Risks of Genetic Engineering

Down to Earth and GMOs

Down to Earth is opposed to the development of products containing GMOs because we believe they may pose health, safety, and other potential risks that far outweigh the purported benefits.

Unfortunately, along with many food manufacturers, other retailers, and consumers, Down to Earth is essentially a victim of the biotechnology industry. The biotechnology industry has forced its products upon us with inadequate testing and—due to the lack of government action—without any requirement for labeling. As a result, it is not possible for Down to Earth to identify which products may or may not contain GMOs. Therefore, regrettably, as with all grocers and natural foods stores, we may sell some products that may contain GMOs.

Down to Earth strongly promotes the organic industry, whose products are produced without GMOs. Until recently, selecting foods labeled Organic has been the only way customers could avoid non-GMO foods. However, organic certification covers how a food is grown, not the content of the food itself. And, since food production has become increasingly compromised by cross pollination and cross contamination in processing and handling, even organic certification does not guarantee that a product is GMO free.

If a non-organic product contains corn, soy, canola oil, or even sugar (as a significant amount of sugar is now produced from GMO sugar beets) it may contain GMOs unless the manufacturer makes a specific claim that their product is GMO free. However, even if a manufacturer makes such a claim there is no way to know whether such claims are actually valid because they generally are not backed by third-party testing or adherence to independent standards of transportation and processing, etc.

The natural products industry, along with many concerned consumers and others, have long pressed for and supported efforts to require mandatory labeling of foods containing GMOs. Consumers have repeatedly stated they do not want GMOs in their foods. If such products were labeled, their sales would likely plummet resulting in their economic failure. Sadly, for various reasons, mandatory labeling efforts have not succeeded.

As a result of these issues Down to Earth, along with the natural products industry, strongly supports the Non-GMO Project. The Non-GMO Project provides manufacturers with a "Non-GMO Project Verified" seal that is backed by independent testing. The “Non-GMO Project Verified” seal means that GMO contamination has been avoided throughout the growth and harvesting of crops, their processing, storage and packaging. As of December 2012, over 6,000 products have been verified, with thousands more in the process.

With increasing numbers of manufacturers including the “Non-GMO Project Verified” seal on their packaging, you will see more and more of the verified products on our shelves. Consumers have the right to choose what foods to eat and feed their families. This Non-GMO logo enables consumers to exercise this right!

We call on Congress to support labeling of foods that contain GMOs.

For more information visit The Non-GMO Project

Background

Introduced in 1996, the genetic engineering of plants and animals today looms as one of the greatest and most intractable environmental challenges of the 21st Century. With promises of making more and supposedly “better” food, this new technology - also known as Genetically Modified Organisms (GMOs) - has invaded our grocery stores and our kitchen pantries by fundamentally altering some of our most important staple food crops.

Currently, up to 80 percent of U.S. corn is genetically engineered as are 91 percent of soybeans.¹ It has been estimated that 75-80 percent of processed foods on supermarket shelves--from soda to soup, crackers to condiments--contain genetically engineered ingredients.² Yet another common GMO food source is dairy products from cows injected with the genetically modified hormone Recombinant Bovine Growth Hormone (rBGH).

Because there are no laws mandating that these ingredients must be labeled as genetically modified, consumers are most likely unwittingly consuming genetically modified ingredients, whether they want to or not. While many in the scientific community assert that GMO foods are not toxic and are safe, significant voices within this community are sounding the alarm. They say genetic engineering poses risks that scientists simply do not know enough to identify. In fact, based on what little is known about GMOs, many scientists have identified a variety of ways in which genetically engineered organisms could adversely impact both human health and the environment, so there is reason to be concerned.

One concern is that specific engineered organisms may be harmful by virtue of the novel gene combinations they possess. No one knows with certainty how these new life forms will behave in the future, so the limited risk assessments conducted to date are poor predictors of the safety of GMOs over the long term. Risk assessment is further challenged by the highly complex web of regulatory review, which involves three government agencies and dozens of departments with competing interests that render government oversight practically toothless.

At the most basic level, so-called government risk assessment is suspect because it actually conducts no research on its own. Health and safety reviews rely almost entirely on data supplied by the very companies seeking approvals for their new GMO products. This is a serious conflict of interest that brings into question the validity of safety assurances from the government—raising the specter of environmental contamination and potential harms to human health.

Many scientists, for example, point to the lack of empirical testing, unknown safety risks, and the dangers of allergies, cancer, etc. Still others within the natural and organic products industry are simply philosophically opposed to GMOs. They believe that creating “better” foods in the laboratory by genetically altering foods, or cloning animals, etc. is simply wrong. GMOs are created using processes that do not occur naturally, which poses questions about their safety, and their introduction into the environment is irreversible. Some say that GMO stands for “God Move Over”, i.e. that scientists and big agribusinesses are taking on the role of creating new life forms themselves without the knowledge or understanding to do so.

For these reasons, it is the position of Down to Earth ALL VEGETARIAN Organic and Natural that the development of GMO crops and their introduction into our food supply pose health and safety risks that far outweigh the benefits. We urge government to stop enabling industry to feed the products of genetic engineering to our population, and to ban the release of these crops into the environment where they can never be recalled. At the very least, consumers have the right to choose what foods to eat and feed their families. To enable consumers to exercise this right, we call on Congress to support labeling of foods that contain GMOs. To read about the risks of GMOs click on the links below.

• GMO Labeling: The Right to Choose
• What Are Genetically Modified Organisms (GMOs)?
• What are the Benefits of GMOs?
• How Widespread Is the Adoption of GMOs?
• What Are the Major Concerns?
  1. Potential Harms to Health
     
     1. New Allergens in the Food Supply
     2. Antibiotic Resistance
     3. Production of New Toxins
     4. Concentration of Toxic Metals
     5. Enhancement of the Environment for Toxic Fungi
     6. Unknown Harms to Health
  2. Potential Environmental Harms
     
     1. Cross Contamination
     2. Increased Weediness
     3. Gene Transfer to Wild or Weedy Relatives
     4. Change in Herbicide Use Patterns
     5. Squandering of Valuable Pest Susceptibility Genes
     6. Poisoned Wildlife
     7. Creation of New or Worse Viruses
  3. Unknown Harms to the Environment
  4. Risk Assessment
• Weak Government Oversight

GMO Labeling: The Right to Choose

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What Are Genetically Modified Organisms (GMOs)?

Genetically modified organisms (GMOs) are essentially plants and animals that have had their genetic material (DNA) altered in a way that does not occur naturally. The technology is also known as “biotechnology,” ” bioengineering,” “recombinant DNA technology,” or “genetic engineering.” It allows selected individual genes to be transferred from one organism into another, or between non-related species, e.g. animal genes are being inserted into fruits and vegetables. By being able to take the genetic material from one organism and insert it into the permanent genetic code of another, biotechnologists are inventing genetically modified plants and animals–which are then grown as food. Examples include potatoes with bacteria genes, "super" pigs with human growth genes, fish with cattle growth genes, tomatoes with flounder genes, and thousands of other plants, animals and insects. These creations are now being patented and released into the environment at an alarming rate. Back to top

What are the Benefits of GMOs?

The main focus of the GMO industry during the past decade has been to develop GMO crops that are supposed to increase crop yields while reducing applications of crop protection chemicals. However, the success of these strategies is the subject of much debate with many alleging that the use of GMO crops has led to the use of additional herbicides and no increase in crop yields. New GMO crops currently in development are expected by the big agribusinesses to help farmers produce food that is supposed to be in their opinion healthier, more nutritious and better tasting. To offset the potential impact of global warming, new varieties of GMO food crops that resist higher temperatures, withstand drought, or thrive in salt water are being developed to allegedly help stem potential food shortages in the future. However, there is little evidence to support any of these alleged benefits, and much evidence to the contrary. One thing is for sure though, the companies that make the GMOs benefit by creating patentable seeds that can only be bought from them. Financial benefits to the developers of GMOs are the only indisputable benefits that have been realized to date. Back to top

How Widespread Is the Adoption of GMOs?

In the United States alone, more than 154 million acres of GMO crops were planted in 2008, up from 143 million acres in 2007. The primary GMO crops grown in the U.S. are corn, cotton, canola and soybeans, but also squash, papaya, alfalfa, and sugar beet. Soybeans and cotton that are genetically engineered with herbicide-tolerant traits have been the most widely and rapidly adopted GE crops in the U.S., followed by insect-resistant cotton and corn.³ Globally, GMO acreage in 2008 grew to 309 million acres (125 million hectares) versus 282 million acres (114.3 million hectares) in 2007. This is a 26.43 million acre (10.7 million hectare) increase, an increase of 9.4 percent. In 2008, GMO crops were grown in 25 countries, up from 23 countries in 2007. More than two billion acres (800 million hectares) of GMO crops have been planted globally since 1996.⁴Back to top

What Are the Major Concerns?

The increasingly rapid adoption of GMOs brings to question risks associated with GMOs. It is aggravated by a significant lack of agreement among scientists and thought leaders about what those risks actually are. Discussions have covered a broad range of concerns about the health and environmental safety of GMOs. The three main issues debated are potential harms to human health and environmental safety, and whether the risk assessment itself is reliable.

1. Potential Harms to Health
2. Potential Environmental Harms
3. Unknown Harms to the Environment
4. Risk Assessment

Potential Harms to Health

• New Allergens in the Food Supply
• Antibiotic Resistance
• Production of New Toxins
• Concentration of Toxic Metals
• Enhancement of the Environment for Toxic Fungi
• Unknown Harms to Health

Here are the some examples of the potential adverse effects that genetically engineered organisms may have on human health. Most of these examples are associated with the growth and consumption of genetically engineered crops. Different risks would be associated with genetically engineered animals and, like the risks associated with plants, would depend largely on the new traits introduced into the organism. Back to top

New Allergens in the Food Supply

Genetically engineered crops could bring, and some scientists believe they have already brought, new allergens into foods that sensitive individuals would not know to avoid. An example is transferring the gene for one of the many allergenic proteins found in milk into vegetables like carrots. Mothers who know to avoid giving their sensitive children milk would not know to avoid giving them genetically engineered carrots containing milk proteins. The problem is unique to genetic engineering because it alone can transfer proteins across species boundaries into completely unrelated organisms. Genetic engineering routinely moves proteins into the food supply from organisms that have never been consumed as foods. Some of those proteins could be food allergens, since virtually all known food allergens are proteins. Recent research substantiates concerns about genetic engineering rendering previously safe foods allergenic. A study by scientists at the University of Nebraska shows that soybeans genetically engineered to contain Brazil-nut proteins cause reactions in individuals allergic to Brazil nuts. Scientists have limited ability to predict whether a particular protein will be a food allergen, if consumed by humans. The only sure way to determine whether protein will be an allergen is through experience. Thus importing proteins, particularly from nonfood sources, is a gamble with respect to their allergenicity. In addition, there is evidence to indicate that there is a significant increase in the number of people suffering from food allergies; some believe this could be related to the increased amount of GMOs in the food supply.⁵Back to top

Antibiotic Resistance

Genetic engineering often uses genes for antibiotic resistance as "selectable markers." Early in the engineering process, these markers help select cells that have taken up foreign genes. Although they have no further use, the genes continue to be expressed in plant tissues. Most genetically engineered plant foods carry fully functioning antibiotic-resistance genes. The presence of antibiotic-resistance genes in foods could have two harmful effects. First, eating these foods could reduce the effectiveness of antibiotics to fight disease when these antibiotics are taken with meals. Antibiotic-resistance genes produce enzymes that can degrade antibiotics. If a tomato with an antibiotic-resistance gene is eaten at the same time as an antibiotic, it could destroy the antibiotic in the stomach. Second, the resistance genes could be transferred to human or animal pathogens, making them impervious to antibiotics. If transfer were to occur, it could aggravate the already serious health problem of antibiotic-resistant disease organisms. Although unmediated transfers of genetic material from plants to bacteria are believed to be highly unlikely, any possibility that they may occur requires careful scrutiny in light of the seriousness of antibiotic resistance. In addition, the widespread presence of antibiotic-resistance genes in engineered food suggests that as the number of genetically engineered products grows, the effects of antibiotic resistance should be analyzed cumulatively across the food supply. Back to top

Production of New Toxins

Many organisms have the ability to produce toxic substances. For plants, such substances help to defend stationary organisms from the many predators in their environment. In some cases, plants contain inactive pathways leading to toxic substances. Addition of new genetic material through genetic engineering could reactivate these inactive pathways or otherwise increase the levels of toxic substances within the plants. This could happen, for example, if the on/off signals associated with the introduced gene were located on the genome in places where they could turn on the previously inactive genes. Back to top

Concentration of Toxic Metals

Some of the new genes being added to crops can remove heavy metals like mercury from the soil and concentrate them in the plant tissue. One of the purposes for a particular variety of such crops is to make possible the use of municipal sludge as fertilizer. Sludge contains useful plant nutrients, but often cannot be used as fertilizer because it is contaminated with toxic heavy metals. The idea is to engineer plants to remove and sequester those metals in inedible parts of plants. In a tomato, for example, the metals would be sequestered in the roots; in potatoes in the leaves. Turning on the genes in only some parts of the plants requires the use of genetic on/off switches that turn on only in specific tissues, like leaves. Such products pose risks of contaminating foods with high levels of toxic metals if the on/off switches are not completely turned off in edible tissues. There are also environmental risks associated with the handling and disposal of the metal-contaminated parts of plants after harvesting. Back to top

Enhancement of the Environment for Toxic Fungi

Although for the most part health risks are the result of the genetic material newly added to organisms, it is also possible for the removal of genes and gene products to cause problems. For example, genetic engineering might be used to produce decaffeinated coffee beans by deleting or turning off genes associated with caffeine production. But caffeine helps protect coffee beans against fungi. Beans that are unable to produce caffeine might be coated with fungi, which can produce toxins. Fungal toxins, such as aflatoxin, are potent human toxins that can remain active through processes of food preparation. Back to top

Unknown Harms to Health

As with any new technology, the full set of risks associated with genetic engineering have almost certainly not been identified. The ability to imagine what might go wrong with a technology is limited by the currently incomplete understanding of physiology, genetics, and nutrition. Back to top

Potential Environmental Harms

• Cross Contamination
• Increased Weediness
• Gene Transfer to Wild or Weedy Relatives
• Change in Herbicide Use Patterns
• Squandering of Valuable Pest Susceptibility Genes
• Poisoned Wildlife
• Creation of New or Worse Viruses

Contamination

GMO crops may have an indirect effect on food safety and food security due to the movement of genes from GMO plants into conventional crops or related species in the wild, as well as the mixing of crops derived from conventional seeds with those grown using GMO crops. The Center for Food Safety says the following are just a few of the dozens of episodes in which pollen or seeds from genetically engineered (GE) crops have contaminated conventional crops, often causing seed or product recalls, and other problems for farmers and consumers: ⁶

August 2006 — Bayer CropScience and Riceland Foods report widespread contamination of commercial long-grain rice supplies, including exports, with Bayer’s unapproved, herbicide-tolerant GE rice, LL601. Japan immediately suspends imports of US long-grain rice and orders testing of processed rice products that might contain it. Since Bayer stopped field-testing the rice in 2001, it has likely been in the rice seed supply, the food chain and/or the environment for 5 years or more.

August 2006 — EPA scientists announce that golf course grass (i.e. bentgrass) genetically engineered to withstand Monsanto’s Roundup herbicide escaped the test plot via pollen flow or seed dispersal to form viable plants up to 2.4 miles away. Bentgrass can cross-pollinate with many different grasses, and 175 permits authorizing cultivation of over 4,400 acres of GE bentgrass have been issued since 1993.

December 2004 — Biotech giant Syngenta reveals to U.S. authorities that it had mistakenly distributed an unapproved GE corn variety, Bt10, to U.S. farmers from 2001 to 2004. Enough Bt10 to plant 37,000 acres and produce 165,000 tons was distributed. The episode resulted in numerous rejected corn shipments to Japan and the EU. Bt10 remains unapproved by US regulatory authorities.

September 2004 — In the longest “gene flow” incident on record, genetically engineered bentgrass (see above) was found by EPA scientists to have cross-pollinated conventional grass up to 13 miles away in Oregon. The Forest Service and Nature Conservancy report that bentgrass can displace natural grass species in forest and native prairie settings. Herbicide-resistant bentgrass weeds created by such cross-pollination could also endanger the grass seed industry.

December 2003 — UC Davis researchers discover that, for seven years, they had been mistakenly distributing for research purposes GE tomato seed in place of a conventional variety.

July 2003 — Over 100 farmers in Italy discover that the non-GE corn seed they planted was contaminated with an unapproved GE variety.

May 2003 — Tests show that biotech crops have contaminated wheat grown in the US, even though GE wheat is not approved for marketing. Grain industry experts warn that approving GE wheat could mean the end of US exports to Europe and Asia.

September 2002 — An experimental corn variety genetically engineered as a “biofactory” for drug production, produced by ProdiGene, Inc. of Texas, contaminates corn and soybean fields in Iowa and Nebraska. 155 acres of corn is destroyed and 250,000 bushels of contaminated soybeans worth $3 million are quarantined at the elevator and destroyed.

April 2002 — Corn grown in Argentina and sold as corn flour in Europe is discovered contaminated with a GE variety that is not approved for planting in Argentina or for human consumption in Europe.

Sept 2001 – Scientists were surprised to discover GE crop material in wild maize in Oaxaca, Mexico despite the country’s moratorium on GE crop cultivation, in effect since 1998. It is thought that GE maize seed in food aid shipments from the US was saved and planted.

July 2001 – Austrian authorities order thousands of acres of corn destroyed when tests show contamination of non-GE seed by two unapproved GE corn varieties.

April 2001 — Just months after the StarLink fiasco, Monsanto is forced to recall thousands of bags of canola seed contaminated with a GE variety not approved for sale to Canada’s major export markets. Incineration is planned for over 10,000 acres of fields already planted with the unapproved crop.

September 2000 — Over 300 food products were recalled due to contamination by a GE corn (StarLink, produced by Aventis CropScience), not approved for human food due to concerns that it might trigger hazardous food allergies. Experts estimated that half of the state’s corn – about 1 billion bushels – could be contaminated. Exports of corn to Japan decreased by 44% in one year. StarLink contamination is still being discovered in US corn shipments three years later.

May 2000 — Nearly 15,000 acres of farmland in five European countries are contaminated with unapproved GE canola when pollen from the unapproved variety blows into a non-GE seed producers’ field. In addition, French authorities reveal that unapproved GE seeds have contaminated nearly 10,000 acres of corn planted there.

December 1997 — Unapproved GE sugar beet from a Monsanto test field is sent to a sugar refiner, where it contaminates natural sugar sold for animal feed.

May 1997 — Monsanto is forced to recall 60,000 bags of canola seed when it discovers the seed contains unapproved gene-altered DNA, due to contamination from a planting error by a seed producer. Indeed, contamination of conventional crops by GMO crops has been reported around the world. “There were 39 cases of crop contamination in 23 countries in 2007, and more than 200 in 57 countries over the last 10 years, according to GMO critic Greenpeace International.” “Contamination of corn is the biggest concern for those trying to sell biotech-free food. Corn is not only used in human food but is also used to feed livestock, meaning organic beef and dairy farmers must ensure their animals are fed corn that is free of contamination.” “That has become more difficult as biotech corn acres have expanded in the United States. In 2007, an estimated 73 percent of the 92.9 million acres of U.S. corn planted were biotech, according to the U.S. Department of Agriculture.” ⁷ Several countries have adopted strategies to reduce mixing, including a clear separation of the fields within which GMO crops and conventional crops are grown. Concerns about contamination are particularly strong when considering the pending implementation of the next phase of genetically engineered crops: plant-made pharmaceuticals. Also known as Pharm crops, this new development is the result of a breakthrough application of genetic engineering to plants. Scientists are using this technology to develop plants that produce therapeutic proteins that could ultimately be used by the medical community to combat life-threatening illnesses. In this process, plants themselves become "factories" that manufacture therapeutic proteins. These proteins are then extracted, refined and used in pharmaceutical production. Researchers are currently in various stages of field trials and clinical trials of PMP production. The challenge is containment. No one wants pharmaceuticals in their cornflakes. Back to top

Increased Weediness

One way of thinking generally about the environmental harm that genetically engineered plants might do is to consider that they might become weeds. Here, weeds means all plants in places where humans do not want them. The term covers everything from Johnson grass choking crops in fields to kudzu blanketing trees to melaleuca trees invading the Everglades. In each case, the plants are growing unaided by humans in places where they are having unwanted effects. In agriculture, weeds can severely inhibit crop yield. In unmanaged environments, like the Everglades, invading trees can displace natural flora and upset whole ecosystems. Some weeds result from the accidental introduction of alien plants, but many were the result of purposeful introductions for agricultural and horticultural purposes. Some of the plants intentionally introduced into the United States that have become serious weeds are Johnson grass, multi-flora rose, and kudzu. A new combination of traits produced as a result of genetic engineering might enable crops to thrive unaided in the environment in circumstances where they would then be considered new or worse weeds. One example would be a rice plant engineered to be salt-tolerant that escaped cultivation and invaded nearby marine estuaries. Back to top

Gene Transfer to Wild or Weedy Relatives

Novel genes placed in crops will not necessarily stay in agricultural fields. If relatives of the altered crops are growing near the field, the new gene can easily move via pollen into those plants. The new traits might confer on wild or weedy relatives of crop plants the ability to thrive in unwanted places, making them weeds as defined above. For example, a gene changing the oil composition of a crop might move into nearby weedy relatives in which the new oil composition would enable the seeds to survive the winter. Overwintering might allow the plant to become a weed or might intensify weedy properties it already possesses. Back to top

Change in Herbicide Use Patterns

Crops genetically engineered to be resistant to chemical herbicides are tightly linked to the use of particular chemical pesticides. Adoption of these crops could therefore lead to changes in the mix of chemical herbicides used across the country. To the extent that chemical herbicides differ in their environmental toxicity, these changing patterns could result in greater levels of environmental harm overall. In addition, widespread use of herbicide-tolerant crops could lead to the rapid evolution of resistance to herbicides in weeds, either as a result of increased exposure to the herbicide or as a result of the transfer of the herbicide trait to weedy relatives of crops. Again, since herbicides differ in their environmental harm, loss of some herbicides may be detrimental to the environment overall. Back to top

Squandering of Valuable Pest Susceptibility Genes

Many insects contain genes that render them susceptible to pesticides. Often these susceptibility genes predominate in natural populations of insects. These genes are a valuable natural resource because they allow pesticides to remain as effective pest-control tools. The more benign the pesticide, the more valuable the genes that make pests susceptible to it. Certain genetically engineered crops threaten the continued susceptibility of pests to one of nature's most valuable pesticides: the Bacillus thuringiensis or Bt toxin. These "Bt crops" are genetically engineered to contain a gene for the Bt toxin. Because the crops produce the toxin in most plant tissues throughout the life cycle of the plant, pests are constantly exposed to it. This continuous exposure selects for the rare resistance genes in the pest population and in time will render the Bt pesticide useless, unless specific measures are instituted to avoid the development of such resistance. Back to top

Poisoned Wildlife

Addition of foreign genes to plants could also have serious consequences for wildlife in a number of circumstances. For example, engineering crop plants, such as tobacco or rice, to produce plastics or pharmaceuticals could endanger mice or deer who consume crop debris left in the fields after harvesting. Fish that have been engineered to contain metal-sequestering proteins (such fish have been suggested as living pollution clean-up devices) could be harmful if consumed by other fish or animals i.e. bears, raccoons, etc... Back to top

Creation of New or Worse Viruses

One of the most common applications of genetic engineering is the production of virus-tolerant crops. Such crops are produced by engineering components of viruses into the plant genomes. For reasons not well understood, plants producing viral components on their own are resistant to subsequent infection by those viruses. Such plants, however, pose other risks of creating new or worse viruses through two mechanisms: recombination and transcapsidation. Recombination can occur between the plant-produced viral genes and closely related genes of incoming viruses. Such recombination may produce viruses that can infect a wider range of hosts or that may be more virulent than the parent viruses. Transcapsidation involves the encapsulation of the genetic material of one virus by the plant-produced viral proteins. Such hybrid viruses could transfer viral genetic material to a new host plant that it could not otherwise infect. Except in rare circumstances, this would be a one-time-only effect, because the viral genetic material carries no genes for the foreign proteins within which it was encapsulated and would not be able to produce a second generation of hybrid viruses. Back to top

Unknown Harms to the Environment

As with human health risks, it is unlikely that all potential harms to the environment have been identified. Each of the potential harms above is an answer to the question, "Well, what might go wrong?" The answer to that question depends on how well scientists understand the organism and the environment into which it is released. At this point, biology and ecology are too poorly understood to be certain that a question has been answered comprehensively and correctly. Back to top

Risk Assessment

Having identified a list of possible harms that might occur as a result of using or releasing genetically engineered organisms, the next question is how likely are any of these to occur? The answer to this question depends greatly on how well the GMO organisms and their interaction in the environment are understood. Risks must be assessed case by case as new applications of genetic engineering are introduced. To ensure new agriculture biotechnology products are safe for human and animal health and the environment, the US federal government reviews applications for approval based on a coordinated framework that involves three agencies. Under this system, three federal government agencies are responsible for oversight of products developed through biotechnology. The U.S. Government agencies responsible for oversight of the products of agricultural biotechnology are the U.S. Department of Agriculture's Animal and Plant Health Inspection Service (USDA-APHIS), the U.S. Environmental Protection Agency (EPA), and the Department of Health and Human Services' Food and Drug Administration (FDA). Depending on the characteristics of a particular GMO product, it may be subject to review by one or more of these agencies. The quality of the review is complicated by the fact that multiple agencies within each of these Departments have competing interests in the regulatory approval process. In its defense, government says the regulatory framework is well designed to protect consumers’ best interest. The reality is that it involves so many agencies and is so complex that it is difficult to believe that any of their outcomes are credible, and the complexity makes it possible for industry to manipulate the approvals process as they deem fit. In a 2006 public statement announcing the comprehensive, peer-reviewed study of federal regulation of GMOs (co-authored with William Freese, policy analyst for Friends of the Earth), Dr. David Schubert of the renowned Salk Institute described the disturbing conclusion of their evaluations:

"One thing that surprised us is that U.S. regulators rely almost exclusively on information provided by the biotech crop developer, and those data are not published in journals or subjected to peer review... The picture that emerges from our study of U.S. regulation of GM foods is a rubber-stamp 'approval process' designed to increase public confidence in, but not ensure the safety of, genetically engineered foods."

This and numerous other careful studies conclude that present federal oversight is insufficient to address the potential human health, environmental, and economic consequences of experimental genetically engineered crops. ⁸Back to top

Weak Government Oversight

In the waning months of the Bush Administration, the U.S. Department of Agriculture (USDA) released a proposal to completely overhaul its regulation of genetically engineered crops, significantly weakening its oversight. Officials of the Obama Administration are reviewing the proposal and seeking public comment in 2009. An advisory issued by the Center for Food Safety said:

“The proposed rules would virtually ensure that contamination of organic and conventional crops will become even more frequent, and even excuses the Agency from taking any action to remedy such contamination. The rules would continue to allow the dangerous practice of producing drugs and industrial chemicals in food crops grown in the open environment, and in many cases even allow the biotechnology industry to decide whether their GE crops are regulated at all.” “Over four years ago, USDA promised stricter oversight of genetically engineered crops; unfortunately, improvements considered early on have vanished and the regulations have instead become weaker. The proposed rule now has even more gaping holes than the regulations it is replacing, and creates a few new ones as well, resulting in more public exposure to untested and unlabeled genetically engineered foods. Instead of tightening controls to protect the public and the environment from contamination and harm, what USDA has offered further endangers your right to choose the foods you and your family eat and farmers’ right to their chosen livelihoods.” “To make matters worse, USDA published the rules before publishing the full Environmental Impact Statement (EIS), as required by law, and in the absence of public review of the data needed to make regulatory recommendations.”⁹

Clearly, there is something wrong with this picture. We call on the Obama Administration to reject the irresponsible "anything goes" GMO policy, and to put in place rules that will create real change in the regulation and oversight of GE crops. And we request a moratorium on commercial planting of any new GE crops until responsible, comprehensive regulations are in place. Back to top