Vermont-Driven GMO Labeling Could Have Troubling Unintended Consequences

This small state may soon alter the food supply for all Americans

(This post originally appeared on Forbes on 3/26/16)

Over the past week and a half, Mars, General Mills, ConAgra Foods and Kellogg announced that they had decided to start labeling whether their products contain GMOs nationwide, in compliance with a pending Vermont statute. They see this as a way to avoid the cost of maintaining multiple systems for different states.

These companies clearly state that they agree with the scientific consensus that there are no safety issues with biotechnology as it has been applied to crops. Nonetheless, many observers believe that the ultimate impact of the Vermont labeling law will be to encourage companies to seek to use more non-GMO ingredients. That would, of course, be a major victory for the organizations that have promoted labeling and who are actually quite transparent about their agenda of eliminating use of the technology all together.

However this scenario plays out, there are three interesting questions to consider.

1. Why do so many consumers say they want GMO labeling?
2. Why was anyone against labeling in the first place?
3. What might be the long-term effects of this labeling requirement on our food supply?

Why do so many consumers say they want GMO labeling?

This has much to do with how you ask the question.  The term "GMO" is a misleading title made up by anti-GMO activists in Europe in the mid 1990s.  It stands for "Genetically Modified Organism," which isn't a very good term to use since virtually every crop and animal used for food today has had its genetics dramatically modified from what ever it once was in the wild.  However, since few consumers realize this, the term "GMO" has the negative emotive effect that was intended.

The genetic modifications of these plants were vastly 

more dramatic than any modern “GMO crop”

If you use emotive language to ask people about other scary-sounding foods, you can get the same reaction. I've asked many people, "do you think cloned fruit should be labeled?" Virtually everyone says "yes!" Then I explain that all fruit is "cloned" in the sense that it is vegetatively propagated by budding or from cuttings because if you grew it from seed you wouldn't get the same variety. People have been doing this for millennia, but if I use the emotive term "cloned" I can get a "label it" response.

I also sometimes ask, "do you think that food grown with products made from animal excrement should be labeled?"  Most people again say "yes" because I used an emotive term. In that case there is a small, but finite food safety risk associated with manures and composts, but we don't label it.

In any case, after 20 years of active efforts to create fear around plant biotechnology, the label is nearly guaranteed to be seen as a negative by many consumers. Again, that is exactly what certain parties hope.

Why was anyone against labeling in the first place?

On the surface this seems like a logical question, but there were rational reasons to oppose these labels. The FDA wants to reserve the exercise of its labeling authority for things with real, documented risk issues such as food allergies, not for something like biotech crops for which extensive studies show no unique risk.  Realistically, this has become a moot point. By allowing "non-GMO" and "GMO-free" labels, consumers are already being successfully recruited to buy this next example of "non-existence" food, following trends like "gluten-free," "fat-free," "zero cholesterol" and the like.  American consumers are so used to buying food for what it is not that we don't even see the absurdity.

Much of the non-GMO labeling is for products
from crops which have no commercial biotech versions anyway

The reason that the processed food industry opposed labeling for biotech crops has to do with the costs and liabilities associated with maintaining distinct product flows in these very large scale, very low profit margin businesses. It costs money to clean out all the equipment, bins, trains and trucks used for bulk handling.

Grain harvesting equipment and later handling 

are not conducive to easy segregation

Depending on tolerances, it also opens companies up to liabilities for "adventitious presence.”  In the absence of real risk, the costs just don’t make sense. “Identity preservation” of high value crops like apples, oranges or wine grapes is far more feasible, and it is routinely done, but for issues that matter like variety, appellation etc.

What might be long-term effects of labeling on the food supply?

This really depends on whether food companies have the courage to trust their customers enough to continue to use biotech-improved items even in the face of activist pressure. Will they stand-up for their decision (as the Girl Scouts have), or will they give in and start shifting to non-GMO ingredients?

Evidence suggest that many players will take the latter path and that will mean asking farmers to forgo crop traits that they have found to be very helpful. Returning to non-biotech will also make it harder for farmers to use environmentally-sound approaches like minimum-tillage. It will increase the need to spray for insect pests once controlled by Bt traits in the crops. The cost of those non-GMO ingredients will be higher, partly because of these disadvantages, but also because of what it will take to "identity preserve" the non-GMO harvest all the way down the handling, storage and processing stream.

Of greater concern is the possibility that food companies will be tempted to source cheaper version of these non-GMO ingredients from other countries. This has happened all too often for organic.  That will open up the U.S. consumer to environmental pollutants (e.g. heavy metals) and to pesticides that have long been banned here, but which are still made and used in places like China and India.  It will also mean getting items from regions that are much less attuned to the need to detect and exclude dangerous mycotoxins from the food supply.

If Vermont ends up initiating a trend towards more non-GMO products, we should be asking participating food companies to go on record promising that they won't import the ingredients if they are available from the U.S. or other countries that enjoy a general context of sound environmental, food safety, and pesticide regulation. Without such assurances, we could have a serious case of unintended consequences.

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

Why I Don't Buy Organic, And Why You Might Not Want To As Well

Some delicious, conventional Asian Pears

Originally Posted On Forbes 3/19

I don’t buy organic foods. In fact I specifically avoid doing so. It’s not my place to tell anyone else what to do, but I’d like to lay out three, seriously considered factors that have shaped my personal stance on organic:

1. Informed confidence that we are safe buying “conventional” foods
2. Recognizing that some of the best farming practices from an environmental perspective are not always allowed or practical under the organic rules
3. An ethical problem with the tactics that some organic advocates and marketers employ which seriously misrepresents their “conventional” competition

For the last 40 years my wife and I have shared the shopping and cooking for our mostly home-based meals. We have always gardened, but also buy much of our fruit- and vegetable-rich diet from stores. When I say I don’t buy organic, that involves frequent decisions.

By all rights I should be an enthusiastic advocate and consumer of organic. I was a child of the generation influenced by “Silent Spring.” I was a dues-paying member of the Wilderness Society in high school. I grew up helping my beloved grandfather in his organic garden in the 1960s.  Some of our best friends in the late 1970s were pioneers in the development of the commercial organic industry. I’ve spent a significant proportion of my career developing biological and natural product-based pesticides which are applicable to organic. I fully appreciate the contribution that the organic movement made in the early 20^th century when it highlighted the importance of fostering soil health. My problems with institutional organic are not at all about its founding ideals or about organic farmers, but rather about organic's self-imposed limitations and about the ethics of a sub-set of its promoters.

Confidence in the Conventional Food Supply

The USDA, which oversees the foods labeled as "Certified Organic", states quite clearly on its website about its role in organic,  that "Our regulations do not address food safety or nutrition."  Foods labelled "Certified Organic" must adhere to certain rules and regulations but aren't endowed with any particular nutritional or safety features. However, many consumers believe that the Organic label means the food has superior nutrition and is safer, especially in regard to pesticide residues.  This is not true. Studies have shown no appreciable difference in nutrition between crops grown either organically or conventionally.

As for the safety issue. When most people hear the word “pesticide,” they imagine something scary in terms of toxicity to humans and the environment. The reality is that modern agriculture employs an integrated suite of non-pesticidal control measures, and the actual pesticides used today are mostly relatively non-toxic to humans. Organic farmers also use pesticides, and the products they are allowed to use are constrained with few exceptions by whether they can be considered “natural.” That is not a safety standard since many of the most toxic chemicals known are “natural.” Like all pesticides, these natural options are subject to EPA scrutiny, and so the pesticides that organic farmers are allowed to use are “safe when used according to the label requirements” which is the same standard for synthetic pesticides allowed on conventional crops. When it comes to pesticide residues on our food, there is a USDA testing program that demonstrates year after year that the pesticide residues on both organic and conventional foods are at such low levels that we need not worry about them. I confidently buy non-organic foods based on this public data that demonstrates that our system is working and that we consumers are well-protected.

My granddaughter enjoying "conventional" raspberries (yes, she did then eat them)

What the USDA data demonstrates is that the environmental movement was not a failure - it effected real change over the past 5 decades! We don’t have a two-tiered food supply in terms of safety in which only those who can afford the premiums get safe food. I also believe the global scientific consensus that“GMO” foods are safe, and so I don’t need to buy organic to avoid those.

This No-Till Field is good for the environment and the food supply 

Environmental Idealism

I have always been concerned about the human impact on the environment, and particularly about the impact of farming since that industry has the largest “footprint” in terms of land area. I spend a lot of time reading the scientific literature concerning agriculture and the environment. Some of the farming practices that are commonly employed on organic farms are very positive from an environmental perspective, but those practices are also used by progressive “conventional” growers. There are also quite a few farming practices with excellent environmental profiles which are difficult to implement under the organic farming rules (e.g. no-till farming, spoon-feeding of nutrients via irrigation). Compost, which is a major input for organic farms, has a shockingly high “carbon footprint” because of methane emissions. The carbon footprint of “synthetic” fertilizer is much smaller.

From an environmental perspective, the biggest issue for organic is that it requires significantly more land to achieve the same level of production. Were organic to become more than a niche category, this yield gap would be highly problematic from an environmental point of view.  I would much rather buy food from "land-sparing" farmingsystems.

Organic yields are substantially lower for many major crops

Ethical Issues

My third reason for not buying organic has to do with ethics. Organic exists as a sort of “super brand” that transcends anyone marketing under that banner. Unfortunately, within the organic realm there are certain major marketers (and advocacy groups they fund) who employ fear-based and falsehood-based messages to demonize “conventional” foods.  They use these methods as a means to promote organic. One of the most egregious examples is the “Old McDonald/New McDonald” video funded by Only Organic – a consortium of very large organic marketers. This bizarre publicity piece exploits children to depict a completely distorted view of mainstream farming.  I consider it to be "hate speech for profit."

Another example is the organic-industry-funded Environmental Working Group which grossly distorts that transparent, USDA, public database documenting the safety of the food supply and turns it into a “dirty dozen list” designed to drive organic sales. These are extreme examples, but the organic marketing community as a whole quietly benefits from this sort of propaganda and does nothing to correct the “convenient fiction” that organic means no pesticides. I realize that only part of the organic industry funds and promotes the most vicious sort of disinformation, but I rarely see organic representatives standing up and objecting to the sort of fear-mongering that ultimately benefits the sales for the entire super-brand.

The fear-based messaging drives the intense social pressure, that parents in particular feel, about whether they need to buy organic. I don’t want any part in rewarding this sort of fear/shame-based marketing. In the absence of a significant objection from more of the organic community, I don't want to support the "super brand."

So, these are my reasons for not buying organic products. I feel perfectly comfortable buying the alternatives that align with my practical, idealistic and ethical standards.

Please feel free to comment here and/or to email me at savage.sd@gmail.com

Ten Thousand New Reasons Not To Worry About Pesticide Residues

(Originally posted on Forbes 3/1/16)

Each year, the farmers around the world who produce our food (fruits, vegetables, grains) get the equivalent of a “grade” on a giant “group project.”   For 2014 they got another A+ as they have for many years.  The “test” entails thousands of food samples, which the USDA collects from normal US food channels and then scrutinizes for pesticide residues using extremely sensitive laboratory testing methods. They are checking for any detectable residues (41% of samples have none) and whether any of the detectable residues exceed the conservative “tolerances” set by the EPA (99.6% of the samples met that exacting standard). This means that our regulatory/farming system is working extremely well! Farmers are able to produce crops without the inefficiency and quality issues associated with excessive pest damage, and consumers are able to safely enjoy what they grow. The official conclusion from the USDA is “These Pesticide Data Program data show that, overall, pesticide residues found on foods tested are at levels below the tolerances established by the U.S. Environmental Protection Agency (EPA) and pose no safety concern.”

Chemical pesticides are only one part of the pest control regime, but an important one. The chemical pesticides in use today are predominantly low in mammalian toxicity, but for all pesticides the EPA sets detailed rules for how they can be used (e.g. maximum rates, periods of time before harvest…). These are designed to ensure that any residues that remain at the consumer level are below a “tolerance” based on a rigorous, multi-factorial risk assessment by the EPA. The tolerance is generally 100 times less than a dose that could cause any ill effect.  The allowed residues are also lower than the levels of natural pesticidal compounds that many crops make to defend themselves.

The 2014 USDA “test” is called the Pesticide Detection Program or PDP, and it has been conducted every year since 1991. For 2014 tests were done on 10,750 samples including 21 types of fruits or vegetables, two grains, two types of infant formula and salmon. The scientists detected a total of 22,890 specific pesticide residues of which 98.5% were below tolerance or at such low levels they couldn’t even be properly quantified (see table below).

I appreciate the fact that the USDA makes this data available and transparent. It allows us to see that not only are most of the residues below tolerance, a great many of them are more than 10, 100 or even 1,000 times lower than the tolerance (see column chart below - all to the left of the center bar are no-issue detections, but 84% are far below).

There are some minor differences between crops. In the two charts below, the light green bars show how many of the detections in a given crop were below tolerance, and the dark green bars show what percent were 10 or more times lower than the tolerance. The samples of infant formula had, happily, either no detections (dairy-based formula) or a few detections that were between 1000 and 5000 times lower than the very low tolerance (soy-base formula, 7 of 527 samples). Oats and rice also had few detections and those at very low levels.

Unfortunately, the very transparency which documents the safety of our food is grossly misused by an organic industry-supported organization called the Environmental Working Group. EWG conducts its own “analysis” of the data in which they completely ignore how the detections differ from one another and how they relate to the tolerances. Their choice to represent as “dirty” any residue, no matter how low or non-toxic, conveniently ignores the fact that similar pesticide residues are also regularly detected on the organic options that they promote. Hopefully they will refrain from such irresponsible fear-mongering this year.

So, at the risk of being like a parent who only focuses on an A- on a report card of all A+s, I looked in detail at the 1.5% of residues were of any potential concern. For the few detections that exceeded tolerance, most were only marginally higher and thus of very minor concern.  There were some residues detected for which there was not a tolerance for that specific crop, but in most of those cases the levels were lower than the tolerances for other crops.  The EPA also tests for some old, long-banned pesticides notorious for their environmental persistence. There were 18 detections of such materials, including three from organic samples.  Of those 18, 17 were at extremely low levels and only one was very significant (0.46ppm monocrotophos in a squash sample from Mexico).  All in all, I could only find 11 residue examples of moderate concern, which is an amazingly small number (0.045%).  I have posted a much more detailed analysis on Scribd.  If anyone is interested I'll be happy to email you that full summary.

So once again, the take-home message is that we have another 10,000+ reasons to confidentially enjoy our American food supply.  My congratulations to those who produce it for us.