Analysis of Kaua’i County Bill #2491

Today, the County Council of Kaua’i, Hawai’i is considering a bill, #2491, that would create local regulations of genetically engineered crops and pesticides, and was introduced by Kauai County Councilman Gary Hooser. According to this news article, representatives of the Center for Food Safety will be there to advocate for the bill, which may represent a political push to make it more difficult to grow genetically engineered crops. When we heard about the bill, we thought it would be important for an independent source to comment on its contents to the Council. While not stating a position for or against the bill, we put together a testimony outlining the scientific, legal, and economic issues that we saw with the bill, and submitted it to the Council.

If you have an opinion about this bill, you can send your thoughts to counciltestimony@kauai.gov with the bill number (#2491) and your position in the subject line.

PDF of Bill #2491

PDF of BFI Testimony on Bill #2491

Read below for our analysis.

Dear Members of the Kaua’i Council,

We represent Biology Fortified, Inc., a non-profit organization made up of volunteer scientists who are experts in agriculture, including pesticides and biotechnology. We have no ties to the biotech industry, and work to provide science-based information to the public. We are writing to you to provide background information and guidance about the potential consequences of Bill #2491 from a science-based perspective. Unfortunately, this bill does not have a strong grounding in science. We will demonstrate this below.

First, it is important to understand that genetically modified plants are among the most highly studied foods that humans eat. There are literally hundreds of published, peer-reviewed scientific studies that have been conducted on them. Biology Fortified, Inc. is assembling a publicly accessible database of these studies, called the GENetic Engineering Risk Atlas, or GENERA. This is accessible at www.biofortified.org/genera/, and on the whole, these studies support the safety of these crops for human health and the environment. Approximately one third of these studies are independent of industry funding, and the conclusions of these independent studies are in agreement and do not contradict those with industry ties. Reports commissioned by the National Academy of Sciences, along with a compendium of research from the EU, conclude that genetic engineering is not per se more risky than other breeding methods.

http://www.nap.edu/openbook.php?record_id=12804

http://www.nap.edu/openbook.php?isbn=0309092094

ftp.cordis.europa.eu/pub/fp7/kbbe/docs/a-decade-of-eu-funded-gmo-research_en.pdf

Genetic engineering does not introduce any new classes of risk that are not already present with traditional plant breeding. It is a process by which a new trait is introduced, such as pest resistance, disease resistance, and tolerance to drought and other stresses. It differs from other methods used in plant breeding to alter the genetics of crops in that it widens the range of genetic diversity that can be used in breeding to include genes from species outside those that can be crossed through previous plant breeding techniques. This can bring in needed traits that would otherwise be extremely difficult to achieve through other methods.

For instance, scientists at the University of Hawai’i developed papaya trees that are resistant to the papaya ringspot virus, which has had a devastating impact on the papaya industry in the state of Hawai’i. By using a piece of one the virus’s own genes, the trees were effectively immunized against infection, and today, most of the papaya plantations in Hawai’i are planted with these genetically engineered trees. This is a great example of a local Hawai’ian success story with this technology, which should be kept in mind when regulating this technology at a local level.

A trial of genetically engineered virus-resistant trees on the right, compared to susceptible trees on the left.

In sum, there is no reason to think that living near field trials of experimental genetically modified plants poses any additional risk to the residents of Kaua’i, and indeed, there are benefits to the local farming economy from such trials.

We will now address some of the issues in specific sections of the bill.

Section 22-22.1 Findings

The findings argue that development of genetically modified organisms has been unregulated. While Kaua’i may not have specific regulations related to genetically modified organisms, the United States federal government has a system of regulations under the Coordinated Framework, set up in 1994 by the White House Office of Science and Technology Policy. Under the Framework, the Food and Drug Administration is responsible for the food and feed safety of genetically modified organisms. The Environmental Protection Agency is responsible for the safety and proper use and labeling of pesticides, including pesticidal substances produced by genetically modified plants. The United States Department of Agriculture is responsible for safety of US agriculture, including protecting the environment from plant pests and noxious weeds, as well as consideration for human and animal health. A field test of a genetically modified organism must be reviewed and approved by the USDA. The state of Hawai’i, as with any other state, has the right to further review and approve or disapprove the field trial. The Environmental Protection Agency is also responsible for the regulation of pesticides. A field test of an experimental pesticide must be reviewed and approved by the EPA. These agencies have the authority to impose additional safety conditions if the organization applying to conduct a field test has not set safety conditions that are stringent enough. These safety conditions include safeguards for the environment, including any threatened or endangered species or species proposed for listing, of which Kaua’i has many.

Section 22-22.2 Purpose and Section 22-22.4 Mandatory Disclosure of Pesticides and Genetically Modified Organisms.

The stated purpose of the Bill is to inform the public of  field trials happening in Kaua’i. The exact locations of field tests may be kept private from the general public for a variety of reasons, including ensuring that the scientific integrity of the tests is not disturbed, to keep members of the public from going onto the field at times that they might be harmed by the activities in the field, to protect workers in the field, and to reduce the potential for sabotage or destruction of the trial. Considering the thorough science-based regulation of both pesticides and genetically engineered plants, the potential harm of notifying the public of exact locations of field tests outweighs any potential benefits.

In 2011 and 2012, genetically engineered papaya trees were vandalized.

Indeed, it seems that the risk of vandalism and sabotage by individuals and organizations opposed to genetically engineered crops is particularly high in the state of Hawai’i. While these cases subsided in recent years around the US, In Hawai’i, papaya farmers have had their trees slashed in both 2011 and 2012, in protest against [Edit 8-20-2013: possibly in protest against] genetically engineered papayas. (http://www.biofortified.org/2013/06/gmo-crops-vandalized-in-oregon/) Providing a means to mandate disclosure of field trials in the local area may encourage activists to engage in similar acts. By the wording of section 22-22.4, it indicates that mandatory disclosure will involve posting the locations of field trials 60 days after the end of the calendar year. While annual crops will have been harvested, perennial crops such as trees will still be present at these locations, leaving them vulnerable to destruction. If a new virus-resistant papaya was being developed for Hawai’ian farmers, this section may enable individuals and organizations to seek out and chop down such trees, destroying years of research and putting Hawai’ian farmers at risk of losing their crops to disease.

Much of the requested data for genetically modified organisms is already available. Anyone can visit the public website http://www.isb.vt.edu/data.aspx to search for data provided by the USDA about field trials. Specifically, one can obtain information about field trials that includes the organization running the trial, the number of acres, the type of plant, the dates during which the trial will be conducted, the state in which the trial will be conducted, and the phenotypes or traits being tested. Because the State of Hawai’i reviews all applications for field tests, Kaua’i could potentially request from the State some more specific information for tests conducted in Kaua’i.

Section 22-22.5 Pesticide Buffer Zones and Section 22-22.6 Prohibition of Open Air Testing of Experimental Pesticides

As stated above, pesticides are extensively regulated by the Environmental Protection Agency. When a pesticide is approved beyond the experimental stage, conditions are set for its safe use. Depending on the toxicity of the pesticide, conditions may include a requirement for it to be applied only by certified pesticide applicators, with certain equipment at certain application rates, under certain weather conditions, with buffer zones, prohibit use of the pesticide in certain environments, and so on. This is what is means for a pesticide to be “restricted use”. These application conditions are science-based, and designed to protect both humans and the environment. Similarly, applications for field tests of experimental pesticides are evaluated for safety to humans and to the environment, with specific considerations for the plants, animals, and other organisms in the location where the field test will be conducted.

Section 22-22.7 Moratorium

As stated above, the USDA conducts an evaluation of each field test application for genetically modified organisms, including consideration of safety for humans and the environment. Genetically modified organisms undergo much additional evaluation in the petition for deregulation process. Setting a moratorium for planting of genetically modified plants overrides the entire science-based federal regulatory process. This section sets an exception for persons who were growing experimental genetically modified organisms before this ordinance was introduced. If the Council of Kaua’i truly believes there is a risk to its people or environment from these organisms, it is inconsistent to grant such an exception.

Section 22-22.8 Environmental Impact Statement: Administration

This section requires Kaua’i to conduct an Environmental Impact Statement for genetically modified organisms and for any pesticides that might be used with genetically modified organisms. Since the specific effects of any single genetically modified organism or any single pesticide can vary widely, this means that an EIS must be conducted for every individual genetically modified organism or pesticide that an applicant may wish to grow or use. EIS are complex documents that require an experienced staff with a variety of expertise in plant biology, genetics, agronomy, toxicology, soil biology, wildlife biology, pest control, and so on. These documents may take months or even years to complete. This process has a cost that is greater than zero, and it can be quite costly to have all of these experts on staff. This section states that funding for the EIS may come from property taxes or from permit application fees. To cover the costs, these taxes and fees would have to be quite high, and considering that this entire process is a duplication of federal regulatory efforts, applicants wishing to use any pesticide or grow any genetically modified plants in Kaua’i would have a high incentive to consider legal action against Kaua’i for this additional regulation. We recommend that the Council consider the burden this might place on the residents of Kaua’i. Further, this section seems to require an EIS for any pesticide used with genetically modified organisms but does not require an EIS for the same pesticides used with the non-genetically modified counterparts. If the Council of Kaua’i truly believes there is a risk to its people or environment from these pesticides, it is inconsistent to grant such an exception.

Section 22-22.9 Permitting

As stated above, the USDA issues permits for the cultivation of genetically modified plants, which take into account the issues of flowering, cross-pollination, and environmental impact of field trials. This section would duplicate this process which is already conducted by the Federal government. While the states can set additional requirements, such powers are not granted to individual counties at the federal level. We suggest that the State of Hawai’i be consulted about any changes to the regulation of field trials of genetically modified crops within the State.

In addition, the provision about human testing does not meet ethical and scientific standards. No statements are made about the requirements of consent, privacy, and ethical use of human testing, except only the redaction of names. This section is vague about what an individual would be volunteering for, or whether a human volunteer would be required before a permit is issued. In addition, without a clear scientific goal, human testing is not considered ethical. We recommend seriously reviewing this section in accordance with the guidelines for human test subjects by the National Research Act of 1974 and the EPA, (http://www.epa.gov/oppfead1/guidance/human-test.htm).

Setting up an administration at the county level that would oversee a permit process, as stated for the above sections, would present a significant financial burden to the county of Kaua’i.

Section 22-22.10 Prohibition of Open Air Testing of Experimental Genetically Modified Organisms

As stated above, field tests of genetically modified organisms are extensively regulated by the USDA. Applications for field tests are evaluated for safety to humans and to the environment, with specific considerations for the plants, animals, and other organisms in the location where the field test will be conducted.

Conclusion

In conclusion, we ask that the Council of Kaua’i consider the science-based regulation that is already conducted at the federal and state levels, and the impact that this bill would have on the citizens of Kaua’i.

Sincerely,

Biology Fortified, Inc.

To contact us about this letter, and for answers to any questions that you may have, please contact:

Karl Haro von Mogel, Chair

Biology Fortified, Inc.

contact@biofortified.org

Karl earned his Ph.D. in Plant Breeding and Plant Genetics at UW-Madison, with a minor in Life Science Communication. His dissertation was on both the genetics of sweet corn and plant genetics outreach. He currently works as a public research geneticist in Madison, WI. His favorite produce might just be squash.

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87 comments on “Analysis of Kaua’i County Bill #2491
  1. This is a great, science-based criticism of Kauai County Bill #2491. I would like to invite you to comment on Hawaii County Bill 79 draft 2. If you email me, then I can provide the text of the 2nd draft of the bill. Thank you for trying to educate the public about controversial issues related to genetically engineered crops.

    • We thank you! You can contact us/me at the email address above, and I have an email address posted on my profile. I look forward (with some trepidation) to seeing what this other bill is about.

  2. June 26, 2013

    Dear Karl,

    Thank you for your unbiased scientific analysis of Kauai County Bill #2491. I appreciate the time, energy, and money you spent on this. Your words will endure for generations to come in support of a righteous cause.

    We are currently fighting the anti-GMO Bill #79 proposed by the Hawaii County Council. Unfortunately, reason has flown out the door with effective scare tactics presented by activists.

    Yours truly,
    Carol Gonsalves
    (wife of Dennis Gonsalves who led the work on GE Rainbow papaya)

    • Carol,
      Thanks, but it was a team effort – I’m just putting my name as the contact! I’m interested to find out what this other bill is about.
      We would love to tap into your husband’s experience with papayas and more in Hawai’i. Maybe our mascot, Frank can pay y’all a visit over there?

  3. Renee Kester says:

    I vote for a visit from frank! Seriously though, this is a great review if the bill, Kauai is grateful for this non-biased scientific information. Looking forward to seeing more from the bio fortified team concerning Hawaii. Mahalo!!

  4. Susan, Carol, and Renee – I’m so glad that you found this to be useful. I hope the Council does as well.

  5. theoldtechnite says:

    For what my 2 cents is worth a wrote in my stance against this bill, though i’m a resident of Pennsylvania.

  6. Ryan says:

    Mahalo (thank you) for putting this together and helping to cut through the hysteria and misinformation.

  7. Mark Kijima says:

    I’ve been mulling this over for a while. How do you communicate risk assessment to a population that is not particularly scientifically literate? I think that is the crux of the problem.

    • Elaine says:

      A little haughty arenʻt we, Mark?
      Assess all the risks you want but when it comes to assessing my risks and my choice not to have pesticides inundating my God given air, you may step aside and go back to whatever you were doing.
      Try not to be so condescending next time you reference your fellow man.
      Thatʻs a start to ʻcommunicateʻ.

  8. Evan says:

    If I may present an opposing opinion here, I am extremely familiar with the processes of Genetic Manipulation, and am not against the practice at all when done properly. The issue that has caused all of this, is Chemicals. We live in one of the most unique and diverse ecosystems in the world on Kauai. There are plenty of recent independent articles on the negative affects of chemicals, and I will call attention to one here. It is important to understand first that the regulatory bodies follow a set of pre-determined assumptions. Take Glyphosate for example. As I am sure most of you here know, glyphosate kills weeds by inhibiting their growth through the shikimate pathway. The Human body doesn’t have shikimate pathways, so with glyphosate, the assumption is that it could not affect humans. As most of you also probably know, our bodies are shared with a whole host of bacteria, a large concentration of which reside in the gut. Gut bacteria DO have shikimate pathways, and they are affected by glyphosate, which can cause a whole host of diseases if vitamin synthesis and digestion are affected. We have also been losing our reef due to an extremely aggresive new bacteria that is devouring the coral, and my guess would be that it is due to a genetic modification caused by the inhibition of the shikimate pathway through the runoff of glyphosate into our streams that flow directly into the Ocean within a matter of hours during heavy rains. The problem here, is that these companies that are doing this testing, are also the producers of these chemicals, creating a clear conflict of interest. When will we use our brains for the GOOD of humanity, instead of for PROFITS? If these companies were good stewards, and weren’t driven solely by profit, they would not have experienced such blowback on Kauai. We the people of Kauai do not take kindly to being the lab rats for the bio-tech industry, and we do not understand why their is so much resistance to doing these tests in ENCLOSED & CONTROLLED areas, where external contamination would be impossible, especially when most test fields are within feet of schools, hospitals and elderly housing. My point, there is a TON of misinformation on both sides, and unfortunately, when dealing with issues most cannot understand, it is the responsibility of the scientists to ensure the public is well informed, and well protected. The FDA and EPA have a long history of approving chemicals, foods, drugs and practices that KILL PEOPLE, therefore, it is our right as the citizens of Kauai to demand that we do our own testing to ENSURE the safety of the environment, and our children, for generations to come. If these multi-national, multi-billion dollar companies don’t like our requirements, then they can go elsewhere, simple as that. We are constantly at battle over our resources here, as they are highly sought after by many corporations. It is a huge mistake to confuse science and scientists, with the companies that employ them, and in my opinion, if GMOs are really to further HUMANITY, then they should be owned by the public, taking away the fear that all of our food will one day come from Monsanto. This is a VERY DEEP issue, and I encourage all those here, and elsewhere, to educate yourself, as well as those around you with facts, not assurances based on Government agencies that so often fail the public. Let’s get past all of this rhetoric, and get back to using science to save the world, not slowly destroy it. Thank you all for the work you do, but do not allow yourselves to be influenced by those driven solely by profit. Aloha, and Mahalo for the opportunity to bring up these points.

    • Elaine says:

      Thank you, Evan, for a very common sense view on an issue that has become as convoluted as the chemicals themselves.
      You appear to have the background and I am pleased to be able to read your ʻindependentʻ opinion.

    • Tom says:

      Evan,
      Chemicals are not good or bad, they’re just assemblages of atoms. Some of the nastiest chemicals known to humanity are perfectly “natural” (mycotoxins being a prime example). Glyphosate is probably the least toxic and most environmentally friendly herbicide out there (http://naldc.nal.usda.gov/download/17918/PDF). Microbes in the environment have no great difficulty in breaking it down. And the inhibitory effect on the shikimate pathway only works if there are no external sources of protein available, otherwise the microbes will switch off the pathway.

      From what I can tell, the recent disease outbreak seem to be caused by a mix of cyanobacteria and fungi (more info at http://hawaii-reef.com/). The reasons can be many, including temperature and/or pH deviations in the water that can weaken the corals and allow opportunistic infections to take over. If you have a hypothesis about the cause being glyphosate run-off then you need to do the appropriate experiment before drawing any conclusions. I hope the reefs will still be around next time I take a sunset swim at Ke’e Beach.

  9. I very much agree with Mark. I believe in the science rather than the emotions, as should those who form our rules and regulations.

  10. Roy Yamakawa says:

    I would appreciate if you would vet the credibility of Independent Science News, and the following link regarding discovery of a hidden viral gene in commercial GMO crops.

    Aloha!

    http://independentsciencenews.org/commentaries/regulators-discover-a-hidden-viral-gene-in-commercial-gmo-crops/

    • Hi Roy,

      “Independent Science News” and its parent organization has been putting out some questionable claims for years, often misreading studies. This case of danger from a piece of a viral gene that would only affect plants if it was even functional is much the same thing. We have a forum discussion here that addresses this recent claim. I hope this helps!

  11. Robert says:

    Who asked you to an analysis of this bill. Who brought it to your attention?

    • Hi Robert,
      I didn’t say anyone specifically asked us to do an analysis of the bill, but we do get tons of questions about news from our readers and passers-by on the internet. Heck, as you can see, this post spurred two more requests for opinions. A reader asked what we thought, and we went so far as to write it up considering the problems we found, as you can see. In the past, we’ve written and published analyses of labeling bills to be more on top of what’s going on and to help our readers do the same.

  12. prieten says:

    Here we go again, Evan doesn’t list a single fact, just one emotional accusation after another.

  13. Evan says:

    I did list facts about our gut microbes and the FACT that they have shikimate pathways and the FACT that the assumption is made that glyphosate cannot affect the human body due to the FACT that our bodies cells do not have shikimate pathways, that are backed up in the following http://www.mdpi.com/1099-4300/15/4/1416 . What ever happened to the days when Science’s main goal was to disprove what was accepted in order to advance science, not stick with agendas. Albert, Niccola and many others would be very disappointed. Remember, the world is flat, and that’s a FACT if you lived 100’s of years ago.

  14. RAM says:

    Evan, I think the problem here is you are siting a study that does not have the backing of the scientific consensus. Here is a review of that study from another non-profit independent science based site. http://www.geneticliteracyproject.org/2013/05/06/navigating-the-agricultural-biotech-minefield-when-an-mit-study-is-not-an-mit-study/

  15. Robert says:

    I was at the first reading and what bothered me was that hooser and bynum were asking the companies for data if they could provide it but when the activist were up stating studies that was not conclusive, they did not ask for any data from these groups but just treat their statements as fact which makes them look really hypocritcal in their meeting.

    • Elaine says:

      Yes, for all the safety assurances that agribusiness gives us, there hasnʻt been a lot of proof. This is a right to know especially since it is Public Lands, resources and monies that are being tossed into private coffers.

  16. Evan says:

    RAM, Thank you for that link. It certainly raises some important problems with the study, but I think the only problem I have with it, is that it doesn’t refute that if you did do these studies, you might come to the same conclusion about the gut microbes. Of COURSE that DOES NOT MEAN that if it does affect the gut microbes, that therefore it is the cause of every western disease. That would require TONS of additional data. This link seems to also focus a lot on whether or not the scientists in question worked at MIT, which was the claim of the reporter who did not do his research. NOT being from MIT really doesn’t mean much, as the most influential physicist of our time was a simple Patent Clerk when he was first getting published. That is also a similar situation for many Science and Math visionaries, those that are in college etc, are more relied on to prove or disprove those theories, not to attack the messenger based on whether they attended (or worked at) a Major College. I am going to research some of the possibilities here, and hope that someone who has the ability will actually perform these tests in the form of a peer reviewable paper so we could either discount the possibilities of negatively affecting body function through exposure of the gut microbes to glyphosate, or prove that there may be something to this. This issue isn’t about prestige, it is about whether or not this effect can be observed, and whether or not it may pose negative health problems. By the way, I appreciate the chance to actually have a non-emotion based discussion on this. This is the way in which you educate others, as well as yourself, through intelligent discussion.

  17. Evan says:

    It is my opinion that scientists attaching themselves to the “acceptable damage” set by regulatory agencies is HURTING the PRO GMO movement. Please follow this attached cumulative paper on most of the Scientific Studies that have shown the negative effects of glyphosate shown through papers (reviewed in most cases) available through the US National Library of Medicine. http://www.greenmedinfo.com/sites/default/files/free_downloads/gpub_78151_toxic_ingredient_glyphosate_formulations.pdf Aligning with Corporate Interests isn’t Science, and has proven throughout history, with individuals like Mr. Tesla, to actually halt scientific advances in the name of profits. GMO’s truly could hold the key to future food sustainability, but not if we continue to defend the chemicals which the same companies make for profit that are harming People more than they are Helping them. WE NEED GOOD SCIENTISTS, not people that are part of the “Team” of the Biotech Industry.

  18. Evan says:

    By the way RAM, Jon Entine of The Genetic Literacy Project is a journalist by trade for HUGE Media companies, aligned deeply with corporate interests, I wouldn’t really call that “Independent.” Even his Wikipedia Article had to be written by himself, or someone close to him, and has not been verified by enough external sources.

  19. Anders says:

    Arctic apple tweeted a link to this text hosted on the “Hawaii Free Press” website. Just thought I’d ask if it’s there by permission or if they stole it, since it’s in pretty unsavory company, to say the least.

    http://www.hawaiifreepress.com/FrontPage/tabid/36/Default.aspx

    • Thanks for finding that, Anders. It’s fine, they link back to the source and credit us with it. The one quibble I have is that the site states copyrights, but they are obviously cutting and pasting. It looks like a conservative site, but we license our blog posts as creative commons and they aren’t doing anything commercial with it.

  20. MaryM says:

    So, I haven’t been following this debate much. But these trials have been going on for years in Hawaii, right?

    What have been the negative consequences (documented, not by blog posts) that are claimed by the banhammer team?

  21. Vegreef says:

    OK, some peeps are satisfied with the current state of science as to safety of gmos and glycophosphate and some are not not satisfied and dont want to breath the dust. So we debate GMOs. But what about Atrazine? Its bad stuff. The same companies want unlimited use of it too. And this bil is primarily about disclosure. Why are the seed companies fighting even the disclosures? The must want to hide something. SeedCoUSA wants the debate to be about GMO and roundup, but all those other experimental chemicals they ignore. Atrazine is bad news.

    • First Officer says:

      “What are you afraid of? You do have nothing to hide?” A taunt oft repeated with the logic that if, indeed, you have nothing to hide, you are obliged to disclose whenever asked, whatever it may be. And so the logic also goes that you would not be hiding what it is if it were indeed harmless to those you are disclosing it to.

      But the logic fails when what is disclosed is indeed harmless to all but the discloser and/or if the act of disclosing brings harm to others. This is probably why the U.S. constitution enshrines the right to remain silent as fundamental. It is usually interpreted that we all have the right not to incriminate ourselves. However, it is falsely assumed that, just because one remains silent on a subject, that means one must be culpable in some fashion. Another fundamental right, Freedom of Speech, also means freedom to not speak. Compelled speech for the sake of satisfying curiosity is not a requirement that one can impose on another. You must have a good material reason to compel speech.

      “What are you afraid of ? You can tell us.” In the case of GMO’s, it is well known that the those who lobby for labeling are not doing it for any rights to know or choice. Quite the opposite. They want no one to be able to choose GMO’s or know them for themselves. This is not conjecture. Many have said outright that they see labeling as a tool for outright and/or defacto banning. They seek nothing less than a GM free planet. So, even though GMO’s have been proven at least as safe as any other food by hundreds of studies and nearly 20 years of consumption, there is plenty to be afraid of on the part of those pressured to disclose.

      Or, to put it another way, there is nothing wrong with being Jewish. Jews have contributed greatly to the good of the world and have much to be proud of. But, faced with a Nazi back in Nazi Germany, exclaiming, “Are you Jewish? You can tell me? Aren’t you proud to be a Jew?”, if the person being asked fails to disclose he’s Jewish, then, by the logic of the anti-gmoer, there must be something wrong in being Jewish. Clearly, that is not the case.

      So at the heart of the matter is the possible total destruction of a technology that will literally keep billions from starving. We already have gotten a taste of this when Zambia refused GM food in 2002, at the behest of Greenpeace and millions starved. We have seen the effects of such defacto bans in the blind eyes of millions of VAD children whose sight could’ve been saved a decade ago. Even now, generally GM free Europe cannot feed itself while GM America picks up the slack (indirectly by feeding 100’s of millions that would otherwise be a demand on GM free food stocks).

      The FDA responsibility with food is to make sure dangers and allergens and what the food is, is labeled as such. If you use apples in your product, you have to label that as such. However, you don’t have to label that they’re Rome, or McIntosh, Gala, or that they came from Pennsylvania instead of New York. Likewise, the logic goes, you have to say Corn, but you don’t need to label whether it’s hybrid strain XX or Iowa grown, so long as such corns are similar enough not to introduce new dangers to the consumer. And that is the case for the GMO’s, as proven by the tests they have undergone.

      So if this were a right to know and choice crusade, i would be with you. But, we know it is not and literally billions in the future will suffer for it. That is what i’m afraid of.

    • Tom says:

      Oh if only it was glycophosphate. It would have a half-life of minutes to hours in soil and be great phosphate fertilizer. Not much use as a herbicide though.

  22. Daniel says:

    I am a skeptic and an antithest; as such, I am also a proponent of strong use of the scientific method. When I work with clients in relation to their diet and lifestyle, I find numerous instances of people being more into buying whatever the next fad in dietary science or the counter culture equivalent is, than actually becoming scientists themselves. Perhaps they are filling themselves with the latest and greatest artificial sweetener, or conversely eliminating all artificial sweeteners and refined sugars.

    Knowing that diagnosis and treatment of any disease or disorder are outside my scope of practice, what I encourage is personal experimentation and exploration. I encourage people to track what they are doing and how they are feeling. The more markers that can track, tests they can have run, unbiased data that they can collect and observe, the more they can begin to lead a truly examined life.

    Without clear labeling laws it is difficult to allow any individual to actually implement controls in relation to GMO foods. Yes people get extreme. It can be difficult to not get your back up when you feel like people clearly are not listening to certain research. It can also be difficult when you feel like you have lost your informed choice over the most basic essentials to living. It is hard to see why anyone would oppose proper labeling. If the foods are better because they are GMOs, then why are their praises not being sung from the rooftops? If opinions are to be changed to pro GMO attitudes, hiding them “under a bushel” is probably not a great idea. My gut reaction to a lack of labeling is to distrust. It reminds me of any other preacher advocating ignorance. Surely you can see that tactic applied more colorfully by the counter culture crew. This form is more elegant, but it is the same.

    Me… I want the choice. My clients should have the choice also. I will always advocate for anything that helps them to be more fully informed. The information I found here felt… less obviously tainted by one mindset or another. Still, advocating for science in one breath and restricting information feels wrong. I am none the less grateful for the article and space for respectful argument.

    Mahalo

  23. John Diaz says:

    Sorry but I stopped reading when the aome called independant scientists stated that’s these were the most studied crops. The fact of the matter is that because of the term coined ” Substantial Equivelance” no studies needed to be done other than the private three month ones conducted by biotech. Because of the patent, biotech did not allow any independant research other than their own. This is very important to note because this meant that the studies where biotect conducted at the most was a time period of no more than three months. For a technology that can spread by the wind. This is not exceptable. No human feeding trials were necessary because of the Bush administrations ruling of substantial equivalence. The corn that was modified looked, smelled and tasted just like the original. Forget the fact that it ate holes in the insects belly, causing it to burst. Any comment that states that these are the most studied crops is telling a lie. Prop37 was a great reference as to biotect disinformation campaign where industry and university shills were trotted out to deceive the population. There is a bill in California called SB52 where if enacted biotect’s funding would not be able to hide behind phony “Astroturf” groups. Show me a peer reviewed study that lasted over three months by independant scientists. Show me the peer reviewed Human feeding trails conducted by biotect. There are none. Biotect has spent over a half a billion dollars to decieve americans of the truth. 36 congressional bills were defeated by biotect lobby.

    • Ewan R says:

      A lie, unless of course one looks at the peer reviewed literature… then you suddenly notice that massive amounts of study have been done, it’s a depressing little fact but there you have it.

      Precisely as many human feeding trials as banana, papaya, mango and apples combined infact. (at least so far as my quick literature search turned up!) (foodstuffs don’t go through human feeding trials, anything bioactive enough to warrant it wouldn’t make it into the food supply, unlike pharmaceuticals where anything not bioactive enough to warrant a human trial doesn’t make it)

      Which is pretty impressive.

  24. John Diaz says:

    So sorry, the key wording that I left out was feeding trails by biotect; as there are none. I dare anyone to google the question of long term feeding trials of gmo crops to humans and you will get zilch, nada from biotect but from independant scientists not connected to biotech.
    Other claims by these so called independant scientists writing are amazing since a lie can be ferreted out by a quick scan of the truth. Example: Glysophate was patented in the early 1960’s and Round Up herbacides with Glysophate was patented in 1973. These crops did not exist for 10,000 years ago. So how could this be a part of the normal breeding process where genes are inserted into the seeds in a laboratory. So much bunk but say it over and over with deep pockets of money and you can persuade any population with a lie. These so called professors should have their degrees surrendered for ethic violation. Just like doctors who malpractice. Selling your soul to biotect should have its consequences in this life now just after death.Shame on them.

    • Tom says:

      There have probably been tens of thousands of plant species throughout evolution that have been glyphosate resistant only no-one was around to spray them and find out. You can make glyphosate resistant crops with a single DNA base change. Glyphosate resistance means nothing outside agricultural ecosystems.

  25. John Diaz says:

    Tom, you are being ridiculous. Stay with the question. I asked the independant scientists to produce one peer review long term human feeding trial on humans by Monsanto.Show me any long term feeding trial on animals for that facts. All studies done by industry were limited to three months. These boys writting really need to back up your claims because so City government can truely understand that the dogma that is preached has been and trotted out for this issue is false. I say that because ask was stated that these were the most studied crops was false because the proprietary patented seeds, Monsanto prevented real independant scientists from investigation. When I say Real scientists I am talking about the ones who put their jobs on the lines ask they were discredited and lost their jobs or funding from the major universities. I do not respect the claim of independant scientists status n this article for that fact of the huge price paid by these brave men and women for speaking out and losing their livelihood.

    • Ewan R says:

      So when you say real scientists you explicity exclude anyone who doesn’t already support your view?

      That’s pretty clear already.

      http://www.sciencedirect.com/science/article/pii/S0278691511006399

      is a review paper which looks at 12 long term (Greater than 90 days…) and 12 multigenerational studies (how odd that there are even 12 to look at in either category given that you appear to be claiming there are zero… it’s almost like you haven’t looked)

      I do not respect the claim of independant scientists status n this article for that fact of the huge price paid by these brave men and women for speaking out and losing their livelihood.

      Logical incoherence does not an arguement make.

      • John R, Diaz says:

        Dear Ewan R. This is from one of the studies you sent. I placed the heading reference at the end so all can see and read your report.
        this is word for word
        “We can conclude, from the regulatory tests performed today, that it is unacceptable to submit 500 million Europeans and several billions of consumers worldwide to the new pesticide GM-derived foods or feed, this being done without more controls (if any) than the only 3-month-long toxicological tests and using only one mammalian species, especially since there is growing evidence of concern (Tables 1 and 2). This is why we propose to improve the protocol of the 90-day studies to 2-year studies with mature rats, using the Toxotest approach, which should be rendered obligatory, and including sexual hormones assessment too. The reproductive, developmental, and transgenerational studies should also be performed. The new SSC statistical method of analysis is proposed in addition. This should not be optional if the plant is designed to contain a pesticide (as it is the case for more than 99% of cultivated commercialized GMOs), whilst for others, depending on the inserted trait, a case-by-case approach in the method to study toxicity will be necessary”

        monitoring
        “For the record, it must be said that very few tests on humans have been carried out up to now. Moreover, epidemiological studies are not feasible in America, since there is no organized traceability of GMOs anywhere on the continent, where, by far, most of edible GMOs are cultivated (97%). As a consequence, a post-market monitoring (PMM) is offered to the population. The Cartagena Biosafety Protocol identifying GMOs at the borders of a country has now been signed by over 150 countries, including the member states of the European Union. PMM may have some value in detecting unexpected adverse effects. It could therefore be considered as a routine need. This approach makes it possible to collect information related to risk management. It can be relied upon as a technique for monitoring adverse events or other health outcomes related to the consumption of GM plant-derived foods, provided that the Toxotest approach, together with the SSC method, should have already been applied. The PMM should be linked with the possibility of detecting allergenicity reactions to GMOs in routine medicine, thanks to the very same routine cutaneous tests that should be developed prior to large-scale commercialization. A screening of serum banks of patients with allergies could be also put forward in order to search for antibodies against the main GMOs and not only their transgenic proteins, since they may induce secondary allergenic metabolites in the plant not visible in the substantial equivalence study.

        The traceability of products from animals fed on GMOs is also crucial. The reason for this is because they can develop chronic diseases which are not utterly known today. Such possible diseases could be linked to the hepatorenal toxicity observed in some GMO-related cases (Table 1).

        Moreover, labeling animals fed on GMOs is therefore necessary because some pesticide residues linked to GMOs could pass into the food chain and also because nobody would want to eat disabled or physiologically modified animals after long-term GMOs ingestion, even if pesticides residues or DNA fragments are not toxic nor transmitted by themselves”
        GENETICALLY MODIFIED CROPS SAFETY ASSESSMENTS: PRESENT LIMITS AND POSSIBLE IMPROVEMENTS
        Gress1, Joël S de Vendômois2 and Dominique Cellier3
        * Corresponding author: Gilles-Eric Séralini criigen@unicaen.fr

        Author Affiliations

        1 Laboratory of Biochemistry – IBFA, University of Caen, Esplanade de la Paix, 14032 Caen, Cedex, France

        2 CRIIGEN, Paris, France

        3 University of Rouen LITIS EA 4108, 76821 Mont-Saint-Aignan

        • John R, Diaz says:

          Even R, there is no need to be rude to me by your comment on bias. I am sorry but Biotech’s History in the last election in California on Prop 37is now well known. The chemical companies openly discuss that they cannot keep telling the same lies. Too many states are now going for labeling. The chemical companies hid their disinformation tactics behind Astroturf Croplife. We now have a bill sb52 in the assemble to put the top 3 contributors in huge letters 5 seconds before the ad appears. But let’s get back to the subject at hand.
          One, I asked for long term studies on Humans and received – none. I does not take a scientist to understand what is going on. You can read about the chatter of Chemical companies that address insect and herbacide resistance on their sales sites. Dow chemical GM 2-4d Corn(Agent Orange Corn) has been not yet approved in the USA and won’t be looked at by the USDA until 2016. But I believe Canada has entered a product similar into it’s food supply. Now, tell me that eating 2,-4d – half the ingredients in Agent Orange is good for us? Read: PESTACIDE TREADMILL! Monoculture controlled by chemical is our new norm. It’s a money maker for sure but our sad reality. Now, you kids have to excuse me as I do work for a living and because of time pulled up one of the studies that was the longest one you sent. It is qite interesting. I have copied and posted it above. I am still waiting for the long term studies on humans.

  26. Safe Food says:

    I stopped reading this when you said that genetically modified crops are “the most highly studied foods that humans eat.” If your argument is based on that lie, then nothing else you say has any merit. In fact, Monsanto argued to the USDA and FDA, both of which are controlled by Monsanto former attorneys and lobbyists, that their genetically modified organisms are “substantially equivalent” to natural food and therefore they don’t need any studies whatsoever. The USDA and FDA, controlled by Monsanto attorneys and lobbyists, agreed, and have allowed Monsanto’s genetically modified organisms to enter the food system, in fact, with no testing whatsoever. Any academic researcher who even tries to study Monsanto’s genetically modified organisms will be fired since most academic funding in this area comes from Monsanto. See “Scientists Under Attack” for specific details of this. And, furthermore, Monsanto prevents independent study of its genetically modified organisms through its legal licensing terms. The only legitimate long term academic scientific study ever done on Monsanto genetically modified corn, in France, showed a dramatic increase in tumors in rats fed Monsanto genetically modified corn compared with rats who ate natural corn.

  27. Tyler says:

    Dear Karl,

    Thank you for your time and opinions on this highly debated issue. I suspect your panel is well educated. Would you be willing to list the names of those on your panel and show individual financial disclosures? My understanding is that bill #2491 is trying to keep those living in Hawai’i well informed. There may be regulatory agencies involved but unfortunately like it or not lobbyist can influence regulations. It is my opinion that we should have a right to know what is going on in our community. The general community are less likely going to be viewing Web sites such as http://www.isb.vt.edu/data.aspx and doing searches, that is not so practical. I see your point on the dangers of advertising where gmo experiments are occuring, ie destruction of gmo papayas in the past. In the end however ultimately I feel it is the right for proper disclosure. Unfortunately, Hawai’i has been the testing grounds for years. For example, agent orange in the late 60’s. Granted the EPA wasn’t formed until the early 70’s but you get my point. Also, despite your claim of have an unbiased opinion about this issue, I suspect given your background and likely your panel members, it would be hard to be completely unbiased. In fact, I would suspect an unbiased note to the K’auai counsil would discuss both pros and cons of the bill, not only the cons.

    Mahalo.

  28. Ken says:

    Aloha Karl,
    I have nothing against BIOTECH, but I do not like to be constantly bombarded with Pesti-dust(dust laden with pesticides). I do live in Waimea Valley where we get lots of exposure and most of the people who are for GMO do not live or do not care about their health and welfare. What more proof do we need when we feel, see, taste, smell this stuff everywhere in Waimea. We have the proofs; videos/pictures of dust plumes over the valley & in our homes; have tested the water and have found the chemicals that these companies use. What we are asking and is not being done is monitoring these corporations. Just try and find the documents/records of what is supposedly being done to ensure public safety. When these companies started farming they made promises to comply with all Federal/State regulations and I have found many promises broken. ie: grubbing permits which were not on file for over 10 years. This permit is required before doing any type of dirt movement in the state. We could have collected much needed revenue from these billion dollar companies if the state would have fined them but they got away again. There is also the issue of using restricted pesticide when these were banned years ago yet these companies have recently admitted that they have used them in our area. Spraying/farming upwind of adjacent communities requires a concerned effort and these companies have told us to our faces: “Take us to court, we have the best lawyers that money can buy”, or how about “These chemicals are safe” . Well do your homework and find the evidence is what I say and then move to Waimea and feel/see the difference, don’t tell me anything when you are not here. “Seeing is believing” Aloha Ken

    • Hi Ken, I can see where you are coming from. If the companies are breaking the laws, then the laws simply need to be enforced. This bill doesn’t seem to be focused on increasing enforcement. I’m not particularly familiar with the dust issue, and that is an issue in many places where farming occurs. I’ll talk to the companies to see what they are trying to do to control dust. They don’t want to lose the topsoil, either. With regard to water testing, I have inquired about that, and a group did go around with test strips to detect chemicals like atrazine, and got positive results. These test strips can detect a few parts-per-billion of pesticides. But when more sophisticated methods were used, the levels were far lower, in the parts-per-trillion range. Part-per-trillion are not something to worry about. Perhaps you are speaking of other tests that I am not aware of?
      Restricted Use does not mean that no one can use it or that it is banned, but it does mean that an extra level of regulation is placed upon them.
      Anyway, it makes you wonder, if the issue is really about pesticides (and not following the rules about their use), then why are GMOs even in this bill? Why isn’t the bill written as a bill to address the particular issues that people are talking about?
      I will actually be in Kaua’i next week, and plan to go around documenting what is going on first-hand. If you can point me to a good place to go, I would appreciate it.

      • John R, Diaz says:

        Dear Karl, what this is about is the many issues of GMO Monoculture. The issues are Monopoly of the food supply. The right to save seed. It’s about the fact that the people are waking up and learning about the lies of disinformation put out by industry shills; scientist in sheep clothing that sell this technology that promote it as safe as spraying water. It’s about the pestacide tread mill of GM monoculture that is failing.People are waking up to the fact that of out of 80,000 chemicals on the market only a few hundred have been tested for safety*.(Presidential Panel on Cancer 2010) Once these products are approved to be put on the market it takes a huge grass roots effort to get them off. This bill, this grassroots movement is what you are seeing and let’s be honest that this is what you have come to Kauai to fight.

        • Ewan R says:

          If that were what the issue was, why isn’t that what the Bill is about?

          This isn’t a “right to save seed bill” or a “do more testing bill” or a “no monopolies in Hawaii bill” – all of which would directly address your what you are bringing up.

          Once these products are approved to be put on the market it takes a huge grass roots effort to get them off.

          Only when taking them off the market is completely unwarranted. Actual evidence they are harmful would be enough otherwise, but I guess when all you have is your ideology and zero evidence mob rule and disinformation is what you must rely on.

  29. ChemieBabe says:

    Hello,

    I just found this site after some one from Waimae posted a comment on a Western Farm Press Site. I am a licensed Pest Control Adviser in CA. I work with growers and regulatory agencies. Good information Karl, unfortunately the anti everything crowd will not even consider that there is any merit to scientific research that does not support their view. I loved the “French Rat Test” with GMO’s! It was so flawed and yet many people see it as proof of the dangers of GMO’s. The really silly thing is you can choose to buy organic and pretty much avoid GMO’s and conventional pesticides if you so desire.

    • John Diaz says:

      ChemieBabe, Recently the European Union Food Safety Authority adopted the scientific methodology that was used in the Seralini peer reviewed two year study. The implications of this is huge as to why we need not ingest foods made from GMO’s. I cannot help but laugh at the remarks of Science based knowledge represented on this site, – give me a break! Herbacide and insect resistance is now a major problems of GE Monoculture. Google Purdue’s Burndown Madness. They advise adding a little 2-4d to you glysophate to get rid of the pesky super weeds. To combate this super weed problem from the overuse of glysophate, Dow’s 2-4d is now planned to be released in Canada and the USA in early 2014. 2-4d was half of the component used to make up Agent Orange. Our government is paying out liability to members of the armed forces that were exposed to Agent Orange in Vietnam. To put this into a product that has the ability to translocate the poisen into every cell of the plant – into “every bite” is shocking. Would you want to feed your child a know carcinogen? The main fact is that the consumer is King. They are the one that are spending their hard earned money. As for avoiding gmo’s and pesticides by choosing organic does not consider in the problem of cross contamination of gmos into organic agriculture and the fact that we are breathing and drinking glysophate from our ground water.

      • Ewan R says:

        Water was also a component of agent orange. My municipality pumps it willy nilly under the streets and into people’s abodes. (Hint – the part of agent orange that was contaminated with dioxin was the non 2-4d part… thus the connection is spurious and dishonest)

        Agent orange was a mix of 2,4-D and 2,4,5-T. The dioxin in question was an unintended byproduct of 2,4,5-T production. If 2,4,5-T were being recommended for use to combat glyphosate resistance then perhaps the Agent Orange arguement would have some merit. Alas however, you’re left looking either hoodwinked or palpably dishonest.

      • John, what you said about EFSA “adopting” Seralini’s protocol is completely false. In fact, they criticized his study quite heavily. You are referring to the claim that a set of guidelines produced by EFSA had “vindicated” Seralini, which is incorrect, as I will demonstrate.

        The chief criticism of Seralini’s study is that the number of rats in each treatment group were small (10 per sex), and the duration of the experiment was long, a combination which we would expect to find differences due to the random factors that come up in old age. The rats he used were prone to getting a high rate of tumors over their lifespan, and the rates of tumors in Seralini’s study were in the expected range for these rats. In order to do a proper carcinogenicity study, he should have used a larger number of rats per group (50 per sex) to smooth out that variability. And his results did not show a dosage effect, such as a correlation between the amount of GE corn eaten and the number of tumors. He found some groups with more, and other groups with less than the single control group, which is what we would expect with few rats and a highly variable outcome, such as tumors in tumor-prone rats.

        The EFSA guidelines that are being referred to were described by supporters of Seralini as a “vindication” of his protocol, but they base this on a few of the recommendations matching Seralini’s protocol, but not the key issue with regard to the number of rats in each group. On page 12 of the document, they clearly state that 50 animals per sex per dose group is appropriate for a carcinogenicity study. They also recommend an additional 10 animals per sex per dose group for additional experiments on toxicity for a long-term experiment (60 total per group), whereas Seralini only had 10 total per group for his carcinogenicity study.

        The EFSA guidelines go on further on page 13 to address how researchers need to be careful to design their study to test a particular hypothesis and use a number of animals that can find differences between the groups given the natural variability for that trait. For something with a lot of variability like the appearance of tumors you have to make sure that the number of animals you use will allow you to capture real differences between the groups. It appears from Seralini’s study (and his descriptions of the process) that he started a 90-day study and then extended it to 2 years. He should have started over with the right number of animals for a long-term study.

        Direct PDF link to EFSA guidelines:
        http://www.efsa.europa.eu/en/efsajournal/doc/3347.pdf

        The claim that the EFSA was “vindicating” Seralini is also very odd because they published a review of his study and concluded that it did not provide useful information because of how it was designed, carried out, and reported.
        http://www.efsa.europa.eu/en/press/news/121128.htm
        http://www.efsa.europa.eu/en/efsajournal/pub/2986.htm

        There is already a 2-year study on GE soybeans which found no such effects, and they used 50 rats per group. The article is in Japanese, but the abstract and figures are in English.
        http://www.ncbi.nlm.nih.gov/pubmed/18787312

        Here are a few more resources that discuss the issues with Seralini’s study. An unprecedented number of scientific societies and independent scientists have criticized his work, more than I have seen for any other study in this field.

        http://www.bfr.bund.de/en/press_information/2012/29/a_study_of_the_university_of_caen_neither_constitutes_a_reason_for_a_re_evaluation_of_genetically_modified_nk603_maize_nor_does_it_affect_the_renewal_of_the_glyphosate_approval-131739.html
        http://dotearth.blogs.nytimes.com/2012/10/19/six-french-science-academies-dismiss-study-finding-gm-corn-harmed-rats/?_r=0
        http://parrottlab.uga.edu/ProfParrott/rats2012.html
        http://weedcontrolfreaks.com/2012/09/why-i-think-the-seralini-gm-feeding-trial-is-bogus/

        I could pile them on but I think you get the idea! For a lighter way of looking at how scientists have been criticizing Seralini’s study, see this web comic. It gives statisticians a good laugh.
        http://xkcd.com/882/

  30. John Diaz says:

    Karl, so just what is this site about? I see a one sided mioptic view from group that talks about science and blames the activist for their view, but we do not hear from the environmental science’s also found at our universities. Much is written: The science on chemical polution, genetic drift, monopoly of GE agriculture, the monopoly of GE agrgiculture’s economy of scale, Pesticide and herbacide resistance, the revolving door of politics, impact of GE agriculture and the soveignty of agriculture in nation states due to monopoly patents of food in the third world and the displacement of the third world farmer class. The paradigm of GE agriculture goes beyond the gentelmen and women working in the lab. They are far to busy in their own discipline and family life to look outside their area of expertise. I have talked with so many people who claimed to posses scientific knowledge, but were so unaware of these issues.

    • Well we have some About pages that go into that. The posts that appear here have either been written by us, or contributed by others on a voluntary basis. We’ve been trying to seek more diverse points of view, and we recently started with some posts written by an organic farmer. As long as it is factual, interesting, well-written, and in the topic areas we write about, we will try to publish it. We do have some posts discussing those very issues you bring up.

      As for the men and women working in the lab, a huge amount of agriculture-related science is done out in the field, and working with farmers and more. So I don’t share your view that these issues aren’t being considered – or that they aren’t being considered by the scientists.

  31. John Diaz says:

    Poisen Babe, please, I haad to learn about 2-4d as to not give out misinformation as I educated consumers on this matter here is a read for you, but first let me say an arguement of my science is better than yours is worthless other than allowing the consumer to discern the truth.Dow’s genetically engineered corn (DAS-40278-9) designed to survive repeated spraying of the toxic herbicide 2,4-D (Docket No. APHIS–2010–0103), a major component of Agent Orange, the chemical defoliant used by the U.S. military in Vietnam.

    The scientific community has sounded alarms about the dangers of 2,4-D for decades. Numerous studies link 2,4-D exposure to major health problems such as cancer, lowered sperm counts, liver toxicity and Parkinson’s disease. Lab studies show that 2,4-D causes endocrine disruption, reproductive problems, neurotoxicity, and immunosuppression: Further, industry tests show that 2,4-D is contaminated with dioxins. Dioxin contaminants in Agent Orange are thought to be a major cause of many serious medical conditions in both Vietnam veterans and the Vietnamese, including birth defects in the children of exposed parents. EPA has reported that 2,4-D is the seventh largest source of dioxins in the U.S.

    Commercial approval of Dow’s corn will trigger a large increase in 2,4-D use, but USDA has not conducted a meaningful review of the consequent harm to native ecosystems, crop injury from 2,4-D drifting onto neighboring fields, or the evolution of weeds resistant to 2,4-D. Despite its short half-life, 2,4-D is frequently detected in surface waters throughout the U.S. and in groundwater in five states and Canada. Even the existing uses of 2,4-D have been found likely to jeopardize protected species, such as Pacific salmon, the California red-legged frog and Alameda whipsnake; USDA’s proposed unrestricted approval of 2,4-D corn would worsen these impacts, as well as place many other similar and endangered species at risk. Yet the agency has refused to account for these adverse impacts. Additionally, Dow plans to sell this GE 2-4,D corn “stacked” with resistance to glyphosate—the active ingredient in Roundup—or other herbicides, yet neither Dow nor USDA has analyzed the potential synergistic or cumulative impacts that these planned combinations pose.

    Further, this corn has also been engineered to resist another herbicide (quizalofop) never before used in corn. This will likely cause a massive increase in the use of this herbicide, the increase of which has not been properly evaluated for human health or environmental impacts. Given the numerous inadequacies in the USDA’s Environmental Assessment (EA), an approval of this crop should not be considered without at least a full and rigorous Environmental Impact Statement (EIS).

    2,4-D-resistant crops may also pose a new food safety risk in the introduction of 2,4-dichlorophenol (2,4-DCP), a breakdown product of 2,4-D when applied to resistant crops. French scientists who studied the matter concluded that 2,4-D-resistant plants sprayed with 2,4-D may not be acceptable for human consumption due to contamination with 2,4-DCP.

    Finally, Dow is hyping 2,4-D corn as the supposed solution to glyphosate-resistant weeds, which themselves were fostered by GE Roundup Ready crop systems. Yet studies already indicate this approach will rapidly generate weeds with resistance to both herbicides. As Dow and other pesticide firms develop new crops resistant to ever more herbicides, weeds will match and exceed them by evolving multiple resistances, and farmers will respond with increasingly toxic herbicidal cocktails. This chemical arms race with weeds means more pesticidal pollution, more disease, higher production costs, and of course increasing profits for firms like Dow that sell both GE seed and pesticide.

    At a time when farmers, citizens and government have worked hard to limit our use of, and exposure to, toxic chemicals like 2,4-D and dioxin, approving this crop would take us dramatically backwards, endangering human health and the environment. If USDA wants to adhere to a true scientific process, it should stop ignoring the science that doesn’t suit the interests of the biotechnology industry.

  32. ChemieBabe says:

    The test I am talking about was not conducted for two years and was highly criticized by researchers in Europe for being flawed and the evidence not supporting the data. Maybe Mr. Seralini has done some other work?

    It is clear that those in the activist camp will never believe any thing produced by the chemical companies, the Universities, or anybody not on the “activist approved” list. The only thing that will make them happy is to shut down modern agriculture and move back to the stone age. Watch what you wish for, you just might get it!

    • John Diaz says:

      Chem, I have no idea about the test you are talking about. You must provide a link. Did you learn anything about the information on 2-4d? You see, in a past I was talking with a farmer that blamed the toxcidity of Agent Orange on the other component of 2-4d. I said well.. that stuff is also no good. Later,I though, Hey, I need to go home tonight and look it up otherwise I would be giving out false information.
      We live in an amazing day of age where content was only available at the University level and government agencies. Now with through the internet and freedom of information we can look up peer review journals and the FDA,to read what the FDA scientist write about their findings on this subject. It seems do to your lack of knowledge on 2-4d that you should not write before you speak. Only an uninformed consumer would buy into the disinformation found on this site. Funny how you are silent on this. Karl has not responded to my comment to him either..hmmm

      • John, I had not yet responded to your comment because I was out doing work in the field and on campus today and not in front of my computer. I regard this comment of yours as trolling and I think you should think more about your words before you type them out and hit enter.

  33. ChemieBabe says:

    John,

    I was talking about the tests done by Seralini were he fed GMO maize to rats and then published his results and European researchers shot his methodology down. You mentioned him in an earlier post and you talked about the EUFSA so I thought you knew about that.

    I did not address the 2,4,D issue as you seem to have made up your mind on that subject. It was dioxin that was a by product of the 2,4,5-T manufacturing process that was the problem. I have had activist tell me it was RoundUp that was Agent Orange and that is not correct. I have used 2,4,D. It has been sprayed it on grain crops for many years and on range land for broad leaf weed control. I have been present when it has been applied by air, and I worked as a flagger for a crop duster back when that was legal. I would say I have some knowledge about the subject.

  34. John Diaz says:

    Chemical, Babe, as I was saying the study you were refering to was the Serilini study. It was a two year long term study. Thanks for bringing it up because it was that two year study that the European Union Food Safety Authority adopted the long term methodology used in the study.Biotect panned the study over the methods used but by the EUFSA adopting the study methods used to this peer reviewed long term study now is stands confirmed. Russia and France blocked the sales of these gmos to their countries over this. I don’t think eating this corn is a good idea. You tried to trash this report witbout knowing the facts, plain and simple.

  35. ChemieBabe says:

    I wasn’t trying to trash any thing. Turns out we were talking about two different things. You seem very defensive and I would agree with Karl about your trolling. I am pretty much done talking to you because you are just spewing things you find on the internet and like Karl I have an actual job, in agriculture. Have a nice life!

    Namaste

  36. ChemieBabe says:

    Thanks Karl, for the excellent write up on Seralini’s protocol and all the links.

  37. Eric Toulon says:

    The sad part about this is this probably wouldn’t be anywhere near as inflammatory as it is if the seed companies had properly been taking care of the lands, particularly on the west side of Kauai.
    Between crops they allowed the lands to overgrow as a result of which we had a huge mouse infestation, when they finally came in and did something mice were all over the place. We had some grapes next door to the seed fields and while we had mice, the owls were more or less taking care of the problem.
    Unfortunately when they started poisoning the mice guess what happened to the owls? Within about two weeks of their poisoning I found the carcasses of at least five owls.
    I contacted the department of health who told me over the phone they were probably poisoned… really?
    If the seed companies had been mowing a swath by the communities so they wouldn’t have been inflicted with the weeds and mice, a lot of this wouldn’t be an issue.

  38. John Diaz says:

    Dear Karl and Chembabe, sorry to inform you that your information on the Serilini report was outdated. Here is the report that came out a year later which vindicated Serilini as they adopted his lab techniques used in the study as protical for future long term studies http://www.efsa.europa.eu/en/efsajournal/pub/3347.htm
    Here it is open for all to read below:
    Seralini validated by new EFSA guidelines on long-term GMO experiments
    The European Food Safety Authority (EFSA) has issued guidelines for two-year whole food feeding studies to assess the risk of long-term toxicity from GM foods.
    http://www.efsa.europa.eu/en/efsajournal/pub/3347.htm
    This is a fascinating document which largely validates the methodology and choices of Prof, Gilles-Eric Seralini in his 2012 study on GM maize NK603 – methodology and choices that EFSA and countless other critics previously attacked him for.

    Particular points to note:

    1. EFSA admits that “no standardised protocol or guidelines exist for this type of study and [industry] applicants have to adapt protocols” – as Seralini did, too.

    2. EFSA says the same strain of rat that was used in the 90-day study on the GM food should be used in the longer study – thus vindicating Seralini’s use of the Sprague-Dawley rat, which Monsanto used in its 90-day study on the same maize.

    3. EFSA says animals should be fed ad libitum, which Seralini did, but which critics complained made it impossible to measure individual food and water consumption.

    4. EFSA admits that you do not necessarily need a narrow and fixed hypothesis and that such a study can be “exploratory”, in spite of its previous claim that Seralini’s experiment was flawed because it (according to EFSA) didn’t have a clear hypothesis or objective.

    5. EFSA recommends against using the extra control or “reference diet” groups commonly included by Monsanto in its 90-day studies and fed a variety of supposedly non-GM diets, on the grounds that the concurrent controls are the valid controls AND what is being tested is the difference between the GM variety and the non-GM comparator. Seralini was criticised by many for not including these spurious extra control groups and for thus having “inadequate controls”.

    6. EFSA cautions strongly AGAINST relying on historical control data and if it is used, restricts it to within 5 years of the current experiment and to the same testing facility. This is a much stricter requirement than industry ever applies; industry uses ancient data from a wide variety of sources.

    EFSA says: “The use of historical control data should be considered with caution. The historical controls might not be useful because the incidences of neoplastic (or non-neoplastic) lesions would possibly be from control animals kept on different diets than the diet applied in whole food/feed study, and because the diet itself (high/low fat, type of fat, % of carbohydrate, type of carbohydrate, etc.) can influence the formation of neoplastic or non-neoplastic lesions. Where the diet formulation used in the experiment for the control groups cannot be demonstrated to be equivalent to that used for the generation of historical control data, the inclusion may be considered of an additional control group (as similar as possible to the historical controls), in addition to the concurrent control group(s).”

    It’s unfortunate that in rightly condemning the use of historical control data, however, EFSA allows in those extra control or “reference” groups that it rightly condemned in point (5) above.

    7. EFSA recommends a minimum of 10 animals per sex per group for the chronic toxicity phase, the same number that Seralini used.

    8. EFSA recommends housing animals in pairs, as Seralini did, so individual food consumption cannot be measured.

    9. EFSA requires an a priori power analysis to ensure appropriate sample size, depending on the effect size that is being looked for. We’ve never noticed the GM industry doing one of these, resulting in experiments that are virtually guaranteed not to find anything. For Seralini’s team’s comment on this, see:
    http://www.ijbs.com/v05p0706.htm

    Overall, we’re pleased to see EFSA taking on board our cautionary lessons on spurious “reference” control groups and historical control data (even if in the same document EFSA subsequently allows the use of both!), as well as validating the aspects of Seralini’s experiment that he was most criticised for.
    ………………………………………………………………………….
    France and Russia suspended grain sales from the USA over this study. I don’t think it is wise to continue to grow and eat foods that have to be registered as pesticides and that cause cancer after reading this.

    • John, evidently you did not take the time to read my comment above, wherein I go into detail about why the EFSA did not “vindicate” Seralini on the most important aspect of his study, and that is the choice of group sizes and study lengths. Seralini was trying to make conclusions about carcinogenicity, which would require 50 animals per group, plus 10 for a parallel toxicity study. He did not do this. The EFSA was very specific about determining the proper number of animals for the type of study you are doing. Seralini’s study was exploratory, and he should have repeated it with the appropriate number of animals before making his extraordinary claims.

      Moreover, all you did was just copy and paste the contents of this page on Seralini’s Fansite, without reference, which is against our comment policy. It may also be considered plagiarism as you are representing them as your own words. I think it would benefit your argument a lot more if you would be able to integrate some understanding of the issues and what I said about them before making declarations about me or others.

      You say it is unwise to grow and eat foods that cause cancer – and I agree – but Seralini’s study did not demonstrate that GE foods cause cancer – and his protocol wasn’t even capable of trying to.

      • John Diaz says:

        Sorry to inform you Karl, but you must first read the article then comment. Nothing was violated as the direct link to the EUFSA was provided and Serilini always gives the authority to reprint his independent science as rebuttle as his name was referenced in this article. Have a nice day. So nice to share opinions Karl.

        • John, you are apparently still not even reading my comments. I’m already intimately familiar with the EFSA guidelines, Seralini’s paper, the EFSA’s review of it, and the “GMO Seralini” fansite post that you copied and pasted without linking to it. I’m putting thought and time into my comments, and you are not reciprocating. So you’re really not having a discussion.

  39. John Diaz says:

    Thanks Karl, It is great that we can share varied opinions on this matter.. Ewan in a comment gave me the link to this scientist: This is from one of the studies he sent to me. I placed the heading reference at the end so all can see and read your report.
    this is word for word
    “We can conclude, from the regulatory tests performed today, that it is unacceptable to submit 500 million Europeans and several billions of consumers worldwide to the new pesticide GM-derived foods or feed, this being done without more controls (if any) than the only 3-month-long toxicological tests and using only one mammalian species, especially since there is growing evidence of concern (Tables 1 and 2). This is why we propose to improve the protocol of the 90-day studies to 2-year studies with mature rats, using the Toxotest approach, which should be rendered obligatory, and including sexual hormones assessment too. The reproductive, developmental, and transgenerational studies should also be performed. The new SSC statistical method of analysis is proposed in addition. This should not be optional if the plant is designed to contain a pesticide (as it is the case for more than 99% of cultivated commercialized GMOs), whilst for others, depending on the inserted trait, a case-by-case approach in the method to study toxicity will be necessary”

    monitoring
    “For the record, it must be said that very few tests on humans have been carried out up to now. Moreover, epidemiological studies are not feasible in America, since there is no organized traceability of GMOs anywhere on the continent, where, by far, most of edible GMOs are cultivated (97%). As a consequence, a post-market monitoring (PMM) is offered to the population. The Cartagena Biosafety Protocol identifying GMOs at the borders of a country has now been signed by over 150 countries, including the member states of the European Union. PMM may have some value in detecting unexpected adverse effects. It could therefore be considered as a routine need. This approach makes it possible to collect information related to risk management. It can be relied upon as a technique for monitoring adverse events or other health outcomes related to the consumption of GM plant-derived foods, provided that the Toxotest approach, together with the SSC method, should have already been applied. The PMM should be linked with the possibility of detecting allergenicity reactions to GMOs in routine medicine, thanks to the very same routine cutaneous tests that should be developed prior to large-scale commercialization. A screening of serum banks of patients with allergies could be also put forward in order to search for antibodies against the main GMOs and not only their transgenic proteins, since they may induce secondary allergenic metabolites in the plant not visible in the substantial equivalence study.

    The traceability of products from animals fed on GMOs is also crucial. The reason for this is because they can develop chronic diseases which are not utterly known today. Such possible diseases could be linked to the hepatorenal toxicity observed in some GMO-related cases (Table 1).

    Moreover, labeling animals fed on GMOs is therefore necessary because some pesticide residues linked to GMOs could pass into the food chain and also because nobody would want to eat disabled or physiologically modified animals after long-term GMOs ingestion, even if pesticides residues or DNA fragments are not toxic nor transmitted by themselves”
    GENETICALLY MODIFIED CROPS SAFETY ASSESSMENTS: PRESENT LIMITS AND POSSIBLE IMPROVEMENTS
    Gress1, Joël S de Vendômois2 and Dominique Cellier3
    * Corresponding author: Gilles-Eric Séralini criigen@unicaen.fr

    Author Affiliations

    1 Laboratory of Biochemistry – IBFA, University of Caen, Esplanade de la Paix, 14032 Caen, Cedex, France

    2 CRIIGEN, Paris, France

    3 University of Rouen LITIS EA 4108, 76821 Mont-Saint-Aignan

  40. Ewan R says:

    Ewan in a comment gave me the link to this scientist

    Scientist…. you keep using that word….

  41. ChemieBabe says:

    That would be the point. The radical anti pesticide, anti GMO, crowd is not interested in a discussion. They just spew information they find on the internet, they don’t do any fact checking, they just put it out there. That’s why a lot of people tune them out and don’t bother reading their “manifestos”.

    Whole Foods produced a very nice video last week on Face Book about their efforts to label GMO foods in their stores. The reaction from the radical anti crowd was over the top, and very negative. Maybe the best answer is for those folks to quit eating. There is no safe food any where people! There, I posted it on the internet, so it must be true!

    Thanks again Karl,
    ChemieBabe

  42. ChemieBabe says:

    Eric,

    That really sucks! The seed company or any farmer needs to be responsible for their fallow ground. Maybe a local ordinance that makes them clean up their mess is in order. Poisoning owls and other non target species is just plain wrong. Have you reported the dead owls to other agencies, such as Fish and Game, or EPA? Some times you need to find the right agency in order to get the best response to a problem. If the grower used poison bait incorrectly maybe the Ag. Dept. needs to be involved.

  43. Cameron says:

    I lived on Kauai for three years from 2007 to 2010, and I learned a great deal about local perceptions of GM crop trials.

    Some of the smartest people I met put the situation this way:

    Kauai is a small island, roughly 30 by 35 miles. It is also one of the most isolated landmasses in the world. Corporations find its climate desirable for field trials. Many of the citizens of Kauai think that there are much more desirable ways to use the land for agricultural research than to permit GM field testing.

    I asked these citizens, “What are some more desirable uses of the land vis-à-vis agricultural research?” Here are some responses:

    Kauai is home to a thriving permaculture research community. Why not encourage large-scale permaculture research on land tracts that are insisting on GM field trials? It would be extraordinarily beneficial to industrial agricultural research communities to learn how to integrate sophisticated (molecular biology-based) permaculture insights into industrial agriculture. Since the citizens of Kauai are already highly-conscious of land use patterns related to agricultural research, there is a unique opportunity to leverage that concern in ways that will be most beneficial to humanity. Conventional GM field trials can happen anywhere. The mix of cultural factors in Kauai is absolutely unique worldwide, and the best fit for this community would be to enact legislation that integrates the industrial agriculture research agenda with the permaculture agenda of the citizens.

    Based upon these remarks, I would encourage the City Council of the County of Kauai to craft legislation pursuant to large-scale permaculture research.

    Personally, I am more concerned with “Agrilogistics” in general (Timothy Morton’s term) than I am with the techniques of genetic modification of crops. We have an opportunity on Kauai to influence the culture of industrial agricultural research, and we should use this opportunity wisely. Rather than contribute to the larger activist battle against GMOs, I strongly believe that we should use deploy our collective efforts toward the integration of permaculture research within the umbrella of contemporary agricultural research. In time we may trigger the development of alternative knowledge practices that will more effectively accomplish what biotechnology pioneers hoped for when they first dreamt up the techniques of genetic modification at a bar in Waikiki.

    • Thanks for your perspective! During my visit to Kaua’i I picked up on the desire for more research and land use for the kinds of purposes that other local residents want. However, when I talked about this issue with representatives from three of the companies whose facilities I visited, they had already tried that route. They tried offering to lease (even for free) some of their land for farmers to grow other crops in any way they wanted to, but were turned down. One was proposing grants for locals to start up their own farms and do whatever they wanted with it, and the response in that case was rejection, along with calling it “blood money.” I agree that the long-term solution will involve more integration (and less division) in the use of the land on the island, but right now it seems that will be very difficult, socially and politically.
      Part of the problem I think is that some people have a desire for a certain type of farming to be done in their local area, however, few want to actually do it themselves. Limiting or kicking out forms of agriculture that they don’t like is the closest thing to encouraging agriculture that they do like. The assumption seems to be that in the newly opened-up void, that the farms they are looking for will just show up.

      • Cameron says:

        Karl, the farms they are looking for are more likely to show up in a newly opened-up void after kicking out forms of agriculture that they don’t like than they are after rolling over. Clearly the companies doing GM crop research on the island will continue have problems. Kauaians are known for protesting in large numbers. Hundreds jumped into the harbour channel on surfboards to stop the Super Ferry. Those Super Ferry protests were organized through a community radio station that is very popular and very anti-GM crop research. They are also conscious of their island’s plantation history. Sugar cane left a large portion of the island’s soil completely leeched, and corporate owners of the plantation were instrumental convincing plantation workers to overthrow the monarchy once upon a time. “Blood money” is no joke for people whose great grandparents witnessed that history. My sense is that GM crop research on Kauai will be more trouble than its worth in the long run. For that reason I am quite sympathetic to this local legislation. With all due respect, public opinion should influence public policy in a functioning democracy.

        • Cameron says:

          And it’s not that the citizens have a deficit of understanding that will change public opinion “in the right direction” after non-partisan expert intervention. I think this is just one island on the planet for which GM-crop research might not be a good fit.

          • Ewan R says:

            Hawaii is not, as far as I know, at all desirable for field trials. It has a climate utterly unlike the target market.

            What is desirable about Hawaii is that one can grow crops year round. Hawaii is the nursery state.

            The area would likewise be useless for permaculture research that didn’t apply specifically to that environment – there is no use in building a system, or selecting a variety or transgene that does well in Hawaii, because the environment is so radically different to where you need to do well that the results would be devoid of meaning. (for no use here I of course mean in the grand scheme of things as seen by a large Ag company, clearly there is use in developing something if it is used locally)

            • Cameron says:

              Good points,

              Is it any wonder that many Hawaiian citizens find the local Ag company research agenda…gratuitous? It’s like, why here?

              Another angle: we know from game theory simulations in political science that people who feel they have been unfairly wronged in the past are less likely to behave logically. We also know that technical data is often filtered to coincide with background affect, i.e. how the person assessing the science feels about the party making scientific claims. When “honest brokers” from non-partisan research orgs enter the conflict and discuss the preponderance of evidence, the local citizens get the impression that those honest brokers are deliberately ignoring the politics of science. If the honest brokers wish to claim that good science doesn’t have politics, or that the facts can be completely distinguished from the values of the principals who utilize facts, then they are not so honest.

              • Cameron says:

                fyi, I don’t mean that the citizens of Kauai are behaving illogically. But I am acknowledging that experts on biotechnology often attribute illogical behaviour to the actions and arguments of citizens blocking GM crop research.

  44. ChemieBabe says:

    Cameron,

    That is really a well thought out, and well communicated post! I really hope it could happen that way.

    Best Wishes to all the folks on Kauai,
    ChemieBabe

  45. First Officer says:

    Can someone provide a link to the the latest amended text(s) of Bill 2491? I’m finding it hard to come by and i do find it interesting how all the anti-gmo sites supporting this bill do not publish the latest text(s) of it.

  46. DinkyDao says:

    Read you report and Carol Gonsalves comment about Rainbow papaya. That variety was developed at my former workplace. Recall that Drs. Paul Moore and Maureen Fitch (USDA) developed that variety in conjunction with the University of Hawaii. Unfortunately, we cannot combat fear and ignorance. Activists here on Kauai have threatened the mayor for vetoing the bill. The councilmembers who favor the bill have no scientific basis for writing and supporting the bill. However, they have resorted to deceitful practices to override his veto. It is in its eleventh hour because the override vote will commence in an hour today.

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