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  •                                  NETFUTURE
                        Technology and Human Responsibility
    Issue #135                                                 August 29, 2002
                     A Publication of The Nature Institute
               Editor:  Stephen L. Talbott (stevet@netfuture.org)
                      On the Web: http://www.netfuture.org/
         You may redistribute this newsletter for noncommercial purposes.
    Can we take responsibility for technology, or must we sleepwalk
    in submission to its inevitabilities?  NetFuture is a voice for
    responsibility.  It depends on the generosity of those who support
    its goals.  To make a contribution, click here.
    Editor's Note
    Quotes and Provocations
       From Baby Walkers to High Tech: The Anti-developmental Stance
    Should Genetically Modified Foods Be Labeled? (Craig Holdrege)
       A review of the technical and policy issues
    About this newsletter
                                  EDITOR'S NOTE
    Should genetically modified foods be labeled as such?  The official answer
    by the U.S. government is "no", and the question scarcely makes it into
    the newspapers these days.  Yet there is hardly any issue that bears more
    directly upon our long-term welfare.  The decisive question is whether we
    will be a society in which consumers exercise conscious choice regarding
    the technological gifts continually handed to us, or instead a society in
    which we abdicate this choice to commercial and governmental powers.
    In this issue of NetFuture, Craig Holdrege surveys the technical and
    policy issues surrounding the labeling question.  His review is thorough
    and definitive.  I expect its balanced, uncompromising logic will prove
    extremely useful to those working to preserve choice and responsibility on
    behalf of the consumer.
    As Holdrege makes clear, labeling is not only a matter of product safety.
    It also has to do with the consumer's right to make as informed a decision
    as possible about all the implications of a particular purchase.  Why
    would we not push this responsible choice all the way down to the level
    of the individual consumer?  Certainly decentralization of decision-making
    and widespread access to product information are prime requirements of a
    free and capitalist economy.  They are also essential requirements for
    harmonizing the economy with the welfare of both the larger society and
    the earth itself.
    This assumes, of course, that consumers care enough to inform themselves
    and exercise their choices responsibly.  Whether or not such an assumption
    proves correct will be vastly more important to our future than the evils,
    real or imagined, committed by gene-splicing laboratory technicians and
    corporate marketing managers — who are, after all, people just like
    you and me.  The crucial thing about the labeling issue is that it focuses
    attention exactly where it belongs:  on individuals making decisions about
    their own lives.  When a habit of responsible decision-making takes hold,
    it will affect technicians and managers fully as much as the rest of us.
    But it will never take hold as long as we shirk our own responsibilities,
    and one way to do this is to blame others for the world's ills.
    At the end of Craig's article, you will find information about how you can
    make your thoughts on the labeling issue known.  See in particular
    footnote 23.
    Goto table of contents
                             QUOTES AND PROVOCATIONS
    From Baby Walkers to High Tech: The Anti-developmental Stance
    Another study has found "strong associations between the amount of baby
    walker use and the extent of developmental delay".  Children who spend
    time in walkers tend to be slower in "achieving normal locomotor
    milestones".  Also, "baby walkers are known to increase the risk of
    injuries" (British Medical Journal, June 22, 2002).  The walkers at
    issue here are typically round chairs with wheels; they allow babies to
    move around in an upright position, with their feet touching the ground,
    so that they can propel themselves with their own legs.
    I have commented on this before, but it needs repeating.  Could there be a
    more concise picture of our society's pathological distortion of the idea
    of development?  We seem to say, "the child must sooner or later learn to
    walk; if we put him in a walker so he can practice using his legs, maybe
    he'll learn faster, and surely this would be good".
    But, no, surely this would be bad.  If a child normally learns to walk at
    a particular stage of his development, and if (as is certainly the case)
    this walking relates to everything else in the child, from the use of
    other limbs to the structuring of nerve connections in the brain, then why
    should we expect good to come of throwing a wrench into the complex
    developmental sequence?  It is sheer craziness to force a use of the legs
    before the muscles and nervous system have prepared themselves for it.
    Far better to find ways to encourage the fullest expression of the urge to
    crawl so long as that urge prevails.  The child has no difficulty letting
    us know when he is ready for fundamentally new developments such as
    In every domain of society where the "earlier is better" nonsense rules,
    the baby walker case should be contemplated and its grave implications
    registered.  Earlier is never better — not, at least, in any
    automatic sense.  It doesn't even hold for the adult, who still must build
    every physical and cognitive development upon the solid foundation of past
    achievement and in harmony with a life-long rhythm of shifting potentials.
    It is amazing, in a society that makes such a song and dance of
    "evolution" and "development", that the anti-developmental, "earlier is
    better" notion could have taken such root.
    Nowhere has it taken firmer root than in the high-tech industry —
    this despite the fact that many in this industry tend to think of
    themselves as in the vanguard of human and social development.  But the
    powers of development are not mere powers of technical change.  Change by
    itself is not development, because it leaves out of the picture who or
    what is doing the changing — just as injudicious baby walker use
    leaves out of consideration the particular capacities, needs, and
    limitations of the child.
    Limitation is what makes development possible, whether on the individual
    or social level.  Imagine a situation without limitation — which
    would mean, without any definition or fixed character at all — and
    you will not be able to imagine significant development.  There has to be
    a "nature of the thing" before you can talk about meaningful change —
    and understanding the particular nature of the thing is a crucial
    prerequisite for making the change meaningful.  This is why the high-tech
    spirit that glories in new and cool stuff for its own sake — "Let's
    see what we can pull off technically, without regard for how it fits into
    the limitations and character of society" — is not only irresponsible
    but also profoundly anti-developmental.
    As for the small child:  What each phase of his development really needs
    is not to be hurried up and brought out of sequence, but to be
    deepened in the time and place where it belongs.  One then works
    with the developmental process rather than against it.
    It happens that our granddaughter delayed her crawling until an age where
    many babies are taking their first steps, and she chose not to walk until
    she was approaching two years old.  Now she is two and a half, and I'm not
    sure I've ever seen a child show such utter exhilaration as she runs
    endlessly "there and back again".
    It is only misguided adults who find cause for prideful joy in "early
    development".  The child knows nothing of such joy; he is delighted to
    discover whatever properly belongs to each moment.
    (The article, "Locomotor Milestones and Babywalkers: Cross Sectional
    Study", is available at http://bmj.com/content/vol324/issue7352/.)
    Goto table of contents
                                  Craig Holdrege
    It's reasonable to expect that a label will tell you something significant
    about the food you buy.  Based on rich experience of deceptive labeling,
    Congress began passing laws in the early 1900s to regulate food labels.
    The Food, Drug, and Cosmetic Act first passed in 1938 and has been amended
    numerous times.  It states, in connection with the identity of food, that
    the FDA Secretary should make regulations when "such action will promote
    honesty and fair dealing with consumers"1.  On its website the FDA declares
    that it is "one of the nation's oldest and most respected consumer
    protection agencies"2.  Its mission is to ensure that "foods are safe,
    wholesome, sanitary, and properly labeled"3.  The FDA has pages and
    pages of documents defining what should be on labels and what specific
    terms mean and don't mean4.  The "FDA regulates what's on these labels to
    ensure that they are truthful"5.
    A trip to the food store illustrates the FDA's influence.  All products
    must clearly show the identity and amount of their ingredients.  The label
    must also identify any substances — such as preservatives or taste
    enhancers — that have been added to the food.  The FDA has a database
    of over 3,000 food additives that must be named on labels.  If there are
    concerns about the safety of the additive, such as in the case of
    saccharin, the label must contain a health warning for that substance.
    The labels also make distinctions that producers might like to hide.  If
    you want to buy grape juice, then you know it is actually 100% juice if
    the label states "juice".  If it is labeled "drink" or "beverage", you
    know it has been diluted and may contain flavoring.  Or when the ice cream
    label states "vanilla flavored", you know that it contains an artificial
    substitute rather than natural vanilla.
    Food labels also tell you something about the way a food has been
    processed.  If the pasta sauce you buy has been heated (pasteurized) so
    that it will keep longer, it cannot be labeled "fresh", since the label
    "fresh" indicates that a food has not been processed.  Similarly, when you
    buy orange juice, a label tells you whether the juice has been
    reconstituted by adding water to a concentrate.  It states "from
    concentrate" to distinguish it from fresh-squeezed juice.
    Another example of processing is radiation treatment (to kill bacteria).
    Irradiated fruits and vegetables must carry the radura symbol on a label
    stating "treated with radiation".  The FDA has "found it necessary to
    inform the consumer that irradiated food has been processed, because
    irradiation, like other forms of processing, can affect the
    characteristics of food"6.  (Strangely, if an irradiated fruit or
    vegetable is used in a canned or packaged product, it need not be
    labeled, since the FDA reasons that consumers know they are buying a
    processed food.  Evidently the FDA does not consider it important in
    this case to inform us about different kinds of processing.)
    All these examples show a good deal of common sense.  The purpose of the
    label is to accurately inform consumers so that they know what they are
    getting and can make informed choices about the food they buy.  The label
    should embody the intent of open and truthful disclosure.  Insofar as this
    goal is achieved, the FDA is exercising its function as a consumer
    protection agency.
    Genetically Modified Food: No Labeling
    The FDA has declared that genetically modified foods or food ingredients
    need not be labeled.  Why not?  The FDA holds that genetically modified
    foods (GM-foods) are essentially the same as traditional foods — there
    is "substantial equivalence", in the language of food scientists.
    For example, Monsanto scientists performed a detailed nutritional analysis
    of traditionally bred soybeans and also of "Roundup Ready" soybeans,
    which were genetically modified to be resistant to Monsanto's "Roundup"
    herbicide.  The scientists compared nutrient content (protein, fat,
    carbohydrates, fiber, etc.), even analyzing the amounts of the different
    kinds of amino acid that make up proteins.  They also compared so-called
    antinutrients (such as lectins), undesirable substances that occur in
    small amounts in many foods.  In all cases they found no substantial
    differences in composition or amount and therefore concluded that
    conventional and genetically engineered soybeans are substantially
    Utilizing such studies from the companies that produce genetically
    engineered products (the FDA does no testing of its own and does not
    require third-party testing) the FDA formulated its policy on genetically
    modified foods in 1992:
       The agency is not aware of any information showing that foods derived
       by these new methods differ from other foods in any meaningful or
       uniform way, or that, as a class, foods developed by the new
       techniques present any different or greater safety concern than foods
       developed by traditional plant breeding.  For this reason, the agency
       does not believe that the method of development of a new plant variety
       is normally material information ... and would not usually be required to
       be disclosed in labeling for the food8.
    This policy narrowly couples labeling of GM-foods with safety, leaving out
    all the other criteria for labels we described above.  The idea is:  if
    there is no safety issue, there is no reason to label.  And, according to
    the FDA, there is no safety issue, because GM-food and traditional food is
    substantially equivalent, and since traditional food is safe, GM-food must
    also be safe.
    Remaining within this tidy argument, the FDA does not hold the method of
    production to be "material information".  This is a telling conclusion
    that rests on a very specific interpretation of what "material
    information" means.  Normally the term refers to something relevant or
    pertinent to the matter at hand.  But here the FDA has chosen to restrict
    the meaning, equating "material" with "physical substance".  Since
    "genetic engineering", as a method of production, is not a physical
    substance within the plant, it is deemed irrelevant.
    This logic restricts the regulation and labeling of genetically modified
    foods to the narrowest terms possible.  The FDA is applying a very
    different standard than it does for other foods.  I called the FDA and
    asked why it demands labeling of orange juice from concentrate.  Surely, I
    said, it is not a safety issue, and just as surely the agency is not
    raising a question about "substantial equivalence" with fresh-squeezed
    orange juice.  The answer was, "no, of course not; it's a matter of
    truthfulness".  A simple and clear answer (from an FDA employee who did
    not work on GM issues).
    Substantial Equivalence Doesn't Tell it All
    Two foods are defined as substantially equivalent if the investigation of
    certain substances in the foods shows the foods to be "the same".  The
    scientists investigate only a select number of known nutrients and
    antinutrients.  Other substances ("nonnutrients") that are produced,
    expectedly or unexpectedly, through genetic engineering are not taken into
    account.  For example, the fact that each cell of a genetically engineered
    soybean contains a novel protein — the enzyme that prevents the
    herbicide from killing the plant — is not included in the data used
    to determine substantial equivalence.  Nor is the fact that genetically
    engineered plants usually contain five or more genes (DNA sequences) that
    come from other organisms — other plants, bacteria, and viruses (see
    Table below).  No traditionally bred plant contains such an array of
    foreign genes, which include, for example, a bacterial gene that gives the
    plant resistance to a specific antibiotic.
    The concept of substantial equivalence is, by virtue of its narrowness,
    misleading9.  The term itself suggests that all the substances in the foods
    are the same, but in reality only a specific subset of substances has been
    investigated and taken into account in the designation "safe".
                   What A Genetically Engineered Plant Contains
    Plants are never modified by adding just one foreign gene.  A whole
    "DNA construct" made up of DNA from different sources is shot into the
    plant.  In the case of Monsanto's "Roundup Ready" soybeans that are
    genetically modified to become resistant to the herbicide glyphosate,
    the gene construct consists at least of the following10:
    ** DNA originally from the bacterium Agrobacterium, now synthetically
       produced, for herbicide resistance.
    ** DNA from the cauliflower mosaic virus that regulates the expression of
       the herbicide-resistance gene.
    ** DNA from the petunia to move the gene product to the chloroplasts (so
       that the herbicide-resistance gene will be adequately expressed in the
       leaves, which are the main target of the herbicide).
    ** DNA from a bacterium (Agrobacterium tumefaciens) to regulate the
       production of the enzyme needed for herbicide-resistance.
    ** DNA from a fecal Streptococcus bacterium to make the plant antibiotic
       resistance.  It is used as a "marker" gene to help scientists identify
       which plants have been genetically transformed in an experiment.
    ** A circular strand of DNA (called a plasmid) from a bacterium.
    All the other ingredients are biochemically inserted into the plasmid,
    which carries the DNA into the plant's cells.  When the experiment goes
    according to plan, every cell of the organism contains at least one copy
    of the complete construct.  Through the gene construct the metabolism of
    the cells is altered and the plant is obliged to produce novel proteins:
    ** a target protein — for example, the enzyme to convey resistance to
       herbicide in "Roundup Ready" soybeans or the toxin to kill insect
       larvae in "Bt" crops;
    ** enzymes affording antibiotic resistance.
    These proteins are produced continually, in every cell in the plant.  By
    contrast, in normal protein metabolism, proteins are specific to
    particular tissues and functions.
    Foreign Gene Products as Additives
    In the early 1990s Calgene was developing its "flavrsavr" tomato,
    the first GM-food to enter the market.  This tomato was genetically
    engineered to turn red on the vine but remain hard for shipping.
    (The idea was that it would taste better, but in the end Calgene's
    $95,000,000 investment didn't pan out, and the company — on the verge of
    bankruptcy — was bought by Monsanto.)  The FDA at that time was still in
    the process of formulating its policy on GM-foods.  According to Belinda
    Martineau, a scientist who worked on Calgene's tomato project, "the FDA
    did not have a specific process in place for dealing with genetically
    engineered whole foods.  It was up to us, therefore, to decide just how
    to submit to the agency whatever safety data we would produce" (p. 64)11.
    The company had to decide how to deal with the new tomato's novel
    proteins.  The fruit contained, like other genetically engineered crops,
    an antibiotic-resistance gene and the protein (enzyme) produced through
    it.  The scientists involved came to the conclusion that the enzyme would
    fit into the category of food additives, and the tomato would then carry a
    label specifying the additive.  Since food additives are strictly
    regulated, the process of approval might have taken three years.
    Calgene's management wanted to get around this problem by calling the
    antibiotic-resistance enzyme a "processing aid".  Receiving approval for a
    processing aid was likely to be quicker, the company wouldn't have to
    publish safety data, and processing aids don't need to appear on labels.
    This seemed an ideal strategy.
    In the end, the FDA did require that Calgene submit a food-additive
    petition, since this was considered the approach that would cause the
    least problems for approval (See reference 11, p. 161).  The main
    issues considered were whether the tomatoes were safe for human
    consumption (the company did some animal tests), whether the enzyme
    might cause resistance to antibiotics in humans, and whether the gene
    might be transferred to bacteria in the intestines.  Based on all the
    evidence Calgene presented, the FDA declared the enzyme to be a safe food
    But it did not require labeling.  Normally, as I described at the
    beginning of this paper, the FDA requires any added ingredients to be
    indicated on a food's label.  But in the case of the antibiotic-resistance
    enzyme, the FDA reasoned:
       FDA considers an "ingredient" to be a substance used to fabricate
       (i.e., manufacture or produce) a food.  FDA does not consider those
       substances that are inherent components of food to be ingredients that
       must be disclosed in the food label.  A genetic substance introduced
       into a plant by breeding becomes an inherent part of the plant as well
       as of all foods derived from the plant.  Consistent with FDA's general
       approach on ingredient labeling, the agency has not treated as an
       ingredient a new constituent of a plant introduced by breeding,
       regardless of the method used to develop the new plant variety ....
       Accordingly, [the antibiotic-resistance enzyme is not] an ingredient
       that must be individually identified on the labels of foods containing
       them.  (See reference 12.)
    In other words, after declaring the antibiotic-resistance enzyme to be an
    additive (which means it is an ingredient), the FDA immediately turned
    around and, for purposes of labeling, denied the additive-ingredient
    status, calling the enzyme an inherent part of the plant.  The FDA went on
    to "solidify" this position by stating that even if the enzyme were an
    ingredient, it would treat it as a "processing aid" rather than an
    additive, so it wouldn't require labeling anyway.  These logical flip-
    flops seem inexplicable except as efforts to prevent labeling at all
    We'll see why later.  But now we need to look at how genetic engineering
    differs from traditional breeding.
    A Long Way from Traditional Breeding
    It is not only the genetic and biochemical composition that makes GM-crops
    different from conventional crops.  The whole way in which they are
    produced differs radically from traditional breeding, and these
    differences bring new kinds of uncertainty.  First, scientists must
    isolate the various genes used in the genetic manipulation.  This is an
    involved biochemical and technical procedure, yielding products for which
    companies (and universities) seek patents.  You can't help feeling the
    wool is being pulled over your eyes when the same companies that receive
    patents for their products, which according to the patent office must be
    "man-made", argue that genetic engineering is as natural as traditional
    Then genetic engineers make the novel gene construct, consisting of DNA
    from different sources (plants, bacteria, and viruses; sometimes animal
    DNA).  This product of biochemical analysis and synthesis is used to alter
    the plant, a far cry from a breeder taking pollen from one plant variety
    and using it to fertilize another plant of the same species in the hope of
    producing plants with a new combination of characteristics.
    Once the laboratory-produced DNA construct has been made in the lab,
    the task is to get it into the plant.  The most prevalent method is to
    use a "gene gun"13.  Tiny pellets of tungsten or gold are coated with the
    transgenic plasmids and then shot into embryonic plants.  These plants
    are then grown in a medium with antibiotics.  Only a small percentage
    of plants survive — those that have the antibiotic-resistance gene.
    These plants and their progeny are investigated further to see if they
    also express the desired trait (herbicide resistance, toxin production,
    and so on).  Usually a few plants are chosen to be the parent stock of
    the future crop.  At this point traditional breeding methods set in.
    Breeders select and perhaps cross the transgenic plants with other
    known varieties with desirable traits.  Finally, a new transgenic crop
    line emerges.
    When a company has a transgenic crop line, it can carry out a detailed
    genetic analysis to discover how the DNA has been incorporated into the
    plant.  Often the DNA-construct is broken, the desired genes are separated
    from each other, and the individual genes themselves split into fragments.
    These genes and fragments may be incorporated into different places into
    one or more chromosomes.  The foreign DNA may also be inserted into the
    chromosome in such a way that it breaks up one of the plant's genes.  Some
    of the DNA may be broken down altogether.
    All of this can be detected only after the fact.  And sometimes long after
    the fact.   Monsanto originally declared that each cell of Roundup Ready
    soybeans did not contain the entire DNA construct (see Table above), but
    rather a single copy of two of the genes and partial copies of two others.
    Nonetheless the plant "worked" the way the scientists wanted it to (with
    high resistance to the glyphosate herbicide).  Four years after the
    Roundup Ready soybeans had been on the market, Monsanto reported that each
    cell also contained two additional partial segments of the herbicide-
    resistance gene as well as another copy of one of the other genes of the
    Genetic engineering is usually hailed as a precise new technique to make
    exact modifications.  In reality, precision stops when the DNA leaves the
    laboratory and enters the plant.  The scientists have to wait and see what
    the organism has made of their attempted manipulation.
    Unintended Consequences
    By now you can see why there are good grounds to expect unintended effects
    arising from any genetic manipulation.  The plant may be producing new
    substances that it hadn't produced before, or its normal production of
    substances may have been repressed.
    There are countless examples of such changes: transgenic potatoes that
    were supposed to make more starch and less sugar, made less starch and
    less sugar; transgenic tomatoes that were made to produce excess
    carotene did so, but the more carotene they produced, the smaller they
    got; a normally self-fertilizing weed that was made herbicide-resistant
    (as intended) also unexpectedly began cross-pollinating with other
    specimens — a radical change in reproduction14.  Many such undesired and
    unexpected effects are weeded out in the process of selecting plants
    for further breeding.  But there is no reason to believe that the only
    changes are the more obviously detectable ones.  Also, some changes may
    become apparent only in the field, and there are various environmental
    Let me give one example.  Some farmers in Georgia complained about the
    poor performance of their transgenic herbicide-resistant soybeans
    under conditions of drought and heat.  Scientists then carried out a
    comparative laboratory study of transgenic and conventional soybeans16.
    They found that the transgenic plants were shorter, had a lower fresh
    weight, had less chlorophyll content and, at high temperature, suffered
    from stem splitting.  They were clearly different from their conventional
    counterparts in ways other than being herbicide-resistant.  This is one
    of many examples showing how a genetic modification intended to change
    a specific and clearly circumscribed characteristic of the plant, ends
    up affecting the whole organism.  Some of the unintended effects may be
    induced by environmental conditions.  No one can foretell the kind or
    degree of such changes.
    Why A Double Standard?
    All these examples make one wonder how the FDA can claim it "is not aware
    of any information showing that foods derived by these new methods differ
    from other foods in any meaningful or uniform way".  This view has a
    glimmer of credibility only as long as the FDA views GM-food through the
    monocle of substantial equivalence, while wearing blinders to all other
    considerations.  The broader view shows that genetic engineering is a
    radically new way of altering the plants we utilize for food.  Traditional
    food processing and use of additives begins after the plants have been
    harvested and reach the factory.  With genetic engineering, processing and
    adding new substances begins already in the growing plant.
    Even apart from safety issues, shouldn't the FDA, as a consumer protection
    agency, inform consumers via labels about genetic engineering as a new
    method of adding substances to and processing food?  Isn't this at least
    as important as knowing that your orange juice is from concentrate?
    Surely the criteria of truthfulness and honest disclosure remain the same
    in both cases.  Why has the FDA chosen to establish such a crass double
    At the time the FDA was formulating its policy regarding genetically
    modified foods, scientists within the FDA itself were critical of the
    new policy.  These dissenting voices were made public only much later.
    Early in 1992, Linda Kahl, an FDA scientist and compliance officer,
    complained to James Marianski, the FDA's biotechnology coordinator,
    about how the agency was  "trying to force an ultimate conclusion that
    there is no difference between foods modified by genetic engineering
    and foods modified by traditional breeding practices".  This was like
    "trying to fit a square peg into a round hole"17.  Another FDA scientist,
    Louis Pribyl, writes in his comments on the draft document:
       What has happened to scientific elements of this document?  Without a
       sound scientific base to rest on, this becomes a broad, general, "What
       do I have to do to avoid trouble"-type document .... This document
       reads like a biotech REDBOOK!! .... It reads very pro-industry,
       especially in the area of unintended effects, but contains very little
       input from consumers and only a few answers for their concerns18.
    In other words, the FDA took the perspective of the biotech industry in
    formulating its policy.  The pro-biotech bias has not been restricted to
    the FDA.  Dan Glickman, reflecting on his tenure as Clinton's Secretary
    of Agriculture, stated in the summer of 2001:
       Regulators even viewed themselves as cheerleaders for biotechnology.
       It was viewed as science marching forward, and anyone who wasn't
       marching forward was a Luddite.  (Los Angeles Times, July 1, 2001)
    The interviewer goes on to write that Glickman expressed his regrets "that
    industry was allowed to take the lead, as regulators ceded their watchdog
    This pro-biotech bias makes clear why the FDA policy regarding GM-foods
    differs in spirit and in content so radically from its policies regarding
    other foods.  Otherwise it is impossible to understand the tortuous and
    often disingenuous argumentation that FDA uses in its attempts, as Kahl
    put it, to fit square pegs into round holes.  The policy was crafted
    around a foregone conclusion that is also the biotech industry's view --
    GM-food should not be labeled.  So the FDA had to find ways to narrow the
    context (safety as the only reason to label) and to "demonstrate" that
    GM-food and food from traditionally bred plants is the same.  Along the
    way it left out all the factually existing differences in content and
    process, while also ignoring the consumer.
    The Consumer's Right to Know? — Contrasting Views
    When I participated in a panel discussion with representatives from
    the biotech industry and the government earlier this year, the
    representative from the FDA opined that "consumers have a right to
    know — but not to know everything".  This echoes a sentiment expressed
    on the FDA's website, where we can read that law "does not require
    disclosure of information solely on the basis of consumers' desire to
    know"19.  This is a very strange reading of its mission as a consumer
    protection agency, which is (according to the Food, Drug, and Cosmetic
    Act) to "promote honesty and fair dealing with consumers".
    The Europeans have taken a very different stance on labeling genetically
    modified food.  David Byrne, European Commissioner for Health and Consumer
    Protection, spoke to the National Press Club on October 9, 2001:
       Let me be very frank.  Unless we can give EU consumers confidence
       in this new technology then GM is dead in Europe.  Let me assure
       you that this is not a scare tactic on my part.  I am not prone
       to exaggeration .... As part of the new approval process, GM food
       and feed will have to be labeled as such .... Europe is perfectly
       entitled to impose the labeling rules proposed.  Our consumers are
       demanding this.  They are entitled to choice and full information
       is now a right since the Amsterdam Treaty has become part of the
       constitutional arrangements of the European Union .... Labels that
       cover all GM-derived products ensure that our consumers are able to
       choose a GM product or a non-GM product.
    This is a very clear position statement.  It leaves no doubt that the
    main reason to label GM-foods is the consumer's right to know and to
    choose.  Britain's premier scientific society, The Royal Society,
    states in its essentially pro-genetic engineering position paper that
    nonetheless  "public debate must take account of wider issues than
    science alone"20.
    In contrast, U.S. regulations (or rather, the lack thereof) concerning
    GM-food are based solely on a partial examination of the end-product.
    This is called a "science-based" approach.  Biotech advocate Henry
    Miller (Hoover Institution, Stanford University) echoes the FDA's view
    when he states that regulations focusing on process are unscientific
    and therefore the only "rational approach" is not to label genetically
    modified food21.  It is "rational" to ignore process and to ignore
    the consumer.  What a sad view — one might even call it insane, inasmuch
    as insanity entails losing touch with reality.  Following this approach
    the food label would reveal nothing more and nothing less than what
    passed through the filter of an extremely narrow view, so-called "sound
    science".  The authority of "science" (represented by the government
    and the biotech industry) chooses what is fit for the people to know.
    This does not sound like a healthy democracy to me.
    Food Labels — A Window to Food's Story
    During the course of the twentieth century, farming and food production
    and processing became increasingly detached from the lives of most people
    in the Western world.  Children who are told, to their surprise, that milk
    comes from cows and eggs from chickens often find the facts "gross".  More
    broadly, most of us have next to no idea where the food we eat comes from
    or what's involved in its processing.  Food additives labeled on packages
    are just names.  And in many instances we would not be enthralled if we
    knew more about the food we're eating.
    Recently Michael Pollan wrote an exemplary piece on the life of a beef
    steer22.  His detailed "biography" brings home how the food we eat
    is connected with a whole world of social, economic, political, and
    ecological connections.  When we buy food we're supporting that
    particular world — a world about which we usually know nothing.  In a
    sense we're sleepwalking.  This is one of the consequences of the
    technologization of our culture — it distances us from concrete
    processes and we end up living in a world peopled with end-products
    whose life stories we don't know.
    Food labels are one (and only one) small window into the world of food.
    Many labels restrict themselves to end-product information — contents,
    nutritional value, etc.  The more they tell you about processing and
    method of production, the more you as a consumer can see into the world
    connected to that particular product.  Some producers want you to have
    this knowledge, especially in the natural foods industry where the label
    might tell you the contents of salsa are organically grown (and therefore
    genetic engineering was not involved in the food's production).  Or the
    milk you buy might state that the cattle were not treated with hormones
    and did have access to pasture grazing.  All this labeling is voluntary.
    What you don't find (although it is allowed) is voluntary labeling that
    states "genetically engineered" or "factory farmed".  Evidently the
    producers are not interested in any window being open to those worlds.
    The more the window to a food's story is open and the larger that window
    is, the greater the opportunity for consumers to make informed decisions.
    In respect to genetically engineered foods (and to many practices of
    modern agriculture and animal husbandry) the government keeps the window
    closed.  It does not go all the way to promote "honest and fair dealing
    with consumers".
    I doubt that the impetus for making labels transparent will come from
    the government.  The pro-biotech stance is very firm.  But if American
    consumers become more active — as they have in Europe — then things can
    change.  This activity can have at least two complementary directions.
    First, we can inform the government that we do believe in the
    significance of our choices as consumers and in the obligation of the
    federal regulatory agencies to protect these choices.  We can demand
    more open and consistent practices instead of double standards.  We can
    demand that labels be more comprehensive and include information about
    process and production as well as content.  The cynic in us will counter
    that we don't have any power to confront the government-biotech complex.
    But the consumer does still have power.  When the Agriculture Department
    was adopting new "organic" standards, public protest brought about changes
    so that, for example, a product cannot be called organic if it has been
    genetically engineered.  The standards on organic agriculture are far
    from perfect, but they are much better than they would have been had
    citizens not made their opinions known23.
    Second, we can purchase selectively.  We can choose to buy food that does
    open the window to food's story.  In this way we influence the way food is
    produced and labeled.  The more consumers buy products with transparent
    labeling practices, the more such labeling — and the type of farming
    and animal husbandry the labels stand for — will take hold.
    Consumers are a primary force in the rapid expansion of the organic foods
    market, as well as in the burgeoning growth of local and regional food
    networks, such as Community Supported Agriculture (CSA), where there is
    direct contact between consumers and farmers who produce the food.
    Surveys consistently show a majority of Americans in favor of labeling
    GM-foods24.  While the FDA has, for now, set itself against full disclosure,
    surely it cannot remain wholly immune to consumer pressure.  After all, if
    the FDA does not exist to protect the declared interests of consumers,
    particularly with respect to truthfulness and transparency, then what is
    its mission?
    Related articles
    ** "Sowing Technology", by Craig Holdrege and Stephen L. Talbott.  A look at
    biotech issues in agriculture.  (Originally published in Sierra.)
    ** "Golden Genes and World Hunger: Let Them Eat Transgenic Rice?" by Craig
    Holdrege and Stephen L. Talbott.  An assessment of the claims for golden rice
    as a solution for hunger and malnutrition.

    1. Section 401 of the Food, Drug and Cosmetic Act.

    2. http://www.fda.gov/oc/opacom/fda101/fda101text.html.

    3. http://www.fda.gov/opacom/morechoices/mission.html.

    4. Code of Federal Regulations, Title 21, Chapter 1, especially parts 101 and 102. See http://www.access.gpo.gov/cgi-bin/cfrassemble.cgi?title=200121.

    5. See reference 2.

    6. http://www.cfsan.fda.gov/~dms/opa-rdtk.html.

    7. Padgette, S. et al. 1996. "The Composition of Glyphosate-Tolerant Soybean Seeds Is Equivalent to That of Conventional Soybeans", Journal of Nutrition vol. 126: 702-716.

    8. Federal Register vol. 54, No. 104 (1992), p. 22991.

    9. For a succinct overview of the problematic concept of substantial equivalence, including links to other articles, see the discussion on the website of Physicians and Scientists for Responsible Action of Science and Technology (http://www.psrast.org/subeqow.htm).

    10. http://www.genewatch.org. (Click successively on "Database", "Search", and "Search by crop line". Then, under "Select a crop line", click on "GTS 40-3-2".)

    11. Martineau, B. (2001). First Fruit. New York: McGraw-Hill.

    12. Federal Register vol. 59, No. 98 (1994), pp. 26700-26711.

    13. For a good description of the "gene gun", see: http://www.hawkhill.com/926s.html.

    14. Trethewey, R.N. et al. (1998). "Combined Expression of Glucokinase and Invertase in Potato Tubers Leads to a Dramatic Reduction in Starch Accumulation and a Stimulation of Glycolysis", Plant Journal vol. 15, pp. 109-118; Fray, R. et al. (1995). "Constitutive Expression of a Fruit Phytoene Synthase Gene in Transgenic Tomatoes Causes Dwarfism by Redirecting Metabolites from the Gibberellin Pathway", The Plant Journal vol. 8, pp. 693-701; Bergelson, J. et al. (1998). "Promiscuity in Transgenic Plants", Nature vol. 395, p. 25.

    15. Holdrege, C. and S. Talbott (2001). "Sowing Technology", Sierra (July/August), pp. 34 ff.; for an online version of this article, see http://www.netfuture.org/2001/Oct0901_123.html.

    16. Gertz, J.M. et al. (1999). "Tolerance of Transgenic Soybean (Glycine max) to Heat Stress", The Brighton Conference: Weeds. Surrey, U.K.: The Council, pp. 835-840.

    17. http://www.bio-integrity.org/FDAdocs/01.

    18. http://www.bio-integrity.org/FDAdocs/04.

    19. http://www.cfsan.fda.gov/~lrd/biopolcy.html.

    20. http://www.royalsoc.ac.uk (see "GM Plants" under "Issues"; report from February 2002).

    21. Miller, H. (1999). "A Rational Approach to Labeling Biotech-Derived Foods". Science vol. 284, pp. 1471-1472.

    22. Pollan, M. (2002). "Power Steer", New York Times Magazine (March 31), pp. 44ff.

    23. For information about how you can make your opinion known, see the websites for The Campaign (http://www.thecampaign.org) and the Center for Food Safety (http://www.centerforfoodsafety.org).

    24. For a summary of public opinion polls see http://www.centerforfoodsafety.org/facts&issues/polls.html. Goto table of contents ========================================================================== ABOUT THIS NEWSLETTER Copyright 2002 by The Nature Institute. You may redistribute this newsletter for noncommercial purposes. You may also redistribute individual articles in their entirety, provided the NetFuture url and this paragraph are attached. NetFuture is supported by freely given reader contributions, and could not survive without them. For details and special offers, see http://netfuture.org/support.html . Current and past issues of NetFuture are available on the Web: http://netfuture.org/ To subscribe or unsubscribe to NetFuture: http://netfuture.org/subscribe.html. Steve Talbott :: NetFuture #135 :: August 29, 2002 Goto table of contents

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