability of Washington’s agricultural products is of prime importance to our state’s fiscal health.

Product identity is important, but the labeling initiative would not provide or enhance this.  Producers desiring the identity of “Non-GMO” already have services available to them through private agencies such as The Non-GMO Project or official certification using the USDA Organic designations.  Mandatory GE labeling is not required to accomplish this identity.  Since the initiative requires only GE products to carry a label, products lacking labels would have no identity with ‘GMO free’ outside the State of Washington.  Even with the initiative in place, producers of these products would still need to implement one of the above designations or similar in order to achieve the desired identity. I-522 does nothing to enhance product identity, quality or reliability.

(13) The cultivation of genetically engineered crops can cause serious impacts to the environment. For example, most genetically engineered crops are designed to withstand weed killing herbicides. As a result, genetically engineered crops have caused hundreds of millions of pounds of additional herbicides to be applied to the nation’s farmland. The massive increase in use of these herbicides has caused emergence of herbicide-resistant  weeds, which have infested farm fields and roadsides, complicating weed control for farmers and encouraging use of increasingly toxic and more dangerous herbicides. These toxic herbicides damage the vitality of the soil, contaminate drinking water supplies, and pose health risks to consumers and farmworkers. The public should have the choice to avoid purchasing foods produced in ways that can lead to such harm.

The idea the GE products are inexorably linked to herbicide tolerance is one of the most persistent claims of anti-GE supporters.  In truth, however, they are not.  Herbicide tolerant traits can and are introduced into crops using non-GE techniques.  BASF, for example, markets an entire line of crops including rice, wheat, canola, corn, sunflowers, and lentils that are tolerant of the herbicide Beyond® , developed using the process of mutagenesis, not GE (BASF Clearfield products).  They are marketed as non-GE products.  Even if GE products were completely banned, herbicide tolerant crops and the potential problems associated with them would still exist.  The trait is simply too valuable to farmers and producers to abandon. The vagueness of the proposed label would not enable a consumer to avoid GE herbicide resistance traits because they are not explicitly designated as such on the label.

Farmers and agricultural scientists have been aware of herbicide resistant weeds for many years, predating the existence of GE crops.  Their management and control has, therefore, been a topic of discussion for many years and effective strategies to minimize their impact have been subsequently developed.  Agricultural university extension offices and consultants, for example, routinely advise and make material available to growers on the use of best practice methods for controlling resistant pests.  Producers of GE seeds include legal clauses in their contracts with growers, mandating they use accepted management strategies for controlling resistant pests.  Even with these measures in place, researchers continue to evaluate and investigate new management techniques.  No pest control method is immune to development of resistance.  Weed control through tillage and rotation, for example, have encouraged resistance through crop mimicry and seed dormancy.  Diamondback moths exposed to the popular organic insect control, Bacillus thuringiensis (Bt) have shown resistance on at least one occasion.  Pest resistance is not a problem that is unique to GE crops and the means to effectively counter it are well known and used in practice. [EDIT 3/2/2013: An interesting case of weed resistance to hand weeding was recently brought to my attention as well.]

The concept of measuring herbicide (or pesticide) use through simple weights is a non-standard method for measuring product use that has unfortunately been popularized by C. Benbrook in his alarmist anti-GE publications.  For this reason, among many others, these publications have been shown to be inaccurate and misleading.  Because pesticides vary in molecular weight, formulation, efficacy, toxicity, and environmental impact, measuring their impact on a simple weight to weight basis has no meaning or relevance.  More appropriate measures such as the Environmental Impact Quotient (EIQ) are a much better choice.  These measures jointly account for important factors such as the levels of active ingredients (ai), their toxicity, and their environmental effects (EIQ ).  Using this type of metric, it can be shown that use of GE technology to replace an environmentally toxic herbicide like atrazine with a safer alternative, glyphosate, is beneficial (see for example: Brookes and Barfoot 2012).  Likewise, genetic modification of crops to express environmentally benign Bt toxins in order to replace multiple applications of toxic insecticides, provides a vast improvement in environmental and human health concerns. Accurate assessments of the potential environmental impacts of pesticide usage should be based on complete information and not simple “pounds used” comparisons.

This supportive I-522 statement is designed to identify GE technology as different from other agricultural practices and cast it as an environmentally dangerous alternative.  The truth is, however, that GE technology can, in fact, be a much more environmentally friendly choice.  The value of its benefits must be judged on a case by case basis and not summarily dumped into an ‘all are bad’ category.

(14) United States department of agriculture data shows Washington state ranks second in the nation for organic farm-gate sales at two hundred eighty-one million dollars per year. While total United States food sales are virtually stagnant, growing less than one percent overall, the organic food industry grew at 7.7 percent according to 2010 data. Sales of organic fruits and vegetables increased eleven and eight-tenths percent,  accounting for approximately twelve percent of all United States’ fruit and vegetable sales. Organic dairy, another key industry in Washington state, grew at nine percent and comprises nearly six percent of the total United States dairy market. Organic farmers are prohibited from using genetically engineered seeds or livestock feed.

(15) Trade industry data shows the organic industry is creating jobs at four times the national rate.

(16) Published data shows organic farming is more profitable and economically secure than conventional farming over the long term. This important element of Washington’s economy must be protected.

Section 1, Part (15) and Section (16) text not found in Proposition 37.

Section 1, Parts (14) through (16) are primarily promotional material for organic farming methods and have no direct relevance to I-522.  As stated in Section 1, Part (14), organic producers do not use GE products, hence they are labeled as non-GE by default and are not influenced by the direct labeling of GE products.  The implication and claim in Section 1, Part(16) is that GE somehow threatens organic producers.  There has been much talk about the possibility “GE contamination”, however, such claims are overstated as explained in this post and associated comments.  Farmers and producers routinely take precautions to prevent contamination in the crops that can cross pollinate.   In addition, some states have already implemented guidelines for controlling contamination where it might occur.  More to the point, it is not possible that a labeling initiative such as I-522 could or will address these issues.  These concerns must be, and are, dealt with through other means.  The profitability and security of organic versus conventional agricultural methods is far from established in any credible literature.  These qualities are highly dependent on the production system and markets for each particular commodity.  Whether organic is better or not, however, is irrelevant to the labeling question.  The fact that conventional systems , both with and without GE components, currently coexist with organic production systems without problems invalidates the protection claim of Section (16).  Organic production is not threatened by GE operations.

(17) Conventional farmers have a right to choose what crops they grow and many conventional farmers want to grow traditional crops developed without genetic engineering. Identifying seeds and seed stock produced with genetic engineering would protect farmers’ rights to know what they are purchasing and protect their right to choose what they grow.

This is straw man argument and simply a non issue.  Conventional farmers can already plant whatever they think is best for their situation and there is no reason to think they would not be able to in the future.  Many plant both GE and non-GE crops simultaneously (see for example: eatocracy.cnn.com [EDIT 3/2/2013: Lundberg Family Farms of California, a large supporter of Proposition 37 and founder of CaliforniaRightToKnow, farm 14,000 acres of organic and conventional crops together with no apparent problems]).  The vast majority of farmers plant seed or seed stock that is already certified by the USDA or state agencies to be what it says it is.  This ensures they get a uniform quality crop free of weed seeds and other pests.  Seed sold with certification is already clearly labeled and identified as GE or not.  In some areas, there is even a trend towards farmers moving back to non-GE crops because the enhanced GE traits previously employed have been so effective that they are no longer needed.

From: greenbook.net

                Jon Lundgren, Ph.D., entomologist with the USDA Agricultural Research Service in South Dakota, said, in general, there seems to be a “developing market for non-GM corn.”

                “Bt technology has been so effective for so long that we have eliminated the target pests in a lot of the growing regions. The European corn borer has been driven to such low populations that farmers are starting to wonder where did it go, and do I need to plant Bt corn every year. If the pest isn’t there, then the economic value isn’t there for Bt hybrids.”

The additional labeling of seeds and seed stocks by I-522 would be redundant to existing labeling and certification and would provide no additional information to producers.

(18) The purpose of this chapter is to ensure people are fully informed about whether the food they purchase and eat was produced through genetic engineering so they may choose for themselves whether to purchase and eat such food. Identifying foods produced through genetic engineering also will help protect our state’s export market.

The labeling proposed by I-522 is so general as to be useless for informing a consumer.  The labeling of products that qualify would contain no specific information on the type or nature of the modification, nor the ingredient(s) modified, nor the amounts present.  As shown below, the numerous product exemptions granted by the labeling initiative would completely confound consumers’ efforts to avoid GE products based on only the information provided by I-522.  Labeling information on non-GE product status is already voluntarily available to retailers and producers through the USDA Organic designation or GE testing organizations.

NEW SECTION. Sec. 2. The definitions in this section apply throughout this chapter unless the context clearly requires otherwise.

Section 2 provides definitions for terms and phrases used in the initiative below.  No comments are given here.  Refer to the Initiative text for more information.

NEW SECTION. Sec. 3. (1)

Beginning July 1, 2015, any food offered for retail sale in Washington is misbranded if it is, or may have been, entirely or partly produced with genetic engineering and that fact is not disclosed as follows:

(a) In the case of a raw agricultural commodity, on the package offered for retail sale, with the words “genetically engineered” stated clearly and conspicuously on the front of the package of such a commodity, or in the case of such a commodity that is not separately packaged or labeled, on a label appearing on the retail store shelf or bin where such a commodity is displayed for sale;

The fact that raw commodities would be required to display GE labeling on the front of the package is troubling.  Why the front of the package?  Nutritional and health related labels are commonly found together on the side or back of the packaging.  Consumers know, through experience, where to find this type of information, yet this section intentionally deviates from this and requires the label to be on front, separated from other similar information.  California Proposition 37 had a similar clause.  A legal analysis of that initiative stated:

“The government may compel purely factual disclosures to consumers for purposes of preventing consumer deception.  The disclosures required by Prop 37—simple statements indicating that the product is genetically engineered—are factual in nature.  But there is room for debate as to whether the disclosures serve the state’s interest in preventing consumer deception.” (from: foodlawfirm.com).

In other words, if the information is factual (it is) and non-disclosure is intentionally trying to deceive a consumer, the government can force a producer to say something.  But there is a large doubt as to whether producers are intentionally deceiving consumers.  GE products are commonly used in US food items and their use is not a secret.  As part of the First Amendment to the US Constitution, the government cannot compel one to make unwarranted speech.  Forcing producers to put a label on the front of a package, in distinct area separate from other labeling information when no intent to deceive is evident, would appear to be compelled speech.  The legal analysis above concludes with “I predict that if Prop 37 passes, the lawsuit challenging it will contain a First Amendment Element.”  In all likelihood, passage of I-522 will generate this First Amendment battle.  The state will then be obligated to defend a potentially unconstitutional law.

(b) In the case of any processed food, on the front of the package of such food produced by a manufacturer, with the words “partially produced with genetic engineering” or “may be partially produced with genetic  engineering” stated clearly and conspicuously; and

Again, as with raw food items, the labeling information for processed foods is specifically required to be placed on the front of the package, unlike any other food related nutritional or health information.  This seems like a clear attempt to blatantly distinguish GE items as markedly different than non-GE counterparts, contrary to the overwhelming scientific consensus and Federal legal status of GE foods. The required separate and prominent placement of a GE label can be seen as an attempt to scare consumers away from such products. There is evidential precedence for this possibility.  Consumers tend to overstate the importance of labels placed only on the front of a package and separated from nutritional and health information. Given the common negative perceptions of genetic engineering that have been established by anti-GE efforts, the placement language in I-522 would seem to go beyond the implied purpose of a consumers ‘Right to know’ and instead tend towards consumer rejection of the labeled products.  In implementing I-522, the state would be complacent in actively denigrating certain products over others without justifiable cause.  For these reasons, the compelled speech arguments above should apply here as well.

Because the law has the ability impose substantial legal and financial consequences on producers and retailers, the label of ‘may be partially produced with genetic engineering’ is likely to be applied to most products by default simply to preemptively avoid such threats even at the cost of customer appeal. Such wording would of little use to consumers, however, since it is not a guarantee that GE contents are or are not present.  The only means for a consumer to guarantee the GE status of a product would be for them to purchase those labeled as Certified Organic or non-GE; Labels that already exist.  I-522 would provide no additional services to those that are already in place.

(c) In the case of any seed or seed stock, on the seed or seed stock container, sales receipt or any other reference to identification, ownership, or possession, with the words “genetically engineered” or “produced with genetic engineering” stated clearly and conspicuously.

As outlined in section 1, Part (17) above, this is redundant with current practice and government certification of seeds and seed stocks.  Seed companies such as Monsanto, for example, clearly labels all their GE products as such because that quality is a strong selling point for their farming customers.  This section may be present only as an aide in helping support and enforce the required chain of documentation necessitated by later sections of the bill.

(2) Subsections (1) and (3) of this section do not require either the listing or identification of any ingredient or ingredients that were genetically engineered, nor that the term “genetically engineered” be placed immediately preceding any common name or primary product descriptor of a food.

This portion of the initiative continues the removal of any useful label information for the consumer.  The labeling will not provide any clue as to what ingredient(s) are modified.  Referring back to Section 1- Part (1), Section 1- Part(3), and Section 1- Part(13), arguments are made that labeling would help: consumers avoid religious and dietary conflicts, aid the state in tracking health problems, and identify crop products that are herbicide tolerant.  The lack of specific information regarding GE content, however, clearly makes these initial claims false.  The vague labeling provided by I-522 provides no useful information to consumers or state officials.

(3) Subsection (1) of this section does not apply to any of the following:

Like its California predecessor, I-522 provides a long list of exemptions, often targeted at politically and economically powerful agricultural and food sectors. Section 3, similar to Proposition 37 Section 3, 110809.2, begins this list.

(a) Food consisting entirely of, or derived entirely from, an animal that has not itself been genetically engineered, regardless of whether the animal has been fed or injected with any food produced with genetic engineering or any drug that has been produced through means of genetic engineering;

Here an exemption is conveniently given to the entire dairy, livestock, poultry (meat and eggs) as well as farmed seafood industries where the animals may be fed, injected or treated with GE products indiscriminately with no adverse consequences from the law.  It is notable, and probably no coincidence, that these industries comprise up to 30% of Washington State’s agricultural income  and constitute a powerful lobbying group in state politics.  The author(s) of I-522 clearly want to avoid conflicts with these groups.

(b) A raw agricultural commodity or food that has been grown, raised, produced, or derived without the knowing and intentional use of genetically engineered seed or food. To be included within the exclusion under this subsection, the person supplying a raw agricultural commodity or food must provide a sworn statement that the raw agricultural commodity or food: (i) Has not been knowingly or intentionally produced through genetic  engineering; and (ii) has been segregated from, and has not been knowingly or intentionally commingled with, foods that may have been genetically engineered at any time. In providing such a sworn statement, a person may rely on a sworn statement from his or her own supplier that contains such an affirmation;

Section 2, Part(3.b) outlines the immunity of producers who inadvertently violate the law.  The caveat is that producers must be able to provide sworn documentation that each and every ingredient used is GE free (see Section 3, Part(1.c) above, for example).  As with Proposition 37, this section will induce substantial book and record keeping for producers.  Such documentation must be available for all production periods, commodity lots, and years of production, as long as the products are on retailer shelves.  Large retailers and producers can probably incur the costs of maintaining this documentation with little trouble. Smaller businesses, particularly artisan and home based operations, however, would find these additional regulations cumbersome and expensive.  Consider, for example, a small retailer at a booth in the world famous Pike Street Market selling a relish, salsa, preserve or similar product.  Such people would have to keep track of every ingredient they used in their products, documenting the source and potential GE content of each.  Likely, they would have made the product multiple times, with different sources for their materials each time.  Yet, they will be required to have documentation available for each and every instance.  This is far too cumbersome for such small producers who will have little choice but to submit to the “potentially contains GE” labeling, whether it is true or not.  Even if they were to decide to source materials from more expensive organic or certified non-GE ingredients, they would still need to have proof available to demonstrate this.  Small producers are left in a no win situation, regardless of their stance on GE.  Failing to document is not an alternative, as substantial, potentially crippling fines and legal consequences can be levied against them at any time, by any willing party, as mandated in the sections to follow.

It is clear that I-522 will place burdensome and binding inhibitions on small businesses who desire to sell food products in Washington State.  This is in contrast to the numerous exemptions given to large agricultural and food interests removing any liability they may have for GE contents.  Again, the State would find itself complacent in promoting one sector of agricultural business over another for no justifiable reason.

(c) Any processed food that would be subject to this section solely because one or more processing aids or enzymes were produced or derived with genetic engineering;

Another broad exemption which excuses food industry products such as cheese, yoghurt and bakery products that may use enzymatic components in production.  These enzymes are often manufactured through GE technologies.  Up to 80% to 90% of cheeses made in the US and Britain, for example, are made using a GE based rennet product.  These exemptions provide another chance to avoid conflict with economically important and powerful sectors of the agricultural community, many of which often portray themselves as natural and organic producers.

(d) Any alcoholic beverage that is subject to regulation under Title 66 RCW;

Washington State is regarded as number two in production of premium wines giving a 3 billion dollar boost to the state economy in 2006.  Since regulatory changes in 2008, distilleries are also becoming a large business in Washington State.  It is no surprise then that an exemption is also granted to such operations.  These producers may use GE products at will in their products without bothering with the labeling requirements specified in I-522.

(e) Until July 1, 2019, any processed food that would be subject to this section solely because it includes one or more materials produced by genetic engineering, provided that the engineered materials in the aggregate do not account for more than nine-tenths of one percent of the total weight of the processed food;

This clause introduces a time limit (exactly the same as Proposition 37) to the tolerance of 0.9% GE in affected products.  After this time, the implication is that no GE will be permitted, although obtaining such a zero tolerance level is practically impossible.  This will make application of the law difficult at best after the stated deadline.  This appears to be an underlying attempt to an eventual outright ban on GE products.  [Edit 4/5/2013: Lowering limits have been shown to greatly increase costs and make compliance all but impossible.  Even some organic farmers are concerned about this issue.]

(f) Food that an independent organization has determined has not been knowingly and intentionally produced from or commingled with genetically engineered seed or genetically engineered food, provided that such a determination has been made pursuant to a sampling and testing procedure approved for this purpose in rules adopted by the department. These rules may not approve a sampling and testing procedure unless it is consistent with sampling and testing principles recommended by internationally recognized standards organizations, such as the international standards association and the grain and feed trade association. No testing procedure may be approved by the department unless: (i) It does not rely on testing processed foods in which no deoxyribonucleic acid is detectable; and (ii) it is consistent with the most recent “Guidelines on Performance Criteria and Validation of Methods for Detection, Identification and Quantification of Specific DNA Sequences and Specific Proteins in Foods” (CAC/GL 74, 2010) published by the codex alimentarius commission;

This provision allows for private testing entities to give producers a non-GE certified status.  These agents, such as the Non-GMO Project typically provide the certification on a pay-to-play basis.  Again, the producer will be expected to fund any costs of certification and be required to keep track of the associated documentation to avoid coverage and legal consequences of I-522.  Labeling laws provide an attractive business opportunity for these groups.  Not surprisingly, such organizations were vigorous supporters of Proposition 37 and can be expected to offer strong support of I-522.

(g) Food that has been lawfully certified to be labeled, marketed, and offered for sale as “organic” pursuant to the federal organic foods production act of 1990 and the regulations promulgated pursuant thereto by the United States department of agriculture;

This section exempts certified organic producers who are prohibited by Federal law from using GE anyway.

(h) Food that is not packaged for retail sale and that either: (i) Is a processed food prepared and intended for immediate human consumption; or (ii) is served, sold, or otherwise provided in any restaurant or other food  service establishment that is engaged primarily in the sale of food prepared and intended for immediate human consumption; or

Probably the most substantial exemption in I-522, Section 2, Part(3.h) provides a free I-522 pass to all restaurants.  Americans are estimated to eat out an average of 5 times a week and spend as much as $142 billion on fast food alone.  By providing an exemption to the restaurant industry, I-522 proponents avoid a massive conflict with this prominent and economically powerful sector of the food economy.  Consumers who dine out, however, will find no use in the I-522 labeling initiative as chefs, cooks and restaurateurs will be able to use any and all of the GE ingredients they desire, without informing their patrons.  This makes the “Right to know” argument pointless for most citizens.  Proposition 37 saw a long list of celebrity chefs sign on as supporters, and with good reason; Their businesses would have been free of any obligation to comply with the labeling law.  It would be expected that Washington State, with its well known and revered chefs and restaurants, will also attract a list of food centric celebrities who support I-522.  They too, will be immune to its consequences, should it pass.

(i) Medical food.

The last of the exemptions list.   It is somewhat perversely amusing that an initiative that was earlier so concerned with dietary restrictions, allergens, adverse health effects, and unintended health consequences, should so casually and succinctly give an exemption that allows those under medical care to be fed GE products without informing them.  Apparently, eating GE products is ok if one is sick and under medical supervision.  They evidently do not qualify for the “Right to know’.

NEW SECTION. Sec. 4. The department may adopt rules necessary to implement this chapter, provided that the department is not authorized to create any exemptions beyond those provided in section 3(3) of this act.

The State may use any regulatory measures required to enforce I-522, but it cannot adjust or modify the exemptions it covers.  Once made law and surviving any legal challenges, changes to the regulations would be difficult.  Voters may offer a veto referendum (an initiative to repeal a law), but not immediately: From ballotpedia.org– “In Washington, no initiated statute may be amended or repealed for two years without a 2/3 supermajority vote of both chambers. Any initiated law, so amended, is not subject to veto referendum. After two years, the law may be repealed or amended by a simple majority vote.

NEW SECTION. Sec. 5. (1)

The department, acting through the attorney general, may bring an action in a court of competent jurisdiction to enjoin any person violating this chapter.

(2) The department may assess a civil penalty against any person violating this chapter in an amount not to exceed one thousand dollars per day. Each day of violation is considered a separate violation.

( 3) An action to enjoin a violation of this chapter may be brought in any court of competent jurisdiction by any person in the public interest if the action is commenced more than sixty days after the person has given notice of the alleged violation to the department, the attorney general, and to the alleged violator.

(4) The court may award to prevailing plaintiff reasonable costs and attorneys’ fees incurred in investigating and prosecuting an action to enforce this chapter.

Section 5 describes the legal claws of the measure.  In Parts (1) and (2), the state is authorized to bring a legal suit against a producer or retailer and seek financial penalties at the rate of $1000 per day.  Each day is considered a separate violation, requiring the defendant to account for all days that the plaintiff claims are in violation.  Recall from Section 2, Part(3.b) that this means the defendant will be required to produce the documented sworn statements for all the days in question.  Failure to show such documentation for even one day could still amount to a substantial fine.  This is another example where I-522 will place a heavy burden on small producers and retailers.

Parts (3) and (4) are similar to the clauses in Proposition 37 (Section 4, 111910, Parts (a) and (b)) that received extensive debate and attention.  These Parts of I-522 allow anyone to initiate court proceedings against a defendant, if the defendant fails to produce documentation or submit to labeling requirements within 60 days of notification to the state.  Once undertaken, the court can determine that the plaintiff’s legal and investigative costs be taken from the defendant.  In California, this was seen as an opening for frivolous lawsuits by anyone having the gumption to legally attack another.  This seems to be a possibility in Washington as well.  By extending the action of this law to the general citizenry, the initiative author(s) have potentially opened a legal doorway for unnecessary and costly legal actions.

Perhaps a more troubling aspect of Section 5 is that it represents a complete antithesis to the conceptual basis of US law where a defendant is assumed innocent until proved guilty.  In the case of I-522, the plaintiff merely needs to make the complaint.  No evidence is required.  The burden of proof is placed squarely on the defendant, even during the 60 day grace period.  They will either submit to the implied guilt of a “may contain GE” label or be forced to defend themselves in a costly legal battle. For this reason, and the potentially costly financial and legal consequences imposed by the bill, it is likely that most producers will preemptively opt to label all their products with the “may contain GE” designation.  In doing so, they would remove their own liability while simultaneously destroying what little utility the label might have provided in guiding consumer purchases.  Retailers and producers would be left to comply with a useless regulation while consumers would gain nothing except the burden of paying for enforcement and the underlying product costs.

NEW SECTION. Sec. 6. Sections 1 through 5 of this act constitute a new chapter in Title 70 RCW.

If passed into law, I-522 would become part of Washington’s Public Health and Safety regulations (Title 70 RCW).  The initiative provides no funding mechanism for the required monitoring or enforcement actions. [EDIT 3/2/2013: A similar GE labeling bill in Colorado which failed to pass, HB13-1192, was estimated to have cost $480,000 and require 5-6 full time employees to implement.]

NEW SECTION. Sec. 7. If any provision of this act or its application to any person or circumstance is held invalid, the remainder of the act or the application of the provision to other persons or circumstances is not affected.

Provision is given that the entire law cannot be struck down if one part of it is found to be invalid.   This is a standard clause in initiatives to ensure that a single faceted legal challenge will not defeat the entire law.

NOTE: This analysis was provided on a voluntary basis and was not supported by any organizations, industry or otherwise.

 

I have worked in and around experimental and production agriculture for more than 35 years. I am currently a statistician in the College of Agricultural and Life Sciences at the University of Idaho, Moscow, Idaho. I can be found on Twitter at: @pdiff1


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121 comments to Analysis of Washington State GMO Labeling Initiative I-522

  • What a helpful guide–and Frank’s sidelines are extra-handy!

    It was particularly interesting to me to hear about the process. I thought that when it was done with the signatures that was it and it went straight to the ballot. But the legislative vote and possible amendments were news to me.

    Great job!

  • This initiative (and many local attempts in western Canada)is the latest round to try to generate fear in the general public about GM food. The latest poll I saw had 1% of people concerned about GM content. The real goal of labeling is to generate fear as it has in other countries.

    The Federal Government (has jurisdiction in both Canada and the US) is well aware of this fact so if it passes the next step will be federal intervention.

    • Pdiff

      Robert,
      You may well be right. Personally, I don’t agree with labeling, but do see it as likely. I-522 is just a poor implementation. If they are going to do this, then cut the loop holes and make it about truly providing information (right to know) and not propaganda. If this passes, it will be hard to fix at the state level.

  • Jeri Weinhold

    Yes, the initiative has flaws, but the intent is not to generate fear. Pro gmo people feel there is no proof that GMO’s cause health issues so GMO’s must be ok. The problem is there is no way to identify whether they do or they don’t. No testing of their impact has not been tracked because no one knows what they are eating. So if you develop a problem, it cannot be identified with GMO products. If the people who developed GMO’s had allowed independent study or even produced live tests over time, there would not be such a resistance.

    But over and above the health issues, the impact to animals, insects, soil, and plants are arguments that also need to be addressed. Ask any veternarian whether they see more still births or reproductive problems in the animals they treat. When will we start to realize we are heading for a mono-culture of seeds and food? Diversity will disappear.

    No the labeling initiative is not the best. But it does make more people aware that we have not been told that our food has changed without any testing requirement or the public being informed. That is why I choose to support the initiative, not because I want to generate fear.

    • If you are making the argument that such labels will allow possible health consequences to be tracked, it doesn’t hold much water. To get that kind of information, you would have to track the individual traits themselves, not the general category of being a “GMO.” These “may contain” labels do not give you that kind of detail and would not accomplish what you are suggesting.

    • Well I keep hearing about all these countries that label–they must have the evidence, right? Can you give me any evidence from these places about the health issues? And by evidence I mean peer-reviewed, not just stuff from a web page somewhere.

    • Yes, the initiative has flaws, but the intent is not to generate fear.

      I guess the fear issue will be debatable, however to me, an initiative that is rife with references to implied adverse health and environmental effects, in addition to a label that explicitly singles out a trait from all others beyond the normal expectations of such labeling, is indeed designed to promote fear, not a “right to know”.

      The problem is there is no way to identify whether they do or they don’t. No testing of their impact has not been tracked because no one knows what they are eating. So if you develop a problem, it cannot be identified with GMO products. If the people who developed GMO’s had allowed independent study or even produced live tests over time, there would not be such a resistance.

      A bigger problem is that I-522 will do nothing to actually identify or track GM products, but will instead, instill the perception that one can do so. If you are truly concerned about ID’ing GM, then this should bother you. Which is worse: No Information or Incorrect information? In statistics, the later is known as a false positive or type I error and is considered the least acceptable condition. If GM were actually bad for people, then the food they ate at a restaurant, for example, could be GM, but not labeled. You would have a system that tells them it is safe when it was not. Why is this acceptable?

      As for the claims on “developers”, independence, and tests over time, I suggest you carefully look over the Genera list of 600+ articles linked to above. This type of comment is exactly why the reference was put in.

      But over and above the health issues, the impact to animals, insects, soil, and plants are arguments that also need to be addressed. Ask any veternarian whether they see more still births or reproductive problems in the animals they treat.

      We have seen impacts to plant animals, and insects. In fact, the impacts have been positive for insect diversity in cases like Bt. Negative impacts to plants and animals have not been evident. Certainly, application of less toxic herbicides and insecticides would be helpful for these. Actually, out of curiosity, I did ask a veterinarian about an increase in still births, to which their response was literally “Huh?”. This from one who does veterinary research and is familiar with the literature and active areas of research. As MaryM above has mentioned here before, why are these problems not observed in research animals, which are numerous, highly monitored, and fed GM feeds consistently as standard protocol? Simply put, this “problem” either does not exist or has miraculously gone undocumented in several fields of research and animal rearing.

      No the labeling initiative is not the best. But it does make more people aware that we have not been told that our food has changed without any testing requirement or the public being informed. That is why I choose to support the initiative, not because I want to generate fear.

      The testing issue is tiring. GM products are the most tested, investigated and examined agricultural products in human history (unlike conventionally bred products). Their use is not a secret and is quite obvious to those who bother to look for it.

      So you admit the initiative is poor, yet are willing to submit to it. While it may make people aware, it will only do so for a short while and will, IMO, lead to eventual complacency, which you don’t seem to want. Why not stand up for something better? Something does does not exempt the majority of the food system? One that does not skew the state into supporting one section of the economy over another without justification?
      I believe that you personally do not want to generate fear, but why should you support something that will?

      • Peter Whealn

        Bill Price says “I guess the fear issue will be debatable, however to me, an initiative that is rife with references to implied adverse health and environmental effects, in addition to a label that explicitly singles out a trait from all others beyond the normal expectations of such labeling, is indeed designed to promote fear, not a “right to know”.”

        Come on Bill Price, get real. In truth it’s the lack of certainty that has existed since the introduction of GMOs into the nation’s food supply that has perpetuated public fear of genetically engineered food. And this public fear might been abated early on by GMO producers if they had provided consumers with conclusive proof addressing health risks.
        The existing public fear of GMOs should in no way increase when I-522 is enacted. Rather it is likely provide new hope for a more democratic food distribution system.
        We shall see.

        • Yes, we shall see. You may be correct that negative impacts will be minimal. The intent, however, is clear. Labels must be placed on package fronts, separated from other nutritional and health information. Exactly what do you think a customer will think when they see a prominent label on the front that says “May Contain Genetically Modified Ingredients” or similar? If you are going to label, put it where it belongs, with all other labeling information.

          I also agree that industry could have handled the topic better, but to put it frankly, they really didn’t see a need at the time. It was just another breeding technique that had been vetted by the USDA. Perhaps they should have clued in earlier that this was not the perception. Full blame, however, does not just lie there. The scientific illiteracy and knee jerk reaction of the general public and media are also at fault. We should know better by now than to trust every off-the-cuff idea from a Wakefield, Oz or Mercola. It has cost us in safety, lives and environmental integrity. I don’t see this label as providing your “hope”. I do see some light from recent revelations in the media and respected environmentalists that dare to question the propaganda and show some level of rationality when looking at these issues. My hope is we can move past this irrational, unsupported fear. We have bigger problems to face.

  • Lee Biscayart

    Please read the following conclusion statements taken from an article in Science, 8 JUNE 2001 VOL 292 SCIENCE http://www.sciencemag.org. p.1906

    After careful reexamination of the human proteome, we find only 46 genes in the Celera protein set, and 41 in the Ensembl set, that comprise candidates for possible lateral transfer between bacteria and human (19). The evidence presented here provides several plausible biological explanations for the presence of these genes in the hu- man genome. The argument for lateral gene transfer (3) is essentially a statistical one, necessarily so because of the inherent im- possibility of observing events that may have occurred in the distant past. As with all statistical arguments, great care needs to be exercised to confirm assumptions and explore alternative hypotheses. In cases where equally if not more plausible mech- anisms exist, extraordinary events such as horizontal gene transfer do not provide the best explanation. The more probable expla- nation for the existence of genes shared by
    humans and prokaryotes, but missing in nonvertebrates, is a combination of evolu- tionary rate variation, the small sample of nonvertebrate genomes, and gene loss in the nonvertebrate lineages.

    Please note the use of words such as “possible” and argument for lateral gene transfer is essentially a statistical one”, etc. In scientific debate it is very important to be factual and to be clear that many interpretations are just that…not proven fact. To say that genetic engineering, which is often incorrectly referred to as “GMO”, is the same process as lateral gene transfer, is inaccurate. Look at the time parameters involved in lateral gene transfer, look at the nature of the genetic material that is transferred as a unit versus the single gene insertion of genetic engineering and you are not talking about the same thing. If you, as a scientist, are going to fault concerned non-scientists for taking a stand against consuming food with GE products in them, then please do so in a truly scientific manner!

    • I don’t mean to be facetious, but a gross sense, horizontal gene transfer is “scarier” than genetic engineering. On the one hand, we have genes going back and forth between kingdoms, there’s no safety tests, and we don’t even know what they do! On the other hand, we have one, well characterized gene, with safety tests. That’s not to say that HGT is dangerous or that every product of genetic engineering is safe, but it’s difficult to paint either with a broad brush – it’s important to take things as a case by case basis because neither the natural nor the human intervention versions of gene transfer are inherently bad. Some people like to say that genetic engineering is unnatural *because* gene transfer across species doesn’t happen in nature – but it totally does happen in nature! That’s not to say they are the same thing, of course they are not, but the “unnaturalness” argument is silly. Humans do way more unnatural stuff than this ;)

      • NickB

        Is it not the case the gene transfer in nature takes place within bounds, which GM biotech transcends? How in nature could a gene transfer from a gorilla to krill, for example? I’m not saying it’s impossible but is it not vanishingly unlikely? Are you saying there are no GM biotech gene transfers that could not realistically happen in nature?

  • Augusto

    Keep it simple. If a product has any GMO content then put in the label.
    My choice, as a consumer, is to buy only products that are organic and non-GMO. Clear labeling would allow people like me to exercise this choice.

    • By default, processed foods may contain ingredients derived from crops that contain a genetically engineered trait. How does “may be partially produced with genetic engineering” change the default state?

      Consider this – I am a vegetarian. By default I assume processed and prepared foods have animal products hiding in there unless I can find evidence otherwise – such as a voluntary “vegetarian” label or if I call the company to ask what is in their “natural and artificial flavoring”. A “may contain animal products” doesn’t help me at all, so I am not lobbying for such a label. Instead, I vote with my dollars and choose companies that don’t use animal products and that label their products clearly that they are vegetarian. I really don’t understand the concept of fighting to add a label that doesn’t even help me at all.

      • Augusto

        Voluntary labels are not enough (i.e., horse meat found in products labeled as beef). One could find eggs or milk products in something voluntarily labeled “vegetarian”. Nothing is simple when somebody want to sell you what you do not want and has a license to do it. A list of ingredients is needed in this case.

        • If there’s eggs or milk in a product that doesn’t have that on the label, there’s a recall. The ingredients label is the appropriate place for that information, and it is based on law.

          This reminds me of how Burt’s Bees ingredients used to be labeled. They’d have the ingredient then the source in parenthesis. It was neat to see what plant was used, or if it was from milk or honey. I’d be very much in favor of an expansion of that type of labeling, including an indication of genetic engineering. Some people have suggested an r in front of the ingredient to indicate it is recombinant, such as r-corn, although that doesn’t quite work because r currently means that the particular protein, etc was recombinant itself such as rBST. The whole corn plant isn’t recombinant, just one gene is, and for most ingredients such as corn oil or corn syrup the protein isn’t present anyway. But at least then you’d know which ingredients were sourced from genetically engineered crops, which is far more useful than “may contain” on the whole box. Of course, source labeling could be very difficult for those ingredients that have many potential sources, but at least it’s a step in the right direction, in my humble opinion.

          All of this is very different from an unuseful “may contain” on the front of the package.

        • Voluntary labels are not enough (i.e., horse meat found in products labeled as beef).

          The horse meat example is not a case of voluntary labels not working – it is an example of fraud behind required labels. Products are required by law to list their ingredients. If horse meat is included, but the package is labeled with only beef, then the law has been violated.

        • Here’s what I can’t figure out – here’s your list:

          Corn, canola, soybean, sugar in US/Canada, US sourced papaya

          If it has any of these ingredients, or byproducts of these ingredients in Canada/US then it has GMO. If someone really thinks it is important, it’s on the ingredients. Most things already list this information (may contain soy, or canola oil). If someone is worried about highly processed corn ingredients being included then those are most likely found in highly processed food – stay away from that.

          Finally, as Mary has pointed out elsewhere, why refined white sugar would ever be on that list because it was made from a sugarbeet absolutely boggles my mind. It is chemically sugar. Tell me how white sugar from a Roundup Ready sugar beet is any different from white sugar from another source and therefore requires a label. Is a GM label on white sugar for the public good or is it a label for personal preference.

          • Some might object to the sugar issue based on anti-corporate or similar grounds, not chemical/biological grounds. That said, your last point is relevant. The courts have previously ruled that curiosity is not a sufficient reason to compel speech through a label. Litigation over a labeling law may well come down to a determination of whether this is a case of curiosity.

      • M.

        If the label is not useful to you personally, then don’t bother reading it. But to say that nobody else can have a label explaining clearly whether GMO’s are in the product is not cool.

        • Trust me, I won’t bother and neither should you. I522 will not provide a label that clearly explains anything. In fact it will make things less clear. In order to cover their arses, the large food producers will simply label everything they make with the “may contain” designation, whether they actually do or not. Meanwhile, small producers will be left with dismal choices: The hassle of Organic certification, the stigma of a negative GMO label, or the unwanted bureaucracy of documenting every ingredient they utilize. And the customer like you … left with the same situation you have now with the addition of higher costs for products and state enforcement actions. That truly, is not cool.

    • My choice, as a consumer, is to buy only products that are organic and non-GMO. Clear labeling would allow people like me to exercise this choice.

      Augusto,
      In the US, Organic and non-GMO are synonymous. How is the additional label going to help you? Organic is actually a better choice for you than this initiative would be because none of the exemptions, such as restaurants, are allowed.

      • Peter Whelan

        Bill Price says

        “Augusto,
        In the US, Organic and non-GMO are synonymous. How is the additional label going to help you? Organic is actually a better choice for you than this initiative would be because none of the exemptions, such as restaurants, are allowed.”

        Bill Price, what are you talking about? Organic and non-GMO are not synonymous, in the US, or anywhere else. Non-gmo does not mean organic. Come on man. You need to get with the facts.
        Are you confused by exemptions old boy? Just know that this initiative isn’t about choosing organic over mandatory labeling, it’s really about giving consumers a keener sense of certainty that the fundamental liberties on which our nation was founded are not restricted by food suppliers.

        • Yes, Peter, in the US, Organic is synonymous with non-GMO by USDA definitions. I wish they weren’t, but they are. I don’t know why you would think otherwise.

          I object to exemptions that have no purpose. Why would restaurants from a lowly McDonalds to the latest high end Thomas Douglas gourmet experience not have to comply with the initiative, while someone selling salsa at the farmers market would? If GMO’s present health issues, and supposedly doctors and nurses object to them, why are “medical” foods exempted? Why, after we’ve been told repeatedly how GM components can pass through the gut to cause tissue damage, are animals and their products exempted when they’ve been fed GM feed? These are just blatant attempts to avoid confrontation with powerful ag industries. There is no other logical reason for them.

          As for organic, if you read the initiative, you’ll find it repeatedly and openly promotes organic over GM. If this initiative is just about choice, why would they need to mention organic 9 separate times in a bill supposedly about GMO? Clearly from the language of the bill, they want to point “choice” in one direction only. Don’t lecture on liberties here. Your food selection and choices will be restricted by “food suppliers” no matter what production system they use. That, BTW, includes yourself and whatever you choose/can grow on your own.

      • Joe, I am not sure who you were referencing in this comment. This may not be related, but your comment and that of Lee Biscayart have made me realize my laziness in the mish mash of terms I used above. To correct this, I have changed all references of GMO and GM to GE with linkage to the definition given in the initiative, Section 2, Part 3a. Basically, this is the in vitro nucleic acid changes most think of, but excludes things such as mutagenesis processes.

  • Bill,

    My question was actually dierected at Augusto, but I guess that it applies equally to everybody else.

    I just kind of what to see what commenters sympathetic to the Anti-GM movement actually know about genetic engineering.

  • Someone tweeted this item this morning, and I thought it was useful:

    https://twitter.com/_BartCoenen/status/312882239979540480

    I think it’s the first piece I can remember that someone pointed out that there’s no difference between beet sugar and cane sugar in the end product:

    Some sugar sold in the United States is made from genetically modified beets. Some is from unmodified cane. I-522 would mandate a different label for each — but there is no difference in the sugar.

    nitiative 522 begins to look like an organic-food industry effort to impose a label on its competitors.

    Mmm hmm.

  • theoldtechnite

    There’s a lot of talk about GM crop pollen wafting over and mixing with organic crops and, thereby, invalidating those crops for orgainc certification. My question is, why aren’t GMO’s allowed in Organic’s and who was it that said they can’t be? I know the U.S. federal government came out with such a standard themselves but the Feds didn’t create what should and should not be organic on their own.

    • I am no historian here, but I believe the mandate came from a congressional act (1990) and organic representatives were part of the process. Organic producers had come together in some states like CA to determine their own standards and these were the basis of the first national ones. I seem to recall that GE was initially included in those initial national organic standards, but was removed after the public comment period on the act. For what it’s worth, there still seems to be a lot of dissension over the details of what is organic within the organic community (see for example the clashes over antibiotic use in O. apples).

      Perhaps someone with more knowledge can give better details here than I.

      [EDIT] Adam Merberg pointed out this site which has some interesting information on the history of Organic Standards regarding GMOs:
      http://filebox.vt.edu/cals/cses/chagedor/USDAorganic.html

  • theoldtechnite

    Thanks Bill. It just seems to me that this first excluding GMO’s from what is organic and then crying contamination is a self inflicted situation.

  • theoldtechnite

    In the case of refined products such as sucrose and corn syrup, MaryM, i imagine there can’t be any test that could actually verify if such-n-such bag of fructose-glucose powder is from GMO’s or not, since they would be chemically identical.

  • theoldtechnite

    “When the USDA released its draft for an NOP in December 1997, the organic industry was unpleasantly surprised to find that the draft includes possible use of GMOs in organic production and processing, despite the NOSBs recommendation of prohibition. NOSB based its decision that GMOs are inappropriate for organic agriculture on the principle consideration that organic agriculture functions by using natural ecosystems rather than exogenous technologies.” – from http://filebox.vt.edu/cals/cses/chagedor/USDAorganic.html

    I think that this succinctly proves the organic movement’s objection to GMO’s is really based on anti-technology sentiments.

    • They are caught trying to walk the fine line (where many people don’t even see a line to begin with). The “using natural ecosystems” ignores other technologies that are allowed such as mutagenisis via chemical or radiation or chemical enhancement. One wonders how it is possible to produce “organic” triticale, for example.

  • Leonard Dixon

    Hi Bill –
    What’s your Price? I will pay you double what Monsanto is paying you. :-)

    If GE food is so good for you… JUST LABEL IT.
    It’s easy, and no extra expense required if a little note is added to the existing Nutrition Facts label.

    • Leonard, that’s a very generous offer, and it might surprise you to learn that double nothing is still nothing. Shill accusations are tiresome, and detract from meaningful dialog. It also shows that you believe that money rules people’s opinions, which leads to the inevitable questions of who pays you for your opinions, and the downward spiral goes from there. Please read our comment policy before commenting further, and cease this lame line of argument. I’ll delete any further discussion of this accusation from either side, unless Bill really feels the need to respond himself.

      If you want to talk about labeling costs, that is something that we have discussed in many places on the blog, try searching around to see if there is something you want to add to it. I’ve never heard a convincing argument for it being cost-free, because you have to do some sort of tracking and testing (and segregation) to know if you are labeling things accurately.

    • Richard R

      “If GE food is so good for you… JUST LABEL IT.”

      How about this – if GE food is no better or worse for you than non-GE food, then why does it need a label?

      GE seed is labeled for farmers. They need a label to know what qualities the seed has and what it will do.

      GE food is no different than non-GE food, so why does it need a label? I don’t understand why people who think it needs labeling just don’t learn more about what products are GE and avoid them (like vegetarians who have to learn what items contain products derived from animals).

      I buy only canola oil for cooking. I am fully aware that the canola oil will be sourced from GE canola – there is no segregation of GE and non-GE commodities in North America. I work at Monsanto and therefore I would only like to have my canola oil from Roundup Ready canola. Unfortunately, about half the canola grown in Canada is Liberty Link and made by Bayer. Should we start segregating liberty link canola from roundup ready canola so I can know which canola oil I get? Who should pay for the paperwork required and additional facilities required to separate the two? No one should when it doesn’t have any relevance. That is why GE labeling is not needed – it’s not relevant to anything other than personal preference.

      Disclaimer – I work for Monsanto, but my opinions are my own.

  • So refreshing to see the intelligent presentation by people who aren’t motivated purely by blind, uninformed hatred of Monsanto.
    I-522 is an obvious effort from the Organic industry with a blatant goal to try and force all other food to be labeled “NOT Organic-Which is totally better!” Bring on the official NO on I-522 campaign. Can’t wait to get my T-shirt.

    • real

      I don’t see sinister motives on behalf of the organic industry in supporting labels for GE food. Without labels, I have swithched over to buying almost entirely organic food in order to avoid GE foods. I plan to stop buying salmon altogether if GE salmon is approved. So you could argue that organic farmers are better off without labels. Labels that indicate which non-organic products in the store are non-GMO would allow me to buy them instead of organic. I attribute the organic industry’s interest in this topic is due to it trying to safeguard its crops from contamination and a concern for the environment.

      • Perhaps if they actually got labelling it would backfire horribly on them.

        They are, however, pretty safe in the US in suspecting that it is all for naught, and therefore an awesome marketing opportunity.

        Hey, if there is a debate about this there must be something up… I’d better buy organic just to be safe!

      • Real,
        You are correct that alternatives in Organic exist, as does a non-GMO label that is not coincident with organic labeling. You could already be using that to buy non organic non GE. If this or other similar measures are passed and survive legal challenges, manufactures will likely respond with ubiquitous labeling on everything they produce, leaving you in the same boat you are in now. A position, by your admission, where you can already discern GE and non-GE.

        The concept of “contamination” as threatening in terms of organic certification is a red herring. Incidental contamination will not get your certification pulled (nor get you sued). Contamination from a ideological standpoint is, to say the least, very disturbing and traces its roots back to much darker concepts of purity (Google “organic Steiner” for a starter). Organic, as a label, is a multi billion dollar industry in the US. They obviously see this as a business opportunity, which is why they are heavily involved in writing and supporting the bills and promotional material regarding organic production typically constitutes a large proportion of the supporting “evidence” in the Bill’s preambles.

  • NickB

    If the GM advocates have nothing to hide then let’s have mandatory animal feeding trials, instead of the ridiculous “substantive equivalence” as the test that has to be passed prior to bringing a GM product to market. Then labelling won’t be a hot issue.
    And Mike – the organic food industry (to which I have no connection) I am sure would not object to legislation that would force them to label their products organic.

    • The “nothing to hide” argument always irks me. Do you feel the same about unwarranted police searches or the government searching through your email and computer files? You are assuming guilt where there is no evidence or suspicion to suggest it. By forcing the mandatory testing issue, you are implying there is something to find in that narrow aspect of assessment. Current US regulations for all food modifications, additives, etc require generally that evidence be given showing the product to be safe. That evidence may take any form, be it formal testing, historical use, or any other line of argument the applicant deems convincing. In the case of GE, the most obvious, thorough course to pursue is testing, which occurs on many levels. This is what is done. Acceptability of evidence on the part of the regulating agency is carried out on a case by case basis, with requests for as much evidence as they want. Mandatory animal testing would accomplish little more than what is already done and probably force it where it was unnecessary raising questions of ethical treatment of animals and regulatory burden. What’s more, animal and invitro models are often incomplete predictors of human outcomes, hence, a wider scope of information is utilized to discern safety, such as substantive equivalence. If it looks like a duck and quacks like a duck, then why are you assuming it’s a viper?

      IMO, the Organic industry would vehemently oppose mandatory labeling if they were continually and unjustly portrayed in the media and culture as poison, corruption, environmentally unsound, unnatural, and evil. Would they like being called “poopenfood” pushed by the money grubbing Rodevil Institute? I doubt it.

      • NickB

        Bill
        The analogy you are making is clearly misleading. Where does the burden of proof lie in the case of the introduction of new technology? There are always risks associated with new technologies, and these will impact if realised on large numbers of people. In general the burden of proof therefore lies with the technologist that they are reasonably safe. This seems to be generally accepted and is the reason that there are compulsory tests conducted on new drugs before they can be taken to market. It goes by the name of the precautionary principle. Why then do we not have compulsory feeding trials in the case of GM? Why instead has an unscientific criterion of “substantial equivalence” been adopted?
        In the case of the legal system it is important to protect the individual from potential abuses of government power. There is generally no issue of systemic risk in an individual case comparable to the introduction of a new technology.
        Nick

        • Just to be clear, substantial equivalence is never assumed. It has to be proven through extensive testing of various types.

        • Hi NickB,

          Analogy aside, my point remains. The argument you use, “nothing to hide” is generally considered a logical fallacy of the ‘loaded question’ type and presumes that by not disclosing I must be hiding.

          The Precautionary Principle is a broad topic that covers a lot of ground. This is mainly due to the fact that it exists in multiple definitions, each with numerous interpretations. I consider it one of those “looks good on paper” concepts that is difficult to impossible to implement consistently in practice. Taken strictly, it allows no progress because nothing can ever be completely proven safe. This is why all uses of the PP involve some form of a decision set (method) and their corresponding thresholds. I suspect your objections boil down to what decision set and threshold are sufficient. Clearly, the USDA implements a version of the PP, requiring applicants to show evidence of safety (by various methods) until they are satisfied (their threshold is met). The burden of proof does, in fact, lie with the “technologist” (applicant). There is no hiding involved.

          You call for compulsory feeding trials. Given that animal feeding trials are already standard protocol in the approval process for food items, I’m assuming you are suggesting human feeding trials on substances you consider dangerous. I consider that very disturbing. Non-the-less, for the sake of argument, I’ll continue in that direction. A feeding trial regime would basically just be another set of decision rules. Such trials would require controls, which logically would be analogous non-GM versions of the crop/food. Comparisons would be made between the two. You don’t specify, or even generally acknowledge, what the threshold would be there. How many trials are enough? What level of outcome will satisfy you? Eventually these would all come down to statistical tests of significance and conclusions that substantial equivalence either has or has not been met. It solves nothing in the sense that a similar end point is achieved: Substantial Equivalence. Objections would not be addressed as objectors could easily move the goal posts and continue to claim that the tests weren’t enough.

          I also find it intriguing that you want compulsory feeding trials and simultaneously state your distrust of government and corporations. Who’s doing your trials, the government or the company? Who are you going to trust there?

          There is also the issue of why just GM and what kind of GM? GM could simply be the silencing of a gene (which could easily happen in nature) or a cis-genic modification within a species. Are you going to class all these together with transgenic GM? What about induced mutagenisis? Do we need compulsory feeding trials on all those too? Should we start feeding trials on triticale, for example?

          Your additional equating of GM to that of a drug is also completely unfounded, provocative, and misleading. What rationale do you use to make this leap?

          • NickB

            Hi Bill,
            I read here (National Council for Biotechnology Education) that feeding trials are not compulsory for foodstuffs with GMO ingredients:

            Novel food products are not subject to special regulatory approval in the USA if the constituents of the food are the same or substantially similar to substances currently found in other foods (such as proteins, fats, oils and carbohydrates). For example, if a gene from a banana was transferred to a tomato, approval would not ordinarily be required before that food was placed on the market.
            http://www.ncbe.reading.ac.uk/ncbe/gmfood/usregulations.html

            You seem to imply that they are compulsory. Care to clarify? If they are “standard” but not compulsory, why not make them compulsory.

            You say that the comparison to drug testing is unfounded, but not why it is unfounded. Without in-vivo testing we can’t be certain (enough) that there are not adverse consequences. In both cases there are powerful commercial interests at play. I’m not advocating trials on humans of foodstuffs that are suspected of being potentially dangerous – people who favour a laxed regulatory environment around GMOs are advocating a large experiment on the human population.

            There is no inconsistency between distrust of government and corporations and advocacy of regulation. I mean, who would argue the opposite – that because government and corporations are untrustworthy they should be free to do what they like? That is absurd.
            Nick

      • NickB

        Also Bill, the same fact (new technology status of GM) points to a relevant difference to the case of organic. Food produced without pesticides and with conventional cross breeding has been around for centuries, which is presumably why there could never be a media campaign unjustly slurring it in the manner you suggest. There have probably been innovations in organic techniques (I see that organic producers often argue a distinction between organic and traditional) but this hasn’t to my knowledge changed the biology of the crops in anything like the way GM does.
        So your “if they were continually and unjustly portrayed in the media and culture as poison, corruption, environmentally unsound, unnatural, and evil.” is moot, it seems to me. [sentence removed for crassness]
        N

        • Unnecessary crassness is unnecessary. Please refrain from using such language in the future – it does not add to the discussion and diminishes the friendly environment that we are looking to foster. Thank you for your understanding.

        • the bug guy

          Organic produce is not pesticide free. Organic production allows for the use of many crop protection chemicals from insecticides like pyrethrum to copper fungicides.

        • For the record, I have no idea what comment was redacted and had no participation in doing so. Regardless …

          I don’t see why the “newness” of GM has anything to do with your statement that Organic would be happy to have a mandated label as such. My point was only that no one wants to be labeled as something negative. GM has been wrongly and persistently identified as such and that forcing a product to carry a negative connotation to the benefit of a competitor would be wrong.

  • Richard R

    So I was reading the ingredients of my breakfast cereal today and I absolutely do not understand why we need to label for GM ingredients. Here is the information contained on the website about the ingredients:

    Ingredients:
    Whole grain oats, sugar, corn syrup, oat bran, rice, contains 2% or less of honey, modified corn starch, soy grits, molasses, soluble wheat fiber, natural flavor, corn flour, acacia gum, salt, soy protein isolate, oat fiber, evaporated cane juice, malt flavoring, BHT for freshness.
    Vitamins and Minerals: Niacinamide, reduced iron, vitamin B6 (pyridoxine hydrochloride), vitamin B1 (thiamin hydrochloride), vitamin B2 (riboflavin), vitamin A palmitate, folic acid, vitamin D, vitamin B12.

    Allergen Information:
    CONTAINS SOY AND WHEAT INGREDIENTS.

    Dietary Exchange Per Serving:
    2 1/2 carbohydrates, 1/2 fat

    Kosher Status:
    Kosher/Parve

    Now – on the box, I don’t think there was anything about Kosher. I’ll also note that the Canadian box had some slightly different “Contains” information (included Oats I believe and not necessarily listed as “Allergen Information”).

    So – please tell my why does this box of cereal need a contains GM label? It says right on the box “corn syrup” “modified corn starch” and “soy grits.” None of these items are sourced from “organic” ingredients. I know there is a high percentage of corn and soy that are derived from GM ingredients and I know there is no segregation of these items in the food supply. Therefore, I know this box of cereal contains GM ingredients. Why label it?

    Again, every bag of certified seed sold to a farmer contains a label if it is genetically modified. GM products are labeled where it is relevant. If you “care” about knowing whether or not your food is sourced from GM, learn what crops are GM and read the ingredients.

    Disclaimer: I work for Monsanto, but the opinions I post are my own and not necessarily that of my employer. I eat foods with GM ingredients and so do my kids.

    • NickB

      Why label it GM? Here are some reasons.
      Firstly as a consumer I should have the right to make up my mind whether to eat these controversial GM foods or not, just as I should have the right to decide whether to eat products with added sugar or not, whether to eat wheat or barley etc. etc.
      It cannot be assumed that “everyone knows” that if a product is not labelled organic then it may contain GM products. How do you know that “everyone knows” that? A whole lot of people don’t follow these issues or may from time to time not have this in mind.
      Secondly the burden of effort should be on the introducers of new technology to win the consumer over, not on the consumer to inform themselves sufficiently to avoid the products in question. They are not doing this if they slip the products into the food chain under the radar.
      N

      • Charles M. Rader

        NickB, do we have the right to ask you for some consistency about how new technologies are treated?

        Other techniques of developing new breeds of plants are clearly capable of making much more dramatic genetic modifications, for example chemical treatments that induce polyploidy, and the resulting plants are often recognizably and dramatically different from the original non-modified plant.

        Do you think that polyploidy should be labeled?

        Imagine a simple propaganda campaign such as “Human beings who have a single extra chromosome are afflicted with Down’s Syndrome, a terrible genetic disease. Plants bred using chemicals to induce multiple chromosomes are very different from the natural plant in unpredictable ways. No food safety testing is required for these new plants. Do you think that such foods be labeled so that you can decide for yourself whether to eat them?”

        NickB, in what way is this imaginary controversy different from the GMO issue, other than that the propaganda campaign about GMOs is real?

      • Richard R

        ‘It cannot be assumed that “everyone knows”’…I don’t assume everyone knows. My point is that if you “care” to know, it really isn’t that hard to figure it out – read the ingredients and understand a little bit about what crops are genetically modified. “A whole lot of people don’t follow these issues” – this is not a reason to require labeling.

        ‘Secondly the burden of effort should be on the introducers of new technology to win the consumer over.’ Done. The company I work for sells corn, canola, soy and cotton seed with GM traits. We clearly label our products to the consumer – the farmers who buy our product. They know what GM traits are in the product we sell them. In many cases we have won the consumer over (i.e. the farmer who buys our seed). However, we also have competitors who sell their products. In some cases they have won the customer over with their products (including their GM traits). Overwhelmingly the consumers of ours and our competitors’ products (i.e. the farmers) have been won over.

        No one has slipped anything under the radar into foods. All the products have undergone testing prior to release.

        http://www.science.org.au/policy/gene-tech.html

        http://www.ama-assn.org/resources/doc/csaph/a12-csaph2-bioengineeredfoods.pdf

        http://www.who.int/foodsafety/publications/biotech/20questions/en/index.html

        http://www.efsa.europa.eu/en/faqs/faqgmo.htm

        (Source for the above links – as well as a lot of other great info – found at http://ajstein.tumblr.com/post/40504136918/bringing-light-in-the-discussion-about-gmos )

        Disclaimer: I work for Monsanto, but the opinions I post are my own and not necessarily that of my employer. I eat foods with GM ingredients and so do my kids.

      • Ewan R

        Firstly as a consumer I should have the right to make up my mind whether to eat these controversial GM foods or not

        As already stated ad nauseum, if you want to make the decision you are fully aware of how to make it. Buy organic, buy certified non-GMO, buy products not manufactured using corn, soy, canola and other genetically modified ingredients.
        I don’t buy your “I have the right legally mandate what labels are on food” at all, I didn’t buy it previously, but since going vegan I buy it even less – animal products sneak in all over the damn place, yet there are no labeling requirements beyond what is required for regular ingredients – so unless one knows ones subject area it is quite easy to be misled. The vegan movement is pretty much as full of kookery as the anti-GM movement (particularly in regards to the deleterious effects to health of practically any and all animal products) – and so your arguement should stand there “I believe this is, or could be, catastrophic to my health (in the face of all evidence) and therefore demand a label” but it clearly falls flat on its face in both areas.

        A whole lot of people don’t follow these issues or may from time to time not have this in mind.

        This is, I feel, an arguement against, rather than for labelling. Labels stating that “This product contains, or may contain X Y and Z” are generally indicative that something has been shown to be problematic with the ingredient (Phenylalanine for instance, in cases of PKU, or various common allergens) – this is of course a good thing (it protects those who are informed and at risk from serious discomfort or death) but comes with a price (one which is worthwhile given the real benefits) – people latch on to the supposed badness of the ingredient as a true evil (see gluten, for instance, as a maligned substance) and will avoid products with that particular label despite there being no reason to do so.

        Now in the case of GMO you have no tangible benefit (I’d argue that if there was a tangible benefit to labeling in order to protect people this discussion would not be occuring as the product would never have reached the market) with a quite clear downside for producers – an uninformed populace suddenly faced with a new label will (or perhaps may, will is possible a tadly bit strong in such a hypothetical), in droves, avoid said label out of misplaced fear – you’re essentially asking for legislation which will ensure an unfair market for the products for no particular reason other than you don’t particularly like it for *reasons*.

        Secondly the burden of effort should be on the introducers of new technology to win the consumer over, not on the consumer to inform themselves sufficiently to avoid the products in question

        There is a $$100M+ burden of effort to clear regulatory. This convinces government agencies that the end product is safe for consumption. The people have been convinced. Arguements that government bodies etc are in the hands of big business need to explain the $100M pricetag (if I had government regulatory agencies eating out of my hand my regulatory department would be named Steve and would only work 3 days a week, rather than occupying whole wings of my corporate headquarters).

        It would almost seem from your arguments that you’re unaware of the regulatory hurdles which a commercialized GM crop has to pass. One must demonstrate substantial equivalence with the same commodity in the market. One must demonstrate ones performance in feeding trials (both in terms of safety (generally rat studies etc) and in terms of performance (Cattle & Chicken). Given the global nature of agricultural commodity trading one must secure regulatory approval not only in the US, but in every major commodity market – for the Japanese at present this requires not only demonstrating safety of your product (beyond, as far as I am aware, the requirements of any other agency) but also demonstrating, within the borders of Japan (I guess so they can check on you) the Mode of action of the product you’re trying to get deregulated. Apparently though this isn’t burden enough, after all this effort you’re still perfectly fine crippling the whole endeavor with pointless labels serving no purpose other than to do precisely that. I don’t like the technology so any legislation which will cripple it is fine by me.

        • NickB

          My what an extensive set of replies. Actually consumers are not fully aware of how to avoid GM. Your point, I take it, is that if a food is labelled organic then it is with high confidence not GM. But food that is not labelled organic may or may not have GM inputs amongst its ingredients. So if you want to avoid GM then at the moment you have a pretty restricted and expensive diet, right? Maybe in the US it’s not really feasible at all, in which case the consumer has little real choice about the matter.
          When I was a vegan I always did look on the packet for labelling of animal ingredients. I would be supportive of compulsory labelling for that too to aid vegans exercise their freedom of choice, it’s surely not a huge ask for the manufacturer? People want to know what’s in their food, just as they want to know what’s in their drugs.
          GM enthusiasts constantly refrain that GMOs have been proven safe in the food chain, but it seems to me that relatively few animal feeding trials have been conducted, and there are results from those that have been conducted that are cause for potential concern. I recently ran a citation search on studies that referenced the Ewen and Pusztai potato study which appeared in the Lancet in 2002, and there seem to be several now that find effects of GM.
          If the scientific method were really being followed here there would have been several studies trying to replicate those results and showing up the claimed flaws, given the enormous investments that are riding on them. But where is that body of attempted replications / refutations using feeding trials?
          Nick

          • Ewan R

            it seems to me that relatively few animal feeding trials have been conducted

            Which would be utterly at odds with reality. The scientific literature is full of animal feeding trials. That you cite Ewen and Pusztai is essentially laughable – their study has been widely acknowledged as useless. Why hasn’t it been repeated? Because it is useless. Does it need to be repeated? No, because the literature is chock full of feeding studies which find no ill effects. If the Ewen/Pusztai findings were sound then the literature would be awash with papers backing up their findings. As we have it about the only papers published showing negative effects of GMOs come from Seralini, who is perhaps one step up from Bozo the clown in terms of scientific credibility (which is a shame because Bozo did some great work characterizing Mitochondrial transit peptides)

            http://www.annualreviews.org/doi/pdf/10.1146/annurev.arplant.58.032806.103840

            Gives a rather nice rebuttal of Ewen Pusztai, as well as the absurd idea that there are relatively few animal feeding studies available couple of the link outs to reviews follow, although there are far more references available within, including reviews on the equivalence of GM vs nonGM food, rebuttals of E&P paper (one of which is included in the same issue of the Lancet as the paper was published in (and it should also be noted that the Ewen Pusztai paper was published sans peer review in the Lancet in order that the data be available for scrutiny)):-

            Nutritional and safety assessments of foods and feeds nutritionally improved through biotechnology: An executive summary. Compr. Rev. Food Sci. Food Saf. 3:25–104

            Studies on feeds from genetically modified plants (GMP)—Contributions to nutritional and safety assessment; Anim. Feed Sci. Technol. 133:2–30 (This covers 18 studies conducted at one research facility)

            This paper also covers many of the fallacious nonsenses you see around the whole debate, the same fallacious nonsense that you seem to buy into hook line and sinker.

            • NickB

              Dear Charles,
              There is a distinct lack of logic in your post, actually, and an apparent lack of understanding of my comment.
              My point is that there are peer reviewed studies showing differences between animals fed GM and those fed non-GM diets, some of them apparently showing effects that are clearly adverse. Secondly that the compulsory testing that is done for purposes of public safety does not consist of such feeding trials.
              Richard R pointed me to the results of a Googlescholar search – hardly scientific and I don’t see why I should waste my time there separating the wheat from the chaff.
              Finally, I did not “choose a study”. The Ewen / Puztai study was only used by me as a search strategy to identify other studies. I do think it is very odd that no-one has sought to replicate this trial, which would settle any questions about the results reported.
              You ask why I am concerned about GM in particular. The reason is that it can do things that conventional breeding can’t do. That’s the point. It can take a gene from wherever and insert it wherever, with effects that cannot be fully predicted in advance. Plants are also being developed using this technology which are toxic to pests. It therefore seems appropriate that there should be rigorous toxicological testing, and the gold standard, though not perfect is compulsory animal feeding trials as a first step.
              If you don’t like the search strategy of a citation search of the Ewen / Putzai study and prefer gray literature searches have a look here:
              https://d3n8a8pro7vhmx.cloudfront.net/prop37/pages/67/attachments/original/1348032282/Peer_reviewed_studies_on_GM_food_health_risks.pdf?1348032282
              There is a list compiled there of 33 studies, most of them peer reviewed, documenting evidence, much of it from feeding trials, that GM foods pose health risks.
              There is only one thing that matters for the little debate we are having here: is there peer reviewed evidence of health hazards from GM crops or not? I have shown that there is, you are making remarks that if I may say so are beside the point and not helping to clarify matters.

            • NickB

              Hi Ewan,
              I am not relying, as you seem to imply, on the correctness of the Ewen / Putzai paper. For the purposes of argument I am agnostic. Science is supposed to proceed by replication however. And no-one has, apparently, sought to replicate that study, though other feeding trials which I have referred to (those papers that cite Putzai) have found effects which appear to be cause for concern.

              There are various possibilities.
              1. Scientists don’t go there for fear of losing their jobs, because so much as been invested already in developing GM biotech expertise and industry.
              2. That there are some scientists who are biased against GM and who have been trying desperately to replicate Ewen / Putzai’s study and have failed to do so. Those scientists are unethically witholding their null results.
              3. That there are scientists who are biased in favour of GM and who have replicated the Ewen / Putzai study and found that the results hold. These scientists are unethically witholding their positive results.

              Of these possibilities 1 seems most plausible to me, followed by 3 and then 2. 2 seems implausible to me because it is very expensive to conduct a credible trial, and it will be difficult to attract funds from mainstream sources for doing this, given the controversy. Concerning 3 there are precedents for this from the “tobacco wars.”

              Nick

              • There is, however, no reason to replicate the Ewen/Putzai paper.
                It was possibly (if done right, which it wasn’t) relevant then. It isn’t relevant now – why? Because we have multiple examples of GMOs and a literature replete with non-replication of Ewen/Putzai like results. There are oddball results out there in the literature to be sure (your summarization link above (which is horrifically biased and innacurate even in its own claims (it claims for instance that pea alpha-amylase inhibitor is insecticidal))) but these go either unreplicated, or replicated only by the group who produced them (the list is eerily full of Putzai and Seralini references for instance) and which go against all the other evidence (Mary M normally weighs in asking why, if GM ingredients (which one of the papers openly state makes up a goodly portion of rat chow) cause adverse effects haven’t the producers of lab rats noticed this? They breed thousands (if not hundreds of thousands) of animals and keep records to ensure their strains are doing what their strains are meant to do – but yet, crossing the GM rubicon, they’ve not noticed a difference?

                Your trifurcation of possibilities ignores some.

                4. The Ewen Putzai ‘result’ was boring, it was a bad experiment, more experiments which were well designed were done and found nothing. (as a for instance)

                It amuses me that you rail on Richard R pointing you to a google scholar search (I can’t find that pointer, I do see that he points you to numerous actual peer reviewed studies however) because you don’t want to spend time separating wheat from chaff but then you make two pretty egregious errors.

                1. You return a report which is essentially chaff, and report it as if it were wheat.

                2. Your own search started from a massively biased point. Articles which cite Ewen/Putzai are, I would imagine, a rather bad subset of articles – Ewen/Putzai paper wasn’t peer reviewed, and was a sack of crap, it is unsurprising that using it as a start point you wind up finding similar and missing the bulk of the literature which indicates GMOs are safe. Crank magnetism in science publishing (someone in network analysis should see how the web of citations between nonsensical studies operates – Nick’s above link after all contains multiple Putzai references and everyone’s favorite whack-a-loon Seralini)

                • NickB

                  Ewan,
                  There is no bias in starting with the E-P study as a search strategy. Many of the references pulled take a critical stance towards that study. All I was doing was trying to identify some animal feeding studies with comparable goals. Are you saying that any study that references the E-P study can be dismissed out of hand?
                  What counts as a “crank” paper for you, one that does not return the result that GMOs are safe?
                  The link I pasted contains a list of peer-reviewed articles. I’m not relying on the report, just using it to source a list of references. You are saying, I imagine without reading any of them, that they are all crap. I wonder on what you are basing this judgement? That they are listed in a certain source document? This strikes me as an irrelevant criterion. Appearance in peer reviewed journals is supposed to be the thing that counts, at least provisionally, as the quality control.
                  N

                • NickB

                  Also if you read the Lancet issue, it is not the whole truth that the E-P paper was not peer reviewed. The editors gave it out to 6 reviewers 4 of whom advised for publication with revisions and 2 of whom advised against. It is true to say that this was not the normal peer review process.

                • NickB

                  Allow me to correct a comment of yours Ewen:
                  >Nick’s above link after all contains multiple Putzai references and everyone’s favorite whack-a-loon Seralini)

                  Pusztai references: 3
                  Seralini references: 0
                  total references: 33

                  attention to detail is important in science, right?
                  As for the supposed majority of studies that find no effects:
                  i) how many of these are animal feeding trials
                  ii) what is the power analysis of the statistical design (easy to produce null results)
                  iii) null results are not evidence of no effects.

                  • NickB

                    OK I take that back – slightly- my apologies. The count is:
                    Pusztai references: 3
                    Seralini references: 3
                    total references: 33
                    So 27/33 of that particular list are not involving either of your two Bogeymen.
                    N

                    • Yes, attention to detail is important. So we have

                      3 Pusztai references. Which we can throw out.
                      3 Seralini references. Which we can throw out.

                      2 is a communique and as such isn’t peer reviewed.
                      4 is mischaracterized by your paper – alpha amylase inhibitor isn’t insecticidal. The paper does raise an interesting point regarding post translational modification of proteins. One might think industry would check this… oh wait. They do. So we can discard this as showing any harm of commercially available transgenics.

                      5,6,7 & 8 – Maletesta papers looking at fine cellular structure – not 100% sure on these, so lets leave them in for now, the work would certainly warrant doing 90 day safety studies. It is striking that this is 4 papers looking anti-GMO from a single source.

                      9 appears to find nothing but some statistical noise (enzymatic activity apparently up in a couple tissues in a multiparameter study isn’t necessarily indicative of anything at all)

                      10 actually concludes that organic and GM soy have the same effects on rats as each other when compared to a control group fed a casein based diet.

                      11 & 12 are Seralini, so can be discarded.

                      13 finds no relevant differences, there are a few thigns up but again, given the size of the study it’d be surprising if there weren’t (statistics, y’know? Plus effects of small groups (the couple figures I glanced at were of 5 rats / group)

                      14 – Seralini

                      I shall return to this when I have time to, thus far however I am ~50% of the way through the list and the majority are not indicative of anything to be concerned about. We should however apparently be wailing and gnashing our teeth over statistical noise.

                      Which, if one thinks about it, is exactly what the authors of the list of references would want you to do.

                    • Ewan R

                      Quick driveby to address a couple more (no longer in sequence)

                      23. Doesn’t appear at any point to say what the linked paper says it does, is supportive of no ill effects from GMOs.

                      31. Debunked as measuring nothing but noise.

                      25. I seem to recall having read this, and it wasn’t indicative of any risks at all.

                      Your comprehensive list of studies showing ill effects or the possibility thereof is looking incredibly weak.

            • NickB

              And here is another example of the kind of evidence you say does not exist:

              Fine Structural Changes in the Ileum of Mice Fed on d Endotoxin-Treated Potatoes
              and Transgenic Potatoes – Natural Toxins 6, 219-233, 1998.

              Nagui H. Fares and Adel K. El-Sayed

              The present work has been designed to study the effect of feeding on transgenic potatoes, which carry the CryI gene of Bacillus thuringiensis var. kurstaki strain HD1, on the light and electron microscopic structure of the mice ileum, in comparison with feeding on potatoes treated with the endotoxin’ isolated from the same bacterial strain. The microscopic architecture of the enterocytes of the ileum of both groups of mice revealed certain common features such as the appearance of mitochondria with signs of degeneration and disrupted short microvilli at the luminal surface. However, in the group of mice fed on the endotoxin’, several villi appeared with an abnormally large number of enterocytes (151.8 in control group versus 197 and 155.8 in endotoxin and transgenic-treated groups, respectively). Fifty percent of these cells were hypertrophied and multinucleated. The mean area of enterocyte was
              significantly increased (105.3mm2 in control group versus 165.4mm2 and 116.5mm2
              in endotoxin and transgenic-treated groups, respectively). Several forms of secondary lysosomes or auotophagic vacuoles were recognized in these cells. These changes were confirmed with the scanning electron microscope which revealed a remarkable increase in the topographic contour of enterocytes (23mm in control group
              versus 44mm and 28mm in endotoxin and transgenic-treated groups, respectively) at the divulged surface of the villi. The basal lamina along the base of the enterocytes was damaged at several foci. Several disrupted microvilli appeared in association with variable-shaped cytoplasmic fragments. Some of these fragments contained endoplasmic reticulum, as well as ring-shaped annulate lamellae. In addition, the
              Paneth cells were highly activated and contained a large number of secretory granules. These changes may suggest that -endotoxin-treated potatoes resulted in the development of hyperplastic cells in the miceileum. Although mild changes are reported in the structural configuration of the ileum of mice fed on transgenic potatoes, nevertheless, thorough tests of these new types of genetically engineered crops must be made to avoid the risks before marketing.

              In other words, in this paper “mild” effects were found, but not zero effects. enough to warrant a precautionary approach, which is not being taken. Sorry if this impacts on profits. When I say that not many feeding trials have been done, I mean relative to the volume of products being developed and marketed. It is not compulsory to do feeding trials.

              If pro-GM people here are so sure there are no dangers, how about you all volunteer for a year or two of a GM only diet? Then you can be assessed against a control group for stomach lesions, allergies and so on?

              • “If pro-GM people here are so sure there are no dangers, how about you all volunteer for a year or two of a GM only diet? Then you can be assessed against a control group for stomach lesions, allergies and so on?”

                Been on a GM diet since 96/97ish with increasing frequency of GM ingredients. The original post in this thread indicates that I am eating GM as I listed the ingredients and identified which ones were GM. We only use canola oil for cooking – GM. I have been buying a lot of “out-of-season” sweet corn on the cob from the grocery store – probably some of it is GM given the absence of insect damage. If it is not Monsanto’s GM sweet corn then Syngenta’s (and who knows how long I’ve been eating Syngenta’s GM sweet corn).

                Now, going on a “GM only” diet is impossible as I would be limited in diet to corn, soy, papaya, canola oil and sugar beets. How would I achieve a balanced diet? That would be like eating nothing but McDonald’s for 1 month – of course I would feel awful. Maybe instead we could feed a high percentage diet to rats for 90 days to determine if there are any effects….

                Your original statement was that “relatively few animal feeding trials, and there are results from those that have been conducted that are cause for potential concern.” You supported that statement with Pustzai’s article from Lancet and how no one has replicated it to prove it wasn’t correct. I responded with a study that summarized 24 long-term studies, including multi-generation studies. Others have responded demonstrating there are serious issues with the Pustzai article. You continue to question why it has never been replicated citing 3 possible alternatives, 2 of which are “conspiratorial” involving suppression of information by “industry” or unscrupulous anti-GM scientists. You leave out perhaps the simplest anwer – No one chooses to waste time replicating a study that had obvious flaws. Alternatively, it may also be possible that no one kept around the experimental potato that had the GM trait. Or there was no good control non-GM potato available. It could possibly be that all the criticism was correct and no one wants to spend the time or energy trying to replicate this experiment.

                You originally stated that “relatively few” safety studies were done. Of those “relatively few” there are those that show concern. You have now moved the goal post stating that there are some studies show ill effects. You seem focused on the fact I did a google search (you must have hated that movie “The World According to Monsanto”). However, all I did was point out how easy it was to find a study with 24 long term feeding trials if you choose to look.

                • I’d just like to point out that the Puzstai study has been repeated, at least in concept. I’d also like to point out that this conversation is way off topic – wasn’t this post about the Oregon labeling bill?

                  Puzstai’s hypothesis, if I recall correctly, was that the genetic engineering process itself caused some harmful change. His feeding study (various flaws aside) involved a group of rodents fed the protein lectin with potatoes and a group of rodents fed potatoes genetically modified to express lectin. Now, lectins, even though they are found naturally in various foods, can be harmful at higher doses. But if Puzstai was right, then there should have been some effect of the potatoes expressing lectin different from the effect of potatoes and lectin.

                  One thing that you don’t see brought up very often is that lectin is a terrible protein to be used here. If one is trying to find the effect of genetic engineering, why use a protein known to be harmful to mammals, even if only at higher levels?

                  There’s at least one paper that tested the same thing as Puzstai – a protein alone and the same protein expressed by a transgenic plant. I would be surprised if there were not more papers doing the same thing, but this is one that I came across in my thesis research:

                  Safety Assessment of Recombinant Green Fluorescent Protein Orally Administered to Weaned Rats by Richards et al.

                  In this paper, the authors wanted to determine the toxicity of GFP, a fluorescent protein from jellyfish. They could have just compared GFP vs no GFP, but since they were interested specifically in the toxicity of GFP when expressed in a transgenic plant, they added diets of transgenic plants expressing GFP compared to nontransgenic plants.

                  Now, the sample size here is smaller than I would like – only 8 rodents per group – but the researchers did not find any biologically significant difference between the group fed transgenic canola expressing GFP and non transgenic canola alone. There also was no difference between the groups fed sugar solution with GFP and sugar solution without GFP. There was, as expected, a difference between rodents fed canola (GFP or not) vs those fed sugar solution (GFP or not) – the canola adds fatty acids and other compounds not present in the sugar solution. The researchers could have tied a bow on their already clear experiment by adding a group fed non transgenic canola with added purified GFP but it’s not strictly necessary, given the existing groups.

                  The groups fed sugar solutions demonstrated that GFP was not toxic itself. If there was some change caused by the genetic engineering process, it would have shown up as a difference between the two groups fed transgenic canola and the group fed non transgenic canola. But there was no difference.

                  • Yes, despite Pusztai’s claims about the GE process being inherently risky and causing problems, that has not been confirmed by further research. Some may point out that the other studies aren’t using lectins in potatoes, but then it is not a case of the process being risky, but merely lectins in potatoes. I wonder how much it would cost to repeat the Pusztai study with criticisms of its design addressed? I often feel that we need to have a broader conversation about what are appropriate study designs for these things.

                • “If pro-GM people here are so sure there are no dangers, how about you all volunteer for a year or two of a GM only diet? Then you can be assessed against a control group for stomach lesions, allergies and so on?”

                  That’s not a scientific study. To do it right, you need to have the groups randomly assigned, and the participants and their examining doctors need to be blind to which treatment group they are in. If you are up for that and would consent to be part of such a study, I’ll gladly join you.

  • Richard R

    “it seems to me that relatively few animal feeding trials have been conducted, and there are results from those that have been conducted that are cause for potential concern.” — False

    A quick google scholar search of “animal feeding trial MON810″ turned up +400 articles. (MON810 is the only GE trait approved in Europe).

    Now, are those all relevant – probably not. But the list included one that has relevance “Assessment of the health impact of GM plant diets in long-term and multigenerational animal feeding trials: A literature review.” A literature review – someone was nice enough to write a paper that brings together a bunch of other articles – that must mean that there are more than a few studies. I guess “relatively” few could mean anything. Relatively few studies have been circulated in the “biotech is bad” meme. The paper referenced includes in its review “multigenerational” studies – appparently those have occurred, contrary to the popular “these are untested” refrain that no multi-generational studies have ever occurred. Highlights from the article – No sign of toxicity in analyzed parameters has been found in long-term studies. No sign of toxicity in parameters has been found in multigenerational studies. The 90-day OECD Guideline seems adequate for evaluating health effects of GM diets.

    Link to article – http://www.sciencedirect.com/science/article/pii/S0278691511006399

  • NickB

    “it seems to me that relatively few animal feeding trials have been conducted, and there are results from those that have been conducted that are cause for potential concern.” — True.

    I prefer to run my own literature searches thanks. Google scholar pulls a large amount of grey literature. Web of knowledge accessed 15th April 2013. Citation search for the Ewen Pusztai study, Lancet 1999. I was looking for studies that attempted to reproduce the controversial study to confirm or refute it. Any study that does so will cite the original. Results: 135 citations in the peer-reviewed literature. Animal feeding trials 14, of which examining cellular biology or organ functioning: 13. Studies that report evidence of effects of GMOs compared to non-GMO diets: 10. Studies in which the effects are clearly negative: 2. I’m not expert enough to judge to what extent the other effects were “adverse”, but in general these studies reported that not enough is known about these effects or the mechanism through which they occur. Not a single study tried to replicate the Puszai study to see whether or not the varietal they studied has the effects claimed.
    You can reproduce my lit search – please do.

  • Charles M. Rader

    NickB, there’s a distinct lack of logic in your comment. In response to your claim that relatively few animal feeding trials have been conducted, Richard R pointed you to a set of feeding studies. You think you have refuted this counterexample by giving him another example of a feeding study (Pusztai, et al). Apparently you think that a study that purports to find a GMO problem is a proof of the non-existence of other studies.

    In addition, you chose a study that has three separate logical problems. First, it was not convincing enough to pass a peer review. Second, it related to a GMO event that was never meant as a human or animal food. Third, does it occur to you that if Pusztai’s study could be confirmed, those groups who are trying to prove GMO problems would surely have done so. Would Dr. Seralini have not tried to confirm it before embarking on a two year rat study?

    I am still waiting for you to explain why GMO foods are so high on your list of worries, since all the reasons you have given us would apply at least as strongly to many other breeding techniques.

  • I missed this article when it came out the other day, but I found it interesting:

    Early Editorials Against GMO Labeling Initiative in Washington State.

    Reminds me of Michael Pollan talking about that being an issue in Prop37 too.

  • Ron

    Personally I DO NOT want to be part of the GMO experiment. I don’t believe they are safe and it HAS NOT been proven that they are safe. I urge everyone to vote yes on 522.

    • Ron,
      That is certainly your right to make that decision. Fortunately, I guess, you have the tools to do so now and there is no reason to believe you won’t be able to in the future.

      So tell me, if the measure passes as you hope, will you ever eat in a restaurant again? Will you drink alcohol (assuming you may now)? If you are not vegan, how about meat, eggs, cheese or yoghurt? While I’m hoping you do not, if you did end up in the hospital, will you refuse the food there? In short, how will you deal with all the things that are given a free pass by I522? The only way I can see you doing that is by using the things you would use now: organic and non-GMO labels. I522 will do nothing to help you.

  • David Bell

    Doesn’t this just come down to the issue of testing ALL food ingredients for safety, engineered or not. The label could simple say “ALL ingredients tested for safety by the US FDA”. Lets fully fund the FDA and take their advice, this is their job, and this is why we created the FDA.

    • That certainly would be an option. I believe Canada does something along these lines. Unfortunately it would not satisfy the GM-No GM, Organic-Not Organic, etc, etc, contingencies. Then there is the issue that few seem to trust the FDA/EPA/USDA, that is until they want them to regulate something.

  • I am still waiting for one PEER REVIEWED SCIENTIFIC ANALYSIS that says GE crops are safe (NOT AN INDUSTRY FUNDED-NON-PEER REVIEWED OPINION PIECE). There are a plethora of peer reviewed analyses verifying the contrary.

  • Of course I expect my last post to not be published…the usual censorship of fact.

  • MarkfromHam

    Several logical fallacies in the anti-labeling arguments. The first argument, “that the legislation is flawed”, is spurious, no legislation is perfect and many of the more objectionable clauses from previous legislative efforts have been removed. The second argument, that GMOs are proven safe also has logical errors, first, no man-engineered product can be proved to be safe without a significant risk to the population in establishing that proof. If there is a counterbalancing risk, such as in the case of vaccines then sometimes that risk may be worth it, but people are still presented a choice of whether or not they take the vaccine. In the case of GMOs there is no choice on the part of the consumer, they will be fed experiments without knowledge.

    • Thanks for your comment MarkFH. Your first objection would seem to be of the “it’s better than nothing. All legislation is flawed.” line, to which I would reply that this is very lazy argumentation and that such flawed laws can lead to very dire and severe outcomes. Turning a blind eye is a very bad course of action to take. It is no excuse for failing to acknowledge or attempt to correct those flaws. More specifically to your comment, no, many (I would say most) of the objectionable parts have been left in in place from CA P37. The article above explicitly outlines where and how that occurs, such as the numerous exemptions, one sided legal and financial liabilities, and the proposed nightmare of paper documentation for everyone who does not submit to the label, just to name a few. Of course the newly added “must label on package front” is a bonus piece of objectionable material for this law.

      I would agree if there was a counterbalance to the risk/cost, it should be given consideration, however, that just is not present in this law. The label that is proposed would tell the consumer absolutely nothing for the majority of store shelf items other than “may contain”. Of what use is this? We already know that 70% of typical store items “may contain”. Without more specific information as to “Yes it does”, or “No it does not” (or better yet, exactly what the modified ingredient was), the consumer has no new information. And people do have the choice right now through non-GMO labels, organic labels, or simply doing some basic research (conveniently provided by anti-GMO groups on-line) as to what items in the food supply have been modified.

      By societal norms, safety is determined through several avenues including experience, history, as well as laboratory and animal testing. The scholarly research literature over many years of study and use (more than 1700 studies now) have overwhelmingly shown that a) current GM products are safe, and more importantly b) the process for screening GM products for safety works. In objecting to the claim of safety, you are proposing to face off with a mountain of opposing evidence that is accepted by every major and notable scientific and governmental organization available. I wish you luck!

  • Tim

    Why should we trust a company’s (Monsanto) products so blindly whose been known through history to create cancer causing agents? Saccharin, rBST’s, DDT, PCB’s just to name a few. Our FDA is ran by former Monsanto executives. The company is banned in over 15 countries worldwide! The US has more obesity and cancer than anywhere else in the world and just so happens to be Monsanto’s strongest market. Help me understand how we can just overlook this when most of Europe understands? This bill is far from perfect but it’s a start to change. It seems ridiculous that people are fighting this so much. This “ignorance is bliss” stigma is killing the country slowly…

    • Sorry, I can’t help you with your corporate or government paranoia other than point out to you that it is inconsistent to single out one company or government entity. Many corporations and government agencies that currently influence our lives do not have perfect records. Do you avoid Boeing aircraft because they once made B-52s? Do you reject science from the Hubble Telescope because it was built by the weapons manufacturer Lockheed? Should we ignore the NIH because it is headed by someone who openly promotes the Holy Trinity as compatible with science?

      Your implications on cancer causation are also incorrect. Saccharin and rBST are not known to be carcinogenic. Further the US does not have more cancer than other locations and cancer rates (some of which are actually declining) show no correlation with the introduction or prevalence of GM products. As far as I know, neither do obesity rates.

      Whether a country bans a product or company should have little relevance to law making decisions made in the US. Many countries ban homosexuality, or women’s rights, for example, but few would find those to be compelling arguments for determining US law. This is referred to as argument Ad Populum or appeal to popularity. Your mother was right on this topic: “Just because Johnny wants to jump off the Empire State Building doesn’t mean you should.”

      What exactly does Europe understand? That they now have placed their own agricultural production and independence in jeopardy? They now have to import huge amounts of food/grain (much of it GM) to support their greenwashing attitude at the expense of developing countries. In what they do produce, they expose themselves and their environment to unnecessary pesticide use. On the horizon, they have hogtied their scientists’ and agricultural sector’s ability to anticipate and counteract serious plant diseases that threaten several staple crops. That is not a path I wish to follow.

      I can agree with your last statement, however, but probably not in the manner you intended it. :)

  • Tim

    Corporate or government paranoia? More like awareness. I’m not sure that your comparison to aircraft manufacturers is at all relevant. I don’t see Boeing or any other company banned in as many countries as Monsanto. Lets also make it clear that Monsanto as a company is banned in these countries, not just one of their many products. While I understand your point on ‘argument ad populum’, it’s hard to ignore that 15+ developed countries in the world have chosen to do this. A better comparison would be to the tobacco industry in the first 1/2 of the 20th century. The industry touted health benefits in their marketing attempts into the 1960′s.

    While saccharin was only linked to bladder cancer in rats, many of the artificial sweetners have been associated with irritation and inflamation of the bowels and intestines, and as we know inflamation is a precursor to cancer. rBST milk is supercharged with high levels of the natural growth factor (IGF-1), which is readily absorbed through the gut. Excess levels of IGF-1 have been incriminated in well-documented scientific publications as causes of breast, colon, and prostate cancers. Additionally, IGF-1 blocks natural defense mechanisms against early submicroscopic cancers.

    When a government has no regulation surrounding lobbyist or the nomination of agency figure heads, how can you trust that the government is looking out for our people’s best interests?
    Can you explain the reasoning behind the “Monsanto Protection Act” if everything produced by the company is completely healthy? Fortunately the act was killed by the Senate in last night’s funding of the government, but it’s a clear example of corporate interests being put ahead of the people’s interests.

    • Your argument ad populum is still faulty. It is very easy to disregard those 15 countries. And to my knowledge, they haven’t “banned Monsanto”, they have banned, across the board, the growing or producing GM products whether they are sold by Monsanto or not. These decisions are well documented as being based on politically inspired fear campaigns, not actual verifiable science. More to the point, why are you obsessed with Monsanto? What does this have to do with I522? It does not mention Monsanto. It does not ban anything. Or is that your ultimate goal?

      Tobacco is a poor model. The adverse health effects of tobacco were well known and documented. I defy you to find any clear, credible evidence showing adverse health effects for any GM product currently in use. Even prominent GM opponents and skeptics now acknowledge that there are no demonstrable adverse health effects from GM products. This is a dead horse. Stop beating on it.

      I addressed the cancer claims you made for the compounds you listed. If you had other effects in mind, you should have stated them as such and not tried to pass off a cancer scare to make a point. As to your new claims (now expanded to “many artificial sweeteners”), your evidence is still weak at best, showing moderate association. Association is not cause. Precursor is not occurrence. The evidence here is not clear. I’d agree that IGF-1 is documented to cause the ailments you list. Quite fortunately, milk from rBST cows has been found to have minimal increase in IGF-1 levels. The problems with rBST stem from animal health and welfare, not human. Claiming rBST causes cancer is false.

      The fact that you refer to the legislation as the “Monsanto Protection Act” is more than sufficient to tell me you know absolutely nothing about it. Your words following that demonstrate you apparently do not consider farmers interests to be relevant as well. Anyone with an understanding of the legislation, correctly called The Farmers Assurance Provision, would know that A) it does not reference Monsanto and offers them no special rights or protection for them, and B) it is aimed at protecting farmers who have their livelihood and investment already planted in the ground at the time any potential ban is imposed. Hence, the actual name of the legislation.

  • Tim

    What does Monsanto have to do with I522? You are kidding right? They are only responsible for 90% of our GE seed. That has no relevance though right?

    Tobacco is actually a great model. We did not have well documented adverse health effects on tobacco the first 19 years that it had been on the market. GM vegetables have been on the market in the US since 1994 while cigarettes have been since the 1880′s. So simple math tells us that based on the discovery of adverse health effects in cigarettes in the 1950′s, it took us almost 70 years to form that conclusion, then another 10+ years to start labeling the effects.

    I call it the Monsanto Protection Act because who do you think wrote it? The measure undermined the Department of Agriculture’s authority to ban genetically modified crops, even if court rulings found they posed risks to human and environmental health. Do we give the poultry farming industry a “free pass” if it is found they have contaminated meat? Give me a break!

    Please show me evidence of a long term independent study that shows GE seeds are safe because no, I will not take Monsanto’s (or Bayer, BASF, or Syngenta)word for it.

    Here’s an open letter from over 800 scientists in 84 countries that agree with me:
    http://www.i-sis.org.uk/list.php

    • In the 1880′s, the electric light bulb and the phone were new inventions. The X-ray machine wasn’t even invented and no one knew what, if anythng, atoms were made of. To equate the story of tobacco to the seed, accuracy, depth and abilities of modern science and technology and to that of GMO’s just doesn’t fly. For one, absolutely no testing was done on the wholly natural product of tobacco when it was introduced. No animal studies and no followup epidemiological studies until decades later. Other types of studies were all but impossible given the state of technology up thorugh the 1950′s.

      Today, with GMO’s, up front studies on animals and toxicity have been done and numerous epidemiological studies done after the fact, with technology that coudn’t even be dreamed of 60 years ago. “The secret ingredient is that there is no secret ingredient” – Kung Fu Panda’s father.

    • LOL! Tim, I have to thank you, because I hadn’t thought of that “800 Scientists” bit for quite a while and , Boom!, you pull it out for a good laugh. Not only are the science and arguments in the letter (even recent incarnations of it) outdated, but this list itself is well known to be a laughable conglomeration of BS along the lines of C. Moore Butts, PhD. :) Thanks for the laugh, though.

      Reddit proves it is worth something: The “Real List” behind the List

      These arguments by populum (and authority) will only be valid if they are backed by real evidence. They are not.

      Oh, and BTW: Long Term Studies not by Monsanto, Bayer, DuPont, BASF, or Syngenta.

      Survey of Long Term Studies

      Actual references in the above article

      Expecting the goal posts to be moved in 3, … 2, … 1, ….

      • Mlema

        Billa, here’s a link to an (uncorrected) version of the “Survey of Long Term Studies you link to.

        http://www.ask-force.org/web/Longterm/Chelsea-Assessment-Health-Longterm-2011.pdf

        The data presented in the paper don’t support the conclusions. There remains no good research on the effect of consumption on human health. Plus it’s ridiculous to talk about GMOs as a group. They’re all different and some present more problems than others – and there are different problems as well.

        This paper gives an overview of the issue:
        http://static.aboca.com/www.aboca.com/files/attach/news/risk_assessment_of_genetically_modified_crops_for_nutrition.pdf

        • Mlema

          sorry, didn’t mean to type “Billa”

        • From the first link:
          “Results from all the 24 studies do not suggest any health hazards and, in general, there were no statistically significant differences within parameters observed. However, some small differences were observed, though these fell within the normal variation range of the considered parameter and thus had no biological or toxicological significance. If required, a 90-day feeding study performed in rodents, according to the OECD Test Guideline, is generally considered sufficient in order to evaluate the health effects of GM feed. The studies reviewed present evidence to show that GM plants are nutritionally equivalent to their non-GM counterparts and can be safely used in food and feed.”

          The second link (five years old) is suggesting a case-by-case evaluation, which is currently done in the US and Europe. This is in agreement with your statement that ” … it’s ridiculous to talk about GMOs as a group.”, also supporting my original arguments in the post above that generally labeling something as “GMO” is pointless.

          The second link also points out that in some tests, “microscopic and molecular effects” were observed. Some points on this: 1) This would apply to every new batch, variety, crop, season, preparation, or any other conceivable alteration you can imagine. Nothing is molecularly identical every time you eat it. Even if it were, the micobiome you expose it too in your gut would be different and handle it uniquely. Humans have evolved to survive these inconsistencies and it is unlikely that such variation will cause severe detrimental effects. 2) Many of the test results they refer to come from experimental designs that throw everything at the wall to see what sticks. This is a well known statistical fallacy whereby the researcher tests so many things at once that something comes up significant by chance. Such tests have little statistical power for detecting true differences. 3) As others have noted on this site many times, lab and farm animals have consumed millions of GM meals from these same types of GM crops as regular feed. Such animals are highly monitored and measured on regular intervals, yet, at no time, in any place, has any adverse reaction, growth, anomaly been noted or observed. Note that this feeding has occurred on farms and in labs world wide by private, governmental, and corporate entities for over a decade.

          Don’t you feel that if these minute changes were to have adverse effects, that we would have seen it by now? Enough is enough. People made similar claims years ago about hybrid breeding. Eventually such claims became obviously false. We are fast approaching the same conclusions here. Yes, we realize that new transformations may have problems. We have mechanisms in place to investigate and test those (and they were in place before the technology even really began). There is just nothing to see here anymore. It’s time to move on.

  • Tim

    A Reddit blog is your ‘end all be all’ for confirmation huh?

    This is straight from Monsanto’s website:

    In addition to animal feeding studies, are human clinical trials used to test the safety of biotech (GM) crops?
    There are not currently any human clinical trials used to test the safety of GM crops. This is not unusual; no existing food or ingredient – GM or otherwise – has been the subject of human clinical trials. However, there is broad global agreement among food scientists, toxicology experts and regulatory food safety officials on how to evaluate the safety of GM foods. We follow these expert recommendations.
    As long as the introduced gene protein is determined safe (an initial step in the safety assessment) and the GM and non-GM crops are alike in all respects, the GM crop is said to be substantially equivalent, or “equal to,” their conventional counterparts and are not expected to pose any health risks. Experts in the field of food safety are satisfied that this approach is sufficient and reliable to assure the GM crops are as safe their conventional counterparts. This expert community does not see a need and thus does not recommend long-term tests in humans in order to establish food safety. END

    Dr. Thierry Vrain, former Head of Biotechnology at Agriculture Canada’s Summerland Research Station, was once a supporter of GMO.

    Dr.Vrain explained that early geneticists from the 1940’s postulated that one gene was the cause of one protein. But that the truth of the matter is more complex and unpredictable than this as a gene can encode for up to 4 or 5 different proteins in an unpredictable and uncontrollable manner. The technology is anything but precise (a further false claim). This means that in the process of trying to introduce a desired trait into a gene you may unknowingly and simultaneously interfere with, damage, or mutate, 3 or 4 other important and unrelated genes . According to Dr. Vrain up to 43 proteins in the genetically-modified MON 810 plants were found to be damaged or disrupted as compared to their non-GM plant cousins. Dr. Vrain suggests that the biotech industry does little research of its own and the money it gives universities to do research is mostly not for safety studies. Regardless of the outcomes or absence of those corporate or university safety studies on GMO crops, the majority (if not all ) of their published results appear to only put out the message that the GM technology is “safe and innocuous”.

    Please tell me why a life long GMO advocate who dedicated his life to genetics would change his stance?

    I guess we can agree to disagree on this subject but I will leave you with a final piece:

    http://thebovine.wordpress.com/2013/06/11/the-gene-revolution-with-dr-thierry-vrain-gmo-free-langley-shines/

    http://tedxtalks.ted.com/video/The-Gene-Revolution-The-Future

    My point in all this is that there is enough evidence that suggests that their should be more studies above and beyond rats and that people should have a right to know what they are eating. There are products in stores that are not neccesarily labled organic that do not contain GM ingredients.

    • Ewan R

      He is quoted as saying

      Every scientist now learns that any gene can give more than one protein and that inserting a gene anywhere in a plant eventually creates rogue proteins. Some of these proteins are obviously allergenic or toxic

      This is quite clearly false. Yes – any gene *can* give more than one protein. However it is on a gene by gene basis that this is decided. Some genes code one protein, some genes code more than one protein, some genes code one protein but part of their non-coding region codes for non-coding RNAs that disrupt the production of other proteins.

      Bt, and the CP4 insert both code… one protein…

      As for the apparent inevitability of creating rogue proteins by inserting anywhere in the genome… hogwash. This guy is simply making things up.

      According to Dr. Vrain up to 43 proteins in the genetically-modified MON 810 plants were found to be damaged or disrupted as compared to their non-GM plant cousins.

      Citation needed.

      Please tell me why a life long GMO advocate who dedicated his life to genetics would change his stance?

      One assumes he does not want to make the world dance. (Low blow I guess)

      means that in the process of trying to introduce a desired trait into a gene you may unknowingly and simultaneously interfere with, damage, or mutate, 3 or 4 other important and unrelated genes .

      While it is true that any given transformation event may disrupt gene expression (and introduce a mutation or two) biotech doesn’t just do a single transformation – they do 10′s to 100′s of transformations to get a commercial product that doesn’t have offtypes… a transformant that lands in a gene isn’t going to be commercialized (although if one disrupted a gene through insertional effect and wound up having positive yield that’d be at least of interest (although, as far as I know, uncommercializable))

      Dr. Vrain suggests that the biotech industry does little research of its own

      Dr. Vrain, if this is what he suggests, is utterly wrong. the biotech industry is insanely careful about where genes land and what effects they have.

      Reading into his stuff however it is pretty clear that he is buying into the craptastical Russian study alongside Seralini’s scurrilously dishonest publications.

      A little further reading shows that following retirement (as a soil scientist) he became an organic farmer – so um, no conflict of interest there. (Further reading also shows that either he buys Huber’s schtick also, and appears to believe that antibiotic resistance is down to GMO plants also… so hey, not only is he on the fringe on a couple of things, it appears all his current ideas are utterly fringe)

  • Patricia

    NOTHING has been ‘proven’, see

    http://sustainablepulse.com/2013/10/21/global-scientists-issue-gmo-safety-warning-breaking-news/#.UmftaCgdURk

    and see what responsible, precautionary, independent scientists have to say on the matter rather than relying solely on the industry-funded and profit-driven research claims.

  • SEEDS OF DESTRUCTION

    One company’s patents
    to control plant seeds,
    made claims it could
    meet world food needs.

    They injected a toxin
    to kill insects called BT,
    it inflames the stomach
    lining for you and me.

    Injected virus in plant
    DNA was entered
    causing natural DNA
    to be forever tainted.

    Since 1992 the health
    effect is coming true,
    Allergies and disease
    increase for me and you.

    No trace of GMO’s
    are to be found,
    No regulation or labels
    which could astound.

    All was done with
    greatest secrecy,
    A profit motive
    is here to see.

    Warnings from tests
    ignored from scientists,
    put the American consumer
    at a great health risk.

    The powers that be
    were well paid,
    The company prepared
    for its raid.

    Farmers for this seed
    said definitely ‘no’
    but in their gardens
    it began to grow.

    The company could
    find and check,
    they played with
    a loaded deck.

    Never before seen
    New plant DNA,
    could change evolution
    beginning that day.

    Stop the GMO’s
    before it’s too late,
    Know the danger
    Keep them off your plate.

    • Since 1998 there have been no labels,and therefore no liability claims.   24 European countries require labels and have stopped buying United States GMO products.  They are not smarter but they have  allowed scientists and educators to inform the European public. American Scientists and educators who told the truth have been fired and we have been kept in the dark to protect big company owners. Japan refuses all GMO foods and they say they are waiting to see what happens to the health of American children and adults in the next 10 years.

      • Japan doesn’t refuse GMO imports – they import everything from soy to papaya. It wasn’t always the case, but they have arguably been the toughest when it comes to regulation requirements. As for European scientists – they are in agreement with American scientists. But some of the politicians in Europe, however, have been ignoring what the scientists have to say.

      • Wrong.

        Despite all of the concerns about genetically modified food, Japan remains the world’s largest per-capita importer of engineered food and animal feed, Akatsuka said. In 2009, a GM rose was altered for blue color, marking the first biotech crop grown in Japan.

        http://www.oregonlive.com/business/index.ssf/2013/07/post_156.html

        Good luck locating better sources of information.

    • A very creative poem! But wrong on so many particulars. Broadly, correlation is not causation. And Bt does not inflame our stomach linings, we know this from a lot of research on its effects, or lack thereof when it comes to humans and other similar animals. Also, people have not been eating GMOS since 1992.

  • Jane Bennett:
    You are incorrect. European countries import substantial amounts of GMO products from the US as well as Argentina and Brazil (See here: http://www.europabio.org/sites/default/files/facts/low_level_presence_2011_updated_final.pdf ). Some shipments have been rejected because the GM components they contained were not GM events approved by the EU. It should be noted also that this type of rejection of GM products combined with the slow and reluctant approval rate of new GM traits by the EU is now creating cost problems for EU animal producers who rely heavily on imported feed.

    Your claims of the silencing of scientists and academics is unsubstantiated and unfortunately reminiscent of the Creationist “Expelled” tactics of the notorious fraud Ben Stein. One would hope you could provide a better argument than that.

    I hope those that seek to impose
    The arbitrary rules they chose
    May eventually realize the problem
    That they have no facts behind them.

    Pdiff

    • Are you people supporting Monsanto? Whatever is said is incorrect according to your reseach. Congratulations.

      • I don’t support Monsanto – they’re a big kid and can defend themselves. I stick up for science, which has always been in need of defenders.

      • Monsanto? Huh? Sorry I don’t recall bringing that up at all. :) Seriously, why is it always argument ad Monsatum. Even the authors of I-522 and the associated campaign have done their best to stay out of that hole.

        Karl and I said you were incorrect because you simply were: Facts: Japan and European countries import GM products. It is widely acknowledged and undeniably true. It has nothing to do with our “research”.

        When you make statements like these, you should be prepared to back them up. Do you have evidence, or even an anecdote, that scientists are being systematically silenced or fired because of their stance on GMO? I know of none, but am open to seeing whatever you can bring to the table regarding it.

        Until then, I won’t consider it defacto
        That all problems lead to Monsanto
        Or believe a conspiracy theory dream
        That contrary scientists remain unseen

        Pdiff

  • You state that: “claims of the silencing of scientists and academics is unsubstantiated and unfortunately reminiscent of the Creationist “Expelled” tactics of the notorious fraud Ben Stein.”

    Emma Rosi-Marshall is a scientist who makes that claim based on her own experience, as covered by this article in Nature. http://www.nature.com/news/2009/090902/full/461027a.html

    One excerpt summarizes the thrust of the article: “No one gets into research on genetically modified (GM) crops looking for a quiet life. Those who develop such crops face the wrath of anti-biotech activists who vandalize field trials and send hate mail. But those who, like [Emma] Rosi-Marshall and her colleagues, suggest that biotech crops might have harmful environmental effects are learning to expect attacks of a different kind. These strikes are launched from within the scientific community and can sometimes be emotional and personal; heated rhetoric that dismisses papers and can even, as in Rosi-Marshall’s case, accuse scientists of misconduct. “The response we got — it went through your jugular,” says Rosi-Marshall.”

    • I’m sorry, Dropdead, but all I see here is criticism of scientific work. The studies pointed at in this article all came under fire for one type of flaw or another. Granted, yes, these criticisms can become heated, and, unfortunately and unjustly personal, but that is the nature of the business at times. If the work is solid, it will stand. If it is controversial, then the authors need to cover every possible end in minute detail, constantly playing the devils advocate. This is, in part, what I do for a living. I am continually harping on grad students, and at times PI’s, to question their work, support their ideas from multiple angles, and anticipate potential defenses against criticism. There is a reason that a brilliant mind like Darwin’s spent 20+ years collecting evidence. Even then, he only released his work reluctantly under pressure from his peers. Another good example is the ground breaking work of E.O. Wilson, who took vehement criticism from luminaries of the evolutionary field. At times it devolved into the ugliness of personal attacks on himself and coworkers. But he prevailed in the end because his work was solid and well thought out.

      As a final note here, the authors pointed to faced criticism from peers and industry. No one was fired. No one lost there positions or funding. The “Expelled” claims simply don’t hold water.

      • Thank you for follow up to my postings. Since I am a technical editor for environmental consulting firm with background in technical translations & translation publication, rather than a scientist, I am liable to follow a general logic train as opposed to point-by-point details. My business partner frequently calls me on this tendency. ;-)

        As a proponent of R2K legislation who is *also* concerned by the chronic lapse into hyperbole — both in my own arguments as well as those of my fellow campaign members — as an element that weakens the overall nature of this debate, I welcome corrections to my postings & look forward to continuing to follow this dialogue in the future.

        I strongly believe that there is common ground between both sides of the argument & feel duty-bound — as a “fellow traveler” within the scientific community although not a scientist myself *as well as* an active member of GMO Free Oregon & organizer for MAM PDX — to work towards strengthening the ability for rational discourse on this issue. There is no way, IMHO, that an increase in rational communication & a decrease in the amount of “invective-based” dialogue cannot work to the betterment of us all. :-)

        Due to travel to support monitoring field operations in the coming week, I will be unable to post follow up commentary. However, I will follow postings closely until the time that I am able to again enter the conversation with commentary is adequately researched, summarized & sourced until *at least* after Veteran’s Day Holiday.

        Warmest regards to all members of this community. I look forward to “speaking” with you all again.

      • Thank you for follow up to my postings. I was unaware of rules regarding postings & will watch my posts more closely in the future.

        I strongly believe that there is common ground between both sides of the argument & feel duty-bound — as a “fellow traveler” (technical editor) within the scientific community although not a scientist myself *as well as* an active member of GMO Free Oregon & organizer for MAM PDX — to work towards strengthening the ability for rational discourse on this issue. There is no way, IMHO, that an increase in rational communication & a decrease in the amount of “invective-based” dialogue cannot work to the betterment of us all. :-)

        Due to travel to support monitoring field operations in the coming week, I will be unable to post follow up commentary. However, I will follow postings closely until the time that I am able to again enter the conversation with commentary is adequately researched, summarized & sourced until *at least* after Veteran’s Day Holiday.

        Warmest regards to all members of this community. I look forward to “speaking” with you all again.

  • I am curious why only one of the numerous posts I made in reply to statements here are not shown. I saw tags on all posts as “being reviewed for moderation” and now they are gone. Since I merely posted abstracts from articles citing research called into question by this article, I’m wondering why the need to delete those posts.

  • This is not question of whether someone wants to make a rap song out of verse presented by the author. This is question of why the public’s Right to Know should *not* be considered paramount.

    • I am not arguing the “Right to Know”. I will argue, however, that this particular law, I-522, won’t even come close to providing this. People touting I-522 as a RtK issue are scamming, playing on the loaded emotional and political implications of the phrase to gain support. But those who take the time to look into the initiative will find it woefully lacking in its ability to provide any useful knowledge. If the RtK is such a paramount issue, then proponents should start putting forth truly informative labeling measures and abandon these Prop 37 make overs. Anyone who really feels that the RtK issue is paramount should be able to see this and act upon it.

  • […] I start reading the opposing viewpoint, […]

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