NETFUTURE
Technology and Human Responsibility
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Issue #135 August 29, 2002
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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.
CONTENTS
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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
DEPARTMENTS
About this newsletter
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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.
SLT
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QUOTES AND PROVOCATIONS
From Baby Walkers to High Tech: The Anti-developmental Stance
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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
walking.
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/.)
SLT
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SHOULD GENETICALLY MODIFIED FOODS BE LABELED?
Craig Holdrege
(craig@natureinstitute.org)
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
equivalent7.
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".
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Table
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.
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Foreign Gene Products as Additives
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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
additive12.
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
costs.
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
breeding.
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
construct.
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
concerns15.
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
standard?
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
role".
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.)
http://www.netfuture.org/2001/Oct0901_123.html
** "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.
http://www.netfuture.org/Jul0600_108.html
REFERENCES
----------
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.
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Steve Talbott :: NetFuture #135 :: August 29, 2002
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