Regarding: Genetic Engineering Technology and Certified Organic Livestock
Production and Processing Standards
This memorandum is a summary of facts and precedents pertaining to the use of
genetically modified organisms (GMOs) in organic food and fiber production.
1. In October, 1996, in Indianapolis, Indiana, the USDA National Organic
Standards Board ruled that the use of GMOs in organic production and
processing is prohibited. The GMO technological process and its products were
defined as " synthetic". The US Organic Foods Production Act calls for a
prohibition on synthetics unless they have been reviewed according to the
criteria in the Act. The petition to include GMOs was appropriately made and
recognized by the NOSB, who then rendered their unanimous decision to prohibit
.
2. Thereafter, state agencies in the US and private certification agencies in
the US and internationally moved to prohibit the use of GMOS if they had not
already done so.
3. The original list of proposed materials, substances and life forms that are
defined as genetically and or transgenetically modified has been expanded to
include a large number of such items that were formerlly considered "naturals"
according to the Act. They now include, but are not limited to, GMO plant
species such as glyphos resistant soybeans, Bt corn and cotton, GMO livestock
including aquatics, livestock feeds that contain GMO ingredients, such as GMO
cotton seed meal, soybean meal, alfalfa hay, corn and their byproducts when
used as feed supplements and vitamins. They include microbial soil amendments
and enhancers, legume inoculants, sugars, GMO rennets for cheese production
and cultures used in yogurt and other dairy products. The organic standard now
provides that any material or derivation can not have been sourced from GMO
raw products, been altered by genetic engineering or have come in contact with
them during processing.
4. Authoritative health and environmental reseach has not been conducted
appropriately to determine the negative affects on the environment and human
and livestock health by GMO products even though they are planted on millions
of acres and are now found abundantly in conventional food and livestock
feeds. Within the past two years, growing scientific evidence indicates that,
at the very least, a field production moratorium be imposed and require point-
of-purchase labeling for consumers, included on the ingredient panel. Much
anecdotal field observation from farmers also indicates that the claimed
production benefits and negligible affects on the environment are not entirely
valid.
5. Among the many substantiated findings in the field and analytical
laboratories are the following: that unintended mortality from non-target
insect species has been observed in GMO potato production, that laboratory
animals that ingested GMO agricultural products were biologically injured,
that "genetic drift" has been identified in GMO rape seed and corn production,
that cotton production has been severely affected leading to litigation by
farmers in many US states against the manufacturer and supplier of the seed
for the cotton. That because of the use of Bacilus thuringiensis-modified
cotton and corn varieties, rapid Bt resistance to European cornborer and
cotton bollworm is now suspected, that glyphos-resistant weed species are now
identified in those growing areas of the US midwest where the glyphos-
resistant soybean crops have been planted for a number of years.
6. This latter development may lead to the prolonged use of materials
identified as restricted or scheduled for phase-out, and/or the introduction
of new herbicides on an emergency basis, for which environmental evaluation
may be foreshortened. The same can be said for newly-resistant insects which
were at one time susceptible to the topical use of Bacillus thuringiensis. A
broad coaltion of concerned environmentalists and organic farmers filed suit
in February, 1999 against EPA in order to halt the planting of Bt altered
crops in order to guard the continued effectiveness of the product, which is
used by organic and conventional farmers. Government, researchers,
conventional farm officials and industry responded tardily to the prospect of
Bt resistance by suggesting that refuges be planted to guard against such
resistance. Many entomolgists consider that after the 1999 planting season
this effort will be moot.
7. Market access for GMO raw products and ingredients is severely affected by
consumer concerns in Japan, the UK and the EU, and building within the US.
Proposed mandatory labeling of GMOs in consumer goods has now been overtaken
by private sector initatives to either label or prohbit the use of GMO
consumer products. These initatives are now in place within the mainstream
retail sector in the UK and France. WTO may in the end force member states to
accept these products, but consumers have shown in some cases a nation-wide
unwillingness to take at face value the safety claims made by the supply
sector and regulators. These concerns are not limited to the "second wave" of
GMOs in grains and horticulture, but are historical, as observed in the
longstanding prohbitions on meat products where GMO-derived hormones were used
and in rBGH dairy. Health Canada recently prohibited rBGH in dairy production.
8. Organic certification is a systems-based quality assurance program and
process which utilizes laboratory analysis normally in the event when
synthetic contamination of soil or the product is suspected. However, due to
the nature of the absolute prohibitions on GMOS in organic products as well as
suppliers making claims that products are "GMO-free" , laboratory-based GMO
analysis is becoming more commonplace. One result of the concern has lead
organic farmers to seek crop insurance against "genetic drift" or
contamination and to more carefully monitor neighboring land use.
Contamination concerns have provoked agricultural authorities in Spain to
require that GMO agricultural suppliers fund actuarial programs in order to
create a liability protocol, in the event that the environmental guarantees
made by the suppliers and government regulators are indicated otherwise in the
field.
I am glad to be able to respond to your recent inquiries. Please contact me if
I can provide any further information.
Steve Sprinkel
Austin, Texas
512-326-3222
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