Trader Joe's spokesman went on to say, "This documentation is in the form of affidavits, identity-preserved certification of seed stock, and third-party lab results from testing of the ingredients in question." Then, not unlike the US Department of Agriculture, Trader Joe's uses an outside, third-party lab to audit random items with suspect ingredients. For foods to be certified as organic, USDA requires test samples from around five percent of products and they all must be GMO-free. The agency relies on sworn statements for the other 95 percent. Clif Bar & Company requires affidavits from suppliers as well to demonstrate that they are meeting the company's non-GMO provisions. So the "burdensome" argument made by the industry for labeling comes down to adding another line of ink to a label, something that is done quite often for advertising purposes and with no discernible expense to the consumer.
The "opinion and analysis" is full of opinion that has not been analyzed, at least outside of industry. It complains that "Labeling might cause consumers not to choose GM foods, and, as happened in the EU, most major retailers removed GM ingredients from products under their brands, and today it is almost impossible to find GMOs in European supermarkets." That surely would be a sad consequence--from a certain perspective.FDA has tested all the GMOs?
The anonymous editorial board made this statement: "The U.S. Food and Drug Administration has tested all the GMOs on the market to determine whether they are toxic or allergenic. They are not." No wonder the editorial went unsigned. Note to the editorial board: FDA does not test GMOs. It trusts industry for that.
Stacy Malkan, former director of California's failed ballot initiative to label foods containing GMO ingredients, told the New York Daily News, "Saying the FDA has tested all the GMOs on the market is patently false. Each individual company is responsible for testing its own products, and they then decide if they want to voluntarily report it to FDA. But they aren't required to test or report."
Here is the basis for Malkan's words. From testimony before the Subcommittee on Basic Research, House Committee on Science, October 19, 1999, James H. Maryanski, Ph.D., Biotechnology Coordinator, Center for Food Safety and Applied Nutrition for FDA, stated, "Bioengineered foods and food ingredients (including food additives) must adhere to the same standards of safety under the Act that apply to their conventional counterparts. This means that these products must be as safe as the traditional foods on the market." FDA mainly relies, he said, on two sections of the Federal Food, Drug, and Cosmetic Act (FD&C or the Act) to ensure the safety of foods and food ingredients.
- First, FDA has the power to remove a food from the market if the food poses a risk to public health. Okay, first show harm, then FDA might act. If FDA is so inclined.
- Second, under another section of the Act, FDA has authority over substances intentionally added to foods--food additives--unless those substances are generally recognized as safe (GRAS)--so, again, as long as people aren't getting sick, or if they are and it hasn't been connected to the additive, everything's cool.
Maryanski elaborated, "[A] substance that would be a food additive if it were added during traditional food manufacture is also treated as a food additive if it is introduced into food through genetic modification of a food crop. For example, a novel sweetener bioengineered into food would likely require premarket approval." So, it seems that a genetically modified sweetener would require premarket approval, does it not? Not so fast. "Generally, under Agency policy, substances intentionally introduced into food that would be reviewed as food additives include those that have unusual chemical functions, have unknown toxicity, or would be new major dietary components of the food.
"In our experience to date," he continued, "we have not seen substances of that type. The substances intentionally added to food via biotechnology to date have been well-characterized proteins, fats, and carbohydrates, and are functionally very similar to other proteins, fats, and carbohydrates that are commonly and safely consumed in the diet and so will be presumptively generally recognized as safe." Oh, okay, so even though these genetically modified molecules have never before been seen on earth, they look like--and are assumed to be "functionally very similar to"--other proteins, fats, and carbohydrates, so they must be all right. It sounds like what can happen to a duck flying over a pond one fine fall day. He looks down and sees a mallard-duck-colored and mallard-duck-shaped object floating on the water's surface. It is functionally very similar to all the other ducks he's ever seen and so of course it must be another duck, and he starts descending toward the decoy ...
Perhaps unsurprisingly, to the chemical companies who will control what farmers grow, what we eat, and what monies are exchanged throughout, this is not enough; they want it both ways. These never-before-seen substances that are identical to and do not differ from other macronutrients, are at the same time unique enough to be patented. They are identical; they merit patents. Which are you beholding--the faces or the vase? Because it matters. Herein a lesson in adjusting for cognitive dissonance.Conventional crops need more water and pesticides?
Your board of editors says, "[C]onventional crops often require more water and pesticides than GMOs do". Have they examined any evidence to support those claims? There is more about this below.The Article
In the article, titled, "Are Engineered Foods Evil?", the author, David H. Freedman, wrote, "Despite overwhelming evidence that GM crops are safe to eat, the debate over their use continues to rage ..." (emphasis mine). Freedman proffers an odd notion of overwhelming evidence. From Maryanski's 1999 testimony: "[S]ubsequently, FDA established an informal process by which firms can inform the Agency that they have completed a food or safety assessment" (emphases mine). Indeed it is almost entirely up to industry to test their genetically modified products, and having done so whether they wish to report to FDA their results.
Interestingly, in the August 13, 2009, issue of Scientific American, an article titled, "Do Seed Companies Control GM Crop Research?" by the editors, those editors (apparently not the present, anonymous ones) state, "Unfortunately, it is impossible to verify that genetically modified crops perform as advertised. That is because agritech companies have given themselves veto power over the work of independent researchers." Before buying GMO seeds, customers must sign an agreement that specifies what can be done with them, and independent research is prominently in that list. Scientists cannot test seeds under different conditions, such as drought, to see how they perform; they cannot compare seeds from one company with those of another; and they cannot investigate whether GMO crops produce unintended environmental effects.
Freedman's article may not have been as blatantly pro-industry as the editorial but it was its equal in lack of scrutiny. He covered a few points and even raises some tentative questions but finally advocates what he calls a middle ground, which middle ground consists solely of better testing, even though it would "pose a burden for GM researchers" and "slow down the introduction of new crops."
Freedman also left a heck of a lot out of his article, and what he did not say revealed either appalling incompleteness or blatant disingenuousness. Here are some points that were not in his article.