The issue was approached by Dr. Ralph Scorza from the USDA Appalachian Fruit Research Station. I’ve known of Dr. Scorza’s outstanding work for almost two decades.  Years ago he sought a solution to the plum pox virus (PPV), the causative agent of a devastating disease called Sharka. The disease affects stone fruits (peaches, apricots, others) and can destroy whole orchards and decimate natural populations.  While breeding solutions are being pursued with timelines measured in decades, PPV can now be mitigated with Scorza’s solution by grafting a stonefruit scion to the transgenic rootstock.  Works like a charm, and the fruit are not transgenic.

The solution was introduction of a gene encoding the coat protein of PPV.  When overexpressed in plums (because they are routinely transformed in the Scorza Lab), the plant became immune to the disease, almost like a vaccination.  While this was interesting science it was not viewed as an application, that is until PPV was identified in the United States.  While the disease was successfully controlled with quarantine, the development of PPV-resistant plums (a cultivar known as “Honeysweet”) was initiated as a solution in future outbreaks.

Years later in 2010, the Honeysweet cultivar has found approval.  It is a true minority, as very few horticultural crops are ever approved, reserving much of the focus for major agronomical crops like soy and corn.  To date, only 6% of de-regulated crops are horticultural and only 1% had viable commercial potential.  Of that, 0.2 were crops other than tomato and potato. Therein lies the question, why are transgenic technologies not approved (or even pursued) in fruits and vegetables?

A mere 127 horticultural crop lines have sought deregulation, but the vast majority of these did not complete the process to commercialization.  Dr. Scorza indicates that the costs of pursuing deregulation and testing are incredibly expensive, leading companies or universities to abandon the process in mid-stream, even if promising.

He goes on to describe other potential reasons for the waning desire to deregulate.  First, there is a relatively small market for any given horticultural crop, so the likelihood of  substantial profit is low, an important consideration when the costs of R&D and deregulation are concerned.  Universities and small companies do not have the funds, infrastructure or intellectual property resources required to hustle the process along.  Horticultural companies and universities may understand the potentially negative perception that the public has on safe transgenic technology, so they stay away from attempting to commercializing transgenic plant lines that while scientifically proven, may not be tremendously profitable.

The other key reason while these crops do not navigate the maze to deregulation is because there is no incentive for the scientist.  Inventing a solution to a horticultural problem does not bring in grant money, does not generate publications, and requires a tremendous investment of time in meetings and paperwork that may never be rewarded.  Ask anyone working in the public science sector– we didn’t get into it for the love of beaurocracy.  Additionally, there are steep consequences of not following the approval process to the letter, with substantial fines and/or regulatory action. Together these barriers frame a formidable disincentive. To date the effect shows, as private concerns have deregulated many achievements in tomato, potato, squash and tobacco, whereas public entities have only released (the amazingly successful) papaya and now plum.

The other problem is the aforementioned maze of regulatory hassle.  There are three major levels of approval for a GM food crop.  The first is through USDA-APHIS, an agency that regulates the growing of GM foods.  “Honeysweet” cleared this barrier quickly.  Next the FDA has to approve safety.  For ‘Honeysweet’ that took 2.5 years.  Finally, the EPA must approve the new organism, a process that took almost 3 years in the case of ‘Honeysweet’.

After all of the regulatory hurdles the product still may not be commercialized, mostly based on public perception. For instance, it cost nearly half a million dollars to build raspberry plants resistant to the Raspberry Bushy Dwarf Virus, a devastating disease.  While the plants work brilliantly, the industry suggested they not be commercialized due to public fears.

The other problems are from coordinated attacks by anti-GE groups.  In 2007, while ‘Honeysweet’ was in the process of deregulation, instructions on gmofreetrees.com provided details to cut-and-paste complaints into websites of federal agencies. Of the 1725 notes provided, 1708 were negative to ‘Honeysweet’ deregulation, but all followed the cut-and-paste format.

Dr. Scorza completed his discussion by noting that transgenic plant acceptance will be disaster driven.  When farmers and consumers have no choice, then the new technologies will be accepted.  Problems such as PPV in stonefruits, Pierce’s disease in grapes, and citrus greening may all soon benefit from transgenic technology with existing tools that may save an industry.  Even crusty old Europe is considering ‘Honeysweet’ and weighing real risks in the face of losing tremendous stonefruit populations to a viral outbreak.  Just as a major outbreak of polio will send anti-vaccination parents scurrying for a jab, the adoption of GE technology will be found quite acceptable when scenarios dictate no other choice.

I agree with Dr. Scorza’s assessment.  Anti-GE interests don’t trust big, private agribusiness, but then simultaneously support a regulatory system where only it can thrive.  Public scientists that have a mission of societal contribution lack the funds and infrastructure to obtain approval have trouble competing in the disincentivized process.

Dr. Scorza concluded that he remains optimistic.  Consumers have accepted GM soy and corn.  The acceptance of horticultural crops will happen eventually, but the barriers to application will make the process slow, impeding potential benefits to the consumer, the farmer and the environment.

Kevin Folta is an Associate Professor in the Horticultural Sciences Department at the University of Florida.  Armed with a fist-full of genome data and the molecular toolkit to put it to work, his goal is to exploit technology to its fullest to feed more people, more nutritious food, with less environmental impact.  Unfortunately, well-meaning science deniers stand to obstruct this mission.  Wielding the steely sword of science and the velveteen fist of rhetoric, Kevin seeks to win their hearts and change their minds so that we can advance the cause of using biotechnology to feed more people with less harm to our planet.

we reject the organic-conventional dichotomy and emphasize that, in order to optimize environmental sustainability, individual tactics must be evaluated for their environmental impact in the context of an integrated approach, and that policy decisions must be based on empirical data and objective risk-benefit analysis, not arbitrary classifications.

The paper was Choosing Organic Pesticides over Synthetic Pesticides May Not Effectively Mitigate Environmental Risk in Soybeans (full text) by Christine Bahlai et al. Long story short, the research showed that some synthetic pesticides were more environmentally benign than some organic pesticides, showing that it’s inaccurate to say that organic pesticides are better for the environment. Sometimes they are, and sometimes they are not.

The paper itself is really great, deserving of its own post (see Organic pesticides aren’t necessarily more sustainable than synthetic by Colby Vorland), but I’d like to talk about the organic-conventional divide. Normally I don’t approve of thoughts in scientific journal articles that aren’t immediately related to the research, too often authors stray into questionable territory. But Christine’s thoughts here are immediately related to her findings, and her results may indicate that big changes are necessary in the way we think about farming.

Separating out “organic” as defined by the USDA may be beneficial in the short term for farmers that have transitioned to certified organic methods who can then charge a premium, but in the long term, the divide is a detriment to farmers, consumers, and the environment. If we really care about farming in a more environmentally friendly fashion, we need an entirely new system.

We all want the same things*:

1. healthy food that is accessible to everyone regardless of location or income
2. farmers that can afford to farm and to pay fair wages to their employees
3. conservation of resources (especially soil!) and protection of ecosystems

We can get those things through three complimentary and often intertwined avenues:

1. demand
2. policy
3. research

Demand driven change seems to be moving along. We see lots about healthy food in popular media, increasing popularity of farmers’ markets, talk of adding cooking classes to public schools, and a push to make school lunches healthier, just to name a few. More could be done, but it is happening. We might have different ideas of what exactly constitutes healthy food, but I don’t think anyone’s arguing that more fruits and veggies is a bad idea. Ok, probably someone is, but let’s just agree to ignore them.

Policy driven change seems to be moving along as well. Michelle Obama is leading the charge with her Let’s Move program that touches many government programs. Kathleen Merrigan is pushing for help for local food systems, even while Tom Vilsack works mostly within the status quo. As demand for healthier food increases, senators and congressmen will be more likely to support policy changes at the federal level, especially if we somehow start electing people with backgrounds other than business. Yes, it would be nice if everything changed faster, but it’s going to take a while to change a system that’s been in place for 40+ years.

With both demand and policy, the important thing is to keep pushing for changes, and over time things will change. Optimistic, simplistic, yes, but true. The alternative is revolution, which would probably suit some people, but is more than a little extreme.

That leaves us with research. Research is what informs both demand and policy – or at least it should be. Research can provide us with information about which methods are preferable to others, such as which pesticides would have the least impact on farm and off farm ecosystems. Research, if properly applied, can help guide demand and policy to improve human and environmental health, among other things.

Here’s the problem, to borrow from the pesticide comparison paper: not enough “empirical data and objective risk-benefit analysis” and too much “arbitrary classification”. When demand and policy are based on arbitrary classifications like “natural is better” without research to back it up, we end up with demand and policy that are ineffective at best. We also end up with unnecessary divisions that cause efforts to be split, even though we all really want the same thing.

Let’s look at organics as defined by the USDA:

…an ecological production management system that promotes and enhances biodiversity, biological cycles and soil biological activity… The primary goal of organic agriculture is to optimize the health and productivity of interdependent communities of soil life, plants, animals and people. (USDA National Organic Standards Board definition, April 1995)

or agriculture that does

…respond to site-specific conditions by integrating cultural, biological, and mechanical practices that foster cycling of resources, promote ecological balance, and conserve biodiversity. (CFR Regulatory Text, 7 CFR Part 205, Subpart A — Definitions. § 205.2)

Sounds great, right? Except that by separating organic out from the rest of agriculture, we’re implying two things:

1. that non-organic-certified farmers don’t have these goals in mind
2. that they don’t have to.

It probably is true that some conventional** farmers don’t care about their soil, don’t conserve resources, etc. But those aren’t going to be very sucessful farmers if their soil is poor and they have to buy way more fertilizer than their neighbors, for example. If you lined up all of the farmers in the US according to their soil quality, I bet you’d find a bell curve. In each category from bad to great soil, you’d find some conventional and some organic farmers. According to the research, organic methods can be better for soils than conventional methods***, but there is so much variation in how farmers actually apply the methods that a one farm to one farm comparison really doesn’t tell the whole story.

There are many conventional farmers that apply integrated pest management, that use rotations to reduce crop-specific pests, that use legume rotations to help reduce the amount of nitrogen that needs to be applied, that use planting methods that decrease soil compaction, and so on. And there are organic farmers that just do the minimum to keep certified. And a whole range between.

Even if we assume that, on average, organically farmed soils are superior in organic matter, microbial activity, etc, we’re still not saying much. “Certified organic cropland and pasture accounted for about 0.6 percent of U.S. total farmland in 2008″, according to the USDA. When we make regulations for such a very small portion of farms, we’re not actually doing anything at all. Consumers should demand environmentally friendly methods from the other 99.4% of farms and policy should be made that includes all of those farms – and all of it needs to be based on sound research.

Ideally, demand and policy would be based on those methods that have been shown to work. If additional research confirmed that using mineral oil was more harmful to farm ecosystems than one or more synthetic pesticides, then one would hope to see demand and policy encourage use of the insect control strategy that had the least impact instead of arbitrarily choosing the “natural” method over a synthetic. Right now, there’s little if any research driving demand or policy. Instead, we have ideology.

Infighting over whether organic or not-organic is better, can feed the world, blah blah blah, isn’t actually helping anyone. The reality is that some methods used by some organic farmers are superb and some might not be. Some should be widely adopted, and some might even be more harmful their conventional counterparts (see the study I started this post with). Complicate that with the fact that not all farmers use the same methods and trying to decide whether organic is better becomes completely futile.

The research looks at individual methods, not arbitrary classifications – which is  really the only effective way to look at things. What we really need is a system that rewards farmers for environmentally friendly farming practices****. A farmer that uses legume rotations for nitrogen but still needs to use some synthetic N, P, and K  to maintain good soil nutrients should be rewarded or recognized somehow if he uses application methods that have been shown to reduce runoff. A farmer that uses integrated pest management to reduce chemical pesticide application that farmer should be recognized.

Hypothetical label touting E-value of contents.

Perhaps there could be a scoring system where environmentally friendly methods are given a number value and farmers with higher values can seek a higher price from buyers that are interested in such things. I can easily imagine a box of corn flakes labeled “made from corn with E-values of 100 or higher!” Another option might be to revamp the whole subsidy system to focus on farming practices, where farmers could have a financial incentive to choose environmentally friendly practices, epecially in cases where a change from one method to another would have an initial capital cost (like new tilling equipment) or when the change might reduce yields or income.
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Let’s put aside the petty squabbling and focus on the research that has the potential to guide 100% of farms toward more sustainable methods. Not enough research? Let’s demand better federal funding for relevant projects. Let’s demand policy that helps all farmers and all land, not just some.

So, farmers organic and conventional, advocates of various farming methods, consumers, economists, policy analysts, everyone… What sorts of incentive systems might work? Would you spend a little more for a product that you knew was made with ingredients that were sustainable grown? Would this whole crazy idea be just too expensive to implement? Would the cost be mitigated by the benefits?

Bahlai CA, Xue Y, McCreary CM, Schaafsma AW, & Hallett RH (2010). Choosing organic pesticides over synthetic pesticides may not effectively mitigate environmental risk in soybeans. PloS one, 5 (6) PMID: 20582315

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* Yes, agribusiness wants something else – money. But I’m talking about people, not corporations here. And if you think organic agribusiness cares any less about money than other companies, you are simply naive.

** I really don’t like the word conventional, but it’s better than saying “non-organic-certified” every time I want to mention farmers that aren’t organic certified.

*** To name one recent study that shows healthier soil under organic methods:  Moeskops B, et al. 2010. Soil microbial communities and activities under intensive organic and conventional vegetable farming in West Java, Indonesia. Applied soil ecology 45(2)112-120. Within the confines of this particular study, organic soils are closer to local forest soils, but I bet there are farms which would show the opposite to be true. As with all studies, we have to be careful to remember that the findings apply within the conditions of the study and may or may not apply elsewhere.

****I’m not advocating a dissolution of the certified organic system. It’s not perfect, but it’s all we’ve got at the moment. I’m just saying we can have a system that actually works to improve all farms, and organic can keep doing whatever its adherents want.

The various methods of generating electricity are a great example. Humans have become dependent on energy for so many things, some frivolous and some necessary (depending on your point of view). Unless we are all willing to forego electricity, we must find some way to power our lives. Current methods, including coal, have harmful unintended consequences that many of us would say outweigh the positives that we get from the electricity that is generated. Water power, once thought to be one of the cleanest methods of generating electricity, has been found to cause problems big and small. Nuclear has its own set of problems, as does wind.

Because each solution has positive and negative effects, the best we can do is examine each situation individually using the best science available and decide how to achieve the most positive effects while decreasing the negatives. Plant genetics is no different from power generation in this respect.

Every individual plant trait obtained with biotechnology, mutagensis, wide crosses, etc has its own set of positives and negatives. This means that sometimes a biotech solution will work well, sometimes a low-tech traditional solution is best, sometimes the necessary solution is totally out of the box. It makes no sense at all to be “pro-GMO” or “anti-hybrid” or anything like that because those stances don’t take into account the intricacies of individual situations. There might be times when using a hybrid is a bad idea and times when using a GMO is a good idea, but there will also be times when the opposite cases are true!

To complicate things further, plant traits can’t just be considered on their own merit. There will usually also be a complex set of factors including psychology in the form of tradition, fears, education, and so on. There’s economic factors from the individual level all the way up to local, national, and global levels. There’s environmental factors of course, since any agricultural methods can have an effect on ecosystems near and far. And that’s just a few of the many factors that might be involved. We also have to consider what our goals are and how they fit into the big picture.

Considering all of these factors isn’t easy, which I think is a big part of why some people like to sum things up and be anti this or pro that. Easy isn’t always right, though.

How about you? Are you pro-GMO? Anti-GMO? How about pro- or anti-mutagenesis or tissue culture or any of the other techniques out there? Does it make more sense to be pro- or anti- a specific technology or method or to consider an application of that method?

EWG gives many many reasons why they think you should use the guide, specifying that you (the consumer) should eat organic or at least choose the Clean 15™ over the  Dirty Dozen™:

The 12 most contaminated fruits and vegetables (the “Dirty Dozen”) are contaminated with an average of 10 different pesticides, with many tainting more than one type of produce. In contrast, the “Clean 15,” the 15 least contaminated fruits and vegetables, contain an average of less than 2. Eating organic food lowers pesticide body burdens as well. Research shows that concentrations of pesticides in children’s bodies peak during seasons that they eat the most produce, but fall to below detectable levels in just 5 days when they eat organic food.

The list of reasons has a lot of scary facts about how many pesticides detected on food, just how “polluted” our bodies are from the things we eat, and explains how our government barely regulates pesticides. Near the bottom, EWG lets us know that despite the scary facts that the need to eat fresh produce outweighs any risk from pesticide residues. They also remind consumers of the importance of eating fresh produce on their FAQ page. Unfortunately, I’m not sure if anyone gets to that part, considering that media coverage of the Shopper’s Guide rarely mentions it, instead focusing on the scary facts (as in ‘Dirty dozen’ produce carries more pesticide residue, group says on CNN Health, which dismisses the silly government for thinking that small amounts of pesticides won’t hurt us).

The truth is, pesticides are scary. As EWG’s Amy Rosenthal says, “Pesticides are designed to kill things.”

The devil, as always, is in the details.

We need the EWG

Before we get into those details, I’d like to say a few things about the Environmental Working Group in general, or really any group that does what EWG tries to do. EWG has the ability to provide a very important benefit to society. Government spending on science has decreased over the years, leaving most toxicity research to the companies that make the products being tested. Until we follow the wise leadership of India and develop a network of government certified independent testing labs, we’re all kind of left with less information than I’d prefer for many products we use every day. It’s not that I think every corporation is driven by people who choose profits over safety (on the contrary, they have to at least think their products are safe or suffer bad press or worse if people get sick) but results of corporate funded tests are often not made available to the public which leaves regulators with less info than they need to make good science-based decisions. Our system works fairly well (the grand majority of people get through life without health problems caused by things they can’t control other than their own genetics*) but it could always be better. EWG works to get information to regulators and presents a non-industry point of view, which is much needed. Unfortunately, despite their outwardly awesome intentions, some of the results are less than awesome.

Details, details

Danger, elephants. Taken by Adam Foster at Knowsley Safari Park in England. via Flickr.

In the materials accompanying the Shopper’s Guide, there are two details that are never discussed.

The first elephant in the room is dose. For any compound, from water to arsenic to ricin to organophosphates, there are amounts that are safe and amounts that are hazardous. There are amounts that will cause acute (immediate) reactions and amounts that will cause chronic problems after long term exposure. Are the amounts of pesticides found on produce enough to cause acute or chronic health problems? The EWG list does consider amount, but does not compare the amounts to EPA guidelines. The accompanying materials focus on the number of pesticides, not the dose.

The second elephant is the type of pesticides that were found on produce. There isn’t any weighting in the Shopper’s Guide of individual pesticides based on relative toxicity. This could be a problem because not all pesticides are created equal. Organophosphates, for example, are extremely dangerous because they affect cholinesterase, an enzyme that is essential for the human nervous system. Glyphosate, on the other hand, affects EPSPS, an enzyme that is only found in plants so human toxicity is low (surfactants and other ingredients in glyphosate containing herbicides may be dangerous in their own right, but EWG to my knowledge isn’t talking about those types of ingredients).

Careful consideration of dose and toxicity of pesticides on produce may mean a reordering of the list is necessary in order to truly keep consumers safe. It may also mean that many of the scary facts need some sober facts alongside to help us keep things in perspective. Let’s look at the  methods that EWG used to make the list and at the original USDA data.

EWG’s Methods

I have to tip my hat to EWG for providing their methods on their website. I don’t know how many people look at it, but I certainly did! They provide justifications for not discussing dose or type of pesticide:

The goal is to include a range of different measures of pesticide contamination to account for uncertainties in the science. All categories were treated equally; for example, a pesticide linked to cancer is counted the same as a pesticide linked to brain and nervous system toxicity, and the likelihood of eating multiple pesticides on a single food is given the same weight as the amounts of the pesticide detected or the percent of the crop on which pesticides were found.

The problem is that, as strange as it may sound, there are safe amounts of pesticides. With the incredibly low detection limits that advanced methods provide us, we can expect many positive results that aren’t biologically significant. This is why the EPA bothers to determine tolerance limits for each pesticide (see below: The Data). The EWG continues:

The EWG’s Shopper’s Guide is not built on a complex assessment of pesticide risks but instead reflects the overall pesticide loads of common fruits and vegetables. This approach best captures the uncertainties of the risks of pesticide exposure and gives shoppers confidence that when they follow the guide they are buying foods with consistently lower overall levels of pesticide contamination.

In other words, science-based risk assessment is bad because it’s complex? A less complex and unscientific method gives consumers more confidence than a science-based method? Perhaps, but this explanation of the method is a little too close to fibbing for my taste. Maybe we need to look deeper.

EWG looked at contamination in 6 different ways:

• “Percent of samples tested with detectable pesticides.” Assuming that the data was used properly, this is a good metric. It tells us how many of all the samples within a category had pesticide residues.
• “Percent of samples with two or more pesticides.” This metric might be useful if we are concerned about potential effects of consuming more than one pesticide.
• “Average number of pesticides found on a single sample.” This isn’t as useful as a median number of pesticides could be. If most of the samples contain 0 pesticides, the average would be lower than the median. If only one of the samples contains a very large number of pesticides, the average would be artificially high.
• “Average amount (level in parts per million) of all pesticides found.” Here’s where the science gets thrown out. The type of pesticide isn’t considered even though we know that some pesticides are dangerous at low doses while other pesticides are safe at much higher doses. The ppm of different pesticides should not be averaged unless they have similar toxic doses. No where on the Shopper’s Guide site  is there a discussion of how the pesticide levels found in produce match up to EPA guidelines, or how those guidelines are created (in most cases the guidelines from the EPA are at least 10 times lower than the actual dangerous dose).
• “Maximum number of pesticides found on a single sample.” This isn’t very useful either. Perhaps one sample was grown by a particularly zealous farmer who used more pesticides than she should. Perhaps the single sample was accidentally contaminated. Should the entire category of produce be condemned because of this single sample, out of hundreds of samples? Using the median number of pesticides for all of the samples make much more sense.
• “Total number of pesticides found on the commodity.” Again, this number could be based on one or a few samples which are not representative of all of the samples.

The Data

High speed capture of dye droplets by Derek Purdy. via Flickr.

Since 1991, the Agricultural Marketing Service (part of the USDA) has collected data on pesticide residues in food as part of the Pesticide Data Program (PDP) using pretty rigorous methods (pdf). In addition to this testing, the FDA tests domestic and imported food to ensure that pesticide residues are below the tolerance levels (FDA probably doesn’t test enough samples due to funding cuts but that’s another post). The results are compared to tolerance levels (maximum pesticide residue limits) that are set by the EPA (you can find the tolerance for each crop/pesticide/country combo at Maximum Residue Levels database). According to the Latest PDP Findings of Interest to Consumers (pdf), ”the vast majority of samples tested are well below the tolerance levels”. Specifically:

The USDA provides some comparisons to help us understand what 1 part per million is: 1 ounce of salt in a mountain of 62,500 pounds of sugar or 1 ounce of dye in 7,350 gallons of water.

The most recent Annual Summary of the PDP (pdf) contains data that was collected in 2008 and was released in December 2009. The Executive Summary tells us that 11,960 samples were analyzed, including fresh and processed fruit and vegetables (9,028 and 1,354 samples respectively), almonds, honey, corn, and rice (municipal drinking water is also tested). The positive pesticide residue detections were combined by food type; on average 1.6% of samples had positive residue detections. For fresh produce, positive samples ranged from 0 to 3.3% with an average of 1.9%. They go on to say:

For samples containing residues, the vast majority of the detections were well below established tolerances and/or action levels. Before allowing the use of a pesticide on food crops, EPA sets a tolerance, or maximum residue limit, which is the amount of pesticide residue allowed to remain in or on each treated food commodity. Established tolerances are listed in the Code of Federal Regulations, Title 40, Part 180. In setting the tolerance, EPA must make a safety nding that the pesticide can be used with “reasonable certainty of no harm” and that residues at (or below) the tolerance are safe. The reporting of residues present at levels below the established tolerance serves to ensure and verify the safety of the Nation’s food supply.

To restate, the methods used to detect pesticides are very sensitive, but a positive sample does not indicate a problem unless the detected level is above the established tolerance level. “A tolerance violation occurs when a residue is found that exceeds the tolerance level or when a residue is found for which there is no established tolerance.”

There were 60 samples that exceeded tolerance levels, making up 0.5% of all the samples (58 with 1 residue exceeding the tolerance and 2 with 2). There were 442 samples that had pesticide residues that don’t have established tolerance levels, making up 3.7% of all the samples (one reason why there isn’t an established tolerance level is that the pesticide in question isn’t labeled for use on the specific crop being tested). “In most cases, these residues were detected at very low levels and some residues may have resulted from spray drift or crop rotations.” Starting on page 51 of 202, the results are presented in a table the includes the number of samples tested, the number of positive samples by pesticide type, the amount of pesticide detected, and the EPA tolerance for that pesticide. I encourage you to see the report for all the details. The actual data can be downloaded from the Agriculture Marketing Service, although sadly it isn’t in any sort of convenient format (I’m wrestling with the data right now).

Peaches

There do seem to be some discrepancies between what EWG says the USDA data says and what the USDA data says.

The EWG says “more than 96 percent of peaches tested positive for pesticides”, and “peaches had been treated with more pesticides than any other produce, registering combinations of up to 67 different chemicals.” That sounds pretty bad.

Table 3 of the 2008 USDA report lists the “Number of Samples Analyzed and Summary of Results per Commodity” (page 34). According to this table, 616 peach samples were analyzed, with an average number of 130 different analyses conducted on each individual sample, resulting in a total of 80,184 tests done on the 616 peach samples. Of these tests, 2,155 were positive for pesticide residues, and 52 different pesticides were detected. While the number of positive detections out of all the tests isn’t the same as the number of positive samples out of all the samples, it is still interesting to know that only 2.7% of all the tests conducted on peaches were positive.

52 isn’t 67. 2.7% isn’t 96%. What’s happening here?

EWG didn’t use the most recent data. Instead, they seem to have combined data from 2000 to 2008. That seems very strange to me, considering that EPA regulations for allowed pesticide use and allowed pesticide tolerances have been changing over the years, becoming more strict. At least they didn’t include pre-2000 data, but still this isn’t the best way to find the information that consumers want. We need to know how many fruits and vegetables today are positive for pesticides, not all the fruits and vegetables in the past decade.

Even when we consider the fact that the EWG isn’t working with the best dataset, that still doesn’t answer how they decided that more than 96% of peaches were positive for pesticides. Hopefully the answer will be clear once I’ve looked at the USDA data myself.

If not scary “facts”, then what?

I am definitely an advocate of using science-based approaches to farming that reduce input use overall, and of careful Integrated Pest Management strategies that use the safest possible solutions to any pest problem, only using inputs if other options have been unsuccessful, and using the safest possible pesticide whether that pesticide is natural or synthetic.

How do we encourage government to introduce regulation that will make this happen and how do we encourage consumers to care about this enough to talk to their elected officials?

The best course of action would be to present the information in a less agenda driven way. Provide the data along with the EPA guidelines, which would show that the great majority of produce is well within guidelines. There are ways to advocate for reduced pesticide use without alarming people unnecessarily.

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* In the developed world, health problems caused by our own choices (bad nutrition, lack of exercise, smoking, and so on) dwarfs any problems that might be caused by normal use of household chemicals, plastics, foods, etc.

Note: A group called Alliance for Food and Farming, called an “industry front group” by EWG has challenged the Shopper’s Guide, saying that it unnecessarily alarms consumers. I have not read any materials from AFF on this subject prior to writing this post to be sure that my comments were not based even subconsciously on their comments. I heard about the AFF response through the Iowa State Sustainable Agriculture Listserv, which led me to write a few responses about the Shopper’s Guide to the original poster which then were turned into this post. This year’s Shopper’s Guide came out in June 2010.

Genetically modified foods or crops are plants created using the latest technology in microbiology and agricultural science. Much in the same way that certain animals are bred to carry on specific characteristics, genetically modified foods and crops are created to enhance certain traits that make them modified to certain areas, constructs, and situations. For example, many advantages of genetically modified food is that they can be made to be pest resistant, herbicide tolerant, disease resistant, extra nutritious, and most importantly can stand up to effects caused from climate change. This is pertinent to the global warming discussion because by creating crops that can protect Mother Nature from Mother Nature we can operate, produce, and consume food that can outlast any change in climate.

Since 1996, there has been a rapid growth in genetically engineered crops in the United States (with some crops like soybeans growing going from under 10 percent of acres used to over 90 in a 12 year span). This growth can be connected to organizations and companies investing in genetically modified crops as the future of food production and consumption. For example, US biotech companies like Monsanto have begun testing water efficient and drought tolerant engineered crops that can survive and continue to be produced in case of drought or flood cause from climate change. Even humanitarian organizations like the Clinton Global Initiative, organized by close personal aide to Former President Clinton, Doug Band, are working with agricultural research centers like the International Rice Research Institute (IRRI) to produce flood resistant rice crops that will help protect small rice producing villages that are effected by climate change produced flooding.

Sure, genetically modified foods do have their detractors who argue that the chemically altered food isn’t safe and hurts biodiversity, but the positives outweigh the negatives. Genetically modified foods are a clear solution to the effects of climate change and can help keep food production steady in an unsteady climate.

Jack Lundee is a follower of all things green and progressive. With a degree in creative writing, and a strong involvement in the green blogosphere, Jack has been producing and editing his own content concerning things like climate change, carbon emissions, green infrastructure, green space, eco-consciousness, and so on and so forth.

Supreme Court of the United States (Source: SupremeCourt.gov)

In what (for me) seemed like no time at all, the Supreme Court of the United States (SCOTUS) has issued its ruling on the Roundup Ready Alfalfa case. In a landslide 7:1 ruling (with one recusing), the high court has lifted the nationwide ban on planting genetically engineered herbicide-tolerant alfalfa. What does this mean for GE alfalfa and sugar beet plantings that have been affected by the courts?

Although the social media chatter over the case was mostly characterizing it as crucial to win to “stop” GE alfalfa, it was really more about what the proper course of action is for the GE regulatory process, and whether a court can issue an injunction against planting GE crops while the environmental impact statement (EIS) is being drafted, without having to provide evidence of harm. For more background information, read my previous post about the case. In essence, the court was considering whether the lower court was right in “remanding” the GE alfalfa back to the USDA to determine whether it was ok to plant, while also issuing an injunction preventing them from saying it was ok to plant until the EIS is complete.

SCOTUS ruled that the lower court acted wrongly by remanding and enjoining at the same time.

The District Court abused its discretion in enjoining APHIS from effecting a partial deregulation and in prohibiting the planting of RRA pending the agency’s completion of its detailed environmental review.

(…)

Most importantly, respondents cannot show that they will suffer irreparable injury if APHIS is allowed to proceed with any partial deregulation, for at least two reasons. First, if and when APHIS pursues a partial deregulation that arguably runs afoul of NEPA, respondents may file a new suit challenging such action and seeking appropriate preliminary relief. Accordingly, a permanent injunction is not now needed to guard against any present or imminent risk of likely irreparable harm. Second, a partial deregulation need not cause respondents any injury at all; if its scope is sufficiently limited, the risk of gene flow could be virtually nonexistent. Indeed, the broad injunction entered below essentially pre-empts the very procedure by which APHIS could determine, independently of the pending EIS process for assessing the effects of a complete deregulation, that a limited deregulation would not pose any appreciable risk of environmental harm.

This sort of ruling was suggested by reading the transcript of the hearing – it sounded like they were interested in the double-barrier that the lower court had erected. By sending the alfalfa back to the USDA the lower court was saying that the USDA needed to figure out what to do about the alfalfa and whether it can be planted in the future. But by also issuing an injunction the court was saying that the USDA could not decide what to do according to its procedures unless the EIS is fully complete, which means no partial deregulation, which would be allowing some RR alfalfa plantings to go forward. In a bizarre twist, the lower court also said that farmers currently growing it could continue growing it. So essentially the court was saying that the USDA could not decide to allow some farmers to grow it while the EIS is pending because of environmental risk, but the court could. The SCOTUS latched onto that contradiction in their ruling:

First, the impropriety of the District Court’s broad injunction against planting flows from the impropriety of its injunction against partial deregulation. If APHIS may partially deregulate RRA before preparing a full-blown EIS—a question that we need not and do not decide here—farmers should be able to grow and sell RRA in accordance with that agency determination. Because it was inappropriate for the District Court to foreclose even the possibility of a partial and temporary deregulation, it necessarily follows that it was likewise inappropriate to enjoin any and all parties from acting in accordance with the terms ofsuch a deregulation decision.

And to sum it all up:

In sum, the District Court abused its discretion in enjoining APHIS from effecting a partial deregulation and in prohibiting the possibility of planting in accordance with the terms of such a deregulation. Given those errors, this Court need not express any view on whether injunctive relief of some kind was available to respondents on the record before us. Nor does the Court address the question whether the District Court was required to conduct an evidentiary hearing before entering the relief at issue here. The judgment of the Ninth Circuit is reversed, and the case is remanded for further proceedings consistent with this opinion.
It is so ordered.

So what does this mean about GE alfalfa plantings, can farmers just start buying and planting the herbicide-tolerant legume? No, what was lifted by the court was the injunction that prevented the USDA from allowing some farmers to plant GE alfalfa under partial deregulation. The court did not touch on the issue of whether it was right to re-regulate the alfalfa, or on the issue of whether an evidentiary hearing was required. What they did do was determine that the broad injunction was not justified by the National Environmental Policy Act (NEPA), and is saying that it is up to the USDA to assess whether it can partially deregulate the alfalfa should it choose to do so. Until that happens, no new alfalfa plantings can happen.

The dual remand/injunction nature of this situation has led to a lot of confusion in the first few hours of the news coming out. While the traditional news sources are getting it mostly right as lifting the ban, others are saying almost the opposite. The Center for Food Safety, the anti-GE lawyer group that led the legal battle in the first place, is also calling it a victory! Their statement has been carried through social media networks quickly. They said:

The Center for Food Safety today celebrated the United States Supreme Court’s decision in Monsanto v. Geerston Farms, the first genetically modified crop case ever brought before the Supreme Court.  Although the High Court decision reverses parts of the lower courts’ rulings, the judgment holds that a vacatur bars the planting of Monsanto’s Roundup Ready Alfalfa until and unless future deregulation occurs.  It is a victory for the Center for Food Safety and the Farmers and Consumers it represents.

“The Justices’ decision today means that the selling and planting of Roundup Ready Alfalfa is illegal.  The ban on the crop will remain in place until a full and adequate EIS is prepared by USDA and they officially deregulate the crop.  This is a year or more away according to the agency, and even then, a deregulation move may be subject to further litigation if the agency’s analysis is not adequate,” said Andrew Kimbrell, Executive Director of the Center for Food Safety. “In sum, it’s a significant victory in our ongoing fight to protect farmer and consumer choice, the environment and the organic industry.”

In the majority opinion written by Justice Samuel Alito, the Court held: “In sum…the vacatur of APHIS’s deregulation decision means that virtually no RRA (Roundup Ready Alfalfa) can be grown or sold until such time as a new deregulation decision is in place, and we also know that any party aggrieved by a hypothetical future deregulation decision will have ample opportunity to challenge it, and to seek appropriate preliminary relief, if and when such a decision is made.” (Opinion at p. 22).The Court also held that:

• Any further attempt to commercialize RRA even in part may require an EIS subject to legal challenge.
• The Court further recognized that the threat of transgenic contamination is harmful and onerous to organic and conventional farmers and that the injury allows them to challenge future biotech crop commercializations in court.

Uh oh… whenever you see an ellipses (…) check what was removed. Here is the full paragraph:

In sum, we do not know whether and to what extent APHIS would seek to effect a limited deregulation during the pendency of the EIS process if it were free to do so; we do know that the vacatur of APHIS’s deregulation decision means that virtually no RRA can be grown or sold until such time as a new deregulation decision is in place, and we also know that any party aggrieved by a hypothetical future deregulation decision will have ample opportunity to challenge it, and to seek appropriate preliminary relief, if and when such a decision is made. In light of these particular circumstances, we hold that the District Court did not properly exercise its discretion in enjoining a partial deregulation of any kind pending APHIS’s preparation of an EIS. It follows that the Court of Appeals erred in affirming that aspect of the District Court’s judgment.

The court did not rule that no RR alfalfa can be grown, this paragraph says that the court knows what the lower court ruled and its implications. So that’s nothing new. The whole previous section is filled with discussion of what exactly was meant by the lower court’s ruling, so this is a summary of that section. The court did not address whether the lower court was right in sending the alfalfa back to the USDA, from page 3 of the syllabus:

Because petitioners and the Government do not argue other-wise, the Court assumes without deciding that the District Court acted lawfully in vacating the agency’s decision to completely deregu-late RRA. The Court therefore addresses only the injunction prohibiting APHIS from deregulating RRA pending completion of the EIS, and the nationwide injunction prohibiting almost all RRA planting during the pendency of the EIS process.

As if that was not enough spin for the Center For Food Safety to use to declare victory, they also appear to have invented a new part of the ruling that is not even in there.

Any further attempt to commercialize RRA even in part may require an EIS subject to legal challenge.

The court did NOT rule on what would be required for partial regulation, in fact they emphatically declared that they were not ruling on that issue:

We do not express any view on the Government’s contention that a limited deregulation of the kind embodied inits proposed judgment would not require the prior preparation of an EIS.

(…) [note- you can check my ellipses if you want - nothing important left out]

Because APHIS has not yet invoked the procedures necessary to attempt a limited deregulation, any judicial consideration of such issues is not warranted at this time.(p19)

In fact, the ruling did mention in several places that a partial deregulation would involve an Environmental Assessment or EA (less involved than EIS). Page 9: (emphasis added)

In order for a partial deregulation to occur, respondents argued, the case would have to be remanded to the agency, and APHIS would have to prepare an EA “that may or may not come out in favor of a partial deregulation.”

And Page 10:

Nor is any doubt as to whether APHIS would issue a new EA in favor of a partial deregulation sufficient to defeat petitioners’ standing.

And most importantly, on page

If the agency found, on the basis of a new EA, that a limited and temporary deregulation satisfied applicable statutory and regulatory requirements, it could proceed with such a deregulation even if it had not yet finished the onerous EIS required for complete deregulation.

Keep in mind this is not the SCOTUS ruling that an EA is the appropriate action for partial deregulation though they seem to assume it, and they are certainly not saying that an EIS “may be required.” Granted, an EA could be challenged legally, but there is a difference between an EA and an EIS that goes beyond just how they are spelled.

I have left a comment on the CFS website asking for them to point out where in the decision they supposedly rule on this issue, but I expect, as before, that my comment will be moderated out of existence. Here it is for posterity:

Hi, I’m a little unclear about one statement made above about the SCOTUS ruling:
“Any further attempt to commercialize RRA even in part may require an EIS subject to legal challenge. ”
My reading of the ruling indicates otherwise – they said on the bottom of page 19:
“We do not express any view on the Government’s contention that a limited deregulation of the kind embodied in its proposed judgment would not require the prior preparation of an EIS.”
They also mention that a partial deregulation would involve an EA, not an EIS. Could you please point me to the passage in the ruling that supports what was included in your post?

Keep in mind, this press release was issued from the same lawyers that lost the case. As Mica Veihman from the Monsanto blog quips on twitter: “Wonder what Center for Food Safety’s statement would have said if the decision were the reverse. Hmmm…..” Still, you can’t fault them for being optimistic, just for making stuff up.

There is a silver lining for their side, however. The court did decide that conventional non-GE farmers and organic farmers have standing to claim that they can be harmed by cross-pollination of GE crops in court even if the cross-pollination has not yet occurred:

For example, respondents represent that, in order to continue marketing their product to consumers who wish to buy nongenetically-engineered alfalfa, respondents would have to conduct testing to find out whether and to what extenttheir crops have been contaminated. (p11)

Such harms, which respondents will suffer even if their crops are not actually infected with the Roundup ready gene, are sufficiently concrete to satisfy the injury-in-fact prong of the constitutional standing analysis. (p13)

While you could say they are harmed by doing additional testing, at the same time they are charging more for such ‘verified’ food via the Non GMO Project. As standing was necessary for the merits of the case to be addressed at all, it is a thin silver lining to those that want to use the desire of some farmers not to grow any GE plants at all as a means to prevent others from growing any at all. And the level of risk of harm was determined by the court not to be sufficient for an injunction.

So what other implications will there be for GE crops, like sugar beets? They, too, have been sent back to the USDA for a full EIS rather than just an EA. It appears that although the court in that case did not yet grant an injunction against the sugar beets, the judge indicated it was possible, which this could prevent . It could mean that farmers could continue to grow GE sugar beets under partial deregulation despite the fact that the USDA has to draft an EIS for complete deregulation of the beets. The alfalfa is nearer to approving its EIS than the beets, so as I said before the implications for the beets will probably be greater than the alfalfa.

Source: Wikimedia Commons

It seems that the USDA may change its policy of doing the Environmental Assessment before the Environmental Impact Statement, so if that is the case I doubt many other crops being affected by this sort of thing. Except, perhaps, if the CFS or someone else successfully gets a court to reject an EIS and send it back to the USDA, this ruling could probably affect partial deregulation in that case.

Finally, as a 7:1 ruling, this is not a split-decision “blame Clarence Thomas for working for Monsanto 30 years ago” situation. (Which as a more legally-educated science blogger Ed Brayton confirms is not an issue.) This is an overwhelming ruling against the injunction preventing partial deregulation of the alfalfa, and it could set a precedent for lower courts on how they are able to determine what the USDA can or cannot do. The extreme measures of an injunction were ruled as not warranted in this case, which could affect others.

I hope this clears things up, and while the CFS continues to call their defeat a victory, I don’t think it will actually be added to their list of victories. The ban was defeated, not upheld.

It was so ordered.

More resources:

• Monsanto Press Release
• CFS Press Release
• BusinessWeek
• Reuters (on NY Times)
• Saint Louis Dispatch
• SCOTUS Wiki

Disclaimer: I am not a lawyer. This is not legal advice. Information purposes only and yadda yadda yadda. Please correct any misunderstandings in the comments.

The first thing that occurs to me in this discussion about the hybrid seed is that there still is a lot of misinformation flying around about it. Beverly Bell, who ‘sounded the alarm’ about farmers supposedly planning to buy and then burn the donated hybrid seed, continues to make stuff up about the situation. While Monsanto never offered to donate GE seeds, Bell claims that the Haitian Agricultural Ministry rejected such an offer. Ronnie Cummins from the Organic Consumers Association assumes it to be true and expands upon the tall tale:

“Monsanto wanted initially to dump GMO seeds on Haiti, but even the corrupt Haitian government knew that this would spark a rebellion, so Monsanto cleverly decided to dump hybrid seeds instead.”

However according to Monsanto, they never offered GE seeds, ever.

Bell and Cummins both repeat the claim that hybrid seed cannot be saved, or is worthless to save. Also not true. The traits of saved hybrid seed will have a distribution of combinations of their parents’ traits, but will still grow. I would like you to watch this short video which contains an interview with an “Agronomist” named Mark who is taking part in apparent protests against Monsanto in Haiti.

I put “Agronomist” in scare quotes because they profess to having expertise in agronomy and yet they make false statements that a responsible agronomist would not make. Again, he repeats the claim that hybrid seeds cannot be saved, but he also continues to drum up opposition to the seed donation on the idea that they could be GMOs! (Even though the interviewer points out that they are not.)

There is also a very troubling thread of paternalism going on here. After the dire food needs of developing countries, the most troublesome issue as I see it is when people in industrialized nations decide to tell people who are worse off what they can or cannot do. It seems that everyone’s got a vision for the ideal agricultural situation in Haiti – some would like to see them produce enough food to feed the country with hybrid seed, others would like to see them stick to traditional (low-yielding) open-pollinated varieties. Few have mentioned the possibility that Haiti could develop its own local high-producing hybrids down the road. So is everyone just telling the Haitians what to do? No, there is an asymmetry.

The seeds are donated to the nation of Haiti, and will be distributed within the country at a low price to those that wish to buy and plant them. The seeds are not being given out for free, which keeps local seed producers from being driven out of business by having to compete against free seed. No one is forced to grow these seeds if they don’t want to (unless of course you agree that Haiti has a shortage of  seed). And farm inputs to help the seeds grow are also being donated.

The above protest was organized by Mouvman Peyizan Papay (MPP), the organization that Mark the “agronomist” works for. I find it troubling that someone who is conveying false information about hybrids is intimately connected with the initiation of this protest, which means that they could have misled all these protesters with the justification for the protest. (The protest was also apparently against the Haitian president, which is why I called it an ‘apparent protest against Monsanto.’) If they have led the farmers to believe that the seeds cannot be saved, then they have treated these people as mere means to some political or social end, which is wrong.

Indeed, what is the reason for the protest? Is it just to convey the message that ‘We think money would be more help to us than seed and we would like our government to understand that,’ that would be one thing. But I don’t think so. The purpose of this protest may be to stop the hybrid seed donation, which is where the paternalistic asymmetry comes in.

Monsanto is not limiting the choices available to the Haitian farmers by making this donation, however, several well-meaning people and organizations are trying to limit their ability to choose this seed. By continuing to falsely claim that the seeds are genetically engineered, or covering up the fact that the seeds can be saved but just do not breed true, they are also trying to mislead the farmers into rejecting the seed on prejudice.

Developing countries have many different kinds of food and farming systems, and they should be able to choose how they want to do it. I mentioned before that maybe there could be a local hybrid seed economy, with a few breeders specializing in hybrid versions of Haitian crops. (I’m sure that Monsanto would like to open up a Haitian breeding station and sales office  someday as well.) Part of the reaction to this seed donation is the fear of change – that small subsistence farmers in Haiti will be unable to adapt to a changing agricultural system and will be left behind to continue into poverty. At the same time, preventing them from having the option of moving beyond mere subsistence is also leaving them behind in a different way. Haiti imports at least 50 percent of its food, continually leaving them dependent upon foreign aid in both food and money (which the agronomist above preferred). Tariffs and subsidies play a role, but do does local production capacity.

In response to the dependence argument, Ewan commented,

The norms of farming have changed over time – with the advent of hybrids seed saving has become less the norm and more an oddity – this is a trend you’ll often see when a manufacturing process becomes so highly specialized as to require experts to do it – breeders create new hybrids, farmers farm – breeders probably wouldn’t make the best farmers (they’re trained as breeders) farmers probably not the best breeders etc – that’s how any discipline advances, higher specialization leading to a better end product.

Along with the misinformation about hybrids, there has been an upwelling of opposition to the very idea of hybrids themselves. Ronnie Cummins doesn’t like them, people on blogs don’t like em, there are even companies trying to literally bank off of a recent opposition to hybrid seed. But what these people are missing is that although you have to pay someone to produce your hybrid seed (or take special measures to produce them yourselves), the yield or other trait benefits you get outweigh the cost of producing them. Otherwise farmers wouldn’t buy them. Helene who recently stopped by Biofortified said

you want to create “hybrids” (though from what I’ve read Monsanto’s version of hybrids could never occur on their own in nature), fine

In Givin’ props to Hybrids, blogger DeLene writes about a recent paper about hybridization and its demonization as being unnatural. While DeLene is talking about hybrids between species (and animals at that), these perceptions are connected. Hybrids happen in nature, more often than genetic ‘purists’ would like to think.

Finally, the shape of the discussion about the Haitian hybrid seed donation reveals what it is really about. First, when the claim was flying around that the seeds were genetically engineered, that was the reason why the seed donation was bad. Then when that wasn’t even true it was because the seeds are hybrids and that is why they are bad. Now, the discussion is shifting away from hybrids to how the seeds have been treated with common “toxic” fungicides to prevent them from rotting in the soil. The real reason, which will come as no surprise to those who read this blog regularly has little to do with any of those reasons – it is mostly because the donating organization is Monsanto. Look at all the people cheering the symbolic destruction of these seeds on the Non-GMO Project facebook page. You’d think that they would be happy that the seeds aren’t genetically engineered. Nope – it’s entirely about Monsanto.

I for one, think that the seeds should be treated with fungicide. Besides my personal experience with the difficulty of getting non-treated seeds to germinate well in my lab’s nursery field each year, there is a real biosafety reason why seeds donated to Haiti must be treated for fungi: To protect the farms of Haiti from contamination with new strains of crop-eating fungal pathogens that are not native to the island. If any organization is sending seeds grown from crops elsewhere in the world and they are not treating the seeds to kill hitchhiking bugs, they are putting Haitian agriculture at risk. Whenever my lab sends seeds to be grown in our Winter Nursery in Puerto Rico or Mexico, we have to not only treat the seeds, but also include one seed from each packet in a big batch to test for pathogens before importation.

Imagine an alternate situation where Monsanto did not treat the seeds with fungicide – I could easily imagine the opposition claiming that Monsanto is trying to infect Haiti with exotic fungi so that they will become dependent upon them in some other fashion. Does Monsanto have to anticipate every bio-political move and misunderstanding before making a humanitarian gesture? Damned if you do…

I would like to end on one important point. Some people are saying that Monsanto is only doing this for PR purposes. You’ll have to ask them about that because I’m not privy to any motivations other than what they have already said publicly. They sound like they are genuinely trying to help, although people suspect otherwise. And you know what? It doesn’t matter. Monsanto’s intentions do not affect whether or not these seeds will help Haitian farmers. Buy the seeds. Plant them. Grow enough food to feed your family and your neighbors’ too. Thumb your nose at Monsanto and don’t buy hybrids after this again. What matters most is that the people in Haiti have the power to grow what they want and rebuild the food security of their country however they see fit. And if Haitian farmers decide that they like or don’t like these seeds, and choose to grow or not to grow them in the years ahead, that is their choice, not yours or ours. That’s what it comes down to.

I’ll leave the last phrase to Helene:

I think it’s wrong to prevent anyone from having a choice

She felt terrible, with a horrible pain in her gut that cut like a knife, and nausea and fever to match. Usually stoic in the face of pain, my daughter was doubled over and gasping.

When we took her to the hospital, the doctor took one look at her and immediately ordered a scan. Within hours she was in the operating room to have her ruptured appendix removed.  After the operation, the surgeon showed us pictures of the process, including a glossy photo of the inflamed appendix and the staple he had used to close off the end from which it had been removed.  Almost immediately after surgery, my daughter’s fever diminished. Her post-surgical pain was minimal compared to the searing pain that brought us to the hospital in the first place. As I write this, she is still in the hospital where she will remain for a few more days. But the crisis is over and there is improvement by the hour. By the time you read this, she will probably be home again in her own bed.

In the May 2009 issue of Bioethics in Brief, I discussed the fear of novelty that often leads to skepticism about new technology. I urged that moderate skepticism may be appropriate if it leads us to logically weigh the risks involved in new technologies, and that caution may be appropriate when we are unsure how to evaluate the risks we face.

The other side of this equation, of course, is the benefit that technological advances bring. In my grandparents’ generation, people often died from a ruptured appendix, and surgery was a far less certain undertaking.  Today, an appendectomy is a relatively minor procedure. When the surgery is uncomplicated, patients may leave the hospital within a day or so of surgery.

We are grateful for life-saving technologies when we experience their benefits firsthand, and people are typically much less wary of technology—including biotechnology—when their most central interests hang in the balance.

The danger of adopting a technology that is unproven is the difficulty in weighing the involved risks.  Since it is not possible to predict every eventuality, we may not understand how to weigh the risk until it’s too late.  But the alternative danger— the danger involved if new technologies are not adopted—may also involve serious risks. We may not give proper weight to those risks until we experience the benefits first hand. Today as I write this, I am vividly aware of the benefits associated with the surgical technologies that saved my child’s life.

Precautionary Principles

How should we evaluate unproven technologies?  It is sometimes recommended that we adopt a precautionary approach.  The precautionary principle offers a general recommendation that we should be cautious when risks are unknown.  Those who dislike the principle often recommend it as a general, blanket condemnation of any new technology simply on the basis of its novelty.  In a 2003 New York Times editorial, Clyde Prestowitz memorably represented the precautionary principle as a recommendation that “If we can’t prove absolutely that [a new technology] is harmless, let’s ban it.” (Prestowitz, 2003)  Stated in this way, the principle becomes an unfortunate decision criterion.  It is neverpossible to prove absolutely that a novel technology is harmless.  If we are entirely ruled by our fears we will miss the benefits that new technologies offer.

Often, these benefits can be measured in the same terms of life and death, happiness and misery that we may use to weigh risks and costs. Prestowitz is not a fan of the precautionary principle, so his statement of it is intended to make the principle appear ridiculous. While this may make a successful rhetorical point, his argument would have been more interesting and significant if he had re-presented the principle.

A more moderate version of the precautionary principle found its way into international law in the 1992 Rio Declaration. That agreement states “Where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation.”  (Rio Declaration, 1992, Article 15) If Prestowitz’s statement of a precautionary principle is absurdly strong, so that it would prevent acceptance of any new technology, then perhaps the Rio statement is absurdly weak.  Of course “lack of full scientific certainty” should not constitute a reason to postpone “cost effective measures” to prevent harm (or degradation).  Empirical science never provides certainty.  While one precautionary statement seems to rule out acceptance of any technology at all, the Rio statement is too weak to motivate caution even in cases where caution would be fully justified.

Confusion about the precautionary principle has resulted in the existence of opposing rhetorical camps.  Some people reject the principle as obviously excessive while others extol it as a minimal and obviously justified principle for policy choice.  If those involved in this discussion have different principles in mind, they may both be correct.  But they are talking past each other.

Risky Decisions and New Technologies

I am overwhelmingly grateful to the people who developed and employed the surgical procedures that saved my daughter’s life recently. But the first time these procedures were used, the risks involved were unknown, and there must have been a reasonable expectation that they could fail.  In the case of a ruptured appendix, the expected cost of doing nothing is high.  Left to follow its natural course untreated, a ruptured appendix can be expected to lead to pain and death.  In some cases, new technologies leave us with less dire alternatives than this.  The cost of caution is often (though perhaps not always) less immediate and extreme for technologies in agricultural biotechnology.

The question whether we should chose to err on the side of caution or optimism will not be solved by reference to either of the simple principles articulated above.  We need rationally to consider all of the risks involved in our choices, including the opportunity cost of proceeding with an abundance of caution.  These costs are difficult to measure, since they are reflected in the foregone benefits that technologies might have brought.  To see that these costs are very real, we would do well to consider the loss we would have experienced if past technologies had not been developed.  In some cases, these opportunity costs are reflected in the lives of people who might have been positively affected by the adaptation of the new technology, even to the extent of dramatically extending the lengths of their lives.

References

Gardiner, S. 2006.  A Core Precautionary Principle. J. Pol.Phil. 14(1):33-60.

Prestowitz, Clyde. 2003. Don’t Pester Europe on Genetically Modified Food. New York Times, January 25.

Stich, S. 1978. The Recombinant DNA Debate. Philosophy and Public Affairs. 7(3) Spring 78, pp. 187-205.

Clark Wolf is the Director of Bioethics and a Professor in the Department of Philosophy at Iowa State University. He is a faculty member in the Graduate Program in Sustainable Agriculture and has a cortursey appointment in the Department of Political Science. He teaches and co-teaches a variety of courses, including Foundations of Sustainable Agriculture, Environmental Ethics, and Bioethics and Biotechnology. Clark gives and organizes thought-provoking talks to diverse audiences at Iowa State, including talks on biotechnology and intellectual property.*

Any opinions, findings, conclusions, or recommendations expressed in this publication are those of the author(s) and do not necessarily reflect the view of the ISU Office of Biotechnology or Iowa State University.

Wolf, Clark. Precautionary Principles and the Cost of Caution. Bioethics in Brief, a Publication of the Iowa State University Office of Biotechnology. May 2010. Volume 12, Number 2.

* Biography composed by Anastasia Bodnar.

Previously, I showed how Jim Riddle’s 10 reasons why genetic engineering is incompatible with organic agriculture apply equally well to plant breeding. But many plant breeding techniques are allowed in organic agriculture. So how can these characteristics apply to both breeding and genetic engineering while one is compatible and the other is not? The answer lies in a tangled web of invalid logic and unsound argumentation. It requires not only misrepresenting genetic engineering, it also misrepresents organic agriculture. Let’s go through point by point. (You might need a cup of coffee or a stiff drink)

1. Basic science. Humans have a complex digestive system, populated with flora, fauna, and enzymes that have evolved over millennia to recognize and break down foods found in nature to make nutrients available to feed the human body. GMO crops and foods are comprised of novel genetic constructs which have never before been part of the human diet and may not be recognized by the intestinal system as digestible food, leading to the possible relationship between genetic engineering and a dramatic increase in food allergies, obesity, diabetes, and other food-related diseases, which have all dramatically increased correlated to the introduction of GMO crops and foods.

Riddle starts off with a convoluted argument here. I have seen this articulated elsewhere and each time I read it it raises the hair on my back where my prehensile tail should be. This is a mangling of evolutionary biology as well as a misrepresentation of organic agriculture. Most of the foods we eat have not ‘evolved with us’, some of them have only been widespread in the human diet for hundreds of years, some less. And thousands of years is still too short of a time span for us to have evolved resistance to everything harmful in what we eat, nor is there a cohesive way to define foods that are perfectly safe and digestible for us as a result of such evolution. Additionally, the only recent human dietary evolution I am aware of is lactose tolerance past childhood, and not everyone has it (I don’t). This came about when a recent mutation gave dairy-dependent populations a competitive advantage over their lactose-intolerant forebears. Even if we evolved tolerances to different foods, they would probably only be in specific populations, too.

So because genetic engineering can introduce a novel protein that we have not eaten before, so too can plant breeding. Case in point: Organic Kiwifruit. This is a recent introduction into our diet, and it has been known to cause allergic reactions. Yet, this is not cause to exclude it on the principle that it brings novel substances into the human diet. Therefore, the presence of novel substances is not a reason to differentiate between what is or is not compatible with organic agriculture. Finally, there is no evidence that GE crops are the cause of any rise in allergies. As for the claim about diabetes and obesity – this is simply grasping at straws.

2. Ecological impact. Organic agriculture is based on the fundamental principle of building and maintaining healthy soil, aquatic, and terrestrial ecosystems. Since the introduction of GMOs, there has been a dramatic decline in the populations of Monarch butterflies, black swallowtails, lacewings, and caddisflies, and there may be a relationship between genetic engineering and colony collapse in honeybees. GMO crops, including toxic Bt corn residues, have been shown to persist in soils and negatively impact soil ecosystems. Genetically modified rBST (recombinant bovine somatrotropin, injected to enhance a cow’s milk output) has documented negative impacts on the health and well being of dairy cattle, which is a direct contradiction to organic livestock requirements.

As with the allergy claim above, Riddle is confusing correlation with causation when talking about impacts on insects. Even so, the monarch butterfly claim is easily addressed by an authoritative resource published by the USDA. The caddisfly claim is probably based on a flawed paper (debunked here by Anastasia) that did not use proper controls. As for the lacewings, I have not heard this claim before so I had to look it up. It took all of one minute. But the one that I object to more personally as a beekeeper who follows the news is his claim that GE crops may be the cause of Colony Collapse Disorder. Here he has not been paying attention to the research that has come out about CCD and is repeating cultural mythology that even Wikipedia debunked years ago. These are the kinds of claims that distract researchers from the real problems that need investigating and delay their solutions.

The fact is, you can use genetic engineering to improve the ecological impact of farming, just as you can with breeding. Some alterations may make the ecological impact worse, while some may make them better. But throwing a blanket of misinformation over the entire technology and generalizing in that fashion does not do anyone justice. Even if the only example of a GE crop was one that harmed the environment, it would not mean that all GE applications will do so. Moreover, organic agriculture is not a guarantee that the ecological impact is superior. Excessive tillage and erosion can and does occur. There are cases where organic farms are worse than their conventional counterparts. Should tractors be banned from organics?

Finally, if rBST would not mesh with organic livestock requirements, then don’t allow rBST. But because something like herbicide tolerant soybeans would obviously not work with organics, that doesn’t mean that Bt corn or cotton can’t.

3. Control vs harmony. Organic agriculture is based on the establishment of a harmonious relationship with the agricultural ecosystem by farming in harmony with nature. Genetic engineering is based on the exact opposite — an attempt to control nature at its most intimate level – the genetic code, creating organisms that have never previously existed in nature.

Let’s not beat around the bush beans. Organic agriculture is an attempt to control nature through trying to set up a more harmonious relationship with the agricultural ecosystem. Since when is plowing the soil with a tractor, spreading composted manure, and spraying crops with Bt-toxin producing bacteria not trying to control nature? Organic agriculture is best described as a more biological approach to farming as opposed to the more “chemical” approach that it was a response to. In that sense, genetic engineering can fit in perfectly. And it can be used to foster a more harmonious relationship with the natural world. Traits such as drought tolerance, nitrogen use efficiency, and disease and pest resistance are examples where genetic engineering can (and in some cases has already) benefit farming through reducing their ecological impact. Spreading less manure (or getting more out of it, watering less, and having to employ fewer inputs to control pests and diseases can help organic agriculture do just what it has set out to do. If you say, “well, you can work on those traits with breeding,” then you have already admitted that trying to control the genetics of a plant is compatible with organic agriculture.

Every time a breeder makes a cross between two plants he or she is creating an organism that has never before existed. And every time a breeder crosses two plants, the genetic combination represented by the offspring has never before existed. And that’s how nature, how evolution works – by creating new combinations. If the absence of new combinations was a criterion for organic, then there would be no plant on this planet or breeding method compatible with organic systems.

4. Unpredictable consequences. Organic ag is based on a precautionary approach – know the ecological and human health consequences, as best possible, before allowing the use of a practice or input in organic production. Since introduction, genetic modification of agricultural crops has been shown to have numerous unpredicted consequences, at the macro level, and at the genetic level. Altered genetic sequences have now been shown to be unstable, producing unpredicted and unknown outcomes.

It is very interesting that Riddle includes unpredictable consequences in his list of things that organic agriculture does not have. In some respects such as requiring manure to be composted if it is to be spread on crops that are anywhere near harvesting, there is a measure of precaution in organic agriculture. But in the area of the genetics of plants, the organic rules are in fact contradictory on this note. Let me start by asking you, what is the most disruptive thing you can do to modify the genetics of a plant – the one that has the highest risk of unintended consequences? And is it allowed in organic agriculture?

The answer is not “genetic engineering, and no” – it is “mutagenesis, and yes.” Using radiation or chemicals, you can create random mutations all over the genome of a plant. Then you look at thousands of plants that have gone through this process and pick out some that have interesting traits that you can use. Finally, this trait is bred into the crop that you grow. But along with your desired trait there are many other unknown changes that have occurred in the genome and there is no way of knowing where they are except by sequencing the whole thing. Several studies have compared mutagenesis to genetic engineering in its potential to cause unintended consequences, and GE has always come out looking good. In 2001, the National Academy of Sciences compared the risks of unintended consequences between different methods, and concluded that yes, mutagenesis is the worst offender. Mind you, the risks of all the methods they surveyed are low, but if you are going to start drawing lines about acceptable risks, clearly the reason why mutagenesis was ‘grandfathered’ into organic ag and genetic engineering was excluded has nothing to do with relative risks.

We have eaten many foods made from crops that have been modified by mutagenesis, and to no ill effect. The same with genetic engineering. What is interesting is that regular old plant breeding has had its fair share of unintended consequences. That’s why I brought up the potatoes and celery because the old traditional way has caused more harm than the newer methods.

5. Transparency. Organic is based on full disclosure, traceability, information sharing, seed saving and public engagement. Commercial genetic engineering is based on secrecy, absence of labeling, and proprietary genetic patents for corporate profits. The “substantial equivalence” regulatory framework has allowed the GMO industry to move forward without the benefit of rigorous, transparent scientific inquiry. The absence of labels has allowed genetically modified products into the U.S. food supply without the public’s knowledge or engagement., and without the ability to track public health benefits.

While there is nothing in the Organic rules that mandates transparency at every level, Riddle is making a philosophical point here. And that is that ideally, organic agriculture involves making it easy for consumers (producers, farmers, etc) to know everything about the food that they are eating. Currently in the U.S., labels are not required for foods produced involving genetic engineering when it does not change the nutritional or culinary aspects of the food. It is also not prohibited, either. The FDA even has suggestions for how producers can voluntarily label their products as being ‘produced through biotechnology’ and such. Therefore, you can have complete transparency of foods that are genetically engineered and grown in an organic system.

Let’s imagine that today, the Rodale Institute came into a bunch of money and decided that they wanted to start up a genetic engineering project. They could do it completely open-source, tell everyone what they are doing and how they are doing it, and send the resulting plants to independent labs for additional testing. Riddle is not separating the technology from his views of the current regulatory structure. Perhaps he means to say that the regulations that current crops have gone through does not meet his criteria for what would be necessary, but you could, if need be, add additional requirements for GE crops that will be allowed into the organic system. It is simply not true that there have been no independent tests of GE crops, nor that they are virtually unregulated, either. Just take a brief look at this list to get an idea how much scrutiny goes into these crops.

Plant breeding is almost completely unregulated, and harmful mistakes have been made through just rubbing flowers together and growing what came of those crosses. We have no idea what the breeding history is of any of the produce in the supermarket, whether conventional or organic, so where is the transparency on plant breeding here? Polls have shown that a sizable number of people, (40%) believe it or not, want to know if the plant they eat are hybrids!

I would like to know whether any of the organic produce that comes from California has been hand-weeded (by latin-American laborers) – a backbreaking practice banned from conventional ag – but the Organic sector fought for an exemption. No conventional or organic produce must be labeled with what pesticides it has been sprayed with (And there are organic pesticides.) I daresay full transparency is not a characteristic of any agricultural system we have today.

6. Accountability. Organic farmers must comply with NOP requirements and establish buffer zones to protect organic crops from contamination and from contact with prohibited substances, including genetically engineered seeds and pollen. Genetically engineered crops do not respect property lines and cause harm to organic and non-GMO producers through “genetic trespass,” with no required containment or accountability.

Organic food is a premium market. Before genetic engineering came along, it set itself against conventional agriculture that was largely dependent upon artificial inputs such as pesticides and fertilizers. Organic did not want to to have anything to do with that. But like gene flow through pollen, pesticides and fertilizers also have “spillover” effects. Organic agriculture promises its customers that they will make an extra effort to keep these substances from coming in contact with their crops. It would make no sense for a small percentage of organic farming operations to demand that the other 98-99% of farms stop using anything that could ‘contaminate’ their crops and lower their value in a premium market. But that’s not exactly what Riddle is arguing here. Actually, he is arguing something quite bizarre.

This is the formal argument:

A. Organic standards do not permit GE crops

B. GE crops can ‘contaminate’ organic farms through pollen drift, potentially causing harm because they are not permitted.

C. Therefore, GE crops will not work if allowed into the organic standards.

Do you see what the argument is? It is a circular argument. GE crops shouldn’t be allowed in organics because… GE crops aren’t allowed in organics. Note that his objection to gene flow only works while GE is prohibited from organic agriculture. If the standards were changed today, it would no longer be an objection. And as a circular argument, it is also invalid.

Finally, although Riddle does not state that GE is a “prohibited substance,” his wording implies that GE is a prohibited substance in the organic standards – whereas it is actually an “excluded method.” Testing is required only for prohibited substances, too. While there are no maximum thresholds for GE traits in organic fields, without any requirement to keep all genes out or test for them it doesn’t follow that organic farmers are being harmed economically by a low-level presence (LLP) of transgenes. Since Riddle is the Organic Outreach Coordinator for UM, it would be important not to gloss over the distinctions in the NOP requirements, and instead ensure that everyone understands exactly what the NOP requirements are. For an excellent discussion of these distinctions, I suggest reading If your Farm is Organic, must it be GMO Free?

7. Unnecessary. It is well established that healthy soils produce healthy crops, healthy animals, and healthy people. Research and development should focus on agricultural methods, including organic, which recycle nutrients to build soil health, producing abundant yields of nutrient dense foods, while protecting environmental resources. To date, recombinant genetic modification has contributed to the development of herbicide-resistant weeds and an increase in the application of synthetic fertilizers and pesticides, with associated increases in soil erosion and water contamination, while producing foods with lower nutritional content. Technologies, such as genetic engineering, which foster moncropping are not compatible with organic systems, where soil-building crop rotations are required.

Healthy crops involve an interplay between the soil, the weather, the genetic potential of plants, pathogens and pests, and the human health aspect involves a further interaction with human physiology, food preferences and how much time you leave yourself to cook. So while organic agriculture often criticizes conventional agriculture for being too “reductionistic,” here Riddle is reducing our health to merely the health of the soil. While some nutrients are elevated (and a few depressed) in some organically grown crops, largely there is little difference between conventional and organic foods. While research should continue on how growing methods can affect nutrient levels (particularly a plant’s response to stress), there is a huge amount that can be gained through altering the genetic potential of the foods that we grow. This can be accomplished through breeding for nutrient content and bioavailability, and where there is little genetic variation for such traits (or pressing need such as beta-carotene and iron-enriched staples in developing countries) this can also be done with genetic engineering. Take a look at my post about enhancing calcium content in carrots and lettuce for an example.

As for soil erosion, herbicide tolerance in GE crops has contributed positively to the adoption of “no-till” agriculture. While organic no-till research is ongoing (I have seen some such plots myself and they do not look pretty to the eyes or by the numbers), soil erosion has been lessened through reducing the need to plow up and disturb the soil. While many anti-GE people argue that it has not, even Charles Benbrook from the Organic Center has told me (in a recorded interview, not yet posted) that he accepts that it has. He also penned that Bt corn and Bt cotton have reduced insecticide applications considerably.

There is nothing about genetic engineering that says that you need to mono-crop on your farm. Furthermore, there is nothing about genetic engineering that prevents a farmer from planting a cover crop after harvest. This is a complete misunderstanding of what genetic engineering is – it is a tool for modifying the genetics of an organism – it is not an agricultural system or a philosophy on how things are to be grown. Just like you can breed a crop for a particular agricultural system (low input, for example) so, too, can you engineer a crop that is appropriate for such a system.

To come back to the issue of Riddle’s “Healthy Soil” reductionism, if it was all due to healthy soil then there would be no need for plant breeding just as he believes there is no need for genetic engineering. Finally, there is no evidence that genetic engineering has lowered the nutritional content of foods – another piece of cultural mythology espoused.

8. Genetic diversity. Organic farmers are required to maintain or improve the biological and genetic diversity of their operations. Genetic modification has the exact opposite effect by narrowing the gene pool and is focused on mono-cropping GMO varieties.

Technically, when you insert a transgene into a plant, you are increasing genetic diversity. To my knowledge, there are no prima facie requirements in organic agriculture to increase the genetic diversity of their crops within a species. Nevertheless, there is a tendency in organics toward open-pollinated (OP) varieties that contain a mixture of alleles for different genes. You can create OP varieties from a mixture of genetic stocks, and there is nothing about genetic engineering that dictates that you cannot include transgenes in an OP variety. If you were to do that with genes still covered by Monsanto patents you might run into a legal problem with breeding your own Bt sweet corn variety, however when those patents run out (first one will run out in 2014) there is nothing preventing you from doing that. But aside from GE traits that are currently commercialized, traits that benefit OP varieties could be developed through genetic engineering, or traits that benefit any variety can be incorporated into an OP variety.

Not all genetic variation is good. As I pointed out with breeding, the point of artificial selection is to eliminate bad traits. You do not want variability in important traits like how well the plant grows or whether it tolerates various stresses that impact the plant. You do want genetic variation in other genes that may give your population a degree of robustness. Imagine a bag of grass seed that you buy from the grocery store. Many of you may not know this, but these bags of grass seed may have a diverse mix of different species (usually 3) that thrive in different conditions (wet/dry, sun/shade) so that no matter how varied your yard is, you still get a full lawn. Sometimes they can have grass seeds from the same species that simply have genetic diversity for these traits. But some kinds of diversity you don’t want might be grass that grows to different heights or different shades of green. You definitely do not want genetic diversity of that kind.

Organic growers may want to go for this kind of robustness in OP varieties simply because they don’t have the insect, pest, and disease controls available to conventional growers, but there is no such requirement in organic rules. You can have a farm that grows a single genetically identical hybrid variety of corn and call it organic. Many probably do.

GE crops, as I learn more about how the system works, are not genetically uniform across the country or the world. GE traits are licensed out to different seed producing companies, and depending on the details of those license agreements they may be combining those GE traits with the genetics of corn, soybeans, or cotton that is adapted to different regions or contain other useful traits. It has been claimed that GE crops reduce genetic diversity – but to my knowledge there has been no peer reviewed scientific paper that supports this claim. So Jim Riddle’s description of genetic engineering’s effect on genetic diversity is at the least false on its face and at the most a mere hypothesis.

So on this argument we have seen that not only were the premises false, the logic was unsound. Because if increasing genetic diversity was required in organic agriculture, then any plant breeding that reduces that diversity would be incompatible with the system. (BTW, a recent paper examining the genetic diversity of 8 crop species over the last century has revealed that the regional genetic diversity has not gone down, so breeders, you’re doing it right!)

9. Not profitable. According to the 2008 Organic Production Survey conducted by the USDA National Ag Statistics Service, organic farmers netted more than $20,000 per farm over expenses, compared to conventional farmers. Use of GMO varieties has lowered the net profit per acre for conventional producers, forcing them to farm more land in order to stay in business.

This is often a claim made by opponents of genetic engineering, who suggest that farmers that grow them lose money. One or two studies may be cited in support of this claim, ignoring many other studies that say the opposite. The truth is, whether or not you make more or less money growing (current) GE crops will depend on the unique situations that your farm presents. If you have lots of weed pressure, herbicide tolerant crops will probably make you more money. If not, you won’t get anything for the higher price of the seed. If corn borers and rootworm beetles are running rampant in your area, “stacked” GE corn would help you reduce your pesticide costs and raise your yields (even The Organic Center and the UCS agree on that). But if you don’t have those problems you might be wasting your money.

You don’t need to know all these things to understand that farmers are making money planting GE crops – the mere fact that the adoption levels are so high and are stable means that farmers are benefiting from them and a large part of that is probably due to profit. For those who are unsatisfied with shooting from the hip like that (as I am), the National Academy of Sciences just release a huge report on the impacts of GE crops, and one of the areas they examined was profitability. What did they conclude?

Many adopters of genetically engineered crops have experienced either lower costs of production or higher yields, and sometimes both.

Read the report, it’s over 200 pages of science goodness. So it seems that farmers can make more money if they carefully choose GE crops that benefit them.

Finally, Riddle’s claim that GE crops has lowered the profitability of farms rests on poor logic. Because organic farms may make more money than conventional farm as a whole does not mean that the use of genetic engineering by conventional farms is the cause for that disparity. That is not even a valid claim.

10. No consumer demand. Consumers are not calling for organic foods to be genetically engineered. In fact, over 275,000 people said “no GMOs in organic,” in response to the first proposed organic rule in 1997. “Organic” is the only federally regulated food label, which prohibits the use of genetic engineering. By genetically engineering organic foods, consumer choice would be eliminated, in the absence of mandatory labeling of all GMO foods.

Given the fact that many leaders in the organic community use fear of genetic engineering to try to get more people to buy organic, it would come as no surprise that there isn’t much support for GE among organic consumers. But if you polled consumers about whether they wanted their produce to have their genetics altered through breeding and hybridization, how many would stand up and say ‘Yes!’? If you instead asked consumers whether they wanted their produce to taste better, be healthier, more colorful, cheaper, have fewer pesticide residues, etc, you might find more support.

Indeed, there are many things that consumers are looking for that genetic engineering can help provide. For instance, there are several examples of traits that enhance healthful aspects of lettuce, carrots, tomatoes, rice, and soybeans. The first health-oriented (and thus consumer-oriented) crop will soon be commercialized in the US, a soybean that produces Omega-3 fats in its oil. We may soon find a cultural collision occurring among the more health-oriented consumers.  As Organic agriculture continues to claim health benefits, a portion of their market is probably buying it because they think they will be getting more nutrients. There will be people forced to make a decision between a perception of health benefits from organic production and demonstrated health benefits from future GE crops. They may look at an Omega-3 soy product and wonder why it cannot also be organic?

When Anastasia and I met with Michael Pollan back in January, this is one of the things we talked about. And Michael said that he believes that such consumer-oriented traits are going to shift public opinion to accept GE crops. When consumers are more confident in the benefits of such traits, will organic agriculture begin allowing the certification of GE crops grown organically to meet that demand? Will Jim Riddle change his position based upon mere demand?

And does that mean that there must be demand for organic pesticides from consumers before they are approved?

Conclusion

Jim Riddle’s article for the Rodale Institute has gotten some attention, and put forward some arguments why he thinks that genetic engineering is not compatible with organic agriculture. I have demonstrated that not a single one of these ten arguments is adequate for justifying why some genetically engineered traits could not be included in an organic system, and indeed, that these reasons as given can also be used as reasons to exclude even basic plant breeding from organic agriculture. I have shown that most of these arguments are based upon misleading or factually incorrect premises, and/or invalid logic.

Debunking Jim Riddle’s arguments is one thing, but he could always decide to make different ones. Indeed, I invited him to be a part of the discussion in the first post, which he declined to do, but he did say this:

When I said “organisms that have never previously existed in nature” and “novel genetic constructs,” I was referring to corn with bacteria genes and all other transgenic organisms that could otherwise never exist, without listing every such example. I did discuss the unintended impacts of Bt corn, which are the result of inserting the gene for Bt toxicity into every cell of the corn plant, which is something that has not and could not occur through natural or traditional breeding.

My entire article focused on why transgenic organisms are not compatible with organic production, so I see no need to outline my concerns further.

So now we get to the real argument. I’m sure that you could detect it as an undercurrent in many of the ten arguments that he gave. Many of them depended entirely upon this argument, and by not bringing this objection to the forefront it is preventing us from actually getting to the real arguments, and we spend all our time talking about mere cursory arguments. Allow me to venture a guess as to the real reason why the organic sector is against genetic engineering in agriculture, but it comes as no surprise why it did not ‘officially’ make Riddle’s list, because it is a silly argument. Are you ready? Here it is:

Genetic Engineering just isn’t “Natural!”

And of course, neither are tractors, plows, computers, refrigerators, or anything else that humans make that are perfectly fine to use on organic farms, or with organic food. Naturalness is not a property of matter, it is a description of the process by which is was generated, that exists only in degrees, not absolutes. As proponents of organic agriculture rightly argue that humans are a part of the natural world and should not consider ourselves independent of nature, to claim that what human beings do is unnatural depends on excluding human beings from nature. You could say that it is only natural that humans do genetic engineering, as we seek to improve our lives with science and technology. Indeed, gene transfer happens between species in nature as well – it is called Horizontal Gene Transfer – apparently Nature has no respect for the “natural” integrity of species boundaries.

Jim Riddle spent his entire article that was supposed to be about why transgenic organisms are incompatible with Organic Agriculture not even talking about why specifically transgenic organisms are incompatible. Why specifically are new proteins introduced by transformation not allowed, while introducing many unknown proteins through wide crosses are allowed? So we are left still without a rational reason why they shouldn’t be allowed. And it took evaluating ten bad reasons to get to it. I think Jim Riddle does need to outline his reasons further, don’t you?

We need your help, Jim

Granted, Jim Riddle’s article is written for the Rodale Institute, and does not represent the opinion of the University of Minnesota, but his position as the UM’s Organic Outreach Coordinator is important to bring up. He has chosen to educate the public about organic agriculture as a career, and while trying to defend this important agricultural system from a perceived threat, has made several misrepresentations of that very agricultural system. In the discussion over genetic engineering in agriculture and the potential of integrating it into organic growing systems, we desperately need the help of those who are knowledgeable about organic to faithfully represent this form of agriculture.

And we need people who have such know-how to freely admit that there are ways that genetic engineering and organic can work together to improve agriculture, even if it goes against current regulations or personal misgivings. If there is a rational justification for excluding genetic engineering from organic agriculture in principle, then we need to see the real arguments and not invalid post-hoc justifications.

Stay tuned for part III in which I will discuss the enormous error that every response to the idea of GE/Organic has made and what critics need to respond to… or ultimately agree.

Also, thanks to Anastasia Bodnar for taking a look at this post before I hit “publish!”

Red and blue fibers, described as "Morgellons fibers".

MD was first described in academic literature in 2005, when an unidentified number of patients described itching, crawlingsensations, lesions, and the eruption of red and blue fibers and “granules” from their skin. Most had Lyme disease, and MD was thought to be significantly related to that (Savely & Leitao, 2005). Recently, agrobacterium was indicted as the new culprit, when two self-identified MD patients with scleroderma were found to have increased amounts of cellulose-protein complex in their connective tissue (Savely & Stricker, 2007, Harvey et al, 2009). A multi-systemic medical framework for MD with immunodeficiency problems has been described (Harvey et al, 2009).

Lesions, attributed to Morgellons Disease.

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The majority of physicians and researchers consider MD to be synonymous with DP (Murase, Woo & Koo, 2006), with the difference that it is not believed to be parasites, but about the fibers and granules (Robles et al, 2008). In response, proponents of MD as amedical condition herald it as different from DP, citing a “lack of pre-existing psychopathology” (Savely & Stricker, 2007). Yet, a study by Harvey et al (2009) found 25 self-diagnosed MD participants all had previous diagnoses of DP, and 23 had other previous diagnoses, including bipolar disorder, attention-deficit disorder, and obsessive-compulsive disorder, the symptoms of which coincided with the onset of their MD symptoms. These psychological diagnoses have many somatic connections, and their medications commonly have side effects of itching, crawling, and tingling sensations (Hinkle, 2000), indicating that a psychological composition of MD is very likely.

Some will disagree with a psychological conceptualization of MD, and firmly believe that this is a distinct medical condition. In fact, a DP diagnosis is not always accurate, such as with cutaneous myiasis, where fly larvae inhabits the skin of a person (Barros et al, 2010). Medical and scientific knowledge, and identification of new pathogens, diseases, and treatments, continually occur.

The burden of proof is on the advocates for MD to be a distinct medical condition. In my opinion, mental health should be recognized as the possible, if not probable foundation of MD. Fibers and granules of dirt and debris are everywhere. Increased cellulose-protein complex in two patients who also have scleroderma is still distant from being definitive. Harvey’s study found many vague health anomalies, yet the autoimmune problems sound like what one would expect from intense stress (Khansari et al, 1990). What would be more stressful than the real or perceived experience of an infestation of the most personal and offensive kind, the body?

Dr. Harvey recommends that we be open and skeptical, and I agree. The CDC is in the data-analysis stage of an investigation of MD through Kaiser in Northern California. As a scientist and as a person who is aware of the suffering of people with these experiences, I look forward to the results.

Sarah Bione-Dunn is a doctoral candidate in clinical psychology at Alliant International University. She expects her degree in June, 2010.

de Barros N, D’Avila MS, de Pace Bauab S, Issa FK, Freitas FJ, Kim SJ, Chala LF, & Cerri GG (2001). Cutaneous myiasis of the breast: mammographic and us features-report of five cases. Radiology, 218 (2), 517-20 PMID: 11161171

Harvey WT, Bransfield RC, Mercer DE, Wright AJ, Ricchi RM, & Leitao MM (2009). Morgellons disease, illuminating an undefined illness: a case series. Journal of medical case reports, 3 PMID: 19830222

Hinkle, N. (2000). Delusory Parasitosis. American Entomologist, 46 (1), 17-25

Khansari, D., Murgo, A., & Faith, R. (1990). Effects of stress on the immune system Immunology Today, 11, 170-175 DOI: 10.1016/0167-5699(90)90069-L

Murase JE, Wu JJ, & Koo J (2006). Morgellons disease: a rapport-enhancing term for delusions of parasitosis. Journal of the American Academy of Dermatology, 55 (5), 913-4 PMID: 17052509

Robles DT, Romm S, Combs H, Olson J, & Kirby P (2008). Delusional disorders in dermatology: a brief review. Dermatology online journal, 14 (6) PMID: 18713583

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Savely VR, Leitao MM, & Stricker RB (2006). The mystery of Morgellons disease: infection or delusion? American journal of clinical dermatology, 7 (1), 1-5 PMID: 16489838

Savely, V., & Stricker, R. (2007). Morgellons disease: the mystery unfolds Expert Review of Dermatology, 2 (5), 585-591 DOI: 10.1586/17469872.2.5.585