Should Monsanto be the Target?

As I read about the protests held against Monsanto worldwide recently, I found myself wondering: is Monsanto the appropriate target for these protests?

I know there are reasons people are unhappy with Monsanto. One is that during California’s most recent election Monsanto (along with other Big Ag and Big Food companies) contributed millions of dollars used to defeat Prop 37, a proposition which–if it had passed–would have required genetically engineered (GE) foods to be labeled in that state.

Prop 37 was a simple law designed to ensure that the long-standing American tradition of providing information on product labels so that consumers can know just what it is that they are (considering) purchasing would also apply to food products produced using the relatively new technology of genetic engineering. Currently, drugs produced using genetic engineering must be labeled as such in the United States but GE foods sold in grocery stores, or anywhere else, need not be. Prop 37 was meant to rectify that situation and give U.S. citizens the information that the vast majority of them, in poll after poll after poll, have said they want about the foods they buy and feed to their families.

I personally think that for Monsanto and other Big Ag companies to take a stand against labeling, thereby being less than completely up front and transparent about what their products contain and how they are made, is a mistake. I base my opinion, in part, on my experience with the first GE whole food, the Flavr Savr™ tomato, which was labeled and positively received by the public; in fact, those tomatoes–unabashedly labeled “Genetically Modified”–were initially so popular that Calgene Fresh, the company that marketed them, had trouble keeping up with the demand for them. Other scientists are starting to go public with their agreement with me on this point. Instead of going against public opinion on this issue, Big Ag companies could make labeling GE foods part of public relations campaigns designed to educate consumers about positive environmental, nutritional or organoleptic attributes of the ag biotech industry’s various GE products.

However, if companies in the U.S. want to spend tens of millions of dollars in support of misleading advertising campaigns on any side of any political issue in the USA, it is apparently legal for them to do so.

And Monsanto, like any other company, is likely going to do whatever it’s leaders think will have the best chance of resulting in it selling as many products and making as much money as it can.

After all, in a capitalist society like the United States, making money is a company’s primary job; in fact, publicly held companies have a fiduciary responsibility to their stockholders to do so. On the other hand, companies have no legal responsibility to grant U.S. citizens the “right to know” about whether their products were genetically engineered or not. Nor are they required (generally) to protect the public good (unless there are specific laws that require them to do so). The primary function of a company is to make money. And that, I assume, is what Monsanto is primarily doing…it’s job.

The job of protecting the public good and responding to the will of the people in the USA? That job belongs to our democratic government.

And that’s why I believe that the appropriate target for protests related to lack of adequate regulation of GE crops and lack of labeling of GE foods–at least here in the USA–is our own government.

The U.S. Food and Drug Administration (FDA) currently does not require regulation of all GE foods. It should. And FDA currently does not require labeling of GE foods. It should. Foreign proteins have been added to most GE foods marketed to date; there are U.S. laws on the books for regulating food additives like these GE foreign proteins added to GE foods and FDA should require companies like Monsanto to follow them. After all, when “water” is added to a food product in the USA it must be listed on that food’s label; shouldn’t the Bt insecticides in GE foods (for example) be required to be listed as well?

So, perhaps the focus of future protests about GE foods should be the FDA.

Or, for those who want all GE foods labeled (even those with no GE proteins, i.e. food additives, that should come under the laws enforceable by the FDA), consider focusing on the USDA, the U.S. agency in charge of labeling organic food products. Organic farming is a process just as genetic engineering is a process. It therefore seems that an appropriate course of action would be to engage the USDA, as was done to create the standards for organic farming, about labeling foods created using the process of genetic engineering. 

Focus could also be placed on President Obama himself, to get him to live up to the campaign promise he made to label GE foods. (Recent events suggest that more than a faulty memory contributed to the breaking of that promise.)

Monsanto does not have any (legal) responsibility to U.S. citizens who are not stakeholders in that company. The U.S. government does. Therefore, it could be more fruitful for U.S. citizens to focus their displeasure with the way GE crops and foods are being handled in their country on the entity that could be, and should be, doing something about it: their government.

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The 411 on Monsanto’s Genetically Engineered Sweet Corn

Here’s a piece I wrote about Monsanto’s genetically engineered sweet corn that was posted on Tom Philpott’s Mother Jones blog earlier today:

Genetically engineered (GE) sweet corn is being sold at a Walmart near you. And because that company has said it sees “no scientifically validated safety reasons to implement restrictions on this product,” and because US regulations don’t require it, it isn’t labeled “GE.”

Developed by Monsanto, this GE sweet corn is beautiful by fresh corn standards—not a worm hole in sight—since it contains not one, not two, but three insecticides engineered into each cell of every kernel. Having the corn make its own insecticides means that farmers don’t have to spray those chemicals out in the environment. The end result is that no earworms or European corn borers will have anything to do with this good-looking GE sweet corn. But, you may be wondering: should I?

So here’s the 411 on GE sweet corn at Walmart, based in large part on information available on Monsanto’s website.

First, although Monsanto provides links to “Peer Reviewed Safety Publications” for many of its other GE crop products, it does not do so for its “Seminis Performance Series Sweet Corn.” The peer-review process is a hallmark of scientific validation.

As it turns out, scientists have found reason for concern about the sweet corn. There’s this peer-reviewed report documenting the development of resistance among western corn rootworms to one of the bacterial insecticides present in Monsanto’s GE sweet corn. Another peer-reviewed study finds that weeds such as Palmer amaranth are now resistant to glyphosate, the active ingredient in products like Monsanto’s Roundup herbicide. Since a fourth foreign gene in Monsanto’s GE sweet corn confers glyphosate-resistance to it, I expect we’ll see even more of these “superbugs” and “superweeds” showing up in US farmlands soon, unless this new GE sweet corn is agriculturally managed a lot more carefully than previous GE crops have been.

What Monsanto’s GE sweet corn doesn’t contain is an antibiotic-resistance gene. Many GE crops have such genes because they enable genetic engineers to identify plants that have had foreign genes incorporated into them. Monsanto’s scientists went to considerable trouble to remove the “selectable marker” gene from some of their GE corn products prior to commercializing them, a fact that the American Medical Association is bound to be pleased about.

But as a consequence of the method they used to enable removal of the antibiotic-resistance gene, one of the four remaining foreign genes in Monsanto’s GE sweet corn is different than the gene Monsanto scientists set out to engineer into it. As described in a document posted on Monsanto’s website (PDF): a “molecular rearrangement” occurred “either prior to or during the process of T-DNA transfer to the plant cell” and consequently the foreign gene that ended up in Monsanto’s corn is not the same as the one the company’s scientists designed. Genetic engineering got trumped by biology in Monsanto’s GE sweet corn!

This new biotechnology is not as precise as you may have been led to believe. In fact, there are other aspects of agricultural genetic engineering, such as where the foreign genes get inserted among the recipient organisms’ own genes, that are not under the control of genetic engineers and this lack of control can result in unexpected, unintended changes in a GE crop.

Even so, does some technological imprecision mean the GE sweet corn at Walmart isn’t safe? And even if previous GE crops with the same (or very similar) foreign genes as those in Monsanto’s GE sweet corn have led to superbugs and superweeds, should that influence your buying decisions? Not necessarily on both counts.

But that’s not what California’s Proposition 37 is about. Instead, it asks: Do you deserve some indication that pesticides are intentionally present in the fresh corn you contemplate purchasing and eating? And should you have the right to support, or not support, agricultural methods used to produce food crops that could also be producing new plant pests at the same time? My answer: Yes, definitely.

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Op Ed on Prop 37 in The San Jose Mercury News

Here’s an op-ed piece I wrote that was published in The San Jose Mercury News earlier this week:

I’m a molecular geneticist who helped commercialize the world’s first genetically engineered whole food. I wholeheartedly support providing Californians with information about whether the foods in their grocery stores have been genetically engineered. I believe this issue is now best left to lay society to examine.

Richard Feynman, the late, great Nobel laureate in physics, would have agreed with me. He said that scientists have a duty to explain the science that forms the foundation of a new technology to non-scientists — and to not only “tell what’s true but…make clear all the information that is required for somebody else who is intelligent to make up their mind” about how the technology should or shouldn’t be used.

Once scientists have told the truth, warts and all (and genetic engineering has its share of warts), society as a whole must decide how to use and control the technology based on that science. Controlling technology, Feynman said, “is something not so scientific and is not something that the scientist knows so much about.”

The question of whether to label genetically engineered (GE) foods, as Proposition 37 would require, is not about science. Prop 37 is about people having the right to know what’s in their food and how it was produced. It’s about making competition in a free market–the hallmark of capitalism–more transparent. And it’s about fairness. American companies must label their GE products for sale in some 50 other countries; they should label them for us as well.

It’s also about common sense. “Water” must be listed as an ingredient on U.S. food labels, but American shoppers do not know whether fresh corn in their local produce aisles might contain a pesticide (or three) genetically engineered into every cell in every kernel. Prop 37 is about our democratic society deciding how to deal with the powerful technology of genetic engineering as it relates to our food supply. And I believe, as more a “participant historian” than a scientist per se, that a couple of historical facts are pertinent to making this important decision.

First, the world’s first commercially available GE food, Calgene’s Flavr Savr™ tomato, was labeled. Back in 1994, stickers on plastic-wrapped packages informed shoppers that the tomatoes contained in them had been “Grown From Genetically Modified Seeds.” An accompanying tomato-shaped brochure explained the process and gave an 800 number for consumers who wanted still more information.

Second, those labeled GE tomatoes were favorably received by the public. They were so popular for a time that one grocer took to rationing them — two tomatoes per person per day. Transparency was evidently good for both buyers and sellers of the world’s first GE food.

But no GE food has been labeled in the United States since the Flavr Savr tomato. For nearly 18 years, even though poll after poll has indicated that the public wants these products labeled, transparency about GE foods has gone missing in U.S. grocery stores. Capitalism and the U.S. regulatory system for dealing with the food products of genetic engineering have let Americans down.

Democracy, via Prop 37, now serves as a means for Californians to regain a transparency about GE foods that died along with Calgene’s tomato. And this citizen-scientist, for one, is voting “yes” on Prop 37.

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Crop Genetic Engineering, Warts and All

This is a paper I wrote that was published by PBGworks October 26, 2012:

Crop genetic engineering is a powerful technology that is helping scientists reveal how genes and genomes function. It could also be used to solve important global agricultural problems. However, in addition to moving genes, after precise manipulation in laboratories, from one organism to another, crop genetic engineering as it is currently practiced can produce many unexpected, AKA pleiotropic, effects. As a scientist, I take to heart the words of Albert Einstein who said “The right to search for the truth implies also a duty; one must not conceal any part of what one has recognized to be the truth” [1]. Only by considering all of what is known about the science underlying crop genetic engineering, warts and all, can we as a society decide how to most safely, effectively and sustainably utilize this powerful technology.

Both of the current methods for delivering foreign genes into crop plants often result in substantial disruption of host plant DNA. The Agrobacterium-mediated method causes high rates of insertional mutagenesis; “in the plant species most studied (A. thaliana and rice), approximately 27%-63% of T-DNA insertions disrupt known gene sequences” [2 and references therein]. Research scientists have utilized the high rates of T-DNA insertional mutagenesis to mutate, tag and clone plant genes [3, 4]. And although very few analyses of the insertion sites of foreign genes in plants transformed using the particle bombardment method have been published, those available indicate that extremely complex insertions are the norm; for example, in addition to the inserted enoylpyruvate shikimate synthase (EPSPS) transgene in one commercialized Roundup Ready soybean event, fragments of EPSPS transgenes (2), plant DNA and “unidentified” DNA, as well as evidence of altered flanking soybean DNA, were also found [5]. Unintended gene disruptions or gene activations are also a problem in human gene therapy as retroviruses, like Agrobacterium tumefaciens [6 and references therein], preferentially insert DNA into regions of host genomes with active protein-coding genes [7]; unintended mutations in host genes could adversely affect both GE food products [a hypothesis that should be tested in cases like 8-10] and human patients treated for X-linked severe combined immunodeficiency disease using retroviral vectors [7]. Consequently, efforts are underway to establish technologies for site-specifically inserting transgenes into both plants [11, 12] and animals [7].

Other unintended effects can be and have been associated with the foreign DNA inserted into GE crop plants. The Bt protein in StarLink corn was described by the EPA as “potentially allergenic” (whereas other Bt proteins had not been) and therefore “directed to [only] domestic animal feed or to industrial uses” and yet still unintentionally entered the human food supply [13].  In addition to the genes meant for transfer into plants, “vector backbone” sequences can also be unintentionally inserted into GE plants [14]; in one case, a GE corn crop unintentionally containing a “vector backbone” gene encoding an ampicillin-resistance protein was unintentionally introduced into commerce [15]. Other GE crops with transgenes that were not inserted [16] or expressed [17] as intended have also been commercialized.

In addition to unintended effects, there are problems associated with GE crop plants that might be classified as human errors. For example, 20 years ago environmental scientists warned us that, just as over-use of antibiotics led to antibiotic-resistant bacteria, developing GE crops that are resistant to pesticides would result in “super-weeds” or “super-insects” resistant to those pesticides and that is indeed what has come to pass. “Super” versions of pigweed, horseweed and giant ragweed that are glyphosate-resistant [18 and e.g. 19] (glyphosate being the active ingredient in products like Roundup) have now infested millions of acres in at least 22 U.S. states and are also posing problems in agricultural areas of Brazil, Australia and China. “Super-insects” resistant to the insecticides produced in other GE crops are also starting to show up on U.S. farms [20]. Evidence of harm to black swallowtail butterfly larvae caused by exposure to pollen from a GE corn variety expressing especially high levels of insecticide specifically in pollen, a plant tissue bound to “escape” corn fields and therefore potentially affect non-target insects, has also been reported [21].

In light of the potential for unintended effects and human errors, and the fact that the products of this powerful technology are self-replicating, it should be required that each GE crop be evaluated by U.S. regulators on a case-by-case basis prior to commercial release. However, the current “coordinated framework” for regulating GE crops using three different U.S. regulatory agencies can let products of the technology slip through the cracks. Only GE plants that produce their own pesticides need be regulated by EPA [22]. Only GE products produced using organisms (or parts thereof) on USDA’s “plant pest” list need be regulated by that agency [23]. And the FDA, with only a couple of exceptions, recommends that developers consult with them about their GE food products (and claims that developers have routinely done so) but does not require them to [22].  It is therefore currently possible to design a GE crop that would not require pre-market regulation by any U.S. agency.

The current situation I’ve “recognized to be the truth” [1], i.e. commercialization of products of a powerful technology with the potential for myriad unintended side effects yet with inadequate regulation and research [24, 25], is not conducive to inspiring public confidence in crop genetic engineering. The fact that GE food products are also not labeled in the U.S. only makes the situation worse. If the potential of this technology for solving important global agricultural problems is to be realized, it must be utilized more carefully and transparently; pre-market regulation and labeling should be mandatory.

It is worth noting that the world’s first GE whole food, Calgene Inc.’s Flavr SavrTM tomato, was labeled and also well received by the public. There were many reasons why the Flavr Savr tomato eventually flopped (one being that the company “tried to make [the tomato business] too big, too fast” [26]) but public outcry at the fact that it was genetically engineered was not one of them. Almost without exception during the course of its brief commercial run, demand for the Flavr Savr tomato outdistanced supplies [27-31]. Also, a clearly labeled GE tomato paste developed by Zeneca Plant Sciences initially outsold conventional tomato paste in the U.K. by 30% [32]; more than 1.8 million cans of that GE tomato paste were sold in Sainsbury’s and Safeway stores from 1996 through mid-1999. Therefore, based on these historical examples, labels on food products containing genetically engineered ingredients need not serve as “scarlet letters.”

I believe it is in the best interest of the agricultural biotechnology industry to try to (re)establish public confidence in the powerful technology of crop genetic engineering. Being transparent is one way toward accomplishing that. I therefore support Prop 37, the initiative on this November’s California ballot that requires labeling of GE foods.

And science aside, members of any capitalist, democratic society should have the right to know what they are buying in grocery stores to feed themselves and their families.

Belinda Martineau, Ph.D., earned her bachelor’s degree in biology from Harvard College and her doctorate in genetics from U.C. Berkeley. Prior to joining Calgene, Inc. in 1988 she was a post-doctoral fellow at the University of Chicago. She is the author of First Fruit: The Creation of the Flavr SavrTM Tomato and the Birth of Biotech Food and a Principal Editor at U.C. Davis.

References

  1. Panel on Scientific Responsibility and the Conduct of Research, National Academy of Sciences, National Academy of Engineering, Institute of Medicine (1992) Responsible Science, Volume I: Ensuring the Integrity of the Research. The National Academy Press, Washington, D.C., p iii.
  2. Latham JR, Wilson AK, Steinbrecher RA (2006) The mutational consequences of plant transformation. J Biomed and Biotech 2006: 1-7.
  3. Walbot V (1992) Strategies for mutagenesis and gene cloning using transposon tagging and T-DNA insertional mutagenesis. Annu Rev Plant Physiol Plant Mol Biol 43: 49-82.
  4. Alongso JM, Stepanova AN, Leisse TJ et al. (2003) Genome-wide insertional mutagenesis of Arabidopsis thaliana. Science 301: 653-656.
  5. Windels P, Taverniers I, Depicker A et al. (2001) Characterisation of the Roundup Ready soybean insert. Eur Food Res Tech 213: 107-112.
  6. Zambryski PC (1992) Chronicles from the Agrobacterium-plant cell DNA transfer story. Annu Rev Plant Physiol Plant Mol Biol 43: 465-490.
  7. Michel G, Yu Y, Chang T, Yee J-K (2010) Site-specific gene insertion mediated by a Cre-loxP-carrying lentiviral vector. Molec Therapy 18: 1814-1821.
  8. Ewen SWB, Pusztai A (1999) Effect of diets containing genetically modified potatoes expressing Galanthus nivalis lectin on rat small intestine. The Lancet 354: 1353-1354.
  9. de Vendomois JS, Roullier F, Cellier D, Seralini G-E (2009) A comparison of the effects of three GM corn varieties on mammalian health. Int J Biol Sci 5: 706-726.
  10. Seralini G-E, Clair E, Mesnage R et al. (2012) Long term toxicity of a Roundup herbicide and a Roundup-tolerant genetically modified maize. Food Chem Toxicol 50: 4221-4231.
  11. Lyznik LA, Gordon-Kamm W, Gao H, Scelonge C (2007) Application of site-specific recombination systems for targeted modification of plant genomes. Transgenic Plant J 1: 1-9.
  12. Li Z, Xing A, Moon BP et al. (2009) Site-specific integration of transgenes in soybean via recombinase-mediated DNA cassette exchange. Plant Physiol 151: 1087-1095.
  13. EPA website: http://www.epa.gov/oppbppd1/biopesticides/pips/starlink_corn.htm#allergenicity (accessed 23 Oct 2010).
  14.  Martineau B, Voelker TA, Sanders RA (1994) On defining T-DNA. Plant Cell 6: 1032-1033.
  15. FDA website: http://www.fda.gov/Food/Biotechnology/Submissions/ucm121422.htm (accessed 23 Oct 2010).
  16. Monsanto website: http://www.monsanto.com/products/Documents/safety-summaries/mon89034_pss.pdf (accessed 23 Oct 2010).
  17. Monsanto website: http://www.monsanto.com/products/Documents/safety-summaries/corn_pss_NK603.pdf (accessed 23 Oct 2010).
  18. Neuman W and Pollack A (2010) Farmers cope with Roundup-resistant weeds. The New York Times, May 3: http://www.nytimes.com/2010/05/04/business/energy-environment/04weed.html?pagewanted=all&_r=0 (accessed 23 October 2012).
  19. Powles SB (2010) Gene amplification delivers glyphosate-resistant weed evolution. Proc Natl Acad Sci USA 107: 955-956.
  20. Gassmann AJ, Petzold-Maxwell JL, Keweshan RS, Dunbar MW (2011) Field-evolved resistance to Bt maize by Western corn rootworm. PLoS ONE 6: e22629.
  21. Zangerl AR, McKenna D, Wraight CL et al. (2001) Effects of exposure to event 176 Bacillus thuringiensis corn pollen on monarch and black swallowtail caterpillars under field conditions. Proc Natl Acad Sci USA 98: 11908-11912.
  22. FDA website: http://www.fda.gov/Food/Biotechnology/default.htm (accessed 23 Oct 2012).
  23. Waltz E (2011) GE grass eludes outmoded USDA oversight. Nature Biotech 29: 772-773.
  24. EPA website: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OPP-2008-0836-0043;oldLink=false (accessed 23 Oct 2012).
  25. Pollack A (2009) Crop scientists say biotechnology companies are thwarting research. The New York Times, February 19:  http://www.nytimes.com/2009/02/20/business/20crop.html (accessed 23 Oct 2012).
  26. Groves M (1996) Monsanto to raise stake in Calgene and replace CEO. The Los Angeles Times, August 1.
  27. Jenkins N (1994) Retail revolution or produce footnote? Produce Merchandising December.
  28. Anonymous (1994) At last a tomato with home-grown garden flavor. Sacramento Bee, November 26.
  29. Anonymous (1995) Calgene hit with setback. Sacramento Bee, May 17.
  30. Black J (1995) Genetically altered tomatoes ripe for tossing in Seattle salads. Seattle Times, May 17.
  31. MacPherson K (1995) Calgene Flavr Savr beats the standard varieties in a blind taste test. Star-Ledger (Newark, NJ), May 17.
  32. Stecklow S (1999) “Genetically Modified” on the label means…well, it’s hard to say. Wall Street Journal, October 26.
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Danny DeVito and Friends: Yes on 37 Video

Here’s a video about Prop 37 put together by Food & Water Watch’s campaign in favor of labeling GE foods. For more information on Food & Water Watch and Prop 37 visit: www.foodandwaterwatch.org/yeson37.

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On the Right to Know What We’re Buying

Here is the text of an op-ed piece I wrote that was published in the Davis Enterprise on September 20, 2012:

Proposition 37, “The California Right to Know Genetically Engineered Food Act,” was not written “to authorize a whole new category of shake-down lawsuits” as claimed by Kent J. Bradford in his op-ed piece (Davis Enterprise, Sept. 9, 2012) but to give California consumers the right to know what they are buying, a basic tenet of our American supply-and-demand economy.

Chinese consumers (and those in some 40 other countries) currently have this right regarding genetically engineered foods while Americans do not. But, although government and the agricultural biotechnology industry have failed U.S. citizens on this issue, Californians have the opportunity on Nov. 6 to grant themselves this right via Prop 37.

In poll after poll for more than a decade, some 90 percent of Americans have indicated they want GE foods labeled and yet that voice, supported by such a vast majority, has fallen on deaf government ears. Not only unlabeled, most GE foods need not undergo regulation with the U.S. Food and Drug Administration at all.

In fact, despite well-documented incidents of commercialized GE products that have posed risks related to human allergenicity or the development of antibiotic resistance or the well-being of non-target insects like Monarch butterflies over the past 18 years, it is still possible to design a GE food crop that could be commercialized in the United States without FDA, USDA or EPA approval. Our government has let us down.

It’s done worse than let us down. By deciding in 1992 that no GE foods (unless the foreign gene had been isolated from an organism known to cause human allergies or the composition of the GE food had been considerably altered) would require its regulation, FDA effectively ignored the advice of the U.S. National Academy of Sciences, which recommended that every foreign gene, in every different crop plant and in every different environment, should be evaluated for possible risks to the environment and human health. Instead, FDA based its policy on the opinion that genetic engineering is simply an extension of traditional breeding. It is not.

And perhaps the most harmful aspect of the FDA’s unscientific attitude about GE foods is that by not requiring any regulation, it conveys the idea that any product developed using genetic engineering (with the possible exceptions noted above) will be safe, a concept that is completely ludicrous. That’s like saying that any and all uses of nuclear fission will be safe. It’s not true.

Genetic engineering is only as safe as it is used, each time it is used. It can be used carefully or carelessly, or to decrease pesticide use or increase it, or to help poor farmers or to make money, or–in the words of the late, great citizen-scientist-technologist Richard Feynman in reference to any powerful technology–for good or for evil. And we in the United States have experienced multiple incidents related to less-than-careful use of crop genetic engineering.

For example, 20 years ago environmental scientists warned us that, just as over-use of antibiotics led to antibiotic-resistant bacteria, developing GE crops that are resistant to herbicides would result in “superweeds” resistant to those herbicides, and that is indeed what has come to pass. As reported in the New York Times more than two years ago (May 3, 2010), it took about half a decade after Roundup Ready soybeans were commercialized before a superweed showed up in a Delaware soybean field.

“Super” versions of pigweed, horseweed and giant ragweed that are glyphosate-resistant (glyphosate being the active ingredient in products like Roundup) have now infested millions of acres in at least 22 U.S. states and are also posing problems in agricultural areas of Brazil, Australia and China.

So, the “expansion of conservation tillage” enabled by Roundup Ready crops, and mentioned by Bradford in his op-ed piece in The Enterprise, was a good thing while it lasted but many of those farmers are now suffering a doozy of a hangover.

“Super bugs” resistant to the insecticides produced in other GE crops are also starting to show up on U.S. farms (PLoS ONE 2011 6: e22629). And production of Monsanto’s new GE sweet corn, unlabeled and on sale at the Walmart near you, could make this “super” situation worse since it is not only “Roundup Ready” but also contains the same insecticide to which Western corn rootworms have developed resistance.

What is the ag biotech industry’s answer to these problems? The hair of the dog. New GE crops, resistant to other, more noxious herbicides, herbicides meant to be sprayed over vast acreages of agricultural land that inevitably would result in more superweeds, are being readied for commercialization.

We can’t afford to make these same mistakes over and over again. We need a regulatory system for the products of GE technology that has more teeth.

And, regardless of the status of the U.S. regulatory system or individual GE food products, members of a capitalist democratic society like ours have the right to know what they’re buying in the grocery store. Lack of labels on GE foods means that current sales do not reflect accurate “demand” for these products; that’s not the way the market is supposed to work here in America. These companies must label their products for the citizens of other countries, and they should label them for us here at home as well.

Fortunately, through the initiative process in California’s Constitution, we can use the “political power (that) is inherent in the people” to ensure our right to know what we’re buying. On this November’s ballot, that right takes the form of Proposition 37. I urge you to vote “yes” on Prop 37.

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Corrections to San Francisco Chronicle article

I wrote the following letter in response to an article on California’s Prop 37 written by Stacy Finz  in the San Francisco Chronicle; it was published in The Davis Enterprise on August 24, 2012.

First, there are currently no crops grown in the U.S. that have been “genetically engineered to make them more resistant to invasive weeds,” nor have there ever been. But, as reported in The New York Times May 3, 2010, since the dramatic increase in agricultural use of the herbicide glyphosate (the active ingredient in products like RoundUp) that has accompanied the commercialization of GE crops that tolerate that pesticide, we now have “superweeds” just like opponents of genetic engineering feared we would and warned us about 20 years ago when the first products of this new technology were being readied for the marketplace.

Which brings me to error No. 2 in the article. Contrary to the quote attributed to Bob Goldberg, bioengineered crops didn’t even exist 40 years ago and so nobody’s been testing them for anywhere near that long.  Genetic engineering of food crops began circa 1988.

Third, for the Food and Drug Administration, many scientists and medical organizations to have deemed all genetically engineered (GE) food safe is just silly. Any technology is only as safe as how it is used, each time it is used. This technology (crop genetic engineering), for example, is currently a mutagenic process that could result in GE plants that produce e.g. higher levels of a toxin or lower levels of a nutrient than normally would be found in the non-engineered plant; consequently, each GE product should be tested to determine whether it is safe to consume.

However, a loophole that would allow some GE food crops to avoid any regulation by the USDA recently was reported in the scientific journal Nature Biotechnology (Sept. 8, 2011) and, depending on the GE crop, regulation by the EPA or the FDA isn’t required either. (“Regulation” at the latter agency consists of a “voluntary consultation” process for most GE foods.)

And so, in contrast to the erroneously reported “40 years of testing,” certain GE food products actually could get to market in the U.S. without any government oversight at all.

Vote “yes” on Prop 37.

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I’m Voting “yes” on California’s Proposition 37

I’m in favor of labeling genetically engineered (GE) foods. And so I’m voting for California’s Proposition 37, the “California Right to Know Genetically Engineered Food Act,” in November. Prop 37 calls for the labeling of all whole (GE) foods, like Monsanto’s GE sweet corn currently being sold at Wal-Mart, and processed foods with GE ingredients like corn syrup and soy lecithin sold in grocery stores in California. I’m voting for it and I’m posting the “nut shell” version of why I’m voting for it (that I recently composed in response to a family friend’s request for background information related to Prop 37) below.

But first, in the interest of full transparency, I want to disclose that am working on the Prop 37 campaign. I’ve written a couple of op-ed pieces, I’ve met with editorial writers from a couple of California newspapers, and when newspaper or radio reporters ask Prop 37 staff for the name of a scientist they could talk to about genetic engineering technology who is not a “zealot” in favor of it and who, therefore, might be able to provide a more balanced explanation of it, the staff often send them to me. I am a volunteer; I receive no payment of any kind for my time and effort in connection with the Prop 37 campaign.

In a nutshell:

“I’m definitely voting “yes” on Prop 37. Citizens in a capitalist democratic society like ours have the right to know what’s been added to their food, and there are laws on U.S. books indicating the same. The foreign protein in the GE tomato I helped bring to market was regulated as a food additive but after officially approving that GE food FDA came out and declared that no other GE food need be regulated similarly; currently, the FDA does not require regulation of nearly all GE foods. (One exception is when a foreign gene was obtained from an organism known to cause allergies in humans.) In fact, it’s possible to create a GE food that doesn’t require regulation with any U.S. agency, FDA, USDA or EPA, so no, you can’t trust the FDA to ensure that the foods produced using this powerful technology are safe.

One source of risk with these foods is that the process(es) for introducing the genes into the crops is [not under the control of the genetic engineers] and the foreign genes often, at rates as high as 40-60% of the time, land in a plant gene disrupting and mutating it. Therefore, regulation is necessary on a case-by-case basis.

Also, the tomato I worked on was labeled in grocery stores and they flew off the shelves. (In Davis the owner of the store rationed them, two GE tomatoes/person/day.) I think not labeling just makes people distrust the technology.

But, safe or not, Prop 37 is about having the right to know what’s in our food and how it was produced. And I believe we should have that right in the U.S. These companies label their products for sale in other countries, they should label them for us as well.”

To conclude, if you’re a registered voter in California, I urge you to vote “yes” on Prop 37 in November’s election.

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Open Letter to the American Medical Association

It is striking that nowhere in AMA document H-480.958, amended June 2012, is it mentioned that both of the major methods currently utilized to genetically engineer crop plants are highly mutagenic processes.  Foreign genes transferred from one organism to another recipient plant often, estimates can be 30-40% or higher (Walbot 1992 Annu. Rev. Plant Physiol. Plant Mol. Biol. 43:49-82; Latham et al. 2006), land within recipient genes thereby mutating them.  The two major processes, transformation utilizing Agrobacterium tumefaciens or the biolistics technique of literally shooting DNA into a recipient plant’s cells, both cause other unintended perturbations of recipient DNA at high frequencies (Latham et al. 2006).

The mutagenic nature of the current transformation technologies could lead to problems in animals that eat them like those that have been observed in rats in connection with transgenic potatoes (Ewen and Pusztai 1999), transgenic tomatoes (Martineau 2001 First Fruit McGraw-Hill, pp 149-153), and transgenic corn (Spiroux de Vendomois et al. 2009).  And because of the random nature of transgene insertion into a recipient’s genome, additional experiments in which the same transgene is inserted into additional recipients, like those cited in AMA document H-480.958 with regard to a lectin transgene inserted into rice plants (Poulsen et al. 2007 Food Chem. Toxicol. 45:350-63), are not an appropriate means of testing whether the process of genetic engineering was the cause of any observed problems related to the original GE plant; additional transgenic plants will have insertions in additional, different locations of the recipient’s genome, locations not the same as the original insertion site(s).

These mutagenic methods of producing transgenic plants pose a safety risk to human consumers of GE foods and, in conjunction with the fact that the FDA does not currently require all GE foods to systematically undergo safety assessments with the agency, I believe these safety concerns related to the mutagenic production methods utilized to produce GE crops provide the FDA with a science-based, legal basis for labeling GE foods.

I agree with the AMA that there should be mandatory pre-market systematic safety assessments of bioengineered foods but, unfortunately, that is not the current situation in the United States.  Not only is the current process for “regulating” GE foods a purely voluntary process at the U.S. FDA (with the two exceptions mentioned in the AMA document), but it is possible to design GE crops that don’t require any regulation at the USDA or the EPA as well (Waltz 2011). The current “coordinated framework” for regulating GE foods in the United States is therefore inadequate for regulating this powerful new technology of genetic engineering and protecting the public. The fact that FDA’s labeling policies require that “water” be listed as an ingredient on food labels (FDA Food Labeling Guide) but that the agency is prohibited from listing insecticides on food labels, despite the fact that insecticides are being produced in every cell of, for example, every kernel of some GE fresh corn products, is another example of the inadequacy of the current regulatory system in the United States.  I believe that, as examples, insecticides or proteins conferring resistance to antibiotics in GE crops make them “materially different” than their non-GE counterparts and these differences provide another legal basis for FDA to label GE foods.

To summarize, I agree with the AMA that “thorough pre-market evaluation is considered to be the most effective tool to protect the public.” However, GE foods can currently be marketed in the United States without thorough pre-market evaluation.  There are additional good reasons why GE foods should be labeled in a capitalist, democratic society like the United States which is home to international companies that label their GE products for sale in other countries. But, especially since GE foods are currently under-regulated in the U.S., consumers have the right to know how the foods in their grocery stores were produced. Therefore, I support California’s Proposition 37, which requires labeling of GE foods.

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Learn Lessons from Biotech Mistakes Rather than Repeat Them

Twenty years ago, before genetically engineered (GE) foods were commercially available, one of the big concerns environmentalists had about the use of this biotechnology was that it would lead to “superweeds.”  Their concern stemmed from biotech products in the industrial pipeline at the time, like Monsanto’s Roundup Ready crops, that were impervious to various herbicides.  They pointed out that herbicide-resistant crops would encourage over-use of herbicides which could effectively “select” from among the weeds being doused with the chemical those that can survive and…voilà!…superweeds that can no longer be controlled by, for example, glyphosate, the active ingredient in Roundup.  (Some crops, like canola, also are related enough to various weeds that it is possible for them to produce “superweeds” simply by breeding with their weedy relatives.)

But, other scientists claimed, then and later, that evolution of Roundup-resistant weeds was a “negligible possibility” and the U.S. EPA and USDA allowed commercialization of GE Roundup Ready soybeans, corn, cotton, sugar beets, and alfalfa, as well as canola, anyway.

It took not much more than half a decade after Roundup Ready soybeans were commercialized before, according to The New York Times, a “superweed” showed up in a Delaware soybean field.  And now that approximately 90% of the soybeans and 70% of the corn and cotton grown in the U.S. are Roundup Ready, superweeds have infested millions of acres in at least 22 U.S. states.  And “super” versions of, for example, pigweed, horseweed, and giant ragweed that are glyphosate-resistant are posing problems not only in the U.S. but in agricultural areas of Brazil, Australia and China as well.

This is a serious situation.  It means that farmers in the midwest, south and east must spray their fields with more toxic herbicides in their efforts to protect their crops.  It also limits the use of no-till (or low-till) farming methods, methods that reduce erosion and runoff of pesticides and fertilizers into rivers, methods that were originally touted by proponents of Roundup Ready crops as a major reason to embrace these GE herbicide-resistant organisms when they were first commercially introduced.  Even Monsanto admits that the development of glyphosate-resistant superweeds is “a serious issue” although a Monsanto manager went on to tell The New York Times that this serious issue is, nevertheless, “manageable.”

But the primary way that Monsanto and other biotech companies plan to “manage” superweeds is by developing and commercializing GE crops that are resistant to additional herbicides, the idea being that such next-generation herbicide-resistant crops could then be doused with glufosinate or dicamba or 2,4-D (a component of the defoliant Agent Orange used during the Vietnam War), chemicals that should kill the superweeds that Roundup no longer can.

Sound familiar?

Environmental scientists have the same qualms now about these next-generation herbicide-resistant crops as they did about the first GE herbicide-resistant crops 20 years ago…only now the debate isn’t so hypothetical.  We now know, based on the rapid development of glyphosate-resistant superweeds, that genetically engineering crops to be resistant to additional herbicides will only lead to more superweeds.  Creating next-generation herbicide-resistant crops amounts to repeating the same mistake as was made with Roundup Ready crops…only this time around the herbicides that could be sprayed with abandon on the crops genetically engineered to be resistant to them will not be as relatively benign as Roundup (glyphosate).  (And let’s all hope that glyphosate is that benign because another consequence of spraying glyphosate on vast acreages of resistant crops is that, according to one study, it’s showing up in human urine samples; the details of this study are expected to be released later this year.)

Why make the same mistake twice (or three or more times as Monsanto, Syngenta and Dow Chemical are all developing next-generation GE herbicide-resistant crops)?  Haven’t we already learned the lesson that GE herbicide-resistant crops are not the way to sustainably manage weeds?  A more sustainable solution would be to use an integrated weed management (IWM) program instead.

[For more information on especially Dow Chemical’s 2,4-D-resistant crops, please see “Going Backwards: Dow’s 2,4-D-Resistant Crops and a More Toxic Future,” a publication of the Center for Food Safety.]

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