Initative I-522 fails to pass, what’s next?

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Heat map of election night results, by Bill Price. Blue = Yes, Red = No.

Washington Initiative 522, which proposed mandatory front-of-package labels for foods that contain genetically engineered ingredients, or GMOs, came out of election night trailing by about 9 percentage points, with some predicting that the measure failed, while some proponents held out, saying that the election was too close to call. Washington State is a mail-in voting state, and there are at the time of this article still over 300,000 votes that remain to be counted. Mercola.com announced victory prematurely, but the Biofortified Blog predicts that the initiative will fail to pass by about 47.7% Yes to 52.3% No, a 4.7% margin overall.

This calculation was based on multiplying the vote percentages for each county by the remaining votes in each county. While I-522 is projected to gain about 3,000 votes more for Yes than No votes and a few percentage points, it may still end at about 80,000 votes short of passing. This estimate was based on the numbers that were publicly available as of 9 pm Pacific Time, and the calculations can be seen here. Additional votes may be accepted if they were postmarked by November 5, but it is unlikely that these votes will differ significantly from the current trend.

Rachel Maddow covered the I-522 loss on her show on MSNBC, pinning the loss to the large amount of money spent by the No On 522 campaign, noting that most of the money on both sides came from businesses outside of the state.

2012-presidential

A county-by-county breakdown of the 2012 Presidential Election results. Note the same urban-rural pattern, but far more pronounced than the I-522 map. Source: US Election Atlas.  Colors reversed from I-522 map above.

Rachel Maddow called the defeat of Proposition 37 “a loss” for progressives, but assumes that perceptions of genetically engineered foods are politically polarized. Social science research indicates that political party affiliation is not a strong contributor to attitudes about GE foods. Most people remain undecided about genetically engineered crops, and there are some indications that increasing education level increases acceptance of GE. Instead, cognitive variables such as “risk-aversion” seem to play a bigger role than political affiliation or other demographic characteristics. (Instead, an urban-rural divide may more adequately explain the regional results than political party affiliation.)

In the political debate over I-522, this risk aversion may have also played a role in its defeat. The No On 522 campaign stressed the risk of increased food costs and strains on local businesses, and the possible reduction in product choice by companies that would choose to no longer sell in Washington State. In contrast, the risk of harm to health from genetically engineered foods that underlay the “Right to Know” argument from the Yes On 522 campaign failed to gain traction in the face of the scientific consensus that such risk was minimal to non-existent. Faced with competing claims that the measure would cost taxpayers nothing, versus up to $400 per family, like California proposition 37, the past of least risk may have been perceived to be to maintain the status quo.

The No On 37 campaign raised a record amount of money for a Washington State ballot initiative, however, the fundraising disparity between the No and Yes campaigns was 3 to 1, with a slightly wider margin of defeat than proposition 37, which had a 5 to 1 disparity in fundraising (4.7% estimate for I-522 versus 3% for prop 37). This does not support the argument that money alone accounted for the difference between early polls and final results. Campaign money helps get out your message, but ultimately, voters must decide based on their interpretation of the initiative. The 2012 presidential election broke many records for campaign finances, however, evidence is slim that prolific ads do much to sway public opinion.

Robert Shrum, a senior fellow at New York University’s Robert F. Wagner Graduate School of Public Service, said as reported on the Freakonomics blog:

In politics there is certainly no linear relationship between amount of money and degree of success. Just ask the well-heeled Republican losers of presidential primaries past — former Texas Governor John Connally, former Texas Senator Phil Gramm, and former Mayor and front-runner Rudolph Giuliani. Or how about Howard Dean, who raised and spent nearly $40 million before crashing and burning in the 2004 Iowa caucuses?
Big money without the right message can become a penny waiting for change.

By focusing on the money, and not the message, labeling proponents may set themselves up to be defeated in future GMO labeling battles in other states.

The Next Battlefield

In the aftermath of proposition 37, sights were set on Washington State as the next battlefield to win. Several other states are gearing up to repeat the process, and it is rumored that another attempt will be made at California again. Whether the loss of this ballot measure will put a damper on those efforts, or invigorate them remains to be seen.

The aftermath of I-522 is also sure to follow suit with prop. 37 with organized boycotts of companies that funded the campaigns against ballot measures. A campaign called GMO Inside, run by Green America and funded by some of the same food companies that backed the ballot measures, targets popular foods such as Cheerios to lock down their facebook pages, and advertise the products of their “partner” brands instead. Indeed, while the ballot measures have so far not succeeded in achieving mandatory GMO labeling, they have functioned as de facto cause-based marketing for the companies involved. Fears will continue to be stoked and competing products will be offered to satisfy those fears.

Another change in the political debate may come about with the pursuit of a federal pre-emption of state labeling laws, reports the New York Times. A federal law for mandatory labeling is the ultimate goal for the pro-labeling side as well, so taking the discussion to the federal level may bring a swifter end to the political debate than the current state-by-state approach. Last year, there were rumblings that food companies that had opposed proposition 37 were holding meetings about a possible federal-level compromise, but little information has been published about the end result of those meetings.

David Ropeik, a risk communicator, wrote before Election Day that the companies should embrace some sort of labeling scheme, saying that it comes down to trust, and that the companies should abandon their “Fear of Fear.”

Right now you are suffering the common corporate malady of Fear of Fear. The chance that a label like “may contain genetically modified ingredients” could scare away even one end-consumer, has frightened you into opposing such labeling. Your direct customers, the farmers who grow the food and the food companies who sell it, are even more afraid of this consumer fear than you are. The Fear of Fear is common. It seems to make sense. And certainly you and the food production and retail industry are right to some degree. Such labels almost certainly will scare some people away.

But the Fear of Fear has locked you into a myopic defensiveness blinding you to realities about how people respond to risk, psychological and cognitive realities that suggest that a change of tack on labeling may be far better for you, and acceptance of biotechnology, than you think.

But are labels for genetically engineered foods really high on the list of desires for Americans? A survey by researchers at Rutgers University (pdf) found that depending on how you ask the question, desire for labeling may be seen as high or low. When asked as an open-ended question about what information was needed on labels that is not already present, only 7% named GMO labels as needed. But when asked directly whether respondents thought GMO labels should be required, about 73% answered yes. There were similar levels for other kinds of information such as pesticide use, allergens, or antibiotics. Knowledge about these crops is low, however, about 3/4 of survey respondents were aware that GMOs existed. Some new pieces of information were also revealed by this survey. For instance, the desire for information is about as high for restaurant foods as it is for packaged products, while both labeling bills exempted restaurants from disclosure requirements.

Surveys continue to show both low levels of knowledge about genetically engineered foods, and a desire for more information. There is uncertainty about safety, and few people believe they are definitely safe or unsafe in general. The current situation can be both an opportunity for misinformation to take hold, but also education. For one thing, a total of $67 million has been spent by opponents of these two ballot measures combined, and there are no signs that this has eased people’s doubts about the technology. That same sum of money could have instead helped to turn the overall debate around through outreach and education. David Ropeik echoes this sentiment while calling for the companies not only to change their position on labeling, but also to spend considerable resources communicating that change. Andrew Revkin at the NY Times Dot Earth Blog chimes in that the current deficit-model thinking has mired climate scientists for years with little progress.

Labeling Endgame

Would it in fact be possible to form a coalition among scientists, companies, and labeling supporters to form an approach that would provide more information both about GMO content and safety, while minimizing costs and not creating a stigma? Can such a label be on the path to consumer education, awareness, and acceptance of genetically engineered foods, or how can that be achieved in absence of a label? If a mandatory label is inevitable, will the companies that make, or make foods from genetically engineered crops have a hand in its final form, or will the drafting of the legal language be ceded to the competing industry? Questions linger about what the eventual result of the labeling debate will be, and the status quo does not look good for either side. For now, we can at least laugh along with Stephen Colbert.

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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43 comments on “Initative I-522 fails to pass, what’s next?
  1. Will says:

    I don’t think Mercola actually declared victory; he just thanked everyone for their support and participation.

    • Actually if you look at the top of the browser bar, it says “Washington State Votes YES to GMO Labeling” – but the article itself isn’t worded the same way. Mercola.com does not allow Google caches of their site, but the information was preserved on another site that mirrored the content, take a look.

      Washington State Votes YES to GMO Labeling
      The Washington State is the first US state to vote YES on a law to label genetically modified organism (GMO) in foods.
      Read more at articles.mercola.com

      I think he pulled a Dewey. This blogger considers it to have been intentional link bait.

      • MaryM says:

        Seems Ronnie Cummins was counting some avians too:

        So does the notion that states such as Washington, Connecticut, Maine and Vermont will soon require mandatory labeling of GMOs, which will likely drive these controversial foods and crops off the market, just as labeling laws have already done in Europe.

        http://www.alternet.org/food/5-things-we-can-learn-battle-against-gmos?paging=off&current_page=1#bookmark

        • Good catch. I especially want to point people to this telling sentence:

          We sabotaged several dozen corporate Facebook pages, tarnishing brand names such as Kashi, Cascadian Farm, Honest Tea, Naked Juice, Silk, Horizon, and Ben and Jerry’s, to depress sales.

          Organic Community: the Organic Consumer’s Association is not your friend, but will attack you at a moment’s notice if you deviate from their ideology.

          • theoldtechnician says:

            That whole alternet.org article, reads like their plan to literally take over the world. It seems they have everything figured out except their obligatory mass salute.

      • It was totally link bait. Hit the Share Button or the Tweet Button on the article. All of the social media exposure declared the vote as a YES. it worked but a lot of people, including myself, were let down when they discovered the truth.

  2. Keith Hayes says:

    I get amused when discussions of campaign outcomes are pinned on money. I don’t think money has as much influence on people’s minds as they think.

    Sure, you need some significant funding to get the message out, but if your message doesn’t resonate with the voting public, then you can spend a trillion dollars and you’ll still lose.

    • Ewan R says:

      That Pie chart makes me cringe. $550 shouldnt be visible.

    • MaryM says:

      What I think about the money is that the folks in the state got played by out-of-staters on both ends.

      I think the initial thrust for the signature campaign was manipulated by people who thought WA was the place where this could happen. And only later it got any significant support from within the state (which is still not the 70% in small donations someone claimed to me that it was).

      And then it didn’t get in-state opposition because mostly nobody cared. As I’ve mentioned elsewhere, take the current turnout number (now ~36%), and take about half of that who voted yes (for the back-of-the-napkin say that’s 18%).

      That means that 82% of voters either voted “no” or didn’t care about this. It was driven by manipulators to get it going, and then the voters had their say. Probably nobody cared enough to give money because nobody cared enough at all, recognizing this for the giant waste of resources that it was.

      • That’s a great point – so many people didn’t even bother to vote. If they had cared about GMO labeling, they would have voted. To make matters worse- anyone can request an absentee ballot in Washington State (compare that to Virginia where you annoyingly must have a “reason” to vote via absentee ballot). So all the voters had to do was contact their county “in person, by phone, fax, electronically or by mail” up to 90 days before the election. I think this result demonstrates very clearly that people are not interested in GMO labeling (at least in Washington).

  3. MaryM says:

    I thought I was a progressive. And I thought it was the right outcome.

    Perhaps I have been excommunicated though, but I haven’t received the formal letter or council hand-spanking, whatever the official method is.

  4. Melvin Torme says:

    The issue revolving around GM products has *little* to do with the science of food safety (scholar.google.com is your friend, as is an education in environmental toxicology). It has *everything* to do with economics.

    The organic food market has reached a saturation point. There is little growth potential for sales so the only way for organic producers to grow their market share is by driving people away from conventional farming techniques and those that rely on GM additives. This article in Barrons lays out the basics of the econimic argument: “And while organic food sales continue to increase at a robust pace, that growth is slowing.”

    So you take your competitors out with a legislative blow because you can’t win in the marketplace. You do this by using FUD (fear, uncertainty, and doubt) in your competitor’s product. It doesn’t even have to be a factual campaign, as the people who pushed the computer operating system SCO Unix understood. You just have to make the campaigns believable.

    Mothers avoid getting vaccines for their infant children because of FUD surrounding a non-existent link to autism; people make financial claims against power companies against power companies because of FUD of a supposed link between electromagnetic radiation and cancer; cell phone companies are put on the defensive every time a FUD news article is published linking cancer to cell phone use.

    This has nothing to do with food safety. It is all about raw commercial competition.

  5. Charles M. Rader says:

    Karl, I have a few questions about your projection. First, how do you know how many votes haven’t yet been counted in each county?

    Second, what are these votes? If they are mail-in votes that arrived after election day but with proper postmark, they must have been mailed near the end of the legal voting time. But the polls seemed to show the initiative with wide support at first and much less support toward the end, so I would expect the last mailed votes to show less support for the proposition, not more. On the other hand, as the votes keep coming in, the reported percentage of NO is shrinking. What am I missing here?

    • Bill Price says:

      Charles, As I understand it, the projected number of outstanding votes to be counted is estimated by the state from previous voting turn out numbers and historical rates of returns coming in. They probably have votes that have come in, but did not make the most recent count as well.

      The votes are all mail in as WA has been mail only since 2011. Rachael, who lives in WA, has said before that voting records show liberals, for some reason, tend to vote later or at the last minute, so, if we assume some level of liberal-Yes on I522 connection, it is not unreasonable to expect the No percentage to drop. King county, the big blue spot in the left center of my map above, also contains ~25% of eligible WA voters and tends to be a liberal county, providing more expectation that later votes will be skewed towards the Yes side.

    • Hi Charles, on one of the links above, you can go to the State of Washington voter turnout page, and is lists an estimate of how many ballots are on hand and remain to be counted in each county. But of course if more ballots come in then this number will increase and there will be more votes to count. I just based the estimate off of the current voting percentages for each county multiplied by the number of ballots remaining in each county. It doesn’t obviously take into account any ballots that aren’t counted in the estimate, and doesn’t take into account the ballots still coming in by mail. I’m no Nate Silver!
      I can back up the claim that liberals tend to vote later in WA, just by watching this vote tally (if we reasonably assume that liberals will tend to vote for the measure). The vote percentages have shifted for several counties, and the most shifting that has occurred has been in the Yes On 522 direction. Some of the counties in the Seattle area have crossed the line from being majority No to majority Yes, if only slightly. Additional Yes votes coming in have narrowed the percentage, and, don’t forget, even if the difference in the absolute number of votes does not change, as the total increases, the percentage will decrease. I estimated a couple days ago that it would fail by about 80,000 votes, and currently it is behind by about 70,000. So it may indeed be a little closer, but so far it seems not too far off!
      I wanted to give some sort of estimate to show how difficult it would be for the measure to pass for the “too close to call” folks. Based on how King county is doing, it would take 400,000 total votes more for King county to sway the election in the other direction, providing the needed 70,000 vote difference. Though the percentages are getting closer, the chance of changing the outcome is slim.

  6. MaryM says:

    I’ve seen some interesting reactions to this. This one surprised me:

    @SavorTooth 8 Nov

    Dear rationalists fuming about GMOs: You’re right. Now, is it more important to solve the prob, or force the antis to admit they are wrong?

    Several people asked him what “the prob” is, but that was not described. Personally I think the problem is that they are wrong–not just on the label but on the foundations of what they claim the issues are. So that makes everything wrong, and labels won’t prevent future wrongness. Labels have not prevented EU wrongness on multiple aspects–including Golden Rice.

    But there have also been these two surprises:
    Is GMO Labeling The Wrong Food Fight?

    GMOs aren’t the problem. Our industrial food system is

    Both of these suffer from a lot of misconceptions still–but at least they are beginning to realize that the “GMOness” isn’t the right specific target at some level.

    I’d say that’s progress.

    • MaryM says:

      Well, ok, not everyone is making progress:

      Gene-Altered Food Fight Rages On as Oregon Takes Lead

      “I don’t see any reason at all to change strategy,” said George Kimbrell, a senior attorney in the Portland office of the Center for Food Safety, which supports labeling. “The only thing that is causing us to narrowly lose these initiatives is the tidal wave of money that the chemical companies are spending.”

      LMTTFY (let me translate that for you): We raise a bunch of money for these things anyway, so I get paid even if they lose. I’m good with that.

    • MaryM says:

      More chatter, interesting conclusion, not sure how solid it is but it’s nice to see someone write it out:

      Monsanto & Co. Win Again

      It is looking more and more likely that — instead of requiring GMO labeling — products that do not have GMOs in them will be labeled as such. This is in much the same way that Kosher and organic products, as well as Fair Trade foods, are labeled. There’s usually negligible difference in the nutritional value, but a big difference in how the product makes it into the consumer’s belly.

      • Molly Phelps says:

        This may end up being the better way…certainly big Corp. money will not stop good business from advertising to their chosen market by saying they are GMO free.

  7. Daryl Victoriano says:

    For those of you who think the majority voted against I-522 did so because of corporations like Monsanto are making baseless assumptions. My entire family and I voted against it because there is no Scientific evidence that shows GMO’s are dangerous. Not just that, but Genetic Engineering is our future. It’ll enable us to feed massive amounts of people without having to cultivate large amounts of land which negatively impact are environment. But most importantly, because of our incredible ability to adapt, Genetic Engineering is our only way to evolve as a species. An all that starts with GMO’s.

    • Tom says:

      It is only because of the power exercised by corporations like Monsanto that you could believe so many silly things:

      1. “because there is no Scientific evidence that shows GMO’s are dangerous”

      For decades, cigarette companies were able to recruit doctors to promote smoking, because there was “no scientific evidence that shows smoking is dangerous.” That is, there were plenty of indications, but not enough massively expensive longitudinal studies to give proof beyond a shadow of a doubt. Smoking is still the leading (obviously) preventable cause of disease and death nationwide … and it was easy for cautious people to avoid smoking (unlike GMOs). People only accept this kind of reckless logic because of industry-funded messaging.

      2. “Genetic Engineering [will] enable us to feed massive amounts of people without having to cultivate large amounts of land which negatively impact are environment”

      You would only believe this if you believe (a) that genetic engineering provides consistent increases in crop yields per hectare (it currently does not, nor is there any evidence it will); and (b) that expanding agricultural land area must necessarily harm the environment. Given the prevalance of industrial agriculture in America, many people today assume (b) because they are unaware of sustainable farming practices: in fact, properly decentralizing (i.e., spreading out) agriculture would substantially reduce its negative environmental impact. But (a) is simply a figment of industry PR campaigns.

      3. “because of our incredible ability to adapt, Genetic Engineering is our only way to evolve as a species”

      Are you saying that because genetic engineering will force our species to adapt to its products, we should use it to make ourselves stronger? If you really want to put some selective pressure on your germ line, you should try eating lead. Or are you saying that because genetic engineering is a new technology, we should use it to keep changing things since we may not evolve in the same ways that we used to? If all change is good, maybe we should launch the nuclear weapons. Perhaps this last idea of yours was not the result of corporate media — even Monsanto has its limits.

      It makes me cringe to think people are voting for reasons like these.

      • OrchidGrowinMan says:

        That’s just silly.

      • Melvin Torme says:

        “It is only because of the power exercised by corporations like Monsanto that you could believe so many silly things:”

        Yes, Tom. None of us can think for ourselves. We are completely incapable of reading peer-refereed literature, reports from national scientific panels, or acknowledging the stunning paucity of *scientific* literature by anti-GM organizations showing any negative health or environmental impact from GM products.

        Of course if you negate all of those statements, you’ve summed up the anti-GM quite succinctly.

        “1. “because there is no Scientific evidence that shows GMO’s are dangerous” For decades, cigarette companies were able to recruit doctors to promote smoking, because there was “no scientific evidence that shows smoking is dangerous.””

        Flawed analogy. There were plenty of people, doctors included, who knew quite well the negative health effects of smoking. Even the public was well aware of the health risks, as popular media gave birth to songs warning of the dangers of ‘coffin nails’.

        In contrast, there haven’t been *any* published reports showing a connection between a diet containing GM foodstufs and negative health consequences. There may be food allergies of some people how are sensitive to GM products, but that percentage of the population is no greater than people who are allergic to non-GM foods. There simply isn’t ANY *scientific* evidence for the dangers the anti-GM crowd propose – none.

        So that leaves everyone in the anti-GM camp clinging desperately to the precautionary principle: the idea that you regulate everything as though it *is* dangerous until it can be proven scientifically that it isn’t harmful. Since you can’t prove a negative scientifically, that means every aspect of daily life is carefully regulated by the State, giving every scientific endeavor a thumbs-up or thumbs-down based on how a regulator “feels” about a certain technology. No scientific evidence is asked for, just a “feeling” that the technology *may* be dangerous.

        So all of those people now living longer, more comfortable lives using human insulin (a GM product) would still be living short, miserable lives using porcine insulin because a faceless bureaucrat would *believe* (not have scientific evidence) that the product was dangerous.

        Why don’t the anti-GM forces bring up human insulin in their arguments? Is it possible that they would lose even MORE support for their efforts?

        You will eventually have to face facts, Tom. I-522 was nothing more than an effort by organic farmers to use the power of the State to force a competitor out of business. It failed and your propagandistic efforts will fail as well. The US has shown time and again that the precautionary principle doesn’t work here.

        • Tom says:

          “None of us can think for ourselves.”

          In the absence of information, people are naturally (and rationally!) inclined to take some precaution. Daryl seems to feel that an absence of proven danger is reason enough to try something. This is not called “thinking for yourself,” this is called being ignorant and reckless. I doubt anyone would be so foolish unless they had been lured into a sense of security by someone with an agenda.

          “you can’t prove a negative scientifically”

          Proving negatives is an extremely important part of science. Statistical power analysis (roughly speaking) allows researchers to put statistical bounds on the likelihood of failing to observe effects of a certain size in a given study. True, you can never prove (statistically) that an effect is completely absent, only that it is below a certain tolerance. But this is always the case in empirical science: we cannot prove that general relativity is a perfect model of gravity, only that it is very close. If regulators wanted more proof of the safety of GMOs, it could be had.

          The level of precaution that people demand will depend upon their prior theoretical notions about the potential dangers. Right now, regulators *feel* that GMOs are probably safe, and very little research is required. If GMOs were classified as drugs, human clinical trials would be required for their approval. (Of course, clinical trials for GMOs are considered unethical because they have no purported benefits for consumers!) The only reason they have been subject to (almost) no human testing is because they have been declared “substantially equivalent” to non-GMO food, an assumption rooted in very thin empirical evidence.

          “there haven’t been *any* published reports showing a connection between a diet containing GM foodstufs [sic] and negative health consequences”

          There haven’t been any *studies* of this possibility either. If you don’t study feeding people GMOs to gain empirical evidence, the only way to develop confidence about their safety is to attain a *very* comprehensive theoretical understanding of their effects (this is the costly and difficult approach taken by climate science, in the absence of experimental planets).

          The present record for GMOs shows that such comprehensive understanding is a long way off. Biotech researchers assured regulators that the Bt toxin would not make it past the digestive tract, and lo and behold, it’s now in most human cord blood and breast milk. Until recently, researchers seem to have almost completely ignored potential population effects on intestinal microflora. As with most biological interventions, our understanding of systemic GMO effects is obviously very preliminary, and any confidence based on theory alone is severely misplaced. Perhaps because many commenters on this web site work with biotechnology, they feel more comfortable about it than the average person, but this is likewise “just a feeling.”

          This is the crux of the issue. There is little scientific reason to believe (without substantial empirical evidence) that GMOs exhibit long-term safety, *or* that they don’t. Hundreds of short-term animal studies don’t fully answer these questions, no matter how many there are. We just don’t know. People’s judgment depends on how they feel. I-522 would have let people easily make choices based on their feelings.

          A brief response to your other points:

          “There were plenty of people, doctors included, who knew quite well the negative health effects of smoking.”

          Prior to long-term studies, you cannot say that people “knew” the health effects of smoking — they just had a *feeling*. The only flaw in the analogy is that people’s feelings in this instance were better informed by their own experience—because they knew if they were smoking.

          “people now living longer, more comfortable lives using human insulin (a GM product)”

          This case is very different from GMO foods for two reasons: (1) there is an obvious and substantial benefit to these people, which balances the precautionary principle; (2) it was thus developed as a drug and tested in clinical trials.

          “I-522 was nothing more than an effort by organic farmers to use the power of the State to force a competitor out of business”

          That is a totally baseless claim. The I-522 petition was signed by 350,000 people (the second highest total in WA state history) and the campaign had over 13,000 donors with median contribution $25 (the minimum required to be reported). There are less than a thousand organic farms in Washington, so the vast majority are definitely not farmers. By contrast (prior to legal investigation) the opposition had 10 donors with median contribution over $500K, all of whom were biotech or food manufacturing companies. It’s quite clear which side is dominated by business concerns.

          “the precautionary principle doesn’t work here”

          Since you are wrong about proving negatives, you are also wrong about the precautionary principle: there is *always* a place for precaution. The purpose of labeling is that people get to decide for themselves how much precaution is warranted.

          Some labeling opponents say that because each GMO is different, it makes no sense to have a universal label for all. But as I have pointed out, the need for the label is because GMOs have all been categorized similarly by regulators, and are thus universally understudied. More detail would be better, but there are limits to reasonable regulation.

          This discussion has focused mainly on human dietary safety of GMOs per se, but in my personal view, this is a secondary issue. I think it likely that any dietary dangers of GMOs will be minor compared to the broader and deeper effects of nonsustainable agriculture on the nutrition and toxicity of food and the environment. GMOs are an important part of that system, and I mainly avoid them for that reason. So as you can see, labeling is not just about safety: it is about consumer choice in all its complexity.

          • Ewan R says:

            Right now, regulators *feel* that GMOs are probably safe, and very little research is required.

            Very little may be required, but quite a significant amount is actually done. Both pre and post commercialization. Animal studies are generally used, but then, they are in clinical trials also.

            Biotech researchers assured regulators that the Bt toxin would not make it past the digestive tract, and lo and behold, it’s now in most human cord blood and breast milk.

            So long as by “it’s now in” you mean “a paper measured noise using an inappropriate test kit” I guess… but hey, what’s a limit of detection even for right? What’s a calibration curve between friends? Who cares if the makers of a kit explicitly say “Hey, you do realize you can’t use our kit to measure that”….

            There is little scientific reason to believe (without substantial empirical evidence) that GMOs exhibit long-term safety, *or* that they don’t.

            Other than, y’know, a whole slew of long term studies, including multigenerational ones, and the inclusion of GMOs in the diets of animals raised for lab testing with no red flags being thrown up, or no scientifically plausibly mechanism by which as yet unseen effects may occur. But yes, other than their being a preponderance of reasons to accept long term safety and zero to accept lack thereof your point stands.

            Your “proving negatives” paragraph is rather odd. You start by saying proving negatives is an important part of science, but then go on to say, essentially, that one cannot prove a negative.

            True, you can never prove (statistically) that an effect is completely absent, only that it is below a certain tolerance.

            This statement, to anyone who espouses the view that science cannot prove a negative, is infact exactly what they mean. All that can be done is to say “we have done X studies and have found no evidence of harm, this is the evidence we have that there is no harm to be had” if in the X + 1th study harm is found, and the study is sound, and the results can be replicated…. then we can say “we were wrong” at no level of testing however is it possible to honestly say that you have proven something causes zero harm, only that to date you have not been able to demonstrate harm. Herein lies a bonanza for the anti-GM movement. If short term animal studies are provided they will cry for longer term studies. When long term studies are provided they will cry for multi-generational studies. When these come along they’ll demand human trials, and so on, and so forth. A line must be drawn. It is ludicrous (indeed it is because it is ludicrous that the trials are demanded – activists must know (unless they’re actually stupid) that large scale human feeding trials are widly expensive and thus prohibitive (hey, look, we can prevent the technology simply by upping the bar high enough!)) to demand the level of testing you’re demanding given the actual science behind the crops. Throwing out a random grab bag of pseudoscientific bafflegab to justify the demand for silly trials is just that… silly – if there was a worthwhile hypothesis to test, then it’d be tested, but the problem with arm-chair scientific theorizing is that rarely does it come up with either a worthwhile hypothesis, or one that has not actually already been tested in some capacity.

            The purpose of labeling is that people get to decide for themselves how much precaution is warranted.

            Indeed. While there is no actual evidence that food prepared by left handed people is more dangerous than that prepared by right handed people there is likewise no proof positive (show me a long term human study) that it is safe, and therefore I am sure you will agree that the handedness of the food preparation employees should be meticulously tracked from field to plate and labels mandatorily applied to an arbitrary subset of foods in certain situations but not others. I will decide for myself how much precaution is warranted. Experts and common sense be damned.

            the broader and deeper effects of nonsustainable agriculture on the nutrition and toxicity of food and the environment.

            shouldn’t you be pushing for labelling of something other than GMOs, which while predominantly utilized in industrial ag could quite as easily provide exactly the same benefits in any system which allows them (golden rice, for instance, or Bt… RR not so much, as it is utterly pointless in any system that doesn’t use herbicides)

            • Tom says:

              “a paper measured noise using an inappropriate test kit”

              I assume you refer to the Aris & Leblanc paper. I’m aware the interpretation of their results is disputed, so perhaps it is premature to say “it’s now in.” The authors have defended the sensitivity of their method. It is odd that not even the well-funded critics of the study appear to have commissioned a relevant follow-up of their own, since this would be an important finding. My larger point was about the theoretical uncertainties surrounding GM foods: it does not seem credible to me given the present state of knowledge that people can broadly discount the possibility of these types of unexpected results without testing (but they frequently do).

              “no red flags being thrown up”

              There are many studies that claim to find red flags. It is possible to argue that they are all flawed or fraudulent, but this argument stretches credulity when the researchers involved come from so many places, and so many backgrounds, many of them with no apparent conflicts of interest. Relative to the number of independent studies done, that seems like a great many mistakes. If in fact they are all mistaken, one would again expect that well-funded critics would invest in follow-up, but the more typical outcome is that such studies are simply denounced and then ignored.

              “no scientifically plausibly mechanism by which as yet unseen effects may occur”

              I would argue that our understanding of the relationships between food and human health is still so limited (relative to its complexity) that even requiring specific plausible mechanisms is too high a standard against some investigative precaution. But there are indeed such plausible mechanisms: the safety of glyphosate was justified in part upon the absence of a shikimate pathway in animals, but the human symbiosis with its diverse microflora was not well appreciated at the time. (True, glyphosate is not a part of the GM organism itself, but this is largely irrelevant to the consumer.)

              “if in the X + 1th study harm is found … then we can say ‘we were wrong'”

              No, because it would never have been justified in the first place to claim evidence that there is zero harm. You would simply claim evidence that the harm is below a certain tolerance, which would not be incorrect. You seem to argue that people will only accept zero risk, but from the choices that people make that is obviously not the case. If you can provide evidence that a risk is low enough, people will accept it.

              “a worthwhile hypothesis”

              You could start with the really obvious ones, like association of GM food consumption with leading chronic diseases in humans. You could even start with observational studies like the Nurses Health Study. (Labeling GM foods would help enable this kind of research.) If you could give clinical evidence that GM foods are not connected to any of the biggest health issues, that would go a long way to convincing skeptics.

              “food prepared by left handed people”

              I think almost anyone would agree that our theoretical grasp of the potential effects here is far more complete than in the case of GM foods. This is an important reason why people feel better about this possible issue. As I said, the appropriate level of precaution in the absence of empirical evidence depends on how people feel. Public policy reflects this collective feeling. I don’t think it is wrong for someone to oppose GMO labeling (the political complexity of which goes even beyond these issues), but I do think it is wrong that people do it because of misleading or nonsensical messages by its opponents.

              “shouldn’t you be pushing for labelling of something other than GMOs”

              You are right in principle, but the practical difficulties are great. To precisely assess the net impact of the food you eat on your health and the environment is extremely complicated. For instance, have you ever tried to interpret USDA/FDA pesticide test data? I have, and that alone is mind-numbing. The standards for the National Organic Program try to address some of this complexity, and they are enormous, which is one reason for the high cost of organic. If one wants to take another step forward in public policy, looking for an attribute that is both simple (i.e., not costly) and significant, the obvious one is GMO foods. Since it’s not a ban (just a label), it leaves those prepared to deal with greater complexity still able to do so.

              Yes, it would be better if there were a more multifaceted assessment of the impact of foods available to consumers, but this could (a) reduce its usefulness in practice, and (b) invite greater manipulation by interested parties at the expense of consumers. For regulations, simplicity has value in itself.

              • Keith Hayes says:

                I assume you refer to the Aris & Leblanc paper. I’m aware the interpretation of their results is disputed, so perhaps it is premature to say “it’s now in.” The authors have defended the sensitivity of their method. It is odd that not even the well-funded critics of the study appear to have commissioned a relevant follow-up of their own, since this would be an important finding.

                It’s not the critic’s job to prove a claim made by somebody else. If Aris and Leblanc sincerely believe that the can detect BT proteins in the blood of an umbilical cord, then they can do a follow-up experiment with the right experimental design and an analysis that addresses the critic’s issues with the original study.

                Reproducibility is a well established corner-stone of science.

                My larger point was about the theoretical uncertainties surrounding GM foods: it does not seem credible to me given the present state of knowledge that people can broadly discount the possibility of these types of unexpected results without testing (but they frequently do).

                This larger point seems to be a rephrase of the “There’s not enough testing being done” argument

                There are many studies that claim to find red flags. It is possible to argue that they are all flawed or fraudulent, but this argument stretches credulity when the researchers involved come from so many places, and so many backgrounds, many of them with no apparent conflicts of interest.

                Is it your contention that many flawed studies can make another flawed study look better? I suppose it’s possible, but scientic relevance would be zero.

                I see what you’re getting at. You think the volume of the studies throwing up red flags from such diverse areas of study should mean that there’s something there. But what about the studies that don’t show any negative issues at all; the studies that outnumber studies like Leblanc about 1000 to 1?

                If one wants to take another step forward in public policy, looking for an attribute that is both simple (i.e., not costly) and significant, the obvious one is GMO foods. Since it’s not a ban (just a label), it leaves those prepared to deal with greater complexity still able to do so.

                This seems to be a very naive viewpoint to me.

                If one wants to “take a step forward in public policy” he can always score points by trying to ban something. That tends to get people voting. In the case of GMO’s he can’t really cite any proof of harm so he falls back on labeling and people’s “Right to Know”.

                Add to this dynamic an industry that is forbiddin to use GMO’s for ideological reasons (organic) and can’t compete with lower cost foods. Supporting a labeling requirement while one launches a slick advertising campaign about how GMO’s are bad and unnatural might be good for business, eh?

                Unless there’s a clear and legitimate hazard, labels just add to confusion among customers. Prop 65 immediately comes to mind.

                • Tom says:

                  “It’s not the critic’s job to prove a claim made by somebody else. If Aris and Leblanc sincerely believe that the can detect BT proteins in the blood of an umbilical cord, then they can do a follow-up experiment with the right experimental design and an analysis that addresses the critic’s issues with the original study.”

                  With respect to this study, I had previously read only the objections and responses published in the peer-reviewed literature. Looking at the discussion here on Biofortified, it appears others have raised many additional objections, but since none of these have been published in connection with the original paper (i.e., by letters to the editor), and the authors have thus presumably not been invited to respond to them, drawing conclusions based on these seems a slight abuse of the conventional scientific process. I agree that the authors could follow up their work with additional study if so able, but from the current publication trail, it seemed to me that the ball was in the other court, so to speak. Reproducibility as a cornerstone of science most importantly means reproducibility by *others*.

                  “This larger point seems to be a rephrase of the ‘There’s not enough testing being done’ argument”

                  Perhaps some perspective will illuminate the reasons I believe this. My own research deals with classical gravitational dynamics: the motion of objects under Newtonian gravity. The “rules” of the systems we study can be written down in a simple one-line equation. And yet thousands of researchers (among them many of the most prominent scientists in history) have spent *centuries* working out (through theory and observation) the implications of these rules. Even today, fundamental shifts in our understanding still occur every couple of decades.

                  Now consider a subject like human biology. The “rules” of even the human organism alone (ignoring its symbiotes) must be said to incorporate tens of thousands of genes comprising hundreds of megabytes of information. It is inconceivable to me that researchers at the present time could feel they can foresee all the significant potential consequences of disturbances to this system whose very character is unprecedented in biological history. To argue this seems to require that either (a) biological adaptation results in fundamental simplifications relative to mechanical systems (which does not seem true), or (b) biologists are astronomically smarter than those of us working in physical disciplines (which I also doubt).

                  It seems more likely that biologists are reluctant to face the limitations of our current understanding, because acknowledging the baffling complexity of the systems they study would be rather overwhelming. Science is difficult, and it makes us feel better as scientists to convince ourselves that we know a lot. But I have found that the more we learn, the more humble we become about the predictions we can make.

                  “Is it your contention that many flawed studies can make another flawed study look better?”

                  No, but in the absence of more relevant information, the larger the number of peer-reviewed studies in a certain group, the less likely it seems that all are flawed. This kind of simplistic model depends not just on how many studies there are in that group, but how many studies there are in the field altogether. Better information than this requires detailed analysis: I hope the GENERA database will help someone to do an entirely comprehensive review, but until such exists, this very naive sort of meta-analysis is the best I’m able to do.

                  “But what about the studies that don’t show any negative issues at all; the studies that outnumber studies like Leblanc about 1000 to 1?”

                  If we continue with this idea of using number of studies as a measurement for likelihood, it all depends on what sort of prior you have. Based on the effects that might be observed, how many studies among those done would you expect to find them? It’s a complicated question, and (again, by this very naive methodology) that ratio would probably indicate something about what magnitudes of effects might be likely. Your estimate of 1000 to 1 seems a bit high: as of now, there are only 600 studies listed in the GENERA database.

                  “he can always score points by trying to ban something”

                  I’m not interested in scoring points, and I don’t think most scientists are either. What confuses me is why so many scientists seem to be opposed to GMO labeling regardless of their views on safety. It seems they use the following logic:

                  (1) There’s no scientific case against the safety of GMOs, therefore
                  (2) People concerned about GMOs are unscientific, therefore
                  (3) I don’t want those people to have information about GMOs, because they would use it to make unscientific decisions.

                  They are thus in the ironic position of trying to suppress information in the name of scientific principle. As I hope I have indicated, a position of concern about GMOs is not unscientific, and even if it were, science would not be served by suppressing information about it, because this information can provide the data to strengthen our scientific understanding about GMO effects.

                  “good for [organic] business, eh?”

                  Not necessarily. The easy approach for people who really want to avoid GM foods today is to buy organic. If there were GMO labeling, that might expand their options. The people who are more concerned about other things are unlikely to change their buying habits vis-a-vis conventional vs. organic products. The shift is likely to be from non-organic GM foods to non-organic non-GM foods. Maybe the organic suppliers have a leg up here, maybe not.

                  “labels just add to confusion among customers. Prop 65 immediately comes to mind”

                  While Prop 65 arguably was not very educational, I believe it had a significant positive effect in terms of awareness, and I certainly don’t think that those signs “confused” people. Most people in the U.S. are not aware that ordinary places they go are contaminated by thousands of known or suspected carcinogens. Currently, there are some 80,000 industrial chemicals approved for use in the U.S., and even among the most high-volume ones, fewer than half have been evaluated for toxicity. If toxics reform is ever to make progress in this country (again, lagging behind many other nations), people will need to develop more awareness of their chemical exposure. I-522 might have helped to do the same for chemical exposure in food.

                  • Keith Hayes says:

                    Perhaps some perspective will illuminate the reasons I believe this. My own research deals with classical gravitational dynamics: the motion of objects under Newtonian gravity. The “rules” of the systems we study can be written down in a simple one-line equation. And yet thousands of researchers (among them many of the most prominent scientists in history) have spent *centuries* working out (through theory and observation) the implications of these rules. Even today, fundamental shifts in our understanding still occur every couple of decades.

                    We might not know everything there is to know in any particular field, but this doesn’t mean that we know nothing; far from it.

                    To use your example: Machines such as wheels pulleys and ramps were being designed long before Newton worked out his fundamental laws of motion. A person squashed by a boulder flung from a catapult doesn’t become less dead because of this lack of knowledge. Even for those who didn’t know Newton’s laws, it was possible to be effective, even if it was via trial and error. Now, we understand enough to launch satelites into space with extreme precision. And we can still learn how to do it even better as our understanding of nature evolves.

                    Likewise, humanity has been practicing plant and animal domestication through selective breeding long before Gregor Mendel or Charles Darwin published their seminal works. GE is just a continuation of this process and we’ll get better at it and develop better tools or methods. None of this means that the technology at any stage of it’s evolution is useless or ineffective or even be inherently harmful.

                    No, but in the absence of more relevant information, the larger the number of peer-reviewed studies in a certain group, the less likely it seems that all are flawed.

                    This reminds me of debates I have with people that believe UFO’s are extraterrestrials. They’ll point to all those pictures and say that at least some of them are pictures of alien spacecraft because there’s just too many photos for them to all be fake or explainable.

                    This simply isn’t a good line of reasoning.

                    I’m not interested in scoring points, and I don’t think most scientists are either

                    I thought you were referring to politicians. The last part of your reply seemed to be headed that way.

                    It seems they use the following logic:

                    (1) There’s no scientific case against the safety of GMOs, therefore
                    (2) People concerned about GMOs are unscientific, therefore
                    (3) I don’t want those people to have information about GMOs, because they would use it to make unscientific decisions.

                    Not exactly. I don’t know of anybody in the field that “doesn’t want people to have information about GMO’s”. In fact, I see a lot of reaching out to try to educate people. This blog is an example. It’s just that the proposed labeling does nothing to educate the consumer. The consumer might also infer that the labeling implies a hazard when there really isn’t one. Lastly, the people opposed to GE have launched a very effective scare campaign so that if any person wanted to learn more about the technology, they’ll get bombarded with scary images. Try putting a few keywords into Google and see what you get.

                    While Prop 65 arguably was not very educational, I believe it had a significant positive effect in terms of awareness, and I certainly don’t think that those signs “confused” people. Most people in the U.S. are not aware that ordinary places they go are contaminated by thousands of known or suspected carcinogens. Currently, there are some 80,000 industrial chemicals approved for use in the U.S., and even among the most high-volume ones, fewer than half have been evaluated for toxicity. If toxics reform is ever to make progress in this country (again, lagging behind many other nations), people will need to develop more awareness of their chemical exposure.

                    That’s the theory. The reality of Prop 65 has been much different. I know that a lot of people might think of chemicals like benzene and chloroform when they think of prop 65. But a lot of innocuous substances get listed also with no threshold limits. Saccharine ended up on that list! I don’t want to derail the thread further so I’ll stop discussing Prop 65. My main point is that a GMO label won’t do much more educating or informing the customer than an organic or GMO Free label already has. I think most people agree that a nice balance has been struck with voluntary labeling.

                    • Tom says:

                      “None of this means that the technology at any stage of it’s [sic] evolution is useless or ineffective or even be [sic] inherently harmful.”

                      The appropriate level of precaution depends not only on the technology itself but how widely and transparently that technology is deployed. People are mostly okay with launching rockets even though they pose inherent safety and environmental concerns, because there are so few rockets. Airplanes are held to higher standards, and cars (the most ubiquitous) to higher standards still. Moreover, it is relatively straightforward to track the effects of these technologies (there are no invisible cars), so people can be reassured that potential unforeseen problems will be discovered (as *many* have been).

                      Going back to agriculture, a farmer in antiquity who breeds a new subspecies may cause unintended consequences, but those consequences (at least, in antiquity) would be localized, and the web of knowledgeable observers (other farmers) witnessing the deployment of that “technology” would be readily able to spot warning signs. Contrast this with the most common GMO crops, which within a few years have subsumed large fractions of worldwide production in those crops, but are developed and deployed out of public view (and indeed, under high secrecy, so that even researchers cannot legally test them), and are not traced through food consumption (in the absence of labeling). People are rationally much more skeptical about the potential dangers of such a technology, *even if* there is no evidence that the technology itself is more likely to cause harm.

                      “because there’s just too many photos for them to all be fake or explainable”

                      The difference is that anyone can make and disseminate a purported UFO photo without restraint: there is no peer review process designed to uphold a certain standard of quality. You can claim that the peer review process is flawed, but at least in principle, those flaws should apply equally to studies that confirm or question GMO safety. Since there is strong evidence of some bias in the conclusions of industry-funded research, it seems to me that this claim hurts the case for GMO safety more than it helps it.

                      “It’s just that the proposed labeling does nothing to educate the consumer.”

                      That is not its purpose. *None* of the things labeled on food products are intended to “educate the consumer.” Other resources (like this blog) fill that role. The purpose of labels is to annotate, providing traceability. They do not counteract all ignorance, just a very specific kind.

                      “The consumer might also infer that the labeling implies a hazard when there really isn’t one.”

                      You seem to confirm exactly my point: you’re reluctant to give people the information, because they might use it to make unscientific decisions. If enough people had irrational beliefs that protein was harmful, would you think it was bad to include protein on food labels?

                      “if any person wanted to learn more about the technology, they’ll get bombarded with scary images”

                      You seem to be going farther and farther down the road of: people are too ignorant/misinformed to make good decisions for themselves, so we should just keep them in the dark. We have gone from the perspective of a scientist as someone who makes good information available to society to aid their decision making, to a scientist as someone who determines how society *should* decide, and makes the decision for them. The latter view is very troubling to me, and I think most would agree it has historically not worked out well.

                      While I have found this blog and our discussion very educational, this is the uneasy feeling I get from some of its writings and much of its commentary. For science to be part of a free society, it must seek to educate rather than dictate. As soon as science is vested with the power to make decisions independent of the people, that power soon corrupts the practice of science itself, and everyone is worse off.

                      “I think most people agree that a nice balance has been struck with voluntary labeling.”

                      I’m not sure what you feel is being “balanced” here. I agree there is value in voluntary labeling. The only trouble is that this approach imposes significant cost and uncertainty on the consumers concerned. Imagine trying to avoid trans fat in food products if hydrogenated oils were not required to be listed as such on ingredients labels (with different regulations, they could be allowed to be labeled simply as oils, under some dubious notion of, let’s say, “substantial equivalence”). There might be voluntary labeling organizations, but at what cost? And what about the many products that might not be labeled? Surely you can recognize the cost to the people involved with this solution, especially when most people (polls consistently show) want some kind of GMO labeling.

                      From the reporting on I-522, it is clear that (a) most people want information about GMOs in food products, but (b) enough people were convinced by the arguments in opposition advertising to defeat this initiative. These arguments stayed far away from science, and rather, were rooted in fear and confusion about the technicalities of the initiative and its implementation.

                      I often get the sense that some people view the defeat of I-522 as a “victory for science” (whatever that means). But the above picture belies this conclusion: it was a victory for fear and confusion, those feelings most antithetical to scientific inquiry. It can only be considered a victory for science in the dictatorial view of science I described above: anyone who believes in science as part of a democratic society should recognize that the defeat of I-522 has only undermined these values.

                    • Keith Hayes says:

                      Wow, I didn’t know I made so many grammar errors! Anyways…

                      The appropriate level of precaution depends not only on the technology itself but how widely and transparently that technology is deployed. People are mostly okay with launching rockets even though they pose inherent safety and environmental concerns, because there are so few rockets. Airplanes are held to higher standards, and cars (the most ubiquitous) to higher standards still.

                      The technologies that you mention (planes, rockets and cars) have all claimed lives but we don’t ban these technologies because they have a very visible , positive effect on our lives and society at large. Plus they have ways to make these technologies even safer. GE will follow a similar path of development. It’s been about 15 years since the first GMO crops have been commercialized and not so much as a runny nose has been attributed to them. This is impressive for a technology where there are “so many unknowns” but seems ubiquitous in the USA, isn’t it?

                      Let’s keep the risks in perspective.

                      Going back to agriculture, a farmer in antiquity who breeds a new subspecies may cause unintended consequences, but those consequences (at least, in antiquity) would be localized, and the web of knowledgeable observers (other farmers) witnessing the deployment of that “technology” would be readily able to spot warning signs.

                      Why would you think that farmers wouldn’t be as observant now as they were in antiquity? And if any problems were spotted now-a-days, it would ricochet around the internet as fast as electrons can travel.

                      If I were a farmer, and somebody told me about this new genetically modified seed, I might try sowing some in a small area of my farm (an area small enough that I wouldn’t mind losing) to see how it performs. If it did well, I would buy and plant more the following season. If it did poorly I would tell anybody who listened to not bother trying the seed and would probably write a few angry letters to Monsanto (or whomever I bought the seed from) and the USDA.

                      It’s hard for me to imagine a scenario where GMO crops are causing problems, and yet, not being communicated in this day in age. Such widespread adoption would seem to indicate that farmers have a high customer satisfaction rate.

                      Contrast this with the most common GMO crops, which within a few years have subsumed large fractions of worldwide production in those crops, but are developed and deployed out of public view (and indeed, under high secrecy, so that even researchers cannot legally test them), and are not traced through food consumption (in the absence of labeling).

                      This statement doesn’t make any sense to me from what I know about the food industry and product development in general. The R&D may be secret for the GMO crop since no company wants to lose their patent rights or get scooped. But petitions for deregulation are filed publicly with APHIS USDA, they are open to a public comment period and the decision is publicized. What’s the secret there?

                      In regards to traceability, you won’t need a GMO label for that. Everything in food production is traced by lot/batch number from supplier to the end user and all of this is gov’t mandated.

                      You can claim that the peer review process is flawed, but at least in principle, those flaws should apply equally to studies that confirm or question GMO safety.

                      Which is why studies should be evaluated on their merit and design and not whether or not they made it through peer review. You’d have to read a few to get an idea what makes a good experimental design and what makes it a faulty one. Not all studies are funded by industry. Many are independent. And the whole body of research has been evaluated by dozens of regulatory agencies worldwide. Nobody finds any additional risks and that includes the European Food Safety Authority (EFSA) which regulates a region of the world that has extremely hostile attitudes toward GMO’s.

                      You seem to confirm exactly my point: you’re reluctant to give people the information, because they might use it to make unscientific decisions.

                      Not reluctant. I would accept this as a good label:

                      “Ingredients in this product have been derived from corn that has been genetically modified to reduce pesticide use”

                      A label like this would inform and educate at the same time (on a simple level). It is also trait specific. Not all GMO’s have been modified to do the same thing so having a label that says “contains GMO’s” is pretty much useless for consumer information. I would bet a week’s pay that the people pushing the hardest for labeling would object to my proposal because it’s not consistent with their message: “GMO’s are bad!”

                      I believe people have a right to know, but they need to be educated to a level where they can make an informed choice.

                      In another 5-10 years (my estimate), labeling would be a non issue any way. Once nutritionally enhanced GMO’s become commercialized, a food producer would want to advertise this fact freely. Much like the way organic food producers are trying to do. Except the producers using GMO’s will be able to back up their claim since they’ve likely had to submit proof of the nutritional claim. Look at how golden rice is being tested to get an idea about proving nutritional claims.

                      You seem to be going farther and farther down the road of: people are too ignorant/misinformed to make good decisions for themselves, [...]

                      If the shoe fits. Scientific literacy is 1 out of 5 Americans. Do the math.

                      [...]so we should just keep them in the dark.

                      I’m not suggesting keeping people in the dark. I’m suggesting that the labeling wouldn’t really enlighten anybody and just raise costs across the board. It’s a net negative.

                      We have gone from the perspective of a scientist as someone who makes good information available to society to aid their decision making, to a scientist as someone who determines how society *should* decide, and makes the decision for them. The latter view is very troubling to me, and I think most would agree it has historically not worked out well.

                      I also find it troubling that a movement based on ideology wants me to bare the cost of an arbitrary labeling system so they could feel warm and fuzzy inside while remaining “in the dark” as much as they were before. No deal!

                    • Tom says:

                      “because they have a very visible, positive effect on our lives and society at large.”

                      This is much harder to argue for GMO crops than for transportation. The main GMO crops today were essentially developed as a stopgap to prop up industrial monoculture against its inherent vulnerabilities. But the experience of the last 15 years has shown that this approach provides only short-lived solutions, while externalized costs (soil loss and nutrient depletion, ecosystem toxicity, etc.) continue to mount, and perhaps even accelerate if the “chemical treadmill” continues. From a societal perspective, GMO crops to date have been mostly a distraction from long-term solutions for sustainable agriculture; the main positive effects claimed are thus far local and ephemeral.

                      “not so much as a runny nose has been attributed to them.”

                      As I have previously pointed out, it’s impossible to attribute anything without data. Nobody would have been able to attribute smog to cars if all the cars were invisible and almost nobody knew if they used one or not. As an alternative example, the only reason we are finally making progress in phasing out certain carcinogenic flame retardants (with a Washington state ban last year) is that there are convenient ways of testing people’s exposure (if there were even better traceability, such as labels, it would have been easier).

                      “Why would you think that farmers wouldn’t be as observant now as they were in antiquity?”

                      It doesn’t matter if farmers are just as observant (though there are many fewer of them now) if the consequences are not localized. The farmers don’t even see most of the people eating the food they grow, let alone know anything about their health. The dangers to *appliers* of pesticides and their families are much better known than the potential dangers to *eaters*, precisely because the appliers know when they are exposed and can correlate the effects they observe.

                      “not being communicated”

                      The issue is not whether problems can be communicated. It is whether they can be *discovered*.

                      “farmers have a high customer satisfaction rate”

                      This has relatively little to do with the health, safety, and environmental impact of their crops. The agricultural policies that squeeze mainstream farmers leave them relatively little freedom to worry about these things compared with making ends meet.

                      “they are open to a public comment period and the decision is publicized. What’s the secret there?”

                      The secret is that people are not allowed to examine the products and publish their results without permission from the manufacturers. Suppose that anyone buying children’s toys had to sign a license agreement that they could not test the toys for lead and publish their findings without such permission. Do you think the government would take the initiative? (Hint: industry lobbying blocked or repealed all lead safety regulations for *decades* after it was known to be dangerous.) Transparency means a lot more than people questioning the government and the government telling them whether their concerns are valid. This kind of secrecy goes totally against any advocacy for “science-based” regulation: the independent science cannot be done (at least, not independently)! Even the editors at Scientific American, generally friendly to biotech, think this is a big problem:
                      http://www.scientificamerican.com/article.cfm?id=do-seed-companies-control-gm-crop-research

                      “Everything in food production is traced by lot/batch number from supplier to the end user”

                      How many food consumers do you know who obtain and record the lot/batch numbers associated with the food products they buy? Would anybody (researchers, health care providers, even government investigators) have any way of tracking their consumption after the fact? The practical answer is no.

                      “And the whole body of research has been evaluated by dozens of regulatory agencies worldwide.”

                      Regulatory agencies are political bodies with their own biases. If, as GMO proponents claim, there is a scientific consensus about their safety, and the regulatory agencies follow that consensus, you would not see such different policy outcomes from different regulatory agencies around the world. Officials at the USDA have publicly stated that their job is to support the American agriculture industry, and at least one official at the FDA has said that the responsibility for food safety lies with manufacturers. The statements of regulatory agencies have only a loose relationship with reality: the closer their relationships to industry, the more favorable their position on GMOs.

                      “I would accept this as a good label:

                      ‘Ingredients in this product have been derived from corn that has been genetically modified to reduce pesticide use'”

                      This is one particular fact about the genetic modification in that corn. It is not a particularly informative fact (it doesn’t tell you whether the corn is Bt, RR, or what), and it is a fact related to the producer’s motivations, which the consumer may or may not care about. You could argue that the more facts there are, the more educational the label, but choosing one particular (not-unbiased) fact does not, in my view, make for an obviously better label. As I’ve said, labels are for annotation: people looking for in-depth information (education) have resources to find it. I agree that more specific annotations for GM foods could be helpful.

                      “I believe people have a right to know, but they need to be educated to a level where they can make an informed choice.”

                      It is both foolish and undemocratic to make the latter a prerequisite to the former. People will learn about something *because* they know that it is relevant to them. If they see labels on their food products, they may be motivated to educate themselves about GM foods; if they are unaware, not so much.

                      “In another 5-10 years (my estimate), labeling would be a non issue any way. Once nutritionally enhanced GMO’s become commercialized”

                      As a student of nutritional science, I can tell you that human nutrition is a *highly* complex process that is adapted in amazing detail to an extremely diverse biological ecosystem. It will take genetic engineering a *long* time to catch up with billions of years of evolution, and even when it does it is unlikely to be a cost-effective approach to feeding people well. Natural organisms are strongly adapted to be extremely efficient at what they produce, and humans are strongly adapted to use the products of natural organisms.

                      “Look at how golden rice is being tested to get an idea about proving nutritional claims.”

                      Vitamin A deficiency is a problem created by monocropping that can be solved by a return to indigenous, diverse farming methods (with numerous important secondary benefits). Applying a narrow technological fix to this problem may be a straightforward solution, but it is not a long-term or integrative solution. It may not even be a short-term solution: during the time golden rice has been in development, many other short-term interventions have made tremendous progress on VAD blindness. Golden rice is on track to provide more value as a public relations tool for biotechnology than to people with VAD.

                      “I’m not suggesting keeping people in the dark. I’m suggesting that the labeling wouldn’t really enlighten anybody”

                      I infer that you would support more specific labels, which I think is fine. But the defeat of I-522 does nothing to make that future more likely. Public policy progresses by baby steps.

                      The cost issue is a red herring. There are other public policy measures in play that have really substantial fiscal impact. I-522 was not one of them. We could save way more than that by requiring government buildings to use lower-quality toilet paper. And no, I am not counting the opposition’s claims about costs of reformulating products to use non-GM ingredients (which is very unlikely in the short term): responding to consumer demand is not a “taxpayer cost.”

                    • Hi Tom, you have made a lot of comments here but one stuck out to me that I’d like to provide some updated information on.

                      The SciAm article you linked to about researchers not having access to GMOs to do independent research is from 2009. Even at the time it was published, it left out some information. Monsanto and the other seed companies negotiate academic research licenses with universities, and they were actually doing it before 2009 – it’s just that not many people knew about it. Maybe they just assumed they couldn’t do research and didn’t ask.

                      Anyone who wants to do research on GMOs just has to affiliate with a research institution that has a license in place. It’s pretty easy if you aren’t at a university with a license, researchers collaborate across institutions all the time. Anyway, here’s a page from Monsanto explaining their policies.

                      Monsanto admitted they could have done a better job telling researchers about the policies (although, seriously, all people had to do was ask!), as they describe in an article in Nature Biotechnology: Under Wraps.

  8. Charles M. Rader says:

    Tom, your post of November 14, 2013 at 4:47 pm is quite long and makes claims about the real world which I don’t think are correct. But there are too many to be worth arguing. I am therefore going to limit myself to responding only to your claim that defeat of I522 was “a victory for fear and confusion”. I am going to try to put myself into the position of some consumer who has heard and believed some, but not all, of the anti-GMO arguments. I’d like to know if you think I522 helps that consumer.

    One of the anti-GMO arguments is that large corporations have too much power over our food supply. So we should try to boycott their products. But there are large corporations using non-GMO ingredients also. How does the GMO label help me punish large corporations? A variation of this argument is that Monsanto is a particularly bad player. But Monsanto sells both GMO and non-GMO seeds, and there are other GMO products with no connection to Monsanto? How does the GMO label help me to punish Monsanto?

    Another anti-GMO arguments is that there is some doubt about their safety in food. But many ingredients, sourced from GMO crops, are so processed that they contain no DNA and no protein and are absolutely identical at a chemical level with non-GMO ingredients. Yet I522 wants them labeled. It seems to me that the i522 label requirement for, say, sugar or vegetable oil is more confusing to me than helpful. Do you agree?

    Yet another anti-GMO argument is that the technology promotes monoculture. But monoculture is the norm for many large agricultural operations, even in crops like wheat. And there is no reason why one could not grow some GMO crops in mixed non-monoculture operations. If my anti-GMO concern is monoculture, does I522 help me?

    Another concern is that we are using herbicides. But take the example of corn, which is naturally tolerant to atrazine, so that atrazine has long been used for weed control in cornfields. Does the GMO label help me avoid the herbicide use? Even with glyphosate, it is common for wheat producers to spray a field with glyphosate only days before harvest, specifically for the purpose of killing the crop so that the grain will be harvested with a lowered moisture content. It seems that there would be more glyphosate residue in such a wheat crop than there would be for a crop sprayed with glyphosate many months before harvest. If there were ever to be glyphosate tolerant wheat, the drying technique would no longer be used. How does I522 help me to avoid glyphosate?

    Will you concede that I522 was meant, by its organizers, to give a disadvantage to the GMO process, and somewhat less to help consumers make choices that reflect their concerns?

    • Tom says:

      “How does the GMO label help me punish large corporations?”

      I think this political cause is mostly orthogonal to GMO labeling. There are large corporations abusing power in all sectors of the economy, not just in agriculture, and there are more direct ways to resist that. For many sectors (including food manufacturers), it is easy to track brand names. I agree that it’s much trickier for agricultural producers (ADM, Cargill, ConAgra), and different kinds of traceability would be required to enable effective boycotting here, though many consumers (like myself) effectively do so by avoiding processed food and buying traceable meat. The preferential use of GMO products by large producers makes GMO labeling slightly relevant; but fundamentally, I think this issue requires attention at a different level, since it is politically pervasive.

      “How does the GMO label help me to punish Monsanto?”

      The extent to which people single out Monsanto versus other abusive corporations has a lot to do with GM technology, which has unique attributes pertinent to sustainability and legal protection. If, hypothetically, Monsanto phased out its GM technology in favor of its non-GM seed business, I think most people would view it in the same category as other ruthless monopolistic corporations. A large part of Monsanto’s business is GMOs, and they are strongly dominant in that sector, so I think GMO labels help people resist Monsanto to the extent Monsanto is “special” to concerned consumers.

      “the i522 label requirement for, say, sugar or vegetable oil is more confusing to me than helpful. Do you agree?”

      There are obviously subtleties that are not highlighted by the proposed GMO label. Similarly important subtleties (such as trans fat) have been omitted from other labeling requirements in the past. But in this particular case, I believe a consumer concerned about GMOs is reasonably capable of inferring this distinction if the ingredients listing also annotates which ingredients are GMO-derived (which manufacturers have the freedom to do), just as astute consumers avoid trans fat by looking at the ingredients listing.

      “If my anti-GMO concern is monoculture, does I522 help me?”

      The main GMO technologies today were developed to counteract problems highly exacerbated by monoculture, and avoiding them does exert some pressure against monoculture. Though there are non-GMO monocultures, phasing out the GMO ones will spur more development of polyculture technology and practices, which will ripple through the industry. Given the greater inherent potential of polyculture for efficient, sustainable, and nutritious agriculture, this kind of investment should eventually tip the balance. And though there are currently GMOs in polyculture, today’s major GMO crops are hardly necessary in polyculture-intensive world, so these opreations should have little difficulty avoiding them.

      “Does the GMO label help me avoid the herbicide use?”

      Certainly GMO labeling does not help to avoid all (or even most) pesticides: consumers concerned with pesticide avoidance would be more interested in organic certification, which sidesteps the GMO issue entirely. However, one could argue that GMOs enable uniquely pervasive accumulation of certain pesticides (either sprayed on or grown into the plant), not subject to the usual biological balance required to limit crop damage, and that avoiding GMOs could selectively protect the consumer from these unique pesticide dangers. These unique characteristics also pertain to ecological and nutritional concerns a consumer may have, for instance, the effects of glyphosate on soil microbiota.

      “If there were ever to be glyphosate tolerant wheat, the drying technique would no longer be used. How does I522 help me to avoid glyphosate?”

      You describe a specific circumstance in which GMO technology could reduce pesticide residues, and of course there are such circumstances. So while simply avoiding GMOs may allow people to achieve certain goals overall, they may have to consider more detailed information or other simple alternatives (i.e., certified organic) if they want to achieve them in every case.

      I believe by your arguments you mean to suggest that because GMO labeling by itself does not provide precise information about many common consumer concerns, it is not helpful for consumers with those concerns. However, I argue that imprecise information is still useful when it has some significant relevance to those concerns, *especially* when combined with other information that many help conscientious consumers to make more precise deductions. As such a consumer, I can tell you I am quite accustomed to piecing together many available pieces of information about a product (some regulated, some not) to determine unstated facts in which I am interested. Moreover, it is quite implausible that all the attributes in which I am interested would be explicitly regulated (voluntarily or not), so there is no getting around this process. Every additional piece of information adds something to the picture.

      I-522 could have been crafted to require more precise labeling requirements, but that would have created even more problems—both politically and practically—due to inconsistencies with labeling requirements in other countries. Since I-522 was already heavily criticized for the uniqueness of its requirements in the domestic market, this seems like asking too much for a labeling policy at the present time.

      “Will you concede that I522 was meant, by its organizers, to give a disadvantage to the GMO process, and somewhat less to help consumers make choices that reflect their concerns?”

      If by “the organizers” you mean all the thousands of people who worked to promote the initiative, I think this is highly unlikely. I believe most of these people *are* consumers who supported the initiative mostly *because* it would help them make such choices. I-522 was by many accounts one of the most populist initiatives in Washington state history.

      It is hard to see how any special interests enjoy significant gains from GMO labels except insofar as consumers gain. I’ve argued above that any gains for organic producers are unclear, as are gains for health-oriented retailers. It seems the largest business sponsors of I-522 are run by people who believe in GMO labeling and/or want to be associated with supporting consumers.

      In my view, the ideal system is something like what I have seen suggested by Michael Pollan, in which the limited information on the labels of food products is augmented by a unique identifier (i.e., hyperlink) that can be used to access more detailed information in a more suitable format. With some reasonable infrastructure, consumers could then know everything that all the upstream producers know about their food. Nothing is impractical about this in principle, but the current politics, law, and infrastructure in the food industry make progress very difficult.

      For some consumers, it is easier to find trustworthy food by just going to local farms they can see with their own eyes, as people did for millennia. Barring a total collapse of society, people will eventually get what they want. The only question is whether science will help them, or just tell them to go away.

      • Charles M. Rader says:

        Tom, you seem to have agreed with each one of my points, but you won’t put them together to draw the inevitable conclusion.

        1) If corporate power is the problem, you want a label that is about corporate power. Singling out only the corporations who use GMO technology is meant only to disadvantage the technology.
        2) If Monsanto is deserving of a boycott, the label should not be gathering together all GMOs, whether Monsanto’s or not, and it does nothing to help the consumer boycott Monsanto’s non-GMO products. Again, the label is meant only to disadvantage the technology.
        3) If food safety is the concern, the label should be different for foods that cannot possible be less safe than the conventional equivalents. Once again, the label is meant only to disadvantage the technology.
        4) If monoculture is the concern, the connection between GMO and monoculture is so diffuse that the label is, once again, clearly dir3ected against the GMO technology and gives the monoculture practice a free ride.
        5) If the concern is use of herbicides, let’s let the label talk about herbicides. There are GMOs that don’t use herbicides, and non-GMOs that do use herbicides, as well as GMOs that use herbicides of far lower toxicity than other similar plants. Still again, the label is meant to disadvantage the GMO technology.

        Finally, you seem to think that the purpose of I522 can be deduced by some sort of unexamined supposition about the thousands of people who supported it. Please concede that the purpose of I522 must be deduced by the attitudes of the people who wrote it, and those organizers have not concealed their purpose.

        • First Officer says:

          In effect, the anti-gmo argument that labeling is all about the right to know, help the little guy, etc, is nothing more than peeing on our collective leg and telling us its raining.

      • “It is hard to see how any special interests enjoy significant gains from GMO labels except insofar as consumers gain. I’ve argued above that any gains for organic producers are unclear, as are gains for health-oriented retailers. It seems the largest business sponsors of I-522 are run by people who believe in GMO labeling and/or want to be associated with supporting consumers.”

        I’d like to hear more about your theory here. IMHO, it seems logical that the “their product is scary, buy my product” marketing of organic seems to be working pretty darn well. So well that companies are scrambling to add “natural” labels to their products to try to gain some of that health halo that gets people to pay more for organic. Gains for organic companies are quite clear if mandatory GMO labeling is passed.

        “If, hypothetically, Monsanto phased out its GM technology in favor of its non-GM seed business, I think most people would view it in the same category as other ruthless monopolistic corporations. A large part of Monsanto’s business is GMOs, and they are strongly dominant in that sector, so I think GMO labels help people resist Monsanto to the extent Monsanto is “special” to concerned consumers.”

        Actually, Monsanto isn’t that big of a company at all. See the graphs in We have a right to save seeds. If the goal is to hurt Monsanto, labeling might work, but you’re also hurting any other company that is trying to compete with Monsanto (so in the end labeling could actually help Monsanto). Lastly, if the goal is to avoid Monsanto, why not ask for a Monsanto label?

  9. Keith Hayes says:

    The responses have gotten pretty lengthy so I’ll cut it down a little to address the main points. Respectfully Tom, a lot of what you’re saying doesn’t make a whole lot of sense to me. Or you’re simply playing semantics.

    “not so much as a runny nose has been attributed to them.”

    As I have previously pointed out, it’s impossible to attribute anything without data.

    No data? You need to read more. Or perhaps you have and couldn’t find any data, which is like losing a game of hide and seek with a moose in your living room.

    “Why would you think that farmers wouldn’t be as observant now as they were in antiquity?”

    It doesn’t matter if farmers are just as observant (though there are many fewer of them now) if the consequences are not localized.

    You were arguing earlier that the GMO’s have only provided a local benefit and now the consequences aren’t localized? Oookay?

    Have you ever talked to farmers? They’re on Twitter and they’re even blogging in plain English. They even have trade associations. How could any effects go unnoticed with this type of networking?

    The farmers don’t even see most of the people eating the food they grow, let alone know anything about their health.

    It’s interesting that you say this because I think one reason there’s such a big controversey is because people are so detached from agriculture that they don’t have the first clue as to how food is grown, harvested and processed until they hear about those “evil GMO’s” and not quite understand what they read or how it relates to agricultural science at all, but think they can tell farmers how to farm. In regards to the farmers? Yeah, they know what the consumer wants. They’d have to if they had any hope of selling the crops they harvest.

    The dangers to *appliers* of pesticides and their families are much better known than the potential dangers to *eaters*, precisely because the appliers know when they are exposed and can correlate the effects they observe.

    This makes no sense. There are symptoms to exposure to certain chemicals (overexposure to be more precise). It wouldn’t matter if one was the farmer or the “eaters”. The symptoms would be the same. And I thought I’d mention that farmers are “eaters” as well

    Transparency means a lot more than people questioning the government and the government telling them whether their concerns are valid. This kind of secrecy goes totally against any advocacy for “science-based” regulation: the independent science cannot be done (at least, not independently)! Even the editors at Scientific American, generally friendly to biotech, think this is a big problem:
    http://www.scientificamerican.com/article.cfm?id=do-seed-companies-control-gm-crop-research

    I think that Anastasia has addressed this and I have nothing more to add.

    “Everything in food production is traced by lot/batch number from supplier to the end user”

    How many food consumers do you know who obtain and record the lot/batch numbers associated with the food products they buy? Would anybody (researchers, health care providers, even government investigators) have any way of tracking their consumption after the fact? The practical answer is no.

    Take any food item in your refrigerator or pantry and look at the bottom or back near the UPC code. Near the freshness or “use buy” date is an alpha numeric number. That’s the batch number. Any regulator or auditor can contact the manufacturer and have them pull the batch records which would include how much of each raw material was added and its batch number as well as the results of the quality control testing of that batch. Repeat for as long as you want to go up the supply chain.

    You can bet your sweet arse that they’d do it too, especially if there’s a problem that requires a recall.

    Labeling a product as GMO does nothing to facilitate this traceability. It’s useless in that regard and it’s a silly argument to anybody that works in industry.

    Regulatory agencies are political bodies with their own biases. If, as GMO proponents claim, there is a scientific consensus about their safety, and the regulatory agencies follow that consensus, you would not see such different policy outcomes from different regulatory agencies around the world.

    It’s because they’re structured differently. As an example, the USDA, FDA, EPA in the US was created by act of Congress and their rulings carry the force of law. Their rulings tend to be more science based. This hasn’t stopped the public from trying to reverse the rulings in court, but that’s how it goes. This isn’t the design in the EU or many other countries for that matter. The EU has the EFSA (deals with foods) and ECHA (deals with chemicals) which function in a more advisory role to politicians who are more susceptible to whims of voters and public opinion. And even if the EU says GMO’s are okay, the member countries have very wide latitude in interpreting the policy or opting out entirely. That’s one explanation for the differences in policy outcomes. And that’s just for two different regions of the world. Going any deeper would take a whole dissertation and I can’t even be sure I understand the regulatory environment completely. But this gives you an idea.

    Officials at the USDA have publicly stated that their job is to support the American agriculture industry, and at least one official at the FDA has said that the responsibility for food safety lies with manufacturers.

    Yep, the manufacturer has to prove their products are safe and at their own expense. That’s how it works. Or would you rather have the public pay for it?

    “I would accept this as a good label:

    ‘Ingredients in this product have been derived from corn that has been genetically modified to reduce pesticide use’”

    This is one particular fact about the genetic modification in that corn. It is not a particularly informative fact (it doesn’t tell you whether the corn is Bt, RR, or what),

    It’s more informative than the labeling suggestion in I-522! But if you want to designate Bt, or RR, then go ahead. But this wasn’t even close to what I-522 would have mandated.

    …and it is a fact related to the producer’s motivations, which the consumer may or may not care about.

    The consumer doesn’t care anyway. Only 2-3% even buy organic. But you seem to care which is why we have this discussion. I suggested a label and you oppose it because it might look good for the producers. Perhaps you should admit that support for labeling is an attempt to incriminate certain food manufacturers so that the public may avoid purchasing their products.

    It would seem more sensible to call for a boycott if you ask me.

    You could argue that the more facts there are, the more educational the label, but choosing one particular (not-unbiased) fact does not, in my view, make for an obviously better label. As I’ve said, labels are for annotation: people looking for in-depth information (education) have resources to find it.

    The labeling mandated in I-522 fulfills none of these requirements.

    Vitamin A deficiency is a problem created by monocropping that can be solved by a return to indigenous, diverse farming methods (with numerous important secondary benefits).

    Good idea! Instead of going blind, they’ll simply starve before that happens. Problem solved!

    Applying a narrow technological fix to this problem may be a straightforward solution, but it is not a long-term or integrative solution. It may not even be a short-term solution: during the time golden rice has been in development, many other short-term interventions have made tremendous progress on VAD blindness. Golden rice is on track to provide more value as a public relations tool for biotechnology than to people with VAD.

    If your not going to acknowledge such an obvious benefit to golden rice, then it should at least demonstrate a proof of concept that GE can enhance the nutritional content of food.

    Or you can put your fingers in your ears and hum really loudly.

    Your choice.

  10. Michael says:

    The link on this page for “A survey by researchers at Rutgers University (pdf)” is broken.

  11. the bug guy says:

    Off-topic, but is there any way to disable the autostart on the Colbert Report video.

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