Position Statement on Genetic Engineering in Agriculture

Preamble

The Ecological Farming Association has serious concerns that the development and release of Genetically Engineered (GE) crops around the world has rapidly progressed with inadequate government oversight, scant independent health and environmental safety testing, and minimal public debate. We believe that food security and the economic viability of farming are best achieved through the application of ecological principles and the adoption of policies that benefit all participants in the food system. We call for the development of government agricultural policies that reflect a commitment to innovation in ecologically, socially, and economically sustainable agriculture.

The decisions that we make now about genetic engineering in food crops will have permanent consequences on our food production capacity, putting us at a crossroads in terms of the agricultural legacy that we will leave behind for our children and grandchildren. Extensive public participation in government deliberations about the future direction of our food systems and a transparent decision-making process are essential in making policy decisions about food and agriculture. The Ecological Farming Association intends this Position Statement on Genetic Engineering in Agriculture to be used as a platform for education and debate about this important issue.

Genetic Engineering is not ecological (or organic) farming

One of the primary tenets of ecological farming is to reduce or eliminate the use of toxic pesticides. As currently practiced, genetic engineering contravenes ecological farming practices by relying upon costly and toxic farm chemicals sold under a regime of seed patents that prevent the traditional practice of saving seeds. Current GE applications include crops designed to withstand high doses of pesticides or to contain pesticides within every cell. This system of agriculture perpetuates pesticide-dependent farming and pollutes ecological systems on the farm and in surrounding communities.

GE “herbicide tolerant” crops allow farmers to spray fields with herbicides, thus killing all plant life except the income crop. Peer-reviewed studies have found that the use of broad spectrum chemicals such as glyphosate-based Roundup, the herbicide most often used with GE crops, pose hazards to non-target species, mostly notably beneficial insects.ⁱ A peer-reviewed study also found that glyphosate (and Roundup) is toxic to human placental cells and can disrupt hormonal functions at doses lower than those used in farming.ⁱⁱ Glyphosate is also toxic to wildlife, especially to many species of amphibians. ⁱⁱⁱ

GE Bt (Bacillus thurengiensis) crops contain the Bt bacteria in each cell throughout the plant's life cycle. Scientists have become concerned about the emergence of insect resistance to Bt, which is being seen in laboratories and is expected to follow into the field.^iv The emergence of herbicide resistant insects will likely result in increased pesticide spraying to depress the pests that the GE Bt crops cannot control. Currently, limited applications of non-genetically inserted Bacillus thurengiensis are a natural and important tool for organic farmers. Accelerated pest resistance to Bt could weaken its effectiveness in non-GE farming systems. ^v

Finally, GE crops are being researched and synthesized by the same chemical companies that have been the producers of chemicals such as DDT, Agent Orange, PCBs, and many other persistent and toxic chemicals that are now banned in many parts of the world. As both seed producers and pesticide manufacturers, these GE companies aim to increase profits by creating the next generation of chemical-intensive agriculture – the antithesis of ecological farming.

Genetic Engineering threatens health

Long-term health studies on the effects of eating GE foods have not been conducted nor have they been mandated by the U.S. Food and Drug Administration (FDA) prior to approval of any GE crop (see “GE crops are inadequately regulated,” below). Market approval of GE crops is based exclusively upon research conducted by the GE industry. Their research is not fully evaluated by the FDA or peer reviewed by independent, non-industry funded scientists. GE foods are not labeled and, therefore, there is virtually no way for scientists to identify the exposed population or to test the health effects of routinely eating the GE foods now on the market. No system exists for tracking or reporting health problems that may result from exposure to GE organisms.

Despite the absence of mandated GE food safety testing, researchers have identified the following significant health risks associated with GE:

• Contamination of our food supply with unapproved GE drugs—Currently, GE drugs and vaccines not approved for human or animal use are inserted into food crops as a method for manufacturing drugs. These “pharma” crops are grown in the open air without containment and can therefore cross-pollinate with food grown in neighboring fields. Accidental mixing of GE experimental drugs with food crops in the field and after harvest poses a formidable health threat. Although substantial public opposition exists to the manufacture of GE drugs in food crops,^vi seed companies continue this practice because it offers a cheap way to make drugs. The Ventria seed company presently grows GE pharma rice containing synthesized antibiotic proteins ^vii similar to those found in breast milk, saliva, and human tears. ProdiGene uses corn to produce experimental veterinary vaccines to prevent pig diarrhea and other health problems.^viii In two documented instances to date, ProdiGene pharma crops contaminated food crops destined for the food supply (see Contamination section below).
  
• Creation of new allergens in food and allergic reactions—New allergens can be unknowingly synthesized when combining the genes of unrelated organisms. For instance, when researchers engineered a harmless bean protein into pea plants, they found that the GE version of the bean protein unexpectedly caused lung inflammation in laboratory mice.^ix In another experiment, a protein from a known allergen, the Brazil nut, was engineered into a soybean to improve its nutritional quality. Human subjects given small doses of the GE soybean exhibited allergic reactions, indicating that food allergens were transferred between foods via the GE process.^x Currently, genes from non-food plants, animals, viruses, and bacteria genes are being inserted into crops. The function of the genes is to provide instructions for building proteins; however, the allergenicity of most of the proteins being created by the inserted genes remains unstudied, and it will be difficult to avoid the insertion of allergenic proteins into GE Foods.^xi Consumers have no mechanism for avoiding the ingestion of potential allergens in GE foods because labeling of GE ingredients is not required.
  
• Heightened cancer risks and exposure to carcinogens—When the GE hormone, rBGH, is injected into dairy cows to increase milk production it also elevates IGF-1 hormone levels in the cow’s milk. The IGF-1 hormone mostly survives the digestion process intact and, when present in the bloodstream in significant quantities, is associated with increases in breast, prostate, lung, colon, and other cancers. ^xii Canada, Japan, Australia, New Zealand, and all 25 nations of the European Union have banned rBGH due to human or animal health concerns. The US has not followed suit. Subsequently, untold gallons of US milk containing added hormones and possible carcinogens are sold unbeknownst to consumers because no labeling requirements exist for rBGH.
  
• Development of persistent and debilitating health problems—Rhinitis, asthma, skin rashes, adverse gut reactions, and the production of intestinal antibodies to stave off toxins have been known to develop in response to exposure to the toxic soil bacteria, Bt, ^xiii the trait most often genetically engineered into plants to fight pests. Individuals with preexisting allergies or compromised immune systems may be the most susceptible to Bt toxins.^xiv To date, no health studies on the implications of long-term consumption of foods containing Bt have been conducted.
  
• Unpredictable, unintended, cumulative, additive, synergistic, and latent effects—Attempts to assess the potential adverse health effects of eating GE foods are complicated by the fact that multiple and inadvertent changes can occur in food once it is genetically engineered. These changes include increases in the levels of naturally existing toxins, the creation of new toxins, or the stimulation of the production of as-yet undiscovered allergens. While GE can switch off genes that produce toxins and allergens, it can also inadvertently turn on the genes that produce toxins and allergens. Additionally, the mechanisms for turning on and off genes are poorly understood.^xv This means that the health risks of eating multiple GE foods over time is unknown and difficult to predict, particularly since the onset of health problems may be delayed until the toxin or allergen accumulates to a level that triggers an adverse bodily reaction.

Genetic Engineering threatens certified organic farming

Food labeled “organic” cannot include GE ingredients of any kind, in accordance with USDA organic regulations enforced by its deputized organic certification agencies. Organic farming standards and labeling requirements protect the rights of farmers and consumers to choose how their food is grown and to make informed choices about the food that they consume.

In California, the organic foods industry has remained one of the fastest growing agriculture sectors. Retail sales of organic food have grown between 20% and 25% per year for the past six years.^xvi GE contamination threatens the viability of this thriving industry. Scientists agree that GE seeds and pollen can migrate beyond the farms on which they are grown, and subsequent contamination of organic crops by GE pollen can result in the loss of markets for organic growers and the loss of consumer confidence in organic foods. Once released into the environment, GE organisms cannot be recalled. ^xvii

Genetic Engineering is not traditional plant breeding

GE represents an unprecedented departure from traditional plant breeding by creating novel organisms through the insertion of genetic material (DNA) of one species into the living cells of a totally unrelated species. The resultant plant, tree, animal or insect is genetically altered in a way that could have never happened in nature or through traditional breeding. These genetically altered organisms will pass on the genetic changes to offspring with unpredictable consequences on human and ecological systems.^xviii Food that has been genetically engineered includes pigs with roundworm genes, potatoes with bacteria genes, tomatoes with fish genes, and corn with pesticide bacteria.

Traditional plant breeding, in contrast, relies upon vertical inheritance within a species — different males and females of one species are bred for different offspring outcomes. These species share a common evolutionary history and the breeding replicates a process that can occur in nature. Since GE represents a fundamentally different technology than traditional breeding it should be acknowledged and treated as such. Society must proceed with caution in the development and widespread use of GE until independent, non-industry funded, scientific studies can thoroughly evaluate the ecological and human consequences of instituting such radical changes in seed production.

Genetically Engineered crops are inadequately regulated

The first GE crops reached US markets in 1994 with no government mandated monitoring, testing, and inspection. In fact, the laws that govern Genetic Engineering predate the introduction of the technology and have yet to be updated to reflect the regulatory rigorousness required to understand the safety of new GE plant varieties. The FDA’s Substantial Equivalence standard requires that GE foods be analyzed for the presence of a few nutritional components such as essential vitamins and minerals, fatty acids, carbohydrates, proteins, and a handful of known allergens. The standard does not require testing for the presence of potential toxins, mutagens, carcinogens, or new allergens created during the production of GE foods. The Agency has not addressed the question of when and even whether GE foods are fit for human consumption. GE manufacturers are not required to demonstrate the safety of GE crops in order to get FDA approval, and they are held to a less stringent standard than foods containing additives, food colors, sweeteners, and preservatives. GE companies participate in voluntary safety consultations with the FDA. However, they are asked to submit only the summaries of their in-house assessments and not complete safety testing data.

Gaps in GE regulation and monitoring exist at every stage of production. Labeling of GE seeds and rootstock is also not required. Farmers planting GE crops are not obliged to notify their neighbors of their intent to plant GE crops. Public access to such information is difficult, if not impossible to obtain. Farmers have no recourse if their crop is contaminated with GE pollen or seeds because there are no established liability laws to compensate growers. No monitoring, testing or labeling requirements exist yet for GE foods grown in the US or imported to the US.

A USDA internal audit report released in December 2005 concluded that the USDA does not know the exact locations of field test plots that it permits or the harmful ecosystem effects that may have been discovered during field experiments. The Agency also lacks basic information about any methods used by experimenters to prevent GE pollen and seeds from migrating offsite and persisting in the environment. Auditors found GE test crop residues, including crops containing unapproved GE drugs, growing in a test field months after the crop was harvested, providing an opportunity for animals and the elements to scatter seeds beyond the designated field site.^xix

Since the location of most GE field tests remains confidential, people can unknowingly be exposed to unapproved GE pollen or unknowingly eat GE experimental food grown from GE seeds that have migrated off site. GE foods are not labeled. Therefore, there is virtually no way for scientists to identify exposed populations or to test the health effects of routinely eating the GE foods now on the market. Additionally, there is yet no system for tracking or reporting health problems that may result from exposure to GE organisms. Society must proceed with caution in the development and widespread use of GE until independent, non-industry funded, scientific studies can thoroughly evaluate the environmental and human consequences of instituting such radical changes in seed production.

Conflicts of interest abound between the GE industry, government, and universities

Inadequate government regulation and oversight of the GE industry is emblematic of the even more serious problem of a revolving door of personnel between the government and the GE industry. For example, several former employees of Monsanto—patent holder of ninety percent of the world’s GE seeds—joined the FDA to manage its GE regulatory and safety testing programs. In one instance, the lawyer who developed Monsanto’s legal statement on the GE dairy cow growth hormone, rBGH, joined the USDA to draft its rBGH labeling guidelines. FDA guidelines subsequently stipulated that no safety claims could be made to accompany the “rBGH-free” labels used by milk producers, users, and the organic industry, even though the hormone is associated with increases in cancer. During internal USDA debates about rBGH regulations, senior scientist, Richard Burroughs, was fired for insisting upon rBGH health testing.^xx

In another revolving door case, Ann Veneman, USDA Deputy Secretary during the first Bush administration, left her job to work at the DC-based law firm, Patton, Boggs, and Blow, representing agribusiness clients such as Dole Foods. At that time, Veneman also served on the Board of Directors of Calgene, now Monsanto, producer of the first GE food sold in the US, the Flavr Savr tomato. Veneman returned to DC as the USDA Secretary, under the second Bush administration, and used the opportunity to showcase US Genetic Engineering technology. She organized a meeting of agriculture ministers from 180 countries for the expressed purpose of forging global markets in GE seed and food trade.

Conflicts of interest are also plaguing universities where individual scientists, research laboratories, and entire departments have become some of the GE industry’s biggest benefactors. When the GE seed company Ventria wanted to grow pharma rice crops in Missouri, it offered to build and equip a $30 million “Center of Excellence in Plant-Made Pharmaceuticals” at the state’s Northwest campus. Ventria offered Northwest Missouri State a 4% share in Ventria for making the deal and invited university President, Dean Hubbard, to join its Board. The company withdrew the offer and relocated to North Carolina after Anheuser-Busch threatened to stop buying Missouri’s rice if the state grew GE pharma rice.^xxi

GE industry-funded scientists often work to discredit the research of colleagues who cast doubt upon the industry’s safety claims. A notable example of this occurred when UC Berkeley denied tenure to microbial ecologist, Ignacio Chapela, largely due to his vocal criticism of GE-industry funded university research, including the $25 million contract that his department signed with GE seed developer, Novartis. ^xxii Over a year of public debate and protest prompted a review of his case and resulted in the university overturning its decision and granting Chapela tenure.^xxiii As corporate interests increasingly permeate government and universities, fewer and fewer independent, non-industry funded scientists have the financial capability to conduct research in the public interest that ensures the safety of technologies used in our food system.

Genetic Engineering contamination is widespread

Wide agreement exists among scientists that GE organisms inevitably move beyond their intended destination on the farm. Once released into the environment, GE organisms cannot be recalled.^xxiv To date, 113 incidents of contamination have been publicly reported internationally. Nineteen of these incidents took place in the US.^xxv Most notably, a GE corn variety -not approved for human consumption because it contained a possible human allergen- contaminated taco shells sold at supermarkets nationwide. This prompted massive recalls. Traces of this corn variety, called StarLink, which was planted as animal feed, continued to appear in the human food supply for several years.^xxvi In another case, the USDA found ProdiGene’s GE pharma corn, with a gene inserted to produce a pig vaccine, growing in a commercial soybean field. Apparently, the GE pharma corn sprouted from seeds left in the field from the previous season’s field test. Contamination was discovered only after farmers harvested the soybean crop and mixed it with 500,000 bushels of soybeans. In a separate incident, a field of ProdiGene’s pig-drug corn was found growing in close proximity to neighboring corn fields destined for human consumption. This prompted the USDA to order the destruction of over 150 acres of corn.^xxvii

As this situation illustrates, the combination of inadequate regulation and relative ease of contamination puts consumers at risk. This is especially worrisome when GE drugs, vaccines, and industrial chemicals are produced in food crops and in open fields. GE contamination also puts organic and conventional farmers at risk because they depend upon the availability of pure seed and the premium price they receive in the marketplace for growing non-GE contaminated crops. No established liability laws currently protect and compensate farmers and gardeners for GE contamination.

Genetic Engineering will not end world hunger

Government and industry often claim that GE crops are needed to feed an expanding global population. Yet, the GE industry has advanced genetic developments primarily in corn and soy, two crops so over-produced that growers are dependent upon US government subsidy payments to make profits. This situation clearly raises doubts about the motives of the GE industry. Industrial farming, in which GE plays an increasing role, supports the overproduction of crops like corn and soy while hunger grows across the US and the rest of the world. It can be argued that overproduction has led to the increasing impoverishment of rural America with the loss of four million US farms over the last 50 years, an average of 219 farms per day. Ironically, America’s farming communities now suffer some of the highest rates of hunger and poverty in the nation.^xxviii

GE crops will not end hunger because the root cause of hunger is not lack of food. The world currently produces enough food for everyone on earth to consume a healthy diet. Hunger results from the inability of poor people to buy food and to access the land and resources needed to grow their own food.^{xxix xxx} GE will not help poor farmers grow more food because they simply cannot afford to pay for costly seeds, required chemicals, nor the technology user fees.

Declaration of Action

In light of the compelling threats to ecological food systems, human health, and the environment, we recommend a halt to the approval, commercialization, or release of any new GE crops until the following measures are put into place:

• Long-term and thorough safety testing of GE crops is conducted by independent, non-GE industry funded, natural and social scientists with the expertise to study and report on all aspects of health and environmental safety
  
• Prohibition of GE drug and industrial material production in food crops and in open fields
  
• Strict containment requirements and protocols for all fields and laboratories where GE plants are grown and tested and full public disclosure of test plant types and locations
  
• Liability legislation to protect organic and conventional farmers and gardeners from contamination by GE organisms, where the financial costs of contamination are borne by the producer of genetically engineered seeds and, only if negligence is determined, by the grower of the genetically engineered crops
  
• The withdrawal of corporations’ and individuals’ legal rights to patent GE life forms and the reestablishment of farmers’ rights to save and replant seeds
  
• Labeling of GE food currently approved and on the market so consumers can choose whether they want to eat GE food. Likewise, labeling of GE seeds and root-stock, including those that are currently approved and on the market, enabling farmers and gardeners to choose whether or not they want to grow GE crops Protection of the rights of counties and states to make decisions to protect human and environmental health in their jurisdiction, including the regulation of GE crops.

Appendix

Ecological farming yields safe, healthful, and abundant food

Ecological farming is comprised of the world’s best methods for growing and sustaining the human food supply. By harnessing nature’s own processes, ecological farming builds healthy soils, encourages biological diversity in the field, and helps safeguard water quality and availability. Ecological farming practices foster the health of land, farm animals, and wildlife by growing crops without the use of synthetic fertilizers and pesticides, and by raising animals in humane conditions without the use of added hormones and antibiotics. In this thriving agriculture system, solar and wind energy as well as clean, renewable fuels bring power to farm operations and equipment.

Our vision of ecological farming encompasses the growing of abundant, safe, nutritious, flavorful, and diverse foods to sustain the world’s growing population. We support the rights of all people to save, share, and freely plant seeds and we reject the patenting of plant, animal, and human life. We believe that farmers and farm workers must be justly compensated and work in a safe, non-toxic environment. This vision embraces minimizing food miles between growers and consumers and facilitating universal access to fresh, affordable, healthful, and locally grown food.

Please contact us at: Ecological Farming Association 406 Main Street, Ste. 313 Watsonville, CA 95076 (831) 763-2111 www.eco-farm.org

References

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