[House Hearing, 114 Congress]
[From the U.S. Government Publishing Office]
EXAMINATION OF THE COSTS AND IMPACTS
OF MANDATORY BIOTECHNOLOGY
LABELING LAWS
=======================================================================
HEARING
BEFORE THE
COMMITTEE ON AGRICULTURE
HOUSE OF REPRESENTATIVES
ONE HUNDRED FOURTEENTH CONGRESS
FIRST SESSION
__________
MARCH 24, 2015
__________
Serial No. 114-6
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Printed for the use of the Committee on Agriculture
agriculture.house.gov
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COMMITTEE ON AGRICULTURE
K. MICHAEL CONAWAY, Texas, Chairman
RANDY NEUGEBAUER, Texas, COLLIN C. PETERSON, Minnesota,
Vice Chairman Ranking Minority Member
BOB GOODLATTE, Virginia DAVID SCOTT, Georgia
FRANK D. LUCAS, Oklahoma JIM COSTA, California
STEVE KING, Iowa TIMOTHY J. WALZ, Minnesota
MIKE ROGERS, Alabama MARCIA L. FUDGE, Ohio
GLENN THOMPSON, Pennsylvania JAMES P. McGOVERN, Massachusetts
BOB GIBBS, Ohio SUZAN K. DelBENE, Washington
AUSTIN SCOTT, Georgia FILEMON VELA, Texas
ERIC A. ``RICK'' CRAWFORD, Arkansas MICHELLE LUJAN GRISHAM, New Mexico
SCOTT DesJARLAIS, Tennessee ANN M. KUSTER, New Hampshire
CHRISTOPHER P. GIBSON, New York RICHARD M. NOLAN, Minnesota
VICKY HARTZLER, Missouri CHERI BUSTOS, Illinois
DAN BENISHEK, Michigan SEAN PATRICK MALONEY, New York
JEFF DENHAM, California ANN KIRKPATRICK, Arizona
DOUG LaMALFA, California PETE AGUILAR, California
RODNEY DAVIS, Illinois STACEY E. PLASKETT, Virgin Islands
TED S. YOHO, Florida ALMA S. ADAMS, North Carolina
JACKIE WALORSKI, Indiana GWEN GRAHAM, Florida
RICK W. ALLEN, Georgia BRAD ASHFORD, Nebraska
MIKE BOST, Illinois
DAVID ROUZER, North Carolina
RALPH LEE ABRAHAM, Louisiana
TOM EMMER, Minnesota
JOHN R. MOOLENAAR, Michigan
DAN NEWHOUSE, Washington
______
Scott C. Graves, Staff Director
Robert L. Larew, Minority Staff Director
(ii)
C O N T E N T S
----------
Page
Conaway, Hon. K. Michael, a Representative in Congress from
Texas, opening statement....................................... 1
Prepared statement........................................... 3
Submitted article............................................ 77
Davis, Hon. Rodney, a Representative in Congress from Illinois,
opening statement.............................................. 5
DelBene, Hon. Suzan K., a Representative in Congress from
Washington, opening statement.................................. 5
Kirkpatrick, Hon. Ann, a Representative in Congress from Arizona,
submitted letter............................................... 79
McGovern, Hon. James P., a Representative in Congress from
Massachusetts, submitted articles.............................. 71
Peterson, Hon. Collin C., a Representative in Congress from
Minnesota, opening statement................................... 4
Witnesses
Schmidt, David B., President and Chief Executive Officer,
International Food Information Council and Foundation,
Washington, D.C................................................ 6
Prepared statement........................................... 8
Fedoroff, Ph.D., Nina V., Senior Science Advisor, Olsson Frank
Weeda Terman Matz PC (OFW Law), Washington, D.C................ 17
Prepared statement........................................... 19
Supplementary material....................................... 85
Submitted questions.......................................... 88
Lidback, Joanna S., Owner, The Farm at Wheeler Mountain,
Westmore, VT; on behalf of Agri-Mark; National Council of
Farmer Cooperatives; National Milk Producers Federation........ 26
Prepared statement........................................... 27
Submitted question........................................... 91
Clarkson, Lynn, President and Founder, Clarkson Grain Company,
Inc., Cerro Gordo, IL.......................................... 31
Prepared statement........................................... 33
Submitted question........................................... 91
Dempsey, Jr., Thomas W., President and Chief Executive Officer,
Snack Food Association, Arlington, VA.......................... 34
Prepared statement........................................... 36
Submitted question........................................... 92
Policinski, Chris, President and Chief Executive Officer, Land O'
Lakes, Inc., Arden Hills, MN................................... 39
Prepared statement........................................... 41
Submitted question........................................... 94
Submitted Material
McGinty, Scott, President, Aurora Organic Dairy, submitted letter 87
EXAMINATION OF THE COSTS AND IMPACTS OF MANDATORY BIOTECHNOLOGY
LABELING LAWS
----------
TUESDAY, MARCH 24, 2015
House of Representatives,
Committee on Agriculture,
Washington, D.C.
The Committee met, pursuant to call, at 10 a.m., in Room
1300 of the Longworth House Office Building, Hon. K. Michael
Conaway [Chairman of the Committee] presiding.
Members present: Representatives Conaway, Neugebauer,
Lucas, Gibbs, Austin Scott of Georgia, Crawford, Gibson,
Hartzler, Benishek, Denham, LaMalfa, Davis, Yoho, Allen, Bost,
Rouzer, Abraham, Emmer, Moolenaar, Newhouse, Peterson, David
Scott of Georgia, Costa, Walz, McGovern, DelBene, Vela, Kuster,
Nolan, Bustos, Kirkpatrick, Aguilar, Plaskett, Adams, Graham,
and Ashford.
Staff present: Haley Graves, Jackie Barber, Jessica Carter,
John Goldberg, Mary Nowak, Mollie Wilken, Patricia Straughn,
Scott C. Graves, Ted Monoson, Faisal Siddiqui, John Konya,
Keith Jones, Liz Friedlander, and Nicole Scott.
OPENING STATEMENT OF HON. K. MICHAEL CONAWAY, A REPRESENTATIVE
IN CONGRESS FROM TEXAS
The Chairman. Good morning. I want to thank each of you for
being here today to discuss agricultural biotechnology.
Mankind has used biological technologies for more than
10,000 years to improve crops and livestock, to make useful
food products, such as bread and cheese, and to preserve dairy
products. When applied to plant breeding, these technologies
have led to the evolution of nearly every food product we
consume. These and other advances have enabled us to enjoy the
safest, highest-quality, most abundant and affordable supply of
food and fiber.
As our knowledge has increased, so has the speed and
precision in which we are able to harness natural capabilities
to improve the plants we cultivate. These new applications of
biotechnology have been available to American and international
consumers for nearly 3 decades. The safety of the technology
has been confirmed by the world's leading scientific and public
health organizations including the World Health Organization,
the National Academies of Science, the American Association for
the Advancement of Science, the American Medical Association,
and the Royal Society of Great Britain.
Many scientists and farmers are optimistic and enthusiastic
about the prospects of using scientific advances in
biotechnology. The careful and precise addition of one or a few
genes to a plant may make it more productive and nutritious,
more tolerant to environmental stresses such as drought, and
more resistant to disease and pests. These technologies can
likewise improve the efficiency and therefore the productivity
of agriculture, while at the same time reducing detrimental
effects on the environment.
This Committee has frequently reviewed these technologies.
We have reviewed the regulatory mechanisms in place since the
Reagan Administration and have been repeatedly assured by the
absence of any valid concerns regarding the safety or quality
of products derived from these production methodologies.
Despite the facts that are universally on the side of this
technology, we would have to search long and hard to find
another issue matching the negative rhetoric and aggressive
tactics of the detractors. In Washington and across the
country, we are hearing a great deal of misinformation about
so-called GMOs and the use of biotechnology in food and
agricultural production. These unfounded attacks are not
supported by the facts and mislead both consumers and
policymakers. This misinformation would threaten our farmers'
ability to feed an ever-growing population and result in higher
food costs for consumers.
Biotechnology is an essential tool for farmers to have in
the toolbox if we plan to feed an estimated ten billion people
by the year 2050 in an environmentally sound, sustainable, and
affordable way. Unfortunately, threats exist to our ability to
fully utilize this technology in the form of proposed Federal
and state laws, as well as some state laws that will soon be
implemented if we don't act.
A recent report by the Cornell Business School examined the
consumer cost impact of a proposed mandatory label for
biotechnology food products sold in the State of New York.
According to the study, implementing a mandatory biotech
labeling system in the state would mean new costs for consumers
in the checkout aisle. The report finds that a family of four
in New York could pay on average an additional $500 in annual
food costs if mandatory labeling becomes the law. The state
would also incur an estimated $1.6 million in costs from the
writing and enforcing of new regulations and litigating
potential lawsuits related to mandatory labeling, which could
run as high as $8 million and will also factor into the
increased costs consumers see in their annual food bills. What
this report does not reflect is the significant cost to food
manufacturers associated with segregation and testing that
would be passed back to producers, nor does it address
liability costs borne by food processors and producers under
the activist scheme.
As of today 26 states have some form of biotech labeling
legislation pending. These proposals are loaded with arbitrary
and inconsistent policies which would create an unmanageable
situation for food producers, processors, and distributors.
Consumers would ultimately lose as a result both of higher food
costs and the very real likelihood that the technological
innovation that has filled our grocery stores with an abundance
of high-quality products we enjoy would be stifled. As we
examine the costs and impacts if states like Vermont move
forward with mandatory labeling schemes, I think we will agree
that Congressional action to preserve interstate commerce
through national uniformity is necessary.
Although I will introduce our panel in its entirety after
opening statements, I do want to take a moment to discuss one
of our witnesses. Ms. Joanna Lidback is a dairy farmer from the
State of Vermont and the author of a well-read blog on farming,
food, and rural issues. This is actually Ms. Lidback's second
appearance before the Agriculture Committee to discuss
biotechnology. I would be remiss if I didn't acknowledge
Joanna's courage in returning since some of you may be aware
that after her appearance last year, Joanna and her family were
the subject of harassment, interfering with her young family's
peace. I consider the tactics of anti-biotech activists who
harassed you reprehensible, and I want to stress that this
shameful behavior is not acceptable and should not be
tolerated.
Joanna, thank you for being here today and for your
dedication to this important issue.
[The prepared statement of Mr. Conaway follows:]
Prepared Statement of Hon. K. Michael Conaway, a Representative in
Congress from Texas
Good morning. I want to thank each of you for being here today to
discuss agricultural biotechnology.
Mankind has used biological technologies for more than 10,000 years
to improve crops and livestock, and to make useful food products, such
as bread and cheese, and to preserve dairy products. When applied to
plant breeding, these technologies have led to the evolution of nearly
every food product we consume. These and other advances have enabled us
to enjoy the safest, highest quality, most abundant and affordable
supply of food and fiber.
As our knowledge has increased, so has the speed and precision in
which we are able to harness natural capabilities to improve the plants
we cultivate.
These new applications of biotechnology have been available to
American and international consumers for nearly 3 decades. The safety
of the technology has been confirmed by the world's leading scientific
and public health organizations including the World Health
Organization, the National Academies of Science, the American
Association for the Advancement of Science, the American Medical
Association, and the Royal Society of Great Britain.
Many scientists and farmers are optimistic and enthusiastic about
the prospects of using scientific advances in biotechnology. The
careful and precise addition of one or a few genes to a plant may make
it more productive and nutritious, more tolerant to environmental
stresses such as drought, and more resistant to disease and pests.
These technologies can likewise improve the efficiency and therefore
the productivity of agriculture, while at the same time reducing
detrimental effects on the environment.
This Committee has frequently reviewed these technologies. We have
reviewed the regulatory mechanism in place since the Reagan
Administration and have been repeatedly assured by the absence of any
valid concerns regarding the safety or quality of products derived from
these production methodologies.
Despite the facts that are universally on the side of this
technology, we would have to search long and hard to find another issue
matching the negative rhetoric and aggressive tactics of the
detractors.
In Washington and across the country, we are hearing a great deal
of misinformation about so-called ``GMOs'' and the use of biotechnology
in food and agricultural production. These unfounded attacks are not
supported by the facts and mislead both consumers and policymakers.
This misinformation could threaten our farmers' ability to feed an
ever-growing population and result in higher food costs for consumers.
Biotechnology is an essential tool for farmers to have in the
toolbox if we plan to feed an estimated ten billion people by the year
2050 in an environmentally sound, sustainable, and affordable way.
Unfortunately, threats exist to our ability to fully utilize this
technology in the form of proposed Federal and state laws, as well as
some state laws that will soon be implemented if we don't act.
A recent report by the Cornell Business School examined the
consumer cost impact of a proposed mandatory label for biotech food
products sold in the State of New York. According to the study,
implementing a mandatory biotech labeling system in the state would
mean new costs for consumers in the checkout aisle. The report finds
that a family of four in New York State could pay, on average, an
additional $500 in annual food costs if mandatory labeling becomes law.
The state would also incur an estimated $1.6 million in costs from
writing and enforcing new regulations and litigating potential lawsuits
related to mandatory labeling, which could run as high as $8 million
and will also factor into the increased costs consumers see in their
annual food bills. What this report does not reflect is the significant
cost to food manufacturers associated with segregation and testing that
will be passed back to producers; nor does it address liability costs
borne by food producers and processors under the activist scheme.
As of today 26 states have some form of biotech labeling
legislation pending. These proposals are loaded with arbitrary and
inconsistent policies which would create an unmanageable situation for
food producers, processors and distributors. Consumers would ultimately
lose as a result both of higher food costs and the very real likelihood
that the technological innovation that has filled our grocery stores
with an abundance of high quality products we enjoy would be stifled.
As we examine the costs and impacts if states like Vermont move
forward with mandatory labeling schemes, I think we will all agree that
Congressional action to preserve interstate commerce through national
uniformity is necessary.
Although I will introduce our panel in its entirety after opening
statements, I do want to take a moment to discuss one of our witnesses
Ms. Joanna Lidback is a dairy farmer from the State of Vermont and
the author of a well-read blog on farming, food and rural issues. This
is actually Ms. Lidback's second appearance before the Agriculture
Committee to discuss biotechnology. I would be remiss if I didn't
acknowledge Joanna's courage in returning since some of you may be
aware that after her appearance last year, Joanna and her family were
the subject harassment, interfering with her young family's peace.
I consider the tactics of the anti-biotech activists who harassed
you reprehensible, and I want to stress that this shameful behavior is
not acceptable and should not be tolerated. Joanna, thank you for being
here today and for your dedication to this important issue.
The Chairman. And with that, I recognize the Ranking Member
for his statement.
OPENING STATEMENT OF HON. COLLIN C. PETERSON, A REPRESENTATIVE
IN CONGRESS FROM MINNESOTA
Mr. Peterson. Thank you, Mr. Chairman, and thanks for
holding this hearing. This is an issue that I hope that we can
find a way to address because if we don't, we are going to have
50 states with 50 different labeling programs, and that is just
not going to work. If we don't do something to stop this, we
could end up with something similar to what is going on right
now in California with their egg standards.
Consumers have expressed their interest in knowing more
about where their food comes from, and that is a good thing.
But when it comes to labeling, we need to be able to find a
smart way to balance this consumer demand, what we know about
the safety of the foods that our farmers produce. Done
correctly, I think we can find a workable solution.
The Energy and Commerce Committee has most of the
jurisdiction here, so at this point our hands are a little bit
tied. But I do think it is important for us to move forward and
learn more about the impacts some of these state attempts at
labeling genetically engineered food and food ingredients are
going to have.
So I look forward to hearing from our witnesses and thank
you for holding the hearing.
The Chairman. I thank the Ranking Member. I appreciate
that. I recognize Subcommittee Chairman Rodney Davis for his
statement.
OPENING STATEMENT OF HON. RODNEY DAVIS, A REPRESENTATIVE IN
CONGRESS FROM ILLINOIS
Mr. Davis. Thank you, Mr. Chairman, and thank you to all
the witnesses that are here today. And Mr. Chairman, thank you
for holding this hearing on the costs and impacts of the
mandatory biotech labeling laws. And I would like to welcome
one of my constituents who is on the panel, Mr. Lynn Clarkson.
I am very glad you are here representing the small town of
Cerro Gordo very, very well.
Clarkson Grain, your company, turned 40 just last year,
supplies grain to food manufacturing, animal feed industries.
His products include corn, whole grains, and non-GMO grains and
oilseeds. I appreciate your testimony about respecting all
viewpoints and lowering the temperature in this very heated
debate.
I have two distinct memories from the Subcommittee hearing
that I shared last year that Ms. Lidback was a part of. First
of all, we discussed the needs of biotechnology, and it helps
us feed a growing population, reduces negative impacts on our
environment, and also helps combat plant and pest diseases. But
the rhetoric, as Chairman Conaway said, became pretty charged
after the hearing. I was disappointed by this rhetoric and
misinformation and the personal attacks leveled not only at you
but to those who were part of the hearing, including me.
Thanks for coming back. I know you did receive some rude
comments and some bullying on social media, and I really
appreciate hearing your perspective as a dairy farmer, and as a
father of three children myself, I appreciate hearing your
perspective as a mother.
Last, on the right-to-know argument, consumers can already
find out information when they are at the grocery store. Food
that is labeled as USDA certified organic does not contained
genetically modified ingredients. I want to read something from
The New York Times editorial just a couple of years ago.
``Consumers can already find products free of GMO ingredients
with labels voluntarily placed by the manufacturers. For those
who want to avoid such ingredients, the surest way is to buy
products certified as organic under Federal standards.'' Now,
this is The New York Times, not necessarily a hotbed of
conservative rhetoric on their editorial board.
So with that, Mr. Chairman, I yield back.
The Chairman. The gentleman yields back. Thank you. I now
recognize the Ranking Member on the Subcommittee, Ms. DelBene,
for her statement.
OPENING STATEMENT OF HON. SUZAN K. DelBENE, A REPRESENTATIVE IN
CONGRESS FROM WASHINGTON
Ms. DelBene. Thank you, Mr. Chairman. I appreciate you
holding this hearing, and I want to thank all of the witnesses
for being here today.
As the Ranking Member on the Subcommittee, this is an issue
I hear about very often, not only here, but also in my district
back home in Washington State. In fact, Washington State was
among the states which recently voted on a GMO labeling
initiative, and one of the biggest takeaways for many of us
from that initiative, as well as this debate generally, is that
there needs to be more of a dialogue and more education done on
all sides.
I certainly agree that consumers have a right to know what
they are eating, and I also believe that we need to be clear
and take a science-based approach when we are discussing GMOs.
Just as many of us implore folks to look at the science behind
climate change, for example, we can't pick and choose. We need
to understand the science and its findings, including in this
case.
Genetically modified doesn't mean just one thing or just
one company, and as someone who started their career in
biomedical research, I understand that this technology has the
potential to provide benefits to consumers. However, we also
need to ensure that we are having an open conversation about
its impacts and its challenges. This is often an emotional
argument, and it is my hope that moving forward we can have it
be more of a fact-based open discussion on all sides.
I am looking forward to the testimony of our panel today
and am hopeful that we can move closer to a workable solution
as a result for everyone. So thank you again, Mr. Chairman, for
this hearing, and I yield back.
The Chairman. I thank the gentlewoman. The chair would
request that other Members submit their opening statements for
the record so that witnesses may begin their testimony and to
ensure there is ample time for questions.
I would now like to welcome to our witness table the
following witnesses: We have here Mr. David Schmidt, President
and CEO of the International Food Information Council here in
D.C. We have Dr. Nina Federoff, the Senior Science Advisor, OFW
Law Firm here in D.C. We have Ms. Joanna Lidback, owner of The
Farm at Wheeler Mountain, on behalf of Agri-Mark Dairy
Cooperative, the National Council of Farmer Cooperatives, and
the National Milk Producers Federation from Westmore, Vermont.
We have Mr. Lynn Clarkson, President, Clarkson Grain Company at
Cerro Gordo--is that close enough--Illinois. Mr. Thomas
Dempsey, CEO, Snack Food Association in Arlington, Virginia,
and Mr. Chris Policinski. I butchered that, Chris. Sorry about
that. President and CEO, Land O' Lakes in Arden Hills,
Minnesota.
Mr. Schmidt, begin when you are ready, please.
STATEMENT OF DAVID B. SCHMIDT, PRESIDENT AND CHIEF EXECUTIVE
OFFICER, INTERNATIONAL FOOD INFORMATION COUNCIL AND FOUNDATION,
WASHINGTON, D.C.
Mr. Schmidt. Thank you, Chairman Conway, distinguished
Members. I am David Schmidt, President and CEO of the
International Food Information Council and Foundation. We
effectively communicate science-based information on food
safety and nutrition issues to health professionals,
journalists, educators, government officials and consumers. We
are fortunate to receive support for our programs from leading
food, beverage, and agricultural companies, but I must clarify
that we don't represent those industries.
Last year, IFIC conducted the 2014 Consumer Perceptions of
Food Technology Survey. It was our 16th such survey since 1997.
The survey polled 1,000 adults who are reflective of the U.S.
population, according to the U.S. Census Bureau. Our survey
begins with open-ended questions, which are more reliable when
it comes to taking the real pulse of consumers than surveys
with a small number of carefully worded questions designed to
provoke concerns.
When it comes to food labels, the results show that
biotechnology, or even the phrase GMOs, is not a top-of-mind
concern for the vast majority of consumers. Following the open-
ended questions, we get more specific about biotechnology and
genetic engineering, but please note that we do not use the
term GMO for two major reasons. Number one, The U.S. FDA has
provided labeling guidance to industry, reaffirmed as recently
as April 2013, that the scientifically accurate terms are
bioengineered, genetically engineered, or foods produced using
biotechnology. Their analysis considers the term genetically
modified organism, or GMO, as potentially misleading to
consumers because it is a distinction without a difference. And
as you said, Mr. Chairman, humans have been genetically
modifying crops and animals for tens of thousands of years.
Number two, our own consumer research since the early 1990s
has found GMO, as a phrase, to be off-putting at best or even
frightening to many consumers. And unfortunately in today's
marketplace, it is used as something to avoid and a pejorative,
rather than a way to inform consumers.
When we first asked if people were avoiding any particular
foods or ingredients in their diet, only two percent of total
respondents mentioned biotech food or even similar terms like
GMOs. Then we asked them if they could think of any information
that currently is not on food labels but should be. Three-
quarters of them, 75 percent, said no. Just four percent said
that labels should carry information about genetic engineering
or related terms. Two-thirds of Americans said they were
confident in the safety of the food supply. When we asked
people about their specific food safety concerns, biotech or
any related term was far down the list at seven percent. When
we asked the respondents to offer their impressions of food
biotechnology before mentioning any benefits, there was an
almost-even split between 28 percent who were favorable and 29
percent unfavorable with more than four in ten either neutral
or didn't know.
The survey then asked about which sources of information on
food biotechnology consumers trust most. Health organizations,
cited by 50 percent of consumers ranked first, followed by
Federal Government agencies and health professionals at 45
percent each. We then focused on attitudes toward particular
benefits of food biotechnology.
Referring back to my point on language above, it is not
surprising that consumers may shy away when provoked to be
concerned about ``genetically modified organisms in your
food.'' But notice the difference in support when we use more
informative language to explain some of the benefits of the
technology. Seventy-two percent said they were likely to
purchase products made with oils modified by biotechnology to
provide more healthful fats. Sixty-nine percent were likely to
buy such products if they were modified to reduce the potential
for carcinogens, and 69 percent also said they would buy bread,
crackers, cookies, cereals, or pasta made with flour modified
to use less land, water, and/or pesticides.
Next, we returned to labeling issues and tried to get at
consumers' attitudes another way, by asking whether people
favored the current FDA policy regarding foods produced using
biotechnology. We told them the policy requires special
labeling only when biotechnology's use substantially changes
the food's nutritional content or when a potential safety issue
such as a food allergen is identified. Otherwise, special
labeling is not required. Sixty-three percent of respondents
supported the current FDA policy, while 19 percent opposed it.
In fact, every survey we have conducted since 1997 has found a
strong majority of Americans support this FDA labeling policy.
When we looked more generally at the most favored uses of
food biotechnology, reducing pesticide applications topped the
list, followed by keeping food prices stable and helping feed
undernourished people around the world.
Mr. Chairman, in closing, let me emphasize that in our
nearly 2 decades of consumer research, we have learned that
consumers are supportive of the many benefits of food and
agricultural biotechnology when clearly articulated. The food
label is not a playground for every bit of information someone
might want to know. We rely on the FDA to ensure that the
precious real estate available on a food label is reserved for
important health, ingredient, and nutrition information, and it
is clear that a strong majority of Americans have confidence in
the FDA's labeling policy for foods produced using
biotechnology. Thank you for this opportunity to share
consumers' perspectives.
[The prepared statement of Mr. Schmidt follows:]
Prepared Statement of David B. Schmidt, President and Chief Executive
Officer, International Food Information Council and Foundation,
Washington, D.C.
Chairman Conaway, distinguished Members, my name is David Schmidt,
and I'm President and CEO of the International Food Information
Council, or IFIC.
Our mission is to communicate science-based information on food
safety and nutrition issues to health professionals, journalists,
educators and government officials. We are fortunate to receive support
for our programs from leading food, beverage and agricultural
companies, but I must clarify that we don't represent those industries.
Thank you for inviting me to speak today regarding U.S. consumer
attitudes toward food biotechnology and related aspects, such as
labeling.
Last year, IFIC conducted the 2014 Consumer Perceptions of Food
Technology Survey (http://www.foodinsight.org/2014-foodtechsurvey). It
was our 16th such survey since 1997, and it has offered trended U.S.
consumer insights on plant and animal biotechnology and labeling longer
than any publicly available data.
Survey Methodology
Let me begin with the methodology, which can be found in the slides
that are included after my written remarks. The public can access the
full text of the survey's questions and answers, along with many other
educational resources, at foodinsight.org/biotech.
The 2014 IFIC Food Technology Survey polled 1,000 adults who are
reflective of the U.S. population, according to the U.S. Census Bureau,
and had just a three percent margin of error.
Our survey begins with open-ended questions, which are more
reliable when it comes to taking the real pulse of consumers than
surveys with a small number of carefully worded questions designed to
provoke concerns.
We believe this technique yields a more accurate view of what is
most important to Americans. Throughout 18 years of conducting this
research, we have not seen consumer perceptions about food
biotechnology change dramatically. When it comes to food labels, the
results show that biotechnology, or even ``GMOs,'' is not a top-of-mind
concern for the vast majority of consumers.
Following the open-ended questions, we get more specific about
biotechnology and genetic engineering, but please note that we do not
use the term ``GMO'' for two major reasons:
(1) The U.S. Food and Drug Administration (FDA) has provided
labeling guidance to industry, reaffirmed as recently as
April 2013, that the scientifically accurate terms are
``bioengineered,'' ``genetically engineered,'' or ``foods
produced using biotechnology.'' Their analysis considers
the term ``genetically modified organism'' or ``GMO'' as
potentially misleading to consumers, because it is a
distinction without a difference. Humans have been
genetically modifying crops and animals for tens of
thousands of years, but through far less precise or
efficient methods than we enjoy today.
(2) Our own consumer research since the early 1990s has found
``GMO'' to be off-putting at best or even frightening to
many consumers. And unfortunately in today's marketplace,
it is used as something to avoid and a pejorative, rather
than a way to inform consumers.
And now to the survey itself, and I would note that this is the
precise order in which the questions were posed.
Foods Avoided and Food Label Information
We first asked if people were avoiding any particular foods or
ingredients in their diet. Only 2 percent of total respondents
mentioned biotech food--or even similar terms like the aforementioned
``GMOs.''
Then we asked them if they could think of any information that
currently isn't on food labels but should be. Three-quarters said
``no.'' Out of the total sample, just four percent said that labels
should carry information about genetic engineering or related terms.
This is a number that has barely budged over the history of our survey.
Food Safety
Next was the topic of food safety. Two-thirds of Americans said
they were confident in the safety of the food supply. This number has
remained consistently high since 2008, which might come as a surprise
to some, given the tone and tenor of the rhetoric that surrounds us.
Only 13 percent said they're not confident, while 20 percent were
neutral.
When we asked people about their specific food safety concerns,
``biotech'' or any related term was far down the list at seven percent.
Remember, these questions are designed to reveal top-of-mind insights,
not to guide people to a desired outcome. That number, while small, has
indeed risen a few percentage points since 2008, which is undoubtedly a
reflection of the heated communications environment.
Conversely, the food safety threats that most concern consumers,
both today and in past surveys, revolve around diseases and
contamination, along with food handling and preparation--both of which
were mentioned by 18 percent of respondents. That was followed by 12
percent who cited preservatives and chemicals, and ten percent who
mentioned agriculture production issues.
General Impressions of Food Biotechnology
When we asked the respondents to offer their impressions of food
biotechnology (before mentioning any benefits), there was an almost
even split between 28 percent who were favorable to the technology and
29 percent who were unfavorable. More than four in ten were either
neutral or didn't know enough to offer a response.
Consumer Trust
As with much of our other consumer research, the 2014 IFIC Food
Technology Survey then asked about which sources of information on food
biotechnology consumers trust most.
Health organizations, cited by 50 percent of respondents ranked
first, followed by Federal Government agencies and health
professionals, at 45 percent each.
Farmers rated highly for 39 percent of respondents, while
scientists were among the most trusted sources of 33 percent.
At the other end of the spectrum, journalists, bloggers, and
celebrities were trusted by consumers only in the single digits.
Benefits of Food Biotechnology
At this point, we focused on attitudes toward particular benefits
of food biotechnology. When consumers became aware that some products
on the market or in the pipeline offered nutrition and health-related
benefits, they were overwhelmingly positive.
Referring back to my point on language above, it is not surprising
that consumers may shy away when provoked to be concerned about
``genetically modified organisms in your food.'' But notice the
difference in support when we use more informative language to explain
some of the benefits of the technology:
72 percent said they were likely to purchase products made
with oils modified by biotechnology to provide more healthful
fats.
69 percent were likely to buy such products if they were
modified to reduce the potential for carcinogens--the same
number who would buy products if they were modified to be
protected from insect damage and to require fewer pesticide
applications.
69 percent also said they would buy bread, crackers,
cookies, cereals, or pasta made with flour modified to use less
land, water, and/or pesticides.
The list goes on, with positive perceptions of foods modified to
provide enhanced nutritional benefits, eliminate trans fat content,
improve vitamin content, or taste better or fresher.
Current FDA Labeling Policy
Next, we returned to labeling issues and tried to get at consumers'
attitudes another way, by asking whether people favored the current FDA
policy regarding foods produced using biotechnology. We told them the
policy requires special labeling ``only when biotechnology's use
substantially changes the food's nutritional content, or when a
potential safety issue such as a food allergen is identified.
Otherwise, special labeling is not required.''
Sixty-three percent of respondents supported the current FDA
policy, while 19 percent opposed it. The number of those who are
opposed to the policy has risen a few points in recent years, while
support has remained mostly steady. In fact, every survey we have
conducted since 1997 has found a strong majority of Americans support
this FDA labeling policy.
Consumers' Favored Uses
When we looked more generally at the most favored uses of food
biotechnology, reducing pesticide applications topped the list,
followed by keeping food prices stable, and helping feed undernourished
people around the world.
Close behind those favored uses were food crops that can survive in
extreme climates, and the reduced use of nonrenewable resources in food
production.
Conclusion
Mr. Chairman, in closing, let me emphasize that in our nearly 2
decades of consumer research, we've learned that consumers are
supportive of the many benefits of food and agricultural biotechnology
when clearly articulated.
The food label is not a playground for every bit of information
someone might want to know. We rely on the FDA to ensure that the
precious real estate available on a food label is reserved for
important health, ingredient, and nutrition information, and it is
clear that a strong majority of Americans have confidence in the FDA's
labeling policy for foods produced using biotechnology.
The International Food Information Council would be pleased to
offer you or your staff any additional resources in support of my
testimony, as well as the work we do on food biotechnology and other
issues. Thank you once again for this opportunity.
Slides
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The Chairman. Thank you, Mr. Schmidt. Dr. Federoff?
STATEMENT OF NINA V. FEDOROFF, Ph.D., SENIOR SCIENCE ADVISOR,
OLSSON FRANK WEEDA TERMAN MATZ PC (OFW LAW), WASHINGTON, D.C.
Dr. Fedoroff. Chairman Conway, Representative Peterson,
Members of the Committee, thank you for the opportunity to
testify before you today. I am Nina Federoff. I am a Professor
of Plant Molecular Biology and Genetics. I have had 35 years of
experience with GM techniques. I am a member of the U.S.
National Academy of Sciences and a National Medal of Science
Laureate. I served as Science and Technology Adviser to
Secretaries of State Condoleeza Rice and Hillary Clinton. I
authored a book titled Mendel in the Kitchen: A Scientist's
View of Genetically Modified Foods.
I am here to tell you why mandatory labeling of foods
containing GM ingredients will not help Americans make
healthful food choices. More than that, I will tell you why
such labels could well undermine humanity's efforts to achieve
food security.
Now a recent poll, Pew poll, of scientists and the public
gave startling results: Only 37 percent of the public believes
GMOs are safe as compared with almost 90 percent of scientists.
So why are scientists convinced? GM crops have been in
commercial production for almost 20 years. They have an
impeccable safety record and multiple environmental benefits.
They have boosted farmers' incomes and reduced consumer prices.
These are the facts, and they have been documented in
independent studies referenced in my written testimony.
Scientific academies around the world concur that modern
methods of genetic modification are as safe as those used by
previous generations of plant and animal breeders.
Now, until the development of modern GM techniques,
breeders had to depend on either rare natural or more recently
induced mutations--that is just another term for genetic
modifications--to develop better crops. Today we know enough
about genes to introduce a desired trait into an already highly
productive plant or animal without the undesirable downsides of
older methods.
Now it is worth pointing out as the Chairman did that the
history of plant and animal genetic modification extends back
more than 10,000 years. We created corn, not Mother Nature. We
created big, luscious heirloom tomatoes. Mother Nature's are
tiny and can be deadly.
Now the FDA just approved Simplot's GM potato that won't
turn brown after you cut it, and more importantly, it contains
less of a natural amino acid that turns into the toxic compound
acrylamide when the potatoes are French fried in hot oil. These
potatoes will be more healthful and less wasteful. But today,
more than 60 percent of Americans believe that GMOs are unsafe
and probably wouldn't choose to buy them.
Now why is that? The reasons lie in the increasingly
strident efforts of determined anti-GMO activists to convince
the public that GMOs are bad. Some of these folks are--most
prominent among these are the NGOs, such as Greenpeace, and
marketers of organic foods. A recent, meticulously researched
organic marketing report documents how organic marketers have
progressively demonized GMOs while advancing organically grown
foods as more healthful than conventionally grown food.
Now some of these folks and many other kinds of anti-GMO
activists have openly stated that labeling will help them drive
GMOs out of the market. Now, the facts are these: Organic
produce is no more nutritious than conventionally grown
produce. It is more expensive because organic farming is land-
inefficient and labor-intensive. The organic industry's false
and misleading marketing is a primary reason why consumers
believe GMOs are bad and organic food is good. Attaching a GM
label provides no consumer benefit since GM foods are as safe
and nutritious as their non-GM counterparts. But attaching a
label will send the false message that there is something to
worry about because the FDA's labels are there to alert
consumers to food ingredients with health implications.
Now my final point is that there are serious humanitarian
implications should the current GMO vilification efforts
succeed in driving GM technology out of agriculture. Global
agricultural productivity increases are even now lagging behind
population growth, and that is without figuring in the
increasingly negative impacts of climate warming.
Now the future lies in agricultural intensification. We
will need to produce more crop per drop of water and square
meter of land. Genetic modification of plants, in which the
United States currently leads, will be the key to feeding the
nine or ten billion people we expect for dinner in just a few
decades. We cannot afford to discard the best methods we have
ever invented to continue growing the food supply and doing it
more sustainably.
Thank you very much.
[The prepared statement of Dr. Federoff follows:]
Prepared Statement of Nina V. Fedoroff, Ph.D., Senior Science Advisor,
Olsson Frank Weeda Terman Matz PC (OFW Law), Washington, D.C.
Chairman Conway, Representative Peterson, Members of the Committee,
thank you very much for the opportunity to testify before you today. My
name in Nina Fedoroff and I am a professor of plant molecular biology
and genetics. My laboratory pioneered in the adaptation of genetic
modification of GM techniques to plants more than 35 years ago. I am a
member of the U.S. National Academy of Sciences and a National Medal of
Science laureate. I served as the Science and Technology Adviser to
Secretaries of State Condoleeza Rice and Hillary Clinton. I co-authored
a book titled Mendel in the Kitchen: A Scientist's View of Genetically
Modified Foods.\1\
I am here to tell you why mandatory labeling of foods containing GM
ingredients is counterproductive to Americans' ability to make
healthful food choices. More than that, I will tell you why such labels
could well undermine humanity's efforts to achieve food security.
A recent poll of scientists and the public on GMOs gave startling
results: only 37% of the public believes GMOs are safe, compared with
almost 90% of scientists.\2\
So what's the evidence? GM crops have been in commercial production
for almost 20 years.\3\ They have an impeccable safety record and
multiple environmental benefits.\4\ Despite anecdotal reports, often
never published or subsequently retracted, no allergies, illnesses or
deaths have been reproducibly linked to the consumption of GM food or
feed.\5\, \6\, \7\
GM crops have boosted yields and farmers'
incomes.\4\, \8\ The figure [below] illustrates these
impacts graphically (from the cited Klumper and Qaim reference).
Environmental impacts for the period 1996-2012 include the application
of 503,000 tons less pesticide (active ingredient), greenhouse gas
reductions of 16 million tons CO2 and increased soil carbon
sequestration from no till farming estimated at more than 200 million
tons CO2.\4\
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Consumers have benefited not only through continuing low food
prices, but also directly from decreased mycotoxin contamination of
corn.\9\ GM Bt corn contains a bacterial gene that encodes a protein
that is toxic to certain boring insect pests, but not to animals or
people. Such insects bore holes in developing corn plants, allowing
fungi to enter and grow, as illustrated [below]. The fungi, in turn,
produce mycotoxins, which are compounds that are toxic and can be
carcinogens for people and farm animals. Bt corn is protected from
insect attack, so no insect holes, no fungi, no mycotoxins.
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Scientific academies and scientific societies around the world
concur that modern methods of genetic modification are as safe as those
used by previous generations of plant and animal breeders, arguably
safer.\6\ Appendix I shows quotations from the GM statements of
scientific organizations. Decades of research on GMO biosafety have
simply failed to identify hazards unique to the use of GM technology
for crop improvement. Quoting from a recent EU report on GMO research:
\10\
``The main conclusion to be drawn from the efforts of more
than 130 research projects, covering a period of more than 25
years of research, and involving more than 500 independent
research groups, is that biotechnology, and in particular GMOs,
are not per se more risky than e.g., conventional plant
breeding technologies.''
Until the development of modern GM techniques, breeders had to
depend on either rare natural--or more recently--induced mutations
(another name for genetic modifications)--to develop better crops.
Today we know enough about genes to introduce a desired trait into an
already highly productive plant or animal without the undesirable
downsides of older methods.\11\
It's worth pointing out that the history of plant and animal
genetic modification extends back some 10,000 years. We created corn,
not Mother Nature; \12\ we created big, luscious heirloom tomatoes--
Mother Nature's are tiny and can be deadly.\13\
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The FDA just approved Simplot's Innate potato that won't turn brown
after it's peeled and--more importantly--contains less asparagine, a
natural amino acid that turns into the toxic compound acrylamide when
the potatoes are French fried in hot oil. These genetically modified
potatoes will be more healthful and less wasteful. But today, more than
60% of Americans believe that GMOs are unsafe--and probably wouldn't
choose to buy them.
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Why? The reasons lie in the increasingly strident efforts of
determined anti-GMO activists to convince the public that GMOs are bad.
Most prominent among these are NGOs, such as Greenpeace, and the
organic food industry. A recent, meticulously researched ``Organic
Marketing Report'' documents how the organic food industry has
progressively demonized GMOs, while advancing organically grown food as
more healthful than conventionally grown food.\14\
The facts are these. Organic produce is no more nutritious than
conventionally grown produce.\15\ Quoting the conclusion of the cited
2009 analysis of more than 50,000 publications spanning a 50 year
period:
``On the basis of a systematic review of studies of
satisfactory quality, there is no evidence of a difference in
nutrient quality between organically and conventionally
produced food-stuffs. The small differences in nutrient content
detected are biologically plausible and mostly relate to
differences in production methods.''
Organic produce is more expensive because organic farming is land-
inefficient and labor-intensive. Organic marketers--and many other
kinds of anti-GMO activists--have openly stated that GMO labeling will
help them drive GMOs out of the market. Appendix II shows
representative quotations from both anti-GMO activists and organic food
proponents. The anti-GMO activities of vocal NGOs, particularly
Greenpeace, and the organic industry's false and misleading marketing
are the primary reasons that consumers believe GMOs are bad and organic
food is good.
It is often claimed that consumers have a ``right to know'' what
they are eating. However, adding a ``GM'' label to food containing an
ingredient from a GMO will not help the consumer make meaningful
distinctions about either the food's safety or its health benefits. The
GM foods on the market today are as safe as and nutritionally
equivalent to their non-GM counterparts. So the fact that they are GM
is irrelevant information to the consumer. Research on consumer-
decision making reveals paradoxically that more information,
particularly irrelevant information, actually decreases the accuracy of
a consumer's choice, even though it increases the consumer's confidence
in the choice.\16\, \17\
Labeling would drive up the cost of food \18\ while sending the
false message that there's something to worry about, because current
FDA policy requires that labels contain information on food ingredients
that have health (or environmental) implications (http://www.fda.gov/
Food/GuidanceRegulation/GuidanceDocuments
RegulatoryInformation/Biotechnology/ucm096095.htm).
My final point is that there are serious humanitarian implications
should the GMO vilification efforts succeed in driving GM technology
out of agriculture. Global agricultural productivity increases are even
now lagging behind population growth \19\--and that's without figuring
in the growing impact of climate warming.\20\
The future lies in ``agricultural intensification''.\21\ We will
need to produce more crop per drop of water and square meter of land.
The next big breakthrough will be in the efficiency of photosynthesis,
the almost magical process by which crops turn thin air and water into
food powered by sunlight.\22\ Genetic modification of plants, in which
the U.S. currently leads, will be the key to feeding the nine or ten
billion people we expect for dinner in coming decades. Neither
Americans nor the rest of the world can afford to lose the best methods
we've ever invented to keep growing the food supply sustainably.
Endnotes
\1\ Nina V. Fedoroff and Nancy Marie Brown, Mendel in the Kitchen:
A Scientist's View of Genetically Modified Food. (Joseph Henry Press,
2004).
\2\ Pew Research Center, Public and scientists' views on science
and society, (http://www.pewinternet.org/2015/01/29/public-and-
scientists-views-on-science-and-society/), 2015.
\3\ C. James, Global status of commercialized biotech/GM crops:
2014, (http://www.isaaa.org/resources/publications/briefs/49/
executivesummary/default.asp), 2015.
\4\ G. Brookes and P. Barfoot, GM crops: global socio-economic and
environmental impacts 1996-2012, (www.pgeconomics.co.uk/pdf/
2014globalimpactstudyfinal
report.pdf), 2014.
\5\ H.A. Kuiper, G.A. Kleter, H.P.J.M. Noteborn, and W.J. Kok,
Assessment of the food safety issues related to genetically modified
foods, The Plant J. 27 (6), 503-28 (2001).
\6\ A.E. Richroch, Assessment of GE food safety using `-omics'
techniques and long-term animal feeding studies, New Biotechnol. 30,
351-54 (2013).
\7\ A.L. Van Eenennaam and A.E. Young, Prevalence and impacts of
genetically engineered feedstuffs on livestock populations, J. Animal.
Sci. 92 (10), 4255-78 (2014).
\8\ Wilhelm Klumper and Matin Qaim, A meta-analysis of the impacts
of genetically modified crops, PloS one 9 (11), e111629 (2014).
\9\ Erin Bowers, Richard Hellmich, and Gary Munkvold, Vip3Aa and
Cry1Ab proteins in maize reduce Fusarium ear rot and fumonisins by
deterring kernel injury from multiple Lepidopteran pests, World
Mycotoxin Journal 6 (2), 127-35 (2013).
\10\ European Commission, A decade of EU-funded GMO research, 2010.
\11\ Peggy G. Lemaux, Genetically engineered plants and foods: a
scientist's analysis of the issues (Part I), Annu. Rev. Plant Biol. 59
(1), 771 (2008).
\12\ Nina V. Fedoroff, Prehistoric GM corn, Science 302 (5648),
1158-9 (2003).
\13\ Veronique Bergougnoux, The history of tomato: From
domestication to biopharming, Biotechnology Advances 32 (1), 170-89
(2014).
\14\ Joanna Schroeder, Organic Marketing Report, (http://
academicsreview.org/wpcontent/uploads/2014/04/Academics-Review_Organic-
Marketing-Report1.pdf), 2014.
\15\ Alan D. Dangour, Sakhi K. Dodhia, Arabella Hayter, Elizabeth
Allen, Karen Lock, and Ricardo Uauy, Nutritional quality of organic
foods: a systematic review, American J. Clinical Nutrition 90 (3), 680-
5 (2009).
\16\ Anthony Bastardi and Eldar Shafir, On the pursuit and misuse
of useless information, Journal of Personality and Social Psychology 75
(1), 19 (1998).
\17\ Crystal C. Hall, Lynn Ariss, and Alexander Todorov, The
illusion of knowledge: When more information reduces accuracy and
increases confidence, Organizational Behavior and Human Decision
Processes 103 (2), 277-90 (2007).
\18\ A. Van Eenennaam, B.M. Chassy, N. Kalaitzandonakes, and T.P.
Reddick, The potential impacts of mandatory labeling for genetically
engineered food in the United States, CAST report (http://
www.castscience.org/file.cfm/media/products/digitalproducts/
CAST_Issue_Paper_54_web_optimized_29B2AB16AD687.pdf), 2014.
\19\ Deepak K. Ray, Nathaniel D. Mueller, Paul C. West, and
Jonathan A. Foley, Yield trends are insufficient to double global crop
production by 2050, PloS one 8 (6), e66428 (2013).
\20\ A.J. Challinor, J. Watson, D.B. Lobell, S.M. Howden, D.R.
Smith, and N. Chhetri, A metaanalysis of crop yield under climate
change and adaptation, Nature Climate Change 4 (4), 287-91 (2014).
\21\ David Tilman, Christian Balzer, Jason Hill, and Belinda L.
Befort, Global food demand and the sustainable intensification of
agriculture, Proc. Natl. Acad. Sci. USA 108 (50), 20260-4 (2011).
\22\ Veronica G. Maurino and Andreas P.M. Weber, Engineering
photosynthesis in plants and synthetic microorganisms, Journal of
Experimental Botany 64 (3), 743-51 (2013).
Appendix I: Safety of GM Techniques and GM Foods
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``The scientific consensus around the safety of genetically
modified foods is as strong as the scientific consensus around
climate change. These foods are subjected to more testing than
any other and everything tells us that they're safe.''
http://www.axismundionline.com/blog/the-new-is-gm-food-safe-
meme/.
Appendix II: Anti-GMO Activists and Proponents of Organic Food on
Labeling
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The Chairman. Thank you, Dr. Federoff. Ms. Lidback, thanks
again for coming, and let me reiterate my earlier comments. It
is reprehensible. We can have differences of opinion, but to
attack people----
Voice. Yes, our own facts.
The Chairman. Yes, ma'am. And even whether or not based on
facts, you can still--but to resort to name-calling and
threatening and other less genteel kinds of ways is
reprehensible. So thank you for saddling up for a second round.
You are recognized for 5 minutes.
STATEMENT OF JOANNA S. LIDBACK, OWNER, THE FARM AT WHEELER
MOUNTAIN, WESTMORE, VT; ON BEHALF OF AGRI-MARK; NATIONAL
COUNCIL OF FARMER COOPERATIVES;
NATIONAL MILK PRODUCERS FEDERATION
Ms. Lidback. Thank you. Chairman Conaway, Ranking Member
Peterson, and other Members of the Committee. Thank you for
inviting me here today. I am here on behalf of Agri-Mark Dairy
Cooperative, the National Council of Farmer Co-ops, and the
National Milk Producers Federation.
My husband and I have a small 50 cow dairy located in
northeast Vermont. We also make extra hay to sell. We raise
Jersey steers to process and sell beef locally, and we market a
small amount of composted manure. We have two young boys, ages
3 and 2.
My husband and I are both proud to be first-generation
dairy farmers. We believe in the science and capability of
biotechnology and its role in protecting the sustainability of
our farm. Biotech crops are essential to treating our cows and
calves. We feed both GMO corn and soy products year round along
with pasturing, a grass-based silage, and hay.
I believe that biotech varieties improve efficiency and
productivity of farming. In my written testimony, I mentioned
that I could not find a non-GMO option available to me, but I
have since found it. The non-GMO feed would cost $589 per ton.
The same conventional feed we currently feed is $333 per ton.
On our small farm, we purchase about 16 tons of grain per
month, and if you do the math, that is a difference of about
$4,100 a month or $49,000 a year. If there are any dairy
economists here, this is the equivalent of $1,000 per cow on
our farm. I don't see how we could profitably farm with those
increased feed costs.
As a small farm just starting out, we are constantly
exploring new opportunities to grow our business. One of the
things we have been looking at recently is growing our own corn
and alfalfa. In our short growing season, genetically
engineered seeds offer the best options for us. Incidentally,
over 97 percent of the corn grown for silage in Vermont is
biotech crop.
I personally believe that there is room for many different
styles of farming. I also believe that biotechnology will play
a major role in our ability to feed a growing world and to make
improvements on our own individual farms. Certainly, as a dairy
farmer, increasing feed costs would have a devastating impact
on my business. But beyond our farm gate, we know that the
impact would be just as brutal. In my area of rural northeast
Vermont, 80 percent of the children in elementary school
receive free reduced-price school lunches. It is their families
who would suffer the most from price increased caused by
mandatory biotech labeling.
As a mother and a consumer, I do not to purchase organic or
non-GMO food in the store since I would be paying more with no
added nutritional, health, or environmental benefits. I firmly
believe the food I feed my two growing boys is safe.
You must be aware that recently my State of Vermont passed
a mandatory GMO labeling law. In New England, it is very easy
to cross borders for various reasons, such as grocery shopping.
If the Vermont labeling law is activated, there will likely be
one label on food in Vermont and another on the exact same food
in New Hampshire, raising questions about whether or not the
product is actually the same.
Furthermore, the Vermont law exempts meat and dairy from
being labeled. Other states may not exempt those products as
they consider their own GMO labeling bills. Doing so will
affect my ability to market my USDA certified Jersey beef
across state lines. This serves no one's interests, not
consumers, not farmers, not food producers.
I am happy to speak up for our right to farm in whatever
way we choose, which in our case, includes biotechnology and
the use of GMOs. It is important to continue the conversation
about the opportunities and challenges we face as modern-day
farmers and parents. When I have one person or ten people reach
out to me for a question or appreciating my practical
perspective from the farm, then I have succeeded.
Sometimes this isn't an easy task. As the Chairman
mentioned, I testified at a Subcommittee hearing on this very
topic last summer and received some very rude comments from
total strangers on social media and phone calls from them in
the middle of the night.
It was not always the most pleasant experience, but being a
dairy farmer, I am used to having to do unpleasant jobs from
time to time. Even with those negative encounters, or maybe
because of them, I was eager to come back and share my
experiences today. I am proud of how far the American farmer
has come, just as I am proud of how far we have come on our own
farm. If my sons choose to continue in farming, I want to know
that my husband and I have provided them with a firm foundation
to build on.
Thanks again for the opportunity to be here with you today.
[The prepared statement of Ms. Lidback follows:]
Prepared Statement of Joanna S. Lidback, Owner, The Farm at Wheeler
Mountain, Westmore, VT; on Behalf of Agri-Mark; National Council of
Farmer Cooperatives; National Milk Producers Federation
Chairman Conaway, Ranking Member Peterson, and other Members of the
Committee, thank you for inviting me here today to talk about the costs
and impacts of mandatory biotech labeling laws. Today I am here on
behalf of Agri-Mark Dairy Cooperative, the National Council of Farmer
Cooperatives and the National Milk Producers Federation.
My husband and I have a small 50 cow dairy located in northeast
Vermont. We also grow extra hay to sell, raise Jersey steers to process
and sell beef locally, and market a small amount of composted manure.
We rent the farm started by my husband's grandfather, from his aunt and
uncle, and it consists of over 200 acres of tillable land, including
roughly 50 acres of pasture where we graze our herd in temperate
months. We also raise all of our own young stock or replacement
heifers. We have two young boys, ages 3 and 2.
Along with being an active partner on the farm, I have a full-time
job with a Farm Credit Association as a business consultant, serve as
First Vice President of our county Farm Bureau and as a dairy cattle
judge for various youth and 4-H dairy shows across New England. I did
not grow up on a farm but got involved in agriculture through a 4-H
dairy project as a young girl in 1989. Since then, I have not let go of
my Jersey cows. I boarded my animals on neighboring farms and as fate
would have it met a dairy farmer who I would eventually settle down
with, bringing my Jerseys along. I have a bachelor's degree from
Cornell University where I focused on agribusiness management and a
master's in business administration from the F.W. Olin School of
Business at Babson College.
My husband and I are both proud to be first-generation dairy
farmers. Starting out on our own in building our farm has required a
lot of hard work and at times has been tremendously challenging. Being
able to raise our young sons in a farming lifestyle, and living out our
dreams of caring for his family's land and our animals while producing
food for our neighbors and community, though, has been hugely
rewarding.
As we have started out, our overall focus is building a farm that
is sustainable--one that is not just productive and profitable today
but one that we can pass on to our sons 25 years down the road. They
are a daily reminder of the importance of sustainability. That is why
we have diversified and started our direct farm sales; and that also is
why we fully embrace using technology to farm better and with less
impact on our surroundings.
Farming with a backdrop of rolling green pastures edged with woods
and wedged between a mountain and a lake in a small New England town
sometimes comes with preconceived notions. Often it seems people think
that our farm is like something out of a Norman Rockwell painting. And
indeed, passers-by have mistaken us for an organic dairy farm. Yet, we
are a conventional operation and we believe that using tools such as
biotech crops helps us to farm sustainably.
Biotechnology crops are essential to feeding our cows and calves.
When we can, we pasture feed our livestock. But as the past 2 months
have shown, harsh New England weather can make this impossible in
winter and early spring. So during those months, we feed cows and
calves grass that we have processed into hay or grass silage.
Additionally, throughout the year we rely on both corn and soy based
feeds to complete a total mixed ration that makes the best use of our
grass by balancing the needs of our cattle with the nutrients our
forages provide and filling in what is missing.
This gives us a unique perspective on the importance of
biotechnology. I believe that biotech varieties improve efficiency and
productivity of farming. I also believe that biotechnology enables us
to lessen the environmental impact that growing can have because less
fertilizer and pesticides are used to grow an abundant crop.
The use of biotechnology on our farm is also important to the
economic sustainability of our small business. In speaking with our
dairy nutritionist, he pointed out that the only non-GMO feed he could
get us right now was organic. There simply is no non-GMO grain
available to us, or the freight cost would be so prohibitive it's not a
real option. Thus, an organic basic 20 percent protein complete feed
would cost $750 per ton; the same conventional feed is currently $333
per ton. On our small farm, we purchase about 16 tons of grain per
month. So, using 16 tons, that would more than double our grain bill,
or in hard numbers we would spend $5,328 per month for regular feed or
$12,000 per month on organic feed--a difference of $6,672 a month or
$80,064 per year. I do not see how we could profitably farm in the long
term with those increased feed costs. It is important to note that we
choose to not be organic for several reasons and thus would not receive
an organic premium for our milk even if we used the organic grain mix
simply to feed a non-GMO feed.
As a small farm just starting out, we are constantly exploring new
opportunities to grow our business. One of the things we have been
looking at recently is growing our own corn and alfalfa. Given our
location, we will need shorter-day corn varieties, meaning it would
grow in less time than average. Here again, we would want the choice of
the best seed regardless of breeding technology; genetic engineering
offers the best options. Economically it makes the best sense.
Incidentally, over 97 percent of the corn grown for silage in Vermont
is biotech crop.
We face a challenge brought on by what many in agriculture see as
the spread of misinformation about modern agricultural practices,
creating the potential for limiting our ability to use biotechnology in
order to best utilize the resources we have in sustainable ways. In
many cases, this has already happened as we saw with the controversy
over the use of recombinant Bovine Somatotropin (rBST), a technology
that has no adverse effects on human health but was rejected by some
consumers for no sound scientific reason. While many said that rBST was
an example of the evils of ``big agriculture,'' the truth is that many
small dairy farms used rBST as a way to improve and grow their
businesses, better utilizing existing resources including land base and
without needing more capital expenditures. Now, driven by the
marketplace, our cooperative generally must restrict its members from
using rBST. Thus, that option has effectively been taken away from us.
Now the agriculture industry is facing increased scrutiny for its
use of biotechnology--a technology that has enabled farmers to increase
yields while reducing the use of land, pesticides, fertilizers, water,
and even fuel. Despite the fact that there is no credible study of
biotech crops that has found them unsafe for human and animal
consumption, some special interest groups are still choosing to spread
misinformation, reject the technology and demand it be labeled on food
products.
I welcome consumers who want to know more about how their food is
produced--they have a right to know that the meals they serve at the
family dining table every night is safe and nutritious. But a very
small percentage of the population should not be able to impose their
personal, non-science-based food preferences on the rest of us--
prompting food prices to increase and driving farms like mine out of
business.
Certainly, as a dairy farmer, increasing food and feed costs would
have a devastating impact on my business. Beyond our farm gate, though,
we know the impact would be just as brutal. Rural northeast Vermont,
like many rural areas around the country, has a lot of good people who
put in a hard day's work but are just barely getting by as best they
can. This means that, for instance, 80 percent of the children in our
elementary school receive free or reduced school lunches. It is their
families who would suffer the most from price increases caused by
mandatory biotech labeling--those who can least afford it.
As a mother and a consumer, I choose not to purchase organic or
non-GMO food at the store. I will support my local community, however,
and may purchase organic or non-GMO food at a farmers' market or
directly at a farm stand. I generally do not believe in paying the
higher premium for these foods because they provide no added
nutritional or health benefits. With a growing family and a growing
farm business, we have a lot of other places to spend our hard-earned
money. Furthermore, I feel secure in the regulatory steps that have
been taken to the food produced and available for sale in the grocery
store to ensure it is safe to feed my family.
The fact is that American farmers offer consumers more food
choices, while providing the safest food supply than any other time in
our nation's history. Of course, living and working on a farm and being
exposed to farm publications and reports, my view on how food is grown
is different than that of a typical mom. There is information out there
for those who are interested. It's just a matter of getting it from
reliable sources. Some food companies are voluntarily labeling their
products, some participate in the transparent USDA Certified Organic
program and still some use third-party verification and a ``Non-GMO''
label.
Moreover, I feel even better knowing that food produced with
biotechnology or biotech ingredients has been done so with some sort of
advantage in mind--whether it's environmental, health or otherwise. I
certainly do not believe a mandatory biotech label is necessary; in
fact there are more responsible ways to spend [my] taxpayer monies. Be
that as it is, if consumers are to drive some sort of label requirement
I believe it should be done in a cohesive way at the Federal level.
You must be aware that recently my state, the State of Vermont,
passed a mandatory GMO-labeling law. As you can guess, there has been a
fair amount of chatter about it. I am frustrated with it. I believe
that there are better uses of the state's time, and taxpayer resources,
than imposing regulations on a technology that has been used and proven
safe for over 2 decades. I am also concerned about the impact this law
will have on the cost and availability of food in Vermont's grocery
stores.
I might also add that in New England, states are very close and it
is very easy and often more convenient at times to cross borders for
various reasons. Our farm, for example, is not too far from the border
with New Hampshire; we can get there in an hour. If the Vermont
labeling law is activated, there will likely be one label on food in
Vermont, and another on the exact same products in New Hampshire and
the rest of the country raising questions about whether or not the
product is actually the same. This serves no one's interests--not
consumers, not farmers, not food producers.
Further, our close-knit surrounding states are considering their
own GMO-labeling bills. Currently, the Vermont law exempts meat and
dairy from being labeled. Others may not exempt those products. As I
sell my Jersey beef, processed at a USDA certified facility, to people
in other states, this may directly affect my product and my ability to
market it.
In all of this, I think that it is so important for there to be an
ongoing conversation with consumers about this topic. Too many times,
farmers feel like they just need to tell their stories better and to
``educate''; while this is part of it, I think that we also need to do
a better job of listening to consumers, to their questions and concerns
and addressing them.
I volunteer for an online effort called Ask the Farmers. It is a
collaborative resource made up of farmers from all across the country
and Canada; and from all different aspects of farming--animal ag,
biotech crops, organic, conventional, small, large, etc., I'm very
excited to help in an effort to put more good information out there--be
it for genetic engineering, dairy farming, animal welfare, balancing
life with work, farm or family. I am happy to continue to speak up for
our right to farm in the best way we know possible; which in our case
includes biotechnology.
I will continue to pursue an active presence on Facebook, Twitter
and Instagram as well as more traditional communication routes via
newspapers, church meetings or everyday conversation, sharing articles
and ideas along with my knowledge about the opportunities and
challenges we face as modern-day farmers and parents. If I have one
person or ten people reach out to me for a question or appreciating my
hands-on and practical perspective from the farm, then I have
succeeded. And I have.
I may add that I testified at a Subcommittee hearing on this very
topic last summer and received some rude comments from total strangers
on social media. I tried to start a conversation with those folks who
were interested in having one and ignored those who were more
interested in making personal comments and being bullies. It was not
always the most pleasant experience, but being a dairy farmer I'm used
to having to do dirty jobs from time to time. But even with those
negative encounters, or maybe because of them, I was eager to come back
to share my experiences with all of the Members of the Committee.
I personally believe that there is room for many different styles
of responsible farming--the freedom to operate your business or
organize your life as you see fit is one of the things that makes
America great and our economy strong. I also believe that biotechnology
plays a major role in our collective ability to not only feed a growing
global population, but to also make individual improvements on our own
farms be it 50 cows or 5,000 cows; a cash crop operation or an apple
orchard; a multiple-generation farm or a beginning farmer. Even though
less than two percent of the U.S. population now lives on farms or is
actively involved in farming, agriculture comes in all different sizes
and shapes and we need every one of them. Just as importantly, we give
consumers options when they go to the grocery store.
We know more now than we have ever have about growing food, or
caring for animals, and this helps us to achieve a level of
productivity that previous generations of farmers would envy. I am
proud of how far the American farmer has come, just as I am proud of
how far we have come on our own farm.
Thank you again for the opportunity to be here today and to share
my experience with biotechnology.
About Agri-Mark
Agri-Mark, with more than a billion dollars in 2014 sales, markets
more than 300 million gallons of farm fresh milk each year for about
1,200 dairy farm families in New England and New York. The cooperative
is headquartered in Methuen, Mass., has been marketing milk for dairy
farmers since 1913, and actively represents their legislative interests
in the Northeast and in Washington, D.C.
About the National Council of Farmer Cooperatives
Since 1929, NCFC has been the voice of America's farmer
cooperatives. NCFC values farmer ownership and control in the
production and distribution chain; the economic viability of farmers
and the businesses they own; and vibrant rural communities. We have an
extremely diverse membership, which we view as one of our sources of
strength--our members span the country, supply nearly every
agricultural input imaginable, provide credit and related financial
services (including export financing), and market a wide range of
commodities and value-added products.
American agriculture is a modern-day success story. America's
farmers produce the world's safest, most abundant food supply for
consumers at prices far lower than the world average. Farmer
cooperatives are an important part of the success of American
agriculture. Cooperatives differ from other businesses because they are
member-owned and are operated for the shared benefit of their members.
Farmer cooperatives enhance competition in the agricultural
marketplace by acting as bargaining agents for their member' products;
providing market intelligence and pricing information; providing
competitively priced farming supplies; and vertically integrating their
members' production and processing. There are over 3,000 farmer
cooperatives across the U.S., and earnings from their activities (known
as patronage) are returned to their farmer members, helping improve
their members' income from the marketplace.
About the National Milk Producers Federation
The National Milk Producers Federation (NMPF), based in Arlington,
Va., develops and carries out policies that advance the well-being of
U.S. dairy producers and the cooperatives they collectively own. The
members of NMPF's cooperatives produce the majority of the U.S., milk
supply, making NMPF the voice of nearly 32,000 dairy producers on
Capitol Hill and with government agencies. For more on NMPF's
activities, visit www.nmpf.org.
The Chairman. Thank you. I appreciate that. Mr. Clarkson?
STATEMENT OF LYNN CLARKSON, PRESIDENT AND FOUNDER, CLARKSON
GRAIN COMPANY, INC., CERRO GORDO, IL
Mr. Clarkson. Chairman Conaway, Ranking Member Peterson,
and other Members of the Committee, thank you for inviting me
here today. I am the President of Clarkson Grain Company
located in Cerro Gordo, Illinois. Clarkson Grain was founded in
1974 by the Clarkson family, pioneering direct delivery
marketing to link farmers directly to end-users. From that
beginning, we have grown into a grain, oilseed, and ingredient
supplier to manufacturing companies making food and animal feed
with clients around the world. The company procures its raw
materials, primarily corn and soybeans, from farmers in the
United States and Canada. We operate our own commercial
storage, cleaning, and handling facilities, a barge station,
rail sidings. Our products include corn and soy flours, masa,
lechitin, whole grains, organic, non-GMO and GMO.
United States farmers excel in delivering the lowest cost
agricultural products with a grade standard acceptable to
clients. Since our inception, we have segregated corn and soy
by variety and market distinction to realize greater value for
producers and end-users. Buyers of these identity preserved
grains are now asking for features that guarantee their access
to particular markets such as GMO specific, non-GMO, and
organic. Such buyers range from small family companies to the
largest food manufacturers. Shipments range from a small bag to
55,000 ton vessels.
These market preferences are increasingly defining both our
domestic and international markets. To secure corn and soy
sought by these buyers, we contract with farmers before
planting to get particular varieties raised in accord with
buyers' wishes. We secure grower cooperation by paying
premiums.
Our goal is simple: a happy client. We are not in the
business to win a scientific or political argument. We are in
business to please clients seeking legitimate product
distinctions. We don't tell clients what they should want. We
ask them what they want and try to get it for them.
As an identity preserved (IP) merchant, Clarkson Grain is
not at all opposed to the development and commercialization of
GMO crops. Producers and their supply chain partners however
need to recognize that production and handling of any crop has
to be conducted in such a way that preferred market access is
recognized and honored. Neighboring farmers must have the
ability to serve their preferred markets, whether GMO, non-GMO,
or organic. Market access and choice are critical to this.
Wherever you fall on the GMO spectrum, it is clear to me as an
ingredient supplier that an increasingly significant percentage
of consumers want additional transparency in labeling. These
consumers, the GMO sensitive, have certainly proved themselves
to be a significant and vocal voice for transparency in
labeling.
The cost of disregarding this voice is increased social
conflict, expensive political battles, and uncertainty provided
by prolonged court cases. For farmers who use GMOs, this
process prolongs the difficulty for the biotech industry to
bring traits responsibly into the market. Everyone would win if
we could lower the temperature and manage the conflict over GMO
technology.
One critical way to lower the temperature is through a
rational uniform national standard for the labeling of food
that is not produced using GMO traits. Such an action is in the
fundamental interests of both consumers and farmers. Consumers
have a right to exercise their choice and avoid. Farmers have a
right to take advantage of this new market. The creation of a
standard could be accomplished through a mandatory labeling
scheme, but it is my belief that a more appropriate approach is
through a voluntary labeling program. I believe that such
approach would be less contentious, less adversarial, and less
expensive.
I believe we are in a similar place to where we were with
emerging organic market in the early 1990s. At that time
differing state standards for organic products were emerging.
The result was consumer confusion. Independent companies jumped
in. More confusion. Each one was saying their standard was
better than the next. So it was a negative for the entire
sector.
Once the organic sector settled on a uniform national
definition responsibly overseen by the USDA, consumer
confidence returned and served as the fundamental rationale for
explosive growth.
It is my belief the non-GMO market would also grow if it
had a uniform national standard overseen by the USDA. The USDA
has a world-class reputation of managing process-verified
programs. It seems to me to be straightforward. Let Congress
establish a uniform standard, let USDA oversee it, step back,
and let the marketplace work as it does.
To sum up, I want to offer one more rationale for
establishing a uniform standard. Labeling drives other
activities along the supply chain such as seed production. Many
producers struggle with a lack of appropriate non-GMO seed. For
all these pieces to work together within a reasonable time
frame, farmers must have access to an adequate supply.
So in closing I ask for several things. First, Congress to
support a farmer's freedom to produce for his preferred markets
without being dominated by his neighbor's market decisions. I
ask Congress to support through adequate funding, research in
non-GMO corn and soy varieties. I ask Congress to support a
farmers' choice of hybrids or quality attributes, GMO presence
or absence, or organic or non-organic. I ask Congress to help
those of us in the countryside to always balance and respect a
producer's production decisions as they provide a safe and
abundant food supply for the world's needs.
Thank you. I would be happy to answer any questions later
[The prepared statement of Mr. Clarkson follows:]
Prepared Statement of Lynn Clarkson, President and Founder, Clarkson
Grain Company, Inc., Cerro Gordo, IL
Chairman Conaway, Ranking Member Peterson, and other Members of the
Committee, thank you for inviting me here today to talk about the costs
and impacts of mandatory biotech labeling laws. My name is Lynn
Clarkson. I am the President of Clarkson Grain Company, Inc., located
in Cerro Gordo, Illinois, a small rural community about 3 hours south
of Chicago.
Clarkson Grain was founded in 1974 by the Clarkson family, which
pioneered ``Direct Delivery Marketing'' to link farmers directly to
end-users. From that modest beginning, we have grown and evolved into a
grain, oilseed, and ingredient supplier to the food manufacturing and
animal-feed industries serving clients around the world. The company
procures its raw materials--particularly corn and soy from farmers in
the United States and Canada.
We operate our own commercial storage, cleaning and handling
facilities as well as organic soy processing facilities, a barge
station and rail sidings. Our products include corn and soy flours,
masa, meal, refined soy oil, lechitin, whole grains, and organic and
non-GMO grains and oilseeds.
United States farmers and its supply chain partners like us excel
in delivering the lowest cost agricultural products within a grade
standard acceptable to clients around the world. Since our inception,
we have segregated corn and soy by variety and market distinction to
realize greater value for our producers and end-users. Buyers of these
Identity Preserved (IP) grains are now asking for features that
guarantee their access to particular markets such as GMO specific, non-
GMO and organic.
Such buyers range from small family companies to the largest food
manufacturers, starch and oil processors and feeders. Shipments range
from small bags to 55,000 ton ocean vessels.
These market preferences are increasingly defining both our
domestic and international markets. To secure corn and soy sought by
these buyers, we contract with farmers before planting to secure
particular varieties raised in accord with buyers' wishes. We secure
grower cooperation by paying premiums that justify continuing
participation in IP programs year after year.
Our goal is simple; a happy client. We are not in business to win
scientific or political arguments. We are in business to please clients
seeking legitimate product distinctions. We don't tell clients what
they should want. We ask them what they want and help them find it.
In the early days of our business, our major challenge was to keep
corn and soy types segregated by variety. Buyer, seller, and grower
could visibly see the distinctions. That changed with the commercial
introduction of GMO traits. Within a few years, GMO sensitive markets
brought new distinctions into play. For example, in those early days,
Japanese buyers for the soyfood industry worked with the Association of
Official Seed Certifying Agencies to develop testing and segregation
protocols.
As an IP merchant, Clarkson Grain is not at all opposed to the
development and commercialization of GMO crops. Producers and their
supply chain partners however must recognize that production and
handling of any of any crop has to be conducted in a way so that
preferred market access is recognized and honored. Neighboring farmers
must have the ability to serve their preferred markets--whether GMO,
non-GMO or organic. Market access and choice must be preserved. I
believe that this respect and recognition can occur.
Wherever you fall on the pro- or anti-GMO spectrum, it is clear to
me as an ingredient supplier that an increasingly significant
percentage of consumers want additional transparency in labeling so
that they may purchase the food types they and their families desire.
These consumers what one might call, GMO sensitive, have certainly
proved themselves to be a significant and vocal voice for increased
transparency in food labeling.
The cost of disregarding this voice is increased social conflict,
expensive political battles, and uncertainty provided by prolonged
court cases. For my farmers in Illinois who use GMO's this process
simply prolongs the difficulty for the biotech industry to bring traits
responsibly into the market. Those concerned about GMOs however deserve
to be respected even while the biotech industry continues its efforts
to market its traits at the consumer level. Everyone would win if we
could lower the temperature and manage the conflict over GMO
technology.
I am convinced that one critical way to lower the temperature is
through a rational uniform national standard for the labeling of food
that is not produced using GMO traits. Such an action is in the
fundamental interests of both consumers and farmers. Consumers have a
right to exercise their choice to avoid GMOs. Farmers have a right to
take advantage of this new market. The creation of a standard could be
accomplished through a mandatory labeling scheme but it is my belief
that a more appropriate approach is through a voluntary labeling
program. I believe that such an approach would be less contentious,
less adversarial and less expensive.
Here's why I have reached my conclusion. I believe we are at a
similar place in the labeling of non-GMO products to that of the
emerging organic market in the early 1990's
At that time differing state standards for organic products were
beginning to emerge. The result was consumer confusion. With no uniform
national organic standard, states were free to tout their differences.
The private-sector also got into the act. There were numerous private
certifiers each claiming to be better than the other. Consumers didn't
understand these differences but more importantly they became put off
by the sniping in the marketplace. As a result, the entire sector
suffered.
Once the organic sector settled on a uniform national definition,
responsibly overseen by the U.S. Department of Agriculture, consumer
confidence returned and served as the fundamental rationale for the
explosive growth we currently see within the sector. U.S. sales of
organic products in 2013 were $35.1 billion. This remarkable growth
rests on one thing; a uniform national standard, responsibly, overseen
by a Federal agency.
It is my belief the non-GMO market would also grow if there were a
uniform national standard, overseen, by USDA. USDA has world class
expertise in managing process verified programs. It seems to me to be
straightforward. Let Congress establish a uniform standard, let USDA
oversee it, step back and let the marketplace work.
As I begin to sum up, I want to offer one more rationale for
establishing a uniform standard or definition of a non-GMO label.
Labeling drives other activities along the supply chain such as seed
production. Many producers struggle with a lack of appropriate non-GMO
corn and soy varieties to meet specific market needs.
I am convinced a national non-GMO labeling program would send a
clear single to input suppliers such as seed breeders that the non-GMO
marketplace is here to stay. I do not believe that would be the case is
we had a proliferation of state labeling programs. I believe non-GMO is
a legitimate and growing market and that consumers deserve to know what
that is in their food so can make their choices with their hard-earned
dollars.
For that to occur within a reasonable time frame, farmers must have
access to an adequate supply of high yielding non-GMO corn and soy
varieties.
In closing I offer the following thoughts as you consider an
appropriate role for Congress to take in this emerging marketplace:
1. I ask Congress to support a farmer's freedom to produce for his
preferred markets without being dominated by his neighbor's
production choices. As you can see this sword cuts both
ways.
2. I ask Congress to support through adequate funding, research in
non-GMO corn and soy varieties so that farmers might
rapidly access this new market.
3. I ask Congress to support a farmers' choice of hybrids or quality
attributes, GMO presence or absence, or organic or non-
organic production methods.
4. And I ask Congress to help us in the countryside to always
balance and respect a producer's production decisions as
they provide a safe and abundant food supply for the
world's needs.
Thank you for this opportunity. I am happy to answer any questions
you might have.
The Chairman. Thank you, Mr. Clarkson. Mr. Dempsey?
STATEMENT OF THOMAS W. DEMPSEY, Jr., PRESIDENT AND CHIEF
EXECUTIVE OFFICER, SNACK FOOD ASSOCIATION, ARLINGTON, VA
Mr. Dempsey. I want to thank the Committee, Chairman
Conaway, and Ranking Member Peterson for holding this hearing
to provide a balanced review of one of the most critical issues
facing the food industry today, the labeling of genetically
modified organisms, or GMOs.
My name is Tom Dempsey. I have served as the President and
Chief Executive Officer of the Snack Food Association since
2013. Prior to joining SFA, I was the President of one of the
largest privately owned snack brands in the United States. We
represent over 400 companies in the snack industry. My members
include both billion-dollar multi-category companies and small
family-owned businesses in the second and third generation of
management. More than \1/2\ of SFA members have sales of less
than $100 million a year, and many are the primary employers in
their communities.
Mandatory GMO labeling would impact nearly every aspect of
my members' businesses, upping costs by requiring increased
product inventory, added complexity for packaging and
distribution processes, and extensive new regulatory and
training requirements. Absent a Federal solution, manufacturers
will have essentially three options to comply with a state GMO
labeling law: redesign their packaging, reformulate products so
that no labeling is required, or halt sales to that state. Each
option is difficult, costly, time-intensive, and at worst,
could eliminate jobs and consumer choice in the marketplace.
Smaller companies may not have these options at all.
A patchwork of mandatory GMO labeling laws would pose
significant burdens on the manufacturing process itself. They
would require separate storage for GMO and non-GMO products
throughout the entire supply chain beginning with the farmer
and extending through the various stages of production and
distribution. Aside from new administrative and recordkeeping
burdens, snack makers would be forced to clean and boil the
sheeting, baking, frying, and seasoning lines between GMO and
non-GMO production runs with extensive time costly delays.
Duplicative film labeling for the same stock keeping unit
or SKU assigned to each product line is also a problem. Film,
the industry's term for snack bag packaging, would need to be
changed mid-production and two separate inventories of the same
finished product must be kept. If one, ten, or 25 states enact
different GMO labeling laws, this process would become even
more burdensome and difficult to comply with, particularly from
an interstate commerce perspective.
Significant lead times and costs would also go into bag
changes. The cost in plate charges, new film, and
administrative oversight could be more than $750,000 for 800
SKUs, and the process could take 20 to 26 weeks.
GMO and non-GMO producers must continue to be segregated by
state, from the factory to the grocery store, resulting in
increased distribution costs and heightened opportunity for
mistakes.
To be clear, the hardest hit by this will be one-plant
operators with a single line of production. These costs could
put family-owned businesses out of business and increase
consolidation in the industry.
While it is sometimes assumed that companies could remove
GMO ingredients from their products, this is unrealistic
because the availability of non-GMO crops, as you have heard,
is limited. Over 80 percent of the corn, cotton, and soybean
crops in the United States are produced with biotechnology, all
of these products, which are staple items in the snack food
production.
Our members will not have the opportunity to increase their
contracts with farmers or mills for non-GMO corn, for instance,
for over 2 years. Transitioning to GMO-free production will not
happen overnight from genetically engineered plants.
Some manufacturers may choose to end distribution in states
that require GMO labeling resulting in fewer product options
for consumers and causing a ripple effect in the grocery
industry. Even if manufacturers notify grocers of their intent
to stop selling in a state, manufacturers could run the risk of
being fined if retailers do not comply or if mistakes happen in
the distribution process.
Fewer players in the aisle could mean less incentive to
keep quality high and prices low. Fewer products could
disproportionately cause job losses for some in the
distribution chain.
Ultimately, a patchwork of state GMO laws will hit
consumers the hardest in result in either increased cost at the
grocery store or less availability of products on store
shelves. Current Federal law mandates food labels for safety
and nutritional purposes, and because GMOs as you have heard
have proven to have no material difference than non-GMOs, there
is no food safety or nutritional difference that requires an
additional label. Going down a path which calls for mandatory
GMO labels sets a bad precedent for future calls for mandatory
labels for issues that are not related to food safety or
nutrition.
Consumers already have the option to purchase non-GMO
foods, and these options continue to expand. For over a decade,
both the USDA's National Organic Program and the independent
Non-GMO Project have certified that foods are organic and GMO-
free respectively.
Many SFA members have already made the significant
investment in marketing decisions to display these voluntary
labels. Forcing companies to re-label more than 80 percent of
their products does nothing but add cost, confusion, and may
limit the choices.
SFA does not have a single member company that
manufactures, distributes, and sells in just one state which
makes a state labeling law incredibly complex. Multiply these
challenges by five, ten, or 25 states and an insurmountable
burden is placed on the supply chain. SFA supports a voluntary
labeling standard which eliminates the proposed patchwork of
state laws and allows the market forces that are already in
place to continue to inform the consumer. As more and more
states continue to pursue different mandatory GMO labeling
laws, manufacturers and consumers alike need the consistency of
a Federal standard, and we need it urgently.
Thank you for your time and consideration.
[The prepared statement of Mr. Dempsey follows:]
Prepared Statement of Thomas W. Dempsey, Jr., President and Chief
Executive Officer, Snack Food Association, Arlington, VA
Introduction
First, I would like to thank the House Agriculture Committee,
Chairman Conaway, and Ranking Member Peterson for holding this hearing
to review of one of the most critical issues facing the food industry
today, the labeling of genetically modified organisms, better known as
GMOs. I appreciate the opportunity to be here.
My name is Tom Dempsey. I have served as the President and Chief
Executive Officer of the Snack Food Association (SFA) since 2013. Prior
to joining SFA, I was the President of one of the largest privately
owned snack brands in the United States (U.S.) where I spent 24 years
in total, 5 of which I served as the President overseeing all areas of
sales, marketing, finance, human resources, manufacturing,
distribution, research and development, and purchasing. Today at SFA, I
represent more than 400 companies who produce a wide variety of snacks
ranging from potato, tortilla, and pita chips to pork rinds and meat
snacks, to crackers, popcorn, granola bars, and trail mix, as well as
dried fruit and nut mixtures. SFA members range from billion-dollar
multi-category companies to small family owned and operated businesses,
some of which are in the second and third generation of management.
More than half of SFA members do less than $100M/year in sales and many
are the primary employer in their community.
GMO Labeling Debate
Over the last several years there have been a number of state
ballot initiatives calling for mandatory GMO labeling. While voters
have rejected ballot initiatives calling for mandatory GMO labeling in
four states: California, Washington, Colorado, and Oregon, the Vermont
State Legislature approved the nation's first mandatory GMO labeling
law, Act 120, in April 2014. Two other states, Connecticut and Maine
have mandatory GMO labeling laws on the books, but don't become
effective until certain population or surrounding state triggers are
met. In addition, since January 2015, 28 states and Puerto Rico have
introduced over 70 different pieces of legislation calling for some
type of mandatory GMO labeling of foods.
Mandatory GMO labeling at the state level would impact nearly every
aspect of SFA members' business, upping costs by requiring increased
product inventory, added complexity for packaging and distribution
processes, and extensive new regulatory and training requirements.
Absent a Federal GMO solution, manufacturers will have essentially
three options in order to comply with a state labeling law such as
Vermont's Act 120: order new packaging for products, reformulate
products so that no labeling is required, or halt sales to that state.
Each option is difficult, costly, time-intensive, and at worst, could
eliminate jobs and consumer choice in the marketplace which I will
further discuss. I will also outline why some food manufacturers, most
likely small and midsize family businesses, do not have all of these
options available and could be impacted the most.
Production Processes
One of the biggest barriers that prevents a company from complying
with state by state GMO labeling laws is the manufacturing process
itself.
First, it would require separate storage for GMO and non-GMO
products throughout the entire supply chain. Farmers will need to
separate their crops in planting and when transporting to grain
elevators or manufacturers. Once a grain elevator or manufacturer
receives the raw materials from farmers they too will need to store and
produce GMO and non-GMO materials separately. Aside from new
administrative and recordkeeping burdens, manufactures will need to add
separate storage areas to their facilities in order to segregate these
products. Tortilla processing provides an excellent example. The story
begins with the corn. There are two ways to begin the process: one, by
cooking the corn into a mash and the other by purchasing corn masa
(flour), adding water to it, and then sheeting it for cutting into the
triangle shapes we all know as tortilla chips. A mandatory labeling
scheme would require two different silos to hold GMO and non-GMO bulk
corn and masa (flour).
Given the expense of manufacturing machinery, snack makers may be
forced to use the same equipment and conduct thorough cleaning of the
sheeting, baking, frying, and seasoning lines between GMO and non-GMO
production runs to ensure no contamination occurs. Such a process could
take nearly 2 hours and would lead to a loss in valuable production
time. It is not likely a manufacturer would have the financial means or
the floor space to invest in separate equipment for GMO and non-GMO
production.
Another complicating factor is the need for duplicative labeling
film for the same stock keeping unit or SKU assigned to each product
line. In order to comply with a state labeling law, our members will
need to change film in mid-production and then keep two separate
inventories of the same finished product: one with GMO identification
specifically for sale in a state that enacts mandatory GMO labeling,
and the other for the rest of the distribution area. Companies would
not be able to use a single state-required label for all of its
products if a patchwork of varying state rules were enacted. Separating
finished products for not only one, but five, ten, or even twenty
states with various labeling requirements would be incredibly
challenging and nearly impossible for a manufacturer to carry out. Such
a labeling scheme impedes on interstate commerce.
Significant lead times and costs also go into a bag design change.
One SFA member estimated they would need to change over 800 SKUs to
continue to sell in Vermont alone. The cost in plate charges, new film,
and administrative oversight in this instance could be more than
$750,000. The actual cost of the run after converting the film would be
approximately 25 percent higher due to the shorter production runs of
non-GMO product that would be required to fulfill orders in Vermont,
for example. The actual process of designing, compliance review, plate
making, and lead-time for film would be 20-26 weeks. This would become
even more complicated if additional states pass their own onerous
regulations with different specific requirements.
After production, the distribution of most snack foods comes off,
in most cases, a route truck with direct service to the grocery store.
A state law such as Vermont's Act 120 will mandate a dual inventory for
each SKU for every step along the distribution channel. The end result
will be increased distribution costs and heightened opportunity for
mistakes.
To be clear, the hardest hit by this will be the small, family-
owned companies with just one plant or just a single line of
production. Quite frankly, these costs could put some companies out of
business and thereby increase consolidation in the industry by reducing
the players to a few multi-category, multi-national players that can
better take on the added cost of sourcing and segregating GMO and non-
GMO crops. All of these changes will add final product costs to the
consumer. The precise amount of added cost depends on each company's
cost structure.
Sourcing Challenges
In order to avoid the need for duplicate labels in a state like
Vermont, it is sometimes assumed that companies could simply remove the
GMO ingredients from their products altogether. This is unrealistic
because the availability of non-GMO crops is very limited. My
understanding is that over 80 percent of the corn, cotton, and soybean
crops in the U.S. are harvested from genetically engineered plants.\1\
Snack food companies purchase a large majority of their ingredients
derived from these plants.
---------------------------------------------------------------------------
\1\ United States Department of Agriculture Economic Research
Service. ``Recent Trends in GE Adoption''. July 14, 2014. Retrieved
from: http://www.ers.usda.gov/data-products/adoption-of-genetically-
engineered-crops-in-the-us/recent-trends-in-ge-adoption.aspx.
---------------------------------------------------------------------------
For instance, the process for producing potato chips begins with
developing a large network of growers for potatoes, contracting
quantities in advance of plantings and harvests, and purchasing cooking
oils such as cottonseed or soybean in advance to secure quantities and
pricing. The same goes for other crops. One tortilla chip manufacturer
told me that they would not have the opportunity to increase their
contracts for non-GMO corn for a minimum of 2 years. Transitioning to
GMO-free production could not happen overnight, or even by 2016, as is
specified in Vermont's Act 120, for example.
Impact on Consumers and the Economy
On the other hand, manufacturers could also choose to end the
distribution of their lines specifically in states that require
mandatory GMO labeling. However, ceasing distribution isn't simple.
Aside from limiting product options to consumers, there would be a
ripple effect in the grocery industry. Retailers would need to be
notified of the decision to stop selling in a state and manufacturers
could run the risk of being fined if retailers do not comply.
Fewer players in the aisle could mean less incentive to keep
quality high and prices low. Decreased promotion and distribution means
fewer route sales people needed to deliver the product and job losses
for some in the distribution chain, such as drivers, warehouse
personnel, account executives, and field management. Fewer jobs could
also lead to a decrease in tax revenue in a particular state.
Ultimately, a patchwork of state and local GMO labeling laws will
hit consumers the hardest resulting in either increased costs at the
grocery store or less availability of products on store shelves.
A recent study performed by economists at Cornell University
concluded that mandatory GMO labeling laws would increase the cost of
food by about $500 per family per year on average with some families
bearing an increased cost of up to $1,500 per year.\2\ These amounts
don't include the regulatory costs the government will incur to
actually implement the law that would likely be passed onto consumers
in the form of taxes.
---------------------------------------------------------------------------
\2\ Dyson School of Applied Economics and Management, Cornell
University. ``Costs of Labeling Genetically Modified Food Products in
N.Y. State''. May 2014. Retrieved from: http://dyson.cornell.edu/
people/profiles/docs/LabelingNY.pdf.
---------------------------------------------------------------------------
Role of Labels
Current Federal law mandates food labels for safety and nutritional
purposes. And because GMO's have proven to have no material difference
than non-GMOs, there is no food safety or nutritional difference that
requires an additional label. Going down a path in which calls for
mandatory GMO labels sets a bad precedent for future calls for
mandatory labels for issues that are not related to food safety or
nutrition.
GMO-Free Options Already Exist
While we firmly believe the science shows that our GMO products are
safe, SFA members support providing consumers with options in the
marketplace. It is important to note that consumers can already choose
to purchase non-GMO items and these options continue to expand. For
over a decade both the United States Department of Agriculture's (USDA)
National Organic Program and a nonprofit organization, the Non-GMO
Project have certified foods which are organic and non-GMO,
respectively. A company cannot display a USDA Organic Seal or a Non-GMO
Project Verified Seal without going through an intensive and costly
certification process. The Non-GMO Project alone has certified over
20,000 non-GMO products and this number continues to grow.
Many SFA members have already made the large investment required to
gain these voluntary certifications that give our customers the freedom
to choose between products that are produced, distributed, and marketed
as Organic and non-GMO and labeled as such. Forcing companies to re-
label more than 80 percent of their current products does nothing but
add cost, confusion, and, ultimately, may limit the choices available
to consumers.
Conclusion
SFA is concerned both about the burden state-level GMO labeling
would put on interstate commerce, as well as the increased costs that
could drive food companies out of business or increase food prices for
consumers while potentially limiting their options in the marketplace.
SFA does not have a single member company that manufactures,
distributes, and sells in just one state making a state labeling law
incredibly complex to deal with. Multiply the challenges I've presented
here for compliance in Vermont's Act 120 times five, or ten, or even 25
states and you place an insurmountable burden on our food supply chain
and add significant increased cost to our consumers.
For this reason, SFA supports Federal legislation which eliminates
the current proposed patchwork of state GMO labeling laws by creating
one voluntary GMO standard which eliminates confusion, advances food
safety, and provides much-needed consistency for manufacturers and our
consumers.
Again, thank you for your time and consideration of our views. I
look forward to answering your questions.
The Chairman. Thank you, Mr. Dempsey. Mr. Policinski?
Chris, go ahead, 5 minutes. I am sorry about that.
STATEMENT OF CHRIS POLICINSKI, PRESIDENT AND CHIEF EXECUTIVE
OFFICER, LAND O' LAKES, INC., ARDEN HILLS, MN
Mr. Policinski. Thank you. Thank you, Chairman Conaway,
Ranking Member Peterson, and Members of the Committee. Thank
you for holding today's hearing on the costs and impacts of
mandatory biotechnology labeling laws.
I appreciate the opportunity to testify on this important
issue. I am Chris Policinski, President and CEO of Land O'
Lakes. I also serve as Chairman of the National Council of
Farmer Cooperatives and am a Board Member of the Grocery
Manufacturers Association.
Land O' Lakes, based in Arden Hills Minnesota, is a farmer-
owned cooperative, meaning it is owned, governed, and
controlled by farmers and local agricultural cooperatives. Land
O' Lakes touches more than 300,000 farmers across the country
making us well-positioned to understand the benefits of
biotechnology and the impact of measures designed to mandate
the labeling of GMO products.
Biotech crops have been around for 2 decades and provide
extraordinary benefits to farmers and consumers: higher crop
yields per acre, less tilling of the land, decreased use of
natural resources such as water and land, reduced use of
insecticide, better soil quality, and lower consumer prices are
just some of the benefits GM crops provide.
Despite these benefits and the proven safety of GMOs, some
are pushing for states to pass laws that would mandate the
labeling of GMO foods. We are told this is about consumer
choice. The consumers already have these choices and many
others. Some choose to pay a premium for food that is produced
by certain methods, such as organic or does not contain certain
ingredients, such as those that are gluten-free. Others
prioritize affordability, accessibility, convenience, or taste.
Voluntary labeling currently presents all of these choices in
the marketplace, and that is the model that should exist for
GMO labeling as well.
Mandating GMO labeling runs contrary to the essential
purpose of government-mandated labeling, which is to provide
consumers with accurate and relevant information regarding the
safety of the foods they eat. Every major health and regulatory
organization has found that GMOs are as safe as any other food
and as such do not require any special labeling.
Mandated GMO labeling is an effort to stigmatize a form of
technology in an attempt to drive it out of the marketplace.
You don't have to take my word for it. Two months ago an
activist association published an article admitting that the
push to enact state-wide GMO labeling is part of a larger
effort to drive GMOs off the market. In addition to
stigmatizing biotechnology, a state-by-state patchwork of
mandated food labeling laws would be a logistical nightmare
creating dozens of different standards, different definitions,
and different exemptions.
Fortunately, Congress has the authority and the
responsibility to protect the free flow of goods across state
lines. Uniformity in our nation's food labeling ensures
consumers have consistent, accurate information on dairy,
poultry, meat, and other foods. Under Federal preemption,
Congress can create a voluntary uniform national solution to
the labeling of food products derived from ingredients using
biotechnology. The value of this approach is that it not only
respects a consumer's right to choose but it also respects a
farmer's right to choose to use a safe, proven technology.
Stigmatizing GMO foods through a patchwork of state
labeling mandates or even mandatory Federal labeling
jeopardizes innovation and threatens the future of development
and use of technology in agriculture. As a result, farmers will
have fewer choices of what to plant. We will see higher costs
due to crop segregation, lower yields, a decline in
productivity, and an increased environmental footprint. That is
dangerous for everyone.
And this threat is real and imminent. There is currently
some form of GMO labeling legislation pending in over \1/2\ of
our state legislatures, and Vermont's GMO labeling mandate is
scheduled to take effect next year. That is why I strongly urge
Congress to enact a common-sense law that will provide farmers
and consumers with the clarity and certainty needed for
meaningful, voluntary food labeling.
Last year our company supported the Safe and Accurate Food
Labeling Act, and we understand that similar legislation will
be introduced soon. Updates to the bill from last year may
include the creation of a voluntary, non-GMO verification
program run by the U.S. Department of Agriculture. We would
support such a provision which would ensure that consumers get
accurate information while preserving choices available to
shoppers and farmers.
Thank you again for the opportunity to testify before this
Committee. I look forward to working with each of you this year
to pass a common-sense solution that meets the demands and
expectations of the American people.
[The prepared statement of Mr. Policinski follows:]
Prepared Statement of Chris Policinski, President and Chief Executive
Officer, Land O' Lakes, Inc., Arden Hills, MN
Chairman Conaway, Ranking Member Peterson, and Members of the
Committee, thank you for holding today's hearing on the costs and
impacts of mandatory biotechnology labeling laws. I appreciate the
opportunity to testify on this important issue. I am Chris Policinski,
President and CEO of Land O' Lakes, Inc. I also serve as Chairman of
the National Council of Farmer Cooperatives, am on the Board of the
Grocery Manufacturers Association, and have over 30 years of experience
in the food and agriculture industry.
Background on Land O' Lakes, Inc
Land O' Lakes, Inc., based in Arden Hills, Minnesota, is a farmer
cooperative, meaning it is owned, governed and controlled by farmers
and local agricultural cooperatives. Land O' Lakes, Inc. touches more
than 300,000 farmers across the country.
While Land O' Lakes is best known for our dairy business, we are
also comprised of two other important business units: Winfield, one of
the country's leading distributors of agricultural seed and crop
protection products; and Purina Animal Nutrition LLC, which provides a
valued portfolio of complete feeds, supplements and ingredients for
animals and livestock.
Our company touches nearly every aspect of the food supply chain--
from farmers, to seeds, to production, to handling, to food processing
and distribution, to consumer foods sales and marketing. Within those
sectors, we also represent a cross-section of preferences and products.
For example, we sell biotech, conventional and organic products. This
broad and diverse business model makes Land O' Lakes well positioned to
understand the benefits of biotechnology, and the impact of measures
designed to mandate the labeling of GMO products.
Benefits of Biotechnology
Biotech crops have been around for 2 decades, and provide
extraordinary benefits to farmers and consumers. Higher crop yields per
acre; less tilling of land; decreased use of natural resources such as
water and land; reduced use of insecticide, better soil quality, and
lower consumer prices are just some of the benefits GM crops provide.
As the head of a broad agricultural and food company and speaking
on behalf of our farmer-owners, providing consumers with safe,
nutritious, affordable food is our number one priority each and every
day. That is why we have embraced biotechnology.
Our farmers and cooperatives don't just use biotechnology, they
have adopted this technology very quickly. That's because the benefits
that biotechnology provides across the board--for producers, the
environment and to consumers--are substantial and have been well-
established over decades.
Our farmers have also adopted this technology because they have
confidence in the safety of biotechnology. Time and again,
biotechnology and genetically modified ingredients have been proven
safe by organizations such as the American Association for the
Advancement of Science, the World Health Organization, the U.S. Food &
Drug Administration, the American Medical Association, and more. Today,
70-80% of the foods we eat in the United States contain ingredients
that have been genetically modified.
Options in the Market for Consumers
We know that customers want accurate and consistent information
about the food they are buying because we talk with them constantly. We
also know that different customers prioritize information differently.
Our cooperative's branded lines voluntarily offer many products to meet
specific consumer preferences, such as organic, cage-free and low fat.
The U.S. Department of Agriculture's Certified Organic program is a
prime example of an effective system that informs consumers and
certifies products which are available in most grocery stores across
the U.S.
Consumers should, and do, have choices in the marketplace. Some
choose to pay a premium for food that is produced by certain methods,
such as organic, or that does not contain certain ingredients, such as
those that are gluten-free. Others prioritize affordability,
accessibility, convenience or taste. Voluntary labeling currently
presents all of these choices in the marketplace, and that is the model
that should exist for GMO labeling as well.
Mandatory, Varying Standards Creates Chaos
Instead, some are pushing for a different approach. They are
working in states to pass laws that would mandate the labeling of GMO
foods.
Mandating GMO labeling runs contrary to the essential purpose of
government-mandated labeling--which is to provide consumers with
accurate and relevant information regarding the safety of the food they
eat.
Every major health and regulatory organization has found that GMOs
are as safe as any other food and as such do not require any special
labeling. This is what our own FDA has concluded and is further
supported by a 2011 summary report from the European Commission
covering a decade of publicly funded research, 130 research projects
and 500 research groups, which concluded there is no scientific
evidence of higher risks from GE crops.
Mandated GMO labeling is an effort to stigmatize a form of
technology and attempt to drive it out of the marketplace. You don't
have to take my word for it, 2 months ago, the Organic Consumers
Association published an article admitting that the push to enact
statewide GMO labeling laws is part of a larger effort to ``drive GMOs
. . . off the market.''
In addition to stigmatizing biotechnology, a state-by-state
patchwork of mandated food labeling laws would be a logistical
nightmare, creating dozens of different standards, different
definitions, and different exemptions.
Some say this approach is about a ``consumer right to know,'' but
knowledge depends on consistent, accurate information, and their
approach fails this basic test. Under their patchwork approach, a
product may require a GMO label in one state but not another.
Even within states an attempt to mandate GMO labeling will create
confusion. For example, in the State of Vermont, which has enacted a
mandatory GMO labeling law, a can of vegetable soup might be labeled as
GMO, but a can of vegetable beef soup with roughly the same ingredients
will not because meat is exempt from the GMO label. This approach
doesn't inform consumers; it creates confusion.
Inequitable attempts to mandate GMO labeling have been defeated in
a number of states. However, some groups continue to ignore the science
and push a state-based agenda that could put our nation's efficient
food supply system at risk. This year alone, there is some form of GMO
labeling legislation pending in over \1/2\ of our state legislatures.
Vermont's GMO labeling mandate is scheduled to take effect next year.
While it's a small state in terms of population, Vermont's law will
have a significant impact in the region and the nation. This law alone
would require dozens if not hundreds of manufacturing, transportation
and logistics changes not to mention thousands of labeling changes. A
single food company may be forced to change its sourcing, its storage,
its manufacturing, its labeling and its transportation. The companies
least capable of making these adjustments are going to be the small,
independent businesses that many customers want to support.
A National, Voluntary Non-GMO Label is the Solution
Fortunately, Congress has the authority and the responsibility to
protect the free flow of goods across state lines. Uniformity in our
nation's food labeling ensures consumers have consistent, accurate
information on dairy, poultry, meat and other foods. As a result,
Americans can go into a grocery store anywhere in the country and be
confident that their food is subject to the same standards,
certifications and labels.
Under Federal preemption, Congress can create a voluntary, uniform
national solution to the labeling of food products derived from
ingredients using biotechnology. This approach supports efforts already
underway in the marketplace, such as the USDA certified organic
program. More importantly, it appropriately places trust in the
intelligence of consumers to make choices best suited to their
preferences.
The value to this approach is that it not only respects a
consumer's right to choose, but also farmers' right to choose to use a
safe, proven technology. As the Members of this Committee know, our
nation's farmers are tasked with an awesome responsibility. Not only do
they provide sustenance to our nation but to countries all over the
world. At the same time, they face extraordinary challenges such as
fluctuating commodity prices, uncertain weather patterns, and global
competition.
Given the importance of agriculture, our government has been and is
focused on ways to help farmers. I know this Committee agrees with that
sentiment, and is committed to doing just that. But a patchwork
approach of state labeling mandates will make a farmer's job more
difficult, with problems that will extend to every part of our nation's
food production and distribution system.
For farmers, a GMO labeling mandate will stigmatize GMO products
driving down demand for GMO crops. As a result, our farmers will have
fewer choices of what to plant, will see higher costs due to crop
segregation, lower yields, a decline in productivity, and an increased
environmental footprint.
For suppliers, mandates mean building new supply chains--one for GM
crops and a separate for non-GM crops. New supply chains mean new
warehouse and storage space.
For manufacturers, mandates will require separate production runs
for individual states. New labels will need to be designed to comply
with each state's unique laws. Production runs will then be interrupted
for labels to be changed, creating idle equipment and idle workers.
For distributors, mandates will require new delivery routes. These
new routes won't be based on efficiency as they are now, but will be
based on borders.
And for consumers, each of these impacts imposes new costs. In
October 2013, the Washington State Academy of Sciences published a
report on the cost of mandatory labeling. This unbiased, scientific
analysis concluded that mandatory labeling is likely to affect trade
and will impose higher costs on production. Ultimately, this cost will
be passed onto consumers of GM and non-GM products alike. Further, a
recent study by Cornell University found that state-based GMO labeling
mandates could increase a family's annual grocery costs by up to $500.
Ensuring that farmers have a freedom of choice is not about
convenience, it's about necessity.
The world's population is estimated to grow from 7.2 billion to 9.6
billion by 2050. We will need to feed more people in the next 40 years
than the last 10,000 years, combined. Already, we are falling short
with one in eight people on Earth not getting enough to eat.
If farmers are expected to meet the growing demand, then they must
be able to utilize every tool available to them, especially
biotechnology. This technology will allow us to grow more food using
less land and fewer natural resources.
Stigmatizing safe, proven biotechnology through patchwork state
labeling mandates or even mandatory Federal labeling jeopardizes
innovation and threatens future development and use of technology in
agriculture. That's dangerous for everyone.
In conclusion, I strongly urge Congress to enact a common-sense law
that will provide farmers and consumers with the clarity and certainty
needed for meaningful, voluntary food labeling.
Last year, our company supported the Safe and Accurate Food
Labeling Act, and we understand that similar legislation will be
introduced soon. Updates to the bill from last year may include the
creation of a voluntary, non-GMO certification program run by the U.S.
Department of Agriculture. We would support such a provision which
would ensure that consumers get accurate information while preserving
the choices available to shoppers and farmers.
Thank you again for the opportunity to testify before this
Committee. I look forward to working with each of you this year to pass
a common-sense solution that meets the demands and expectations of the
American people.
I am pleased to answer any questions.
The Chairman. Thanks, Chris. I appreciate that. The chair
would remind Members that they will be recognized for
questioning in order of seniority for Members who were here at
the start of the hearing. After that Members will be recognized
in order of arrival, and I appreciate Member's understanding.
With that, I would like to yield my 5 minutes to the
Subcommittee Chairman Rodney Davis. Rodney?
Mr. Davis. Thank you, Mr. Chairman. Obviously with a
constituent in the room, I would like to start my questioning
with Mr. Clarkson. Again, thank you for being here. Thank you
for your testimony. In your testimony you touch on this, but do
you prefer the producers be able to voluntarily market their
products as biotech, non-biotech, or both? And should either of
these marketing claims be mandated?
Mr. Clarkson. I prefer that the farmer have the choice to
pick his market. I wouldn't mandate. I would do what I could to
protect the integrity of his product. It gets into the issues
of cross-pollination and seed purity and other issues, but it
should be an entirely voluntary process.
Mr. Davis. Well, thank you very much for your response. In
your testimony you also say everyone would win if we could
lower the temperature on biotechnology. And this is a very
important point that many touched on in their opening
statements.
Can you expand on this, Mr. Clarkson, and as the labeling
debate continues, what advice do you have in communicating with
the many stakeholders that could help bridge the gap between
those who support biotech and those who don't?
Mr. Clarkson. Well, the emotion of this issue carries a lot
of people away to unfortunate behaviors which my colleague on
the panel was subjected to last year. The fundamental interest
here is the consumer making the choice. Consumers don't choose
their food entirely on safety at all. They make consumer
choices on all sorts of values. I think that should be honored.
It has created a market for the farmer that currently is paying
him about a 15 percent premium, ten to 15 percent premium to
offer non-GMO and three times as much as conventional to offer
organic products in the marketplace.
If we can respect the fundamentals, the interest that seems
to be driving the emotion around the marketplace is to be able
to detect GMOs in at the grocery store. If we can set up a
voluntary labeling program, we define it and make it standard
around the United States, that gets everybody paddling the
canoe in the same direction----
Mr. Davis. Well, thank----
Mr. Clarkson.--while people make their choices.
Mr. Davis. Thank you very much for that response. Ms.
Lidback, I have three school-aged children at home. There is
obviously a lot of false information about the health and
safety of biotech crops that is driving this debate, and we
both saw that after the Subcommittee hearing last year. Can you
expand on why these products are safe for your children and
also mine?
Ms. Lidback. Thank you. Yes, food made with genetically
engineered crops happen to be the most rigorously tested
portion of the food that is available out there. People can
rest assured, I can rest assured, you can rest assured, that
they are safe. They are no more risky than other conventional
non-GMO or organic counterparts.
Mr. Davis. Okay. Thank you. Mr. Policinski? Did I pronounce
that semi-correctly?
Mr. Policinski. Yes.
Mr. Davis. Thank you. Thank you. You run one of the largest
farmer-owned companies in the country. Why has your company
made investments in biotech and what does labeling mean for
food and agricultural companies like yours?
Mr. Policinski. Our farmers have embraced biotechnology
faster than any technology in history, and they have done that
because the benefits to their economics on farm, the
environment, less land and water use, less crop protection
products use, and the consumers are so readily apparent. So
this technology is central to the way our farmers, our farmer-
owners, operate their businesses. So we have embraced that in
terms of the way we manage our business. We have a business
unit called Winfield Solutions that sells seed and crop
protection products to farmers. We sell all types of seed and
crop protection products to farmers. We sell biotechnology,
biotech plants. We sell conventional seeds. So we believe in
farmer choice, and it has been a good business for our farmers.
It has been a good business for us, and it is good for the
consumer in terms of the benefits of lower costs and a lower
environmental footprint.
Mr. Davis. Well, thank you very much. Thank you all for
your testimony. And Mr. Chairman, I have one question for the
panel, but I will wait until my turn. So I will yield back.
The Chairman. The gentleman yields back. The Ranking Member
is recognized for 5 minutes.
Mr. Peterson. Thank you, Mr. Chairman. Mr. Clarkson,
critics of the voluntary labeling say that it will not address
the consumer demand for labeling and will create additional
consumer confusion. And I frankly can't understand that. The
USDA's organic program has been out there and it seems to me it
has met consumer expectations. If it hasn't, how can we have a
$35 billion organic market in the United States? What am I
missing here?
Mr. Clarkson. Congressman, I don't think you are missing a
thing. I think you are right on the money on that. I think the
organic program is certainly getting support because consumers
believe in it. It is a voluntary label. I think a voluntary
label would take care of the underlying consumer interest in
knowing and not punish the industry and others that don't want
to be involved with the cost. I don't think there would be any
additional cost because the people that want that market are
already labeling for that market. It is already taken into
account.
Mr. Peterson. Thank you. Mr. Policinski and Mr. Dempsey, if
states like Vermont, are going off and doing their things like
the mandatory labeling there, and we hope that that gets
overturned in the courts, which some people are optimistic
about, but if it doesn't, what is going to happen with
companies such as yours that have labeling for the whole
country? Are you going to create a separate label for Vermont
where, if they end up with their law being upheld, are you
going to run a separate run in your companies just for Vermont?
Or are you going to basically say we are not going to sell in
Vermont, which is what I would hope you would do.
Mr. Policinski. Congressman Peterson, we haven't yet
decided. I think Mr. Dempsey outlined the three choices very
well. First is to stop selling to any individual state, second
is to relabel our products at considerable expense, and third
is to re-engineer our supply chain and reformulate our products
at even greater expense. None of those are good choices. All of
those choices would result in either denying consumers access
to products which we wouldn't support, but they would also
yield the other two choices short of not selling in any one
individual state are much higher costs passed along to
consumers. So I would agree with Mr. Dempsey's outline of the
three basic choices. As a company, we haven't yet decided.
There are no good choices in any of those.
Let me outline as well that the idea of not selling a
product in Vermont is also a very difficult choice because we
would be liable for any of our products that might find their
way into Vermont, and the cost of that liability is
extraordinary. I think the penalty is $1,000 per item. So even
if you said you wanted to pursue that first option, it is
really not a viable option, which is why we so strongly support
a Federal voluntary labeling law here.
Mr. Dempsey. I would agree. Obviously we have, as I said,
companies that are multi-category, multi-billion dollar
companies and small family-owned businesses. This is going to
be much harder for that small family-owned business with one
plant to do anything to adhere to the Vermont law as well as
sell their product across other states. So those options are
much more limited for the small manufacturer family-owned
businesses than they would be for a multi-plant, multi-billion
dollar business. So I would be repeating what we just already
said to go further, but it would be a difficult decision for
every company to decide what to do in Vermont.
Mr. Peterson. I thank both of you. Dr. Federoff, am I
saying that right? If a voluntary non-GMO labeling program were
to move forward, can we define what a GMO is so that the
consumers would understand the label?
Dr. Fedoroff. I would hope we could do a better job because
the label, genetically modified is, as several people have
pointed out, misleading. We have been genetically modifying
crops and animals for many thousands of years.
I think that Mr. Schmidt's suggestions are very good ones.
Biotechnology is a little bit less of a negative buzzword.
Mr. Peterson. Well, I don't know where the GMO came from. I
guess it was Europe, and there was obviously a purpose behind
it. So thank you, Mr. Chairman, I yield back.
The Chairman. The gentleman yields back. Mr. Gibbs, for 5
minutes?
Mr. Gibbs. Thank you, Mr. Chairman. It is a great panel,
and I want to commend Ms. Lidback for your work and also a
young couple starting in the agriculture industry, that is
commendable, and you say you have two kids, 2 and 3. Really, if
more kids could grow up on the farm, it would be great for our
country I believe.
I want to kind of look back for a little perspective. Back
in 1950, my understanding is the national corn yield was 50
bushels to the acre. In 1975, 40 years ago when I started
farming, my goal was to have 100 bushels an acre. And now we
are pushing 200 bushels an acre here nationally. Anything under
150 bushel would be considered a disaster. I know Land O' Lakes
is shaking his head there.
And it was pointed out, this change from 1950 to 1975 where
we doubled the production, I always contend it is from figuring
out soil nutrient fertility, also hybrid selection, natural
hybrid selection, and then I would contend from this period
forward now where we have pretty much doubled the yield again,
it is because we have been able to select the genetics in a
faster way like Dr. Federoff says. We have been doing it for
thousands of years or at least from our perspective, 100 years
or so. So we have been able to identify those genes and do it
exponentially in the lab. So it is really no different. So that
is one of the reasons why the scientists say it is safe,
because we know what those genes are. We can identify them. But
the benefits, we are growing--we are having 14 billion bushels
of corn crops a year now annually on less acres. Every year it
is less acres. So it is really a food security issue. The
American farmers have provided the food for this country, and
we also export \1/3\ of it. It is a food security yield but it
is about yields. And if we didn't have what has happened in the
last 25 years of this yield, we would be having food shortages.
Do you agree with that, Mr. Policinski?
Mr. Policinski. Yes, I do. I think there is a tremendous
productivity story here. In fact versus 2-2\1/2\ generations
ago, we are growing 6\1/2\ times more corn on 13 percent fewer
acres.
We often talk about that in terms of per-bushel yield, but
I will tell you, there is a tremendous sustainability story
there in terms of less water and land use, less protection and
crop----
Mr. Gibbs. Yes, you say that. In my 40 years now--I just
figured it out. It has been 40 years since I have been farming.
The crop protection, the herbicides we used back then, had
residuals. They didn't break down. They weren't biodegradable.
The crop protection we are using now is virtually--a lot of
them don't have any residuals. I tell people that come to my
farm, it is interesting. You see my neutral soybeans out there,
and we have to--we do a burn-down application before we plant,
and then sometime in June, we come through and we apply a
herbicide again, but we have to time it in such a way that it
is done right before, to kill those weeds that came up, and
then when the soybeans, you get this canopy to provide the
shade so that new weeds won't come because there is no
protection if we miss that timing.
And so we are using safer herbicides, and we are increasing
the yield and also protecting the environment that way.
I would also go on to say that I agree with all of the
panelists of the voluntary aspect because better than 80
percent of the grain grown in this country--was mentioned--is
genetically modified in the lab. Even though it is natural
selection, it was just done in a lab in my opinion. You would
have to label everything if it is mandatory, genetically
modified, which just scares consumers and it puts this country
at a risk of food security. And it hurts the environment in the
long run because we go backwards.
So I support voluntary labeling. If a producer out there
can find a niche market--I am sure there is a market out there.
We see it in organics, and they can demonstrate that it hasn't
been modified in the lab, that they can have that market. But
they can put on there that it is not--I would say artificially
modified--I don't know what the term is--versus naturally
hybrid selection like we did back in the 1960s and 1970s and
the 1980s.
So I want to commend you all for your testimony. Dr.
Federoff, go ahead.
Dr. Fedoroff. What people don't realize that it is in the
20th century we used chemical mutagens and radiation to hasten
the mutation process. So there isn't back then just breeding
and now this artificial method. That is one point. The second
point is that people have looked at the amount of genetic
change that accompanies using these different techniques, and
the evidence supports the conclusion that these are the safest
and least-disturbing techniques, whether you are looking at the
genetics or the epigenetics. That is the kind of control level
of genetic expression.
So these really are the best techniques, the least
disturbing, having the lowest probability of causing a problem
that we have ever developed.
Mr. Gibbs. Well, I thank you and the panelists and your
good work. Thank you, Mr. Chairman.
The Chairman. Thank you. The gentleman yields back. Mr.
McGovern, for 5 minutes.
Mr. McGovern. Thank you, and thank you all for your
testimony. Let me begin by saying everybody is reading from the
same sheet of music here, but nobody here is in favor of
mandatory GMO labeling, am I correct? If we are going to have a
thoughtful discussion on this, we ought to have more of a
diversity of opinion at a hearing like this because it is
important to hear all sides of the subject.
But let me begin by saying that I am a believer in science.
I rely on the scientists to give me informed information. That
is why I believe in climate change as well. That is a subject
for another hearing. But the point of the matter is that there
is great value in our sciences. So I am not here to demonize
GMOs or the technology behind them. I don't think anybody
should be fear-mongering about GMOs. I don't think anybody
should be threatening anybody who wants to produce GMO crops or
whatever. We ought to be able to have a more kind of a measured
conversation on this.
But I do believe in transparency, and I do believe people
ought to have a right to know what they want to know. The
consumers ought to have the right to know what they are eating
and what they are feeding their kids, and how they use that
information in their food choices is up to them, not up to us,
but up to them. There is great confusion with the labeling
system now. I mean, I saw a poll from Consumer Union that found
60 percent of consumers believe that products that say natural
means non-GMO when in fact that is not the case. More consumers
think natural means non-GMO than think organic means non-GMO.
The current system, and even kind of a voluntary system is
lacking. We were told that changing labels will cost food
companies. Food companies change their labels all the time. It
is a false argument to say that labeling requirements will
drive up the cost of food. I do believe there ought to be a
national standard because I do understand the patchwork of
various state initiatives is not in anybody's interest.
In response to the idea that if a product said, ``contains
GMOs'' or whatever the label would be, that somehow that would
discourage people from buying those products, you have 64
country around the world already require labeling of GMO foods.
Brazil, a country whose consumption patterns are similar to
those in the United States, has required GMO labeling since
2001. And from what I can tell, there has been no significant
change in consumption patterns.
But let me just raise one point here. I am deeply troubled
by Friday's announcement from the World Health Organization's
International Agency for Research on Cancer, that glyphosate,
the herbicide most commonly used on GMO crops, is a probable
human carcinogen. Now, IARC is made up of some of the most
renowned scientists in the world, and if they are saying that
glyphosate is a likely cause of cancer, I mean, that may be
something that people want to know.
So I guess my question is, because GMO corn and soybeans,
for example, are designed to withstand glyphosate, the use of
that herbicide has grown dramatically in recent decades, and
given Friday's announcement, I mean, don't you think people
should have the right to know how their food is grown and make
their own decisions? Anybody wants to----
Mr. Policinski. Well, let me just respond because there are
a few things that I would agree with. First, I agree there is
great confusion in the marketplace right now, and state level
labeling laws would increase that. I agree, and the Pompeo bill
that was offered last year said we need to define natural, and
that would be important to do. I think that a voluntary
national standard would provide consumers with that choice and
the information they need to make a decision. I think to do it
the other way around and to mandate the label does stigmatize
the ingredient and infers there is something that must be wrong
with it versus how we have done organic in a certified USDA
organic program. We didn't ask all food to be certified non-
organic to be able to communicate to consumers the value of the
choice to make an organic food.
There is some agreement that we do have tremendous
confusion, and that is why we support very firmly a national
labeling legislation that has voluntary options. I do agree
that we do need to define natural, and that is in the proposed
legislation. But I don't agree that it should be mandatory
because that does stigmatize----
Mr. McGovern. Does anyone want to talk about the glyphosate
finding? I mean that is a legitimate scientific organization.
Dr. Fedoroff. I am glad to address that. That is not based
on any new data, and it is not the case that there have been
many, many studies on glyphosate. We do have an Environmental
Protection Agency, and they require considerable testing. So
the organization has labeled it as----
Mr. McGovern. Probable.
Dr. Fedoroff. Possible carcinogen doesn't mean anything has
changed or any new data has been produced.
Mr. McGovern. But I guess the point is, shouldn't consumers
have a right to be able to know that? I mean, that is the----
Dr. Fedoroff. If there is evidence that it is a carcinogen,
yes. I think that is correct. But there have been so many
studies over the years on this particular compound that have
failed to identify any carcinogenic potential that for one
group to say, ``Oh, well, it just might be, then do we put that
on a label?'' I mean, this doesn't make any sense.
The Chairman. The gentleman's time has expired. Mr. Gibson,
for 5 minutes.
Mr. Gibson. Well, thank you, Mr. Chairman. I appreciate the
hearing, and thank you to the panelists, too, for being here
today.
I believe that people have a right to know what it is that
they are consuming, and I also feel very strongly about science
and recognize the fact that we have avoided famine, because as
was mentioned, we have modified over the years. So I recognize
that as well.
I represent 11 counties in Upstate New York. I am a fervent
and a strident advocate for my farmers. Ensuring the viability
of our family farms is critical, a principle that we can't drop
as we move forward reconciling right-to-know and science. And
so I thank Ms. Lidback for being here today, and thank you for
your testimony.
I also have tremendous faith in the American people that
empowered with information--I guess I don't agree with some of
the assessments that they would change their consumption
habits. I think that they will make good choices. And so I just
want to put that on the record, too. As it relates to right-to-
know, if we thought about it more broadly, we get fixated on
labels immediately. I would be interested in the panel's
response to the possibility of right-to-know with an approach
that provided details on modification on a website where
individuals could go to get information. I would be curious to
know what their reaction would be to that technique.
Mr. Policinski. Congressman, I would like to respond to
your question because there is a desire in the industry to
engage with consumers around this great dialogue where their
food comes from. But we want to do it in a science- and fact-
based way. This actually is part of that, having an orderly
Federal law that is voluntary around labeling GMO products,
would create an environment that we can engage with consumers
in a constructive way. There are a number of things that are
going on in a variety of industry association, two that I am
part of, the National Council of Farmer Cooperatives and the
Grocery Manufacturers Association. Everything from facts up,
from to a discussion of how we can do exactly what you have
described, to engage consumers in a dialogue, which is bigger
than a package panel, regarding where their food comes from and
help them understand that there are a lot of modern business
practices that give us the safest, lowest-cost, most-abundant
food supply in our history.
So that is under way, and this is part of that process, to
create an orderly environment to engage consumers in that
discussion.
Mr. Clarkson. Congressman, when we receive an order from a
Japanese food company, it often comes with a list of 100+
chemical residues that we are supposed to test for.
Realistically, it would cost about $16,000 to $20,000 to test
grain going into a container, which is more than the grain than
the container would be. But that is because they are concerned
about residues. I fully expect we will be asked to certify that
we are delivering products that didn't have Round-Up in it,
glyphosate in it, within a matter of days. Everybody supports
science-based, but science doesn't speak with a single voice,
and that confuses people. It is beyond my capability to know
which scientific argument is right. So I prefer to make the
distinction, if enough people have asked for it, and let them
decide going to the Internet and gathering what information
from whatever source and making their consumer decision.
Ultimately, the market will decide. The market has decided
right now to pay a farmer $3.80 in Illinois for conventional
corn, about $4.20 for non-GMO, and about $12.50 for organic. So
the market is speaking with its dollars and asking people to
perform. I think labels help in the grocery store, and science
is an excellent foundation, the only foundation, but just what
does science say is confusing.
Ms. Lidback. I would like to chime in. Congressman, I
walked away from the Subcommittee hearing last year feeling
like absolutely consumers have a right to know. No one here is
contesting that statement. And in fact, since then, more and
more resources have popped up just exactly the way you have
described them, websites with good information, including one
from my alma mater, Cornell University has a great website, the
Alliance for Science, that explains a bit more in detail some
of these growing processes and what the details are that lead
to farmers making the choices to use the biotechnology that
they do in their everyday practices.
Dr. Fedoroff. Maybe I would just like to make a point that
addresses Mr. Clarkson's comment about how do we decide. In
science we have a concept called the weight of the evidence. If
you have two studies and one says something is dangerous and
one says it is not, you don't know what to decide. If ten
studies say it is not dangerous and one study says it does, you
have a pretty good chance of believing that one. If 100 studies
or 1,000 studies say it is not dangerous and one still keeps
saying it is dangerous, you are very comfortable going with the
weight of the evidence, which is on safety.
Now, in this particular area of GMO, one study often gets
disproportionate attention. There is a famous study by a man by
the name of Seralini who claimed that glyphosate caused tumors
in rats. The study was retracted. The data were terrible, but
that dominates people's thinking. Should we bow to that or
should we go with the weight of the evidence?
Mr. Gibson. I know my time is expired, Mr. Chairman. I want
to make one final comment and that is that arming people with
the information is really what we are talking about here. My
family----
The Chairman. The gentleman's time has expired. Really, we
have other folks, Chris.
Mr. Gibson. You bet.
The Chairman. So Mrs. Kirkpatrick for 5 minutes?
Mrs. Kirkpatrick. Thank you, Mr. Chairman, and I have for
the record a report that I would like to enter from Cardinal
Peter Turkson, President of the Pontifical Council for Justice
and Peace.
The Chairman. Without objection.
[The document referred to is located on p. 79.]
Mrs. Kirkpatrick. I want to read a portion of that, and
then I will ask my question. He says, ``hunger in the world is
a very serious injustice that shows fundamental disrespect for
human dignity. Pope John Paul II called it the first and
fundamental form of poverty. Persistent hunger, starvation, and
malnutrition represent a global failure of humanity that, to
our shame, has dragged on for decades. It is a plague and a
long-term indicator of a system that does not function
properly. Some point to the economic crisis of recent years as
the reason why the world cannot do better, but that is just an
excuse. Food insecurity has persisted for decades through
prosperous times as well as more difficult times.''
And the panel, I want to explain to you. I represent the
Navajo Nation in Arizona where household food insecurity is
above 75 percent. And so my question is, do you think it is
possible to feed a world population of over nine billion people
without the use of genetic engineering and the full use of
agricultural technology? And I will just open that up to the
panel, whoever wants to address that.
Mr. Policinski. I would be glad to offer my perspective
which is based on a few things, but I do agree that we have
talked about this biotechnology and biotech traits in large
part in farmer terms, yield per acre. We haven't done enough of
a discussion around the benefits to the environment, less land,
less water use, less crop inputs, more benign crop inputs.
We haven't talked enough about it in terms of cost and the
benefits to consumers, in terms of lower-cost foods, because we
get a crop--just a couple of years ago we had the drought. We
got a crop. The weather patterns were not that dissimilar from
the late 1980s when we didn't get a crop. So we don't talk
enough about the benefits beyond yield per acre.
I think you raised another benefit and that is the ability
to feed the soon-to-be nine to ten billion people on the planet
in an increasingly productive and sustainable way and adapt to
climate change along the way. I do not think we can feed that
nine to ten billion people that are soon to be on the planet
without chewing up a lot of natural resources without
biotechnology.
Mrs. Kirkpatrick. Anyone else on the panel want to comment?
Ms. Lidback. I would, Congresswoman. I appreciate your
sentiment. And just for example in our country alone, you must
be aware, that less than two percent of our population lives on
farms. So in my opinion, we are going to need every farmer that
we can get, organic, non-GMO, conventional, whatever it takes,
and certainly biotechnology offers a tremendous amount of tools
beyond genetic engineering in order for us to do the best that
we can.
Mrs. Kirkpatrick. Anyone else?
Dr. Fedoroff. Yes, I would like to address it. Today we
produce enough calories to feed everyone in the world a
reasonable number, and it is a matter of unequal distribution
of resources. Today if you have the money, you can buy food. We
are looking at a future where we do not know what the impact of
climate change will be. It is already negatively impacting our
productivity worldwide.
There are still places in the world that productivity can
be increased by conventional methods, but in the end, if we
want to reduce the footprint of agriculture even further--and
conventional breeding and mutagenic breeding has done a
phenomenal job of reducing the required acreage to grow a
certain amount of food. In the future, the real barrier is the
ability of plants to collect sunlight and drive, to convert--it
uses sunlight to convert air and water into foodstuffs. In the
next breakthrough, the next big breakthrough has to be in the
efficiency of photosynthesis. We can't do that by conventional
techniques. We will have to understand, we will have to use all
of the science tools that we have including genetic
modification of plants to make the next big breakthrough that
will allow us to reduce the footprint, make agriculture more
sustainable, and yet continue to increase the food supply.
Mrs. Kirkpatrick. Thank you very much. I appreciate the
testimony that you are giving us today, and I yield back.
The Chairman. I thank the gentlelady. Mr. Benishek, for 5
minutes.
Mr. Benishek. Thank you, Mr. Chairman. Thanks to the panel
for being here today. Dr. Federoff, are the changes that have
been made in the lab, treatment of plants, changed their
properties any different than the way we have been doing it for
thousands of years?
Dr. Fedoroff. Yes. They are very much more precise because
in the last half-century, we have learned more about what genes
are, what they do, what they do in a different context than we
ever knew before. So in a way, we were stumbling blind. We used
chemicals and radiation kind of as a shotgun. Now we can take
just one gene, we know what it does, or half-a-dozen genes. It
doesn't matter. But it is a small number of very well-defined
genes that will confer new properties on plants and animals.
This is something we never could do before.
Now, does that mean that we will never create a plant or an
animal that is substantially different from what was before?
No. So regulation really needs to be based on the properties of
the organism, the environment it is going into, and what is
being added. And all of that, I have to--I can't resist
pointing out that that is exactly what the National Academy of
Sciences recommended in 1987.
Mr. Benishek. Well, thank you. I appreciate that. Going
back, you are exempt from the rules apparently in Vermont, is
that correct?
Ms. Lidback. Currently, yes.
Mr. Benishek. So if you had to comply with those rules,
would you be able to keep farming?
Ms. Lidback. That is an interesting question. It sort of
depends on what kind of a price we would then be able to
receive. So for example, generally speaking, when you convert
to the organic, you also are then able to collect an organic
premium in the market. So probably initially no, but if the
change were to happen overnight, the increasing costs I
detailed in my earlier statement would put us right out of
business.
Mr. Benishek. I guess I don't understand. There is labeling
requirements in the State of Vermont except that the Vermont
producers don't have to--is there only certain producers don't
have to comply or is it all Vermont producers?
Ms. Lidback. It is by industry, and it is really about the
food product itself. So the dairy and meat would be exempt as
well as food sold in restaurants would be exempt from being
labeled, whether it was produced using genetically engineered
ingredients or not.
Mr. Benishek. Let me ask a question, this time of the panel
perhaps. Does anyone disagree that a voluntary labeling Federal
rule, would that not give the consumers all the information
they need to know? I don't understand any reasoning against
that. Mr. Dempsey?
Mr. Dempsey. We do think that is exactly the case. I mean,
we have a template for that. The organic labeling has given the
consumer who wants that product all the information they have
needed. As somebody said earlier, we don't force companies to
form labels that say non-organic. So that doesn't make much
sense along that pattern that we would change anything
different for GMO-free labeling.
The information is there on a voluntary basis. If somebody
wants it, they seek it out and purchase that product.
Mr. Benishek. Right. Right. Anybody else have a different
opinion?
Dr. Fedoroff. My view is that if more information were
provided, if the law stipulated that you had to put together a
lot more information to offer the consumer, then it would
depend on who was doing it, how it was done, how accurate it
was, and so forth.
Mr. Benishek. All right. Thank you.
Mr. Policinski. No, I would agree, just something to add to
Mr. Dempsey's statements, that I would agree. We support the
Federal voluntary labeling program. I think it does allow us to
provide consumers a choice, but importantly it allows us to
continue to engage with consumers in a dialogue regarding where
their food comes from, which is important. I just don't think
the front of the label is where it should be. And as I said
earlier, there are a number of efforts going on in the
industry, in individual companies and within industry
associations to further that desire to engage with consumers
around where their food comes from in the modern business
practices that give us this great lowest-cost, most-abundant,
safest food supply that we have had in our history.
Mr. Benishek. Thank you. I am out of time it seems.
The Chairman. The gentleman's time has expired. Mr.
Aguilar, for 5 minutes.
Mr. Aguilar. Thank you, Mr. Chairman. Ms. Lidback, in your
testimony you mentioned that the marketplace is already sorting
out some of the non-GMO labeling without legislative mandates.
I wanted to just get your feeling and your perception and that
of your peers I suppose on the Whole Foods discussion, that in
2018 they plan to have all their products in the United States
and in Canada labeled.
Can you give the Committee your views on these kind of
private-sector driven initiatives?
Ms. Lidback. Thanks for your question. Yes, it is a topic
of--oftentimes we talk about it a lot, my peers and I. And one
of the frustrations we have is sort of this clash between
providing factual information and wanting to market a product.
It was Mr. McGovern earlier that talked about transparency and
consumers wanting transparency when there are a lot of
different conflicting ideas and statements out there.
For example, a great example is in chicken. I just learned
you are not allowed to label chicken packages as antibiotic-
free. You can use the terms grown without the use of
antibiotics, but you can't label it antibiotic-free. And there
are various restaurants in the country that will have on their
menus antibiotic-free chicken. So in my opinion, that is
misleading. That is misleading the consumer. So the Whole Foods
effort to sort of have a labeling initiative, I don't
necessarily agree with it. They are listening to their
customers, certainly, and they are trying to provide what they
want, but at the same time, are they stigmatizing genetically
engineered foods? And that is what the debate surrounds.
Mr. Aguilar. Thank you. I appreciate the answer.
Dr. Fedoroff. Let me just add to that that many of the
products--since I know what GMOs are on the market and what are
not, many of the products that they are attaching that label to
today are not genetically engineered, never have been. Okay? So
it is basically deceptive marketing.
Mr. Aguilar. Thank you. Mr. Policinski and maybe Mr.
Clarkson can also handle this next one. Sir, you mentioned
earlier that there are some industry components. What I heard
you say was there are some industry components within possible
legislation that you could support, such as the definition of
natural, you mentioned, in addition to the voluntary labeling
that we have heard extensively. What are some other policy
components that you feel industry can get behind showing
consumers as you mentioned more about where their food comes
from?
Mr. Policinski. Well, I don't know if it is policy or not.
I think policy that we have had in this country and our
regulatory agencies have been very fact- and science-based, and
that needs to be continued. We need to be very fact- and
science-based in the policies that do come out and the
regulations that do come out from our regulatory bodies. And I
would say that needs to be continued, and in large part, that
is what we are talking about today.
Other engagement that is going on is voluntary and by
individual companies, and what I am describing and to some
degree even your question about Whole Foods is individual
companies can choose to market how they choose to market, and
consumers could choose to make their own decisions based on
that. I do think that we are seeing very healthy outgrowth of
this conversation and others. Consumers are more interested in
where their food is coming from, and we will see more, I know
we will see more, organizations on a voluntary basis provide
that information on websites and through a variety of means.
So I don't think that is a matter of policy. I think that
is the individual companies trying to be very transparent with
their consumers.
Mr. Aguilar. Sure, but one of the panelists just said that
it was deceptive. So you are saying that we might gravitate
toward that, but one of the panelists just mentioned that those
efforts were deceptive.
Mr. Policinski. Yes. Well, let me be clear. I am not for
deceptive marketing in any way.
Mr. Aguilar. Right.
Mr. Policinski. The record will reflect that, right. And
nor am I accusing anybody of that. I think the notion is just
increased transparency of where your food comes from. There are
a lot of modern business practices that contribute to, as I
have said before and we need to keep saying it, the safest,
lowest-cost, most-abundant food supply in our history and
arguably in the world.
Biotechnology is just one of those modern business
practices that yields that statement. There are other practices
such as advanced breeding on dairy farms that lead to very
efficient dairy cows that produce milk more--there are a lot of
practices that we need to talk more about.
Mr. Aguilar. Mr. Clarkson, do you want the last comment?
Mr. Clarkson. Yes, Congressman Aguilar, one of the key
policy issues is to define what we mean by the term. When we
end up with multiple definitions, the market is in great
confusion that causes trouble for all the players.
So the other thing is in respecting the choice of one
farmer to do something and farmers who are neighbors need to
work together. And it would be nice to have some policies that
would encourage that.
Mr. Aguilar. Thank you so much. Thank you for your answers.
Thank you, Mr. Chairman.
The Chairman. Mr. Allen from Georgia.
Mr. Allen. Thank you, Mr. Chairman, and once again, I
appreciate the panel here and basically the comments that you
have had about this particular issue. One of the things, Dr.
Federoff, that I have been sitting here thinking about is as
far as the testing of these products. Are there any risks for
consumers to choose organic foods?
Dr. Fedoroff. Are there risks?
Mr. Allen. Yes.
Dr. Fedoroff. To choose organic?
Mr. Allen. Yes.
Dr. Fedoroff. Indeed. We share our pathogens with animals,
and the primary tenant of organic farming is a prohibition on
synthetic nitrogen fertilizers. They use green manure or cow
manure or other manures.
Mr. Allen. Right. Okay.
Dr. Fedoroff. Okay? And as I said, we share our pathogens
with animals. And a number of the food poisoning incidents are
coming out of organic farming. The outbreak that killed some 50
people in Europe a couple of years ago was traced to organic
beansprouts.
Mr. Allen. Okay.
Dr. Fedoroff. And this is something that people are just
simply not aware of.
Mr. Allen. And that is what----
Dr. Fedoroff. Now, properly treated manure is safe, but
there is always that probability because there is no uniformity
to that treatment.
Mr. Allen. Ms. Lidback, I grew up on a dairy farm, and the
best decision that my dad made was to get out of that business.
And here you are, first-generation. I applaud you. I chose to
be the clean-up person because I got to sleep a little later.
And speaking of cow manure, I am in trouble there because that
is what I did, is clean that place up every morning, every
night. But I can tell you this, if they get too tough on you
there in Vermont, you are welcome to come to the State of
Georgia and we will do everything we can to help you do
business down there.
Ms. Lidback. Thank you.
Mr. Allen. Yes, I will take any other comments. What we
want is a solution to this and what is the Federal Government's
role in this. We have less than about 2\1/2\ minutes, and I
would like to open it up. What do we need to do on this?
Mr. Dempsey. Just one comment that Congressman Aguilar made
that is important and is kind of overlooked in this Committee
or even on the whole discussion and that is defining the term
natural. Many of my member companies are in numerous litigation
between the different perceptions of what is natural and what
isn't natural, and the part of the bill, my understanding is,
that it mandates a Federal definition of natural. And certainly
that is something that we would advocate very strongly that has
to done.
Dr. Fedoroff. And of course, corn would be totally
unnatural by any definition because we created it.
Mr. Allen. Right.
Mr. Policinski. Congressman, not to be redundant, but I
want to come back to the Pompeo-Butterfield bill that was
offered before that by establishing a national voluntary
standard does clear up confusion. It does provide consumer
choice in the same manner that organic, USDA-certified organic
does, and it does preserve farmer choice. It allows the
marketplace to determine then the size of those businesses and
the size of the use of that technology. There is a simple
solution.
Mr. Allen. Okay.
Mr. Schmidt. If I could also add, too, in terms of my
testimony and my history, earlier in my career I worked for the
USDA Food Safety and Inspection Service and worked with many
talented regulators, with the career staff, also at the Food
and Drug Administration, and we have had a lot of discussion
about who knows? Who do we trust? I mean, these are the people
that tax dollars go to determine what is important health,
nutrition, and safety information? They, as many have
testified, can regulate within the current needs, and there can
be more legislation. But in the meantime, those are the folks
who make those important decisions. Otherwise, there is chaos
out there if we let everybody make those delineations.
Mr. Allen. Well, that is why I asked the question about
organic side. It seems like the GMO is kind of on everybody's
radar. So let us let everybody know what is going on because
the consumer does need to know and the consumer needs to have
the ability to make that choice. Thank you very much, and I
yield back the remainder of my time.
The Chairman. The gentleman yields back. Mr. Scott, for 5
minutes.
Mr. David Scott of Georgia. Thank you, Mr. Chairman. This
has been a fascinating hearing. I think basically what this
boils down is do we have--because all of the consumers need to
know what is in the food. It is basically whether it is one
national standard or state by state. But there is another issue
here that purveys, that runs from the farmer, the producer, all
the way up to the consumer, and that is economics. Mr. Dempsey,
you hit two very important points that we need to pay a little
attention to.
You mentioned in your statement that, first, \1/2\ of your
businesses in your association earn less than $\1/2\ million a
year, or should I say it was $100 million gross. And second,
which means they are basically small businesses. And the other
point was that in some of these communities, that particular
business is the primary source of employment.
We ought to look at these two and how they basically
impact. So tell us just how critical is the need for the
Federal Government to intervene here with a national standard,
rather than as it seems to be a state-by-state approach? What
is that economic impact on the jobs and on small businesses?
Mr. Dempsey. Thank you, Congressman. As I said, most of our
businesses are smaller, family-owned businesses, second-,
third-, fourth-generation. The snack industry is a very
regional, localized business. So you have a lot of small
manufacturers who are employing, the main employers, and the
manufacturing process in their areas.
To be able to basically navigate a list of state laws would
take additional people, additional costs, or painful decisions
to exit a certain market. And in many cases, those markets are
the markets on the border that they would have a hard time
complying with state-by-state laws, especially if those laws
have different nuances and different regulations.
So the hard decisions are you sell or you stop
manufacturing and walk away.
Mr. David Scott of Georgia. Okay. So the impact would be
considerable?
Mr. Dempsey. The impact would be considerable both in more
warehouse space, more SKUs, more film, a greater distribution
burden based upon more SKUs on a truck. It would be
significant, yes.
Mr. David Scott of Georgia. All right. And Mr. Policinski.
Mr. Policinski. Yes.
Mr. David Scott of Georgia. Policinski.
Mr. Policinski. Perfect.
Mr. David Scott of Georgia. Wonderful. Tell me, we haven't
discussed much, but tell me about science-based? What exactly
is science-based voluntary labeling and just how critical is a
voluntary label to your business?
Mr. Policinski. Yes. First, science-based: Dr. Federoff did
a good job talking about science-based decisions and how they
are made. I think that as it relates to this topic of
biotechnology and biotech traits, clearly the weight of the
sciences, that the technology is safe. And that has been
reinforced by a variety of agencies over 20 years, thousands of
studies. So that is the first point. And our company is very
interested in that as is the entire food industry.
Second, the voluntary national labeling standard in the
Pompeo-Butterfield bill just makes order out of a potentially
chaotic situation of state-by-state labeling. That is, as you
have heard from Mr. Dempsey, a situation that is not just
another label. It is often characterized as that. And we do
have products on the marketplace that are modified at the end
of the system, for a new flavor, for example. But this change
would extend all the way back through the food supply chain,
right to the farm, the seeds that are chosen, the inventory of
the seeds that are carried, the segregation of the crop, the
transportation and distribution of a separate crop, the storage
of those raw materials that are factories in separate
facilities or storage areas, and then the segregation of the
manufacturing process where we would have to run one technology
and then clean the lines and then run another technology. I
haven't yet gotten to the forward segregation of the supply
chain when we ship and distribute goods to the grocery store,
which again, would require segregation.
So the reason we are so supportive of a voluntary national
labeling standard, the Pompeo-Butterfield bill that was offered
last year, is it makes order out of that potential chaos or
complexity and saves cost.
Mr. David Scott of Georgia. Thank you, sir. Thank you, Mr.
Chairman.
The Chairman. The gentleman yields back. Mr. Bost, for 5
minutes.
Mr. Bost. Thank you, Mr. Chairman. First off, we probably
went down this earlier, but I have been bouncing in and out of
the room. Mr. Policinski, I would like to know if I can what
your company is already--because Vermont has already passed a
law. Are you preparing already and whether those costs that you
are seeing and everything for one state and how you are going
to handle it. Because I know we have talked about three
different options that could be available. And where are you
going with that at this time?
Mr. Policinski. Congressman, we did talk about this and the
bottom line is we have not decided. There are no good choices.
The three choices that are often mentioned are don't ship to
that state. Well, let me remind you that it is Vermont right
now, but there are 26 states with pending legislation
Mr. Bost. That is pending, yes.
Mr. Policinski. Second, labeling or segregation, the second
and third choices, are difficult and costly as I just tried to
explain. I also want to outline, and you may have been out of
the room when we talked about this, that the idea of not
shipping to a state like Vermont is really a non-starter in my
opinion because of the legal liability. Let us say that was a
choice we made, which I am not advocating that. We would still
be held accountable for the fact that any of the products we
might ship to neighboring states would show up in Vermont, and
the penalty there is substantial. I believe the Vermont
legislation has a penalty of $1,000 per day per SKU. That is a
very substantial penalty. And by the way, that is enforced by
the Vermont Attorney General's Office, not the usual regulatory
bodies that we work with because it is a violation of their
law.
So this is a very onerous situation. In all these paths,
there are no good decisions there. They are all higher-cost
decisions.
Mr. Bost. Mr. Dempsey, did you want to----
Mr. Dempsey. Let me just add that supermarkets are national
in scope as well. So the decision not to sell in Vermont is
more complicated by how you bring your product to market,
whether it is DSD, direct store delivery, or through warehouse
distribution.
If you are shipping product into an Ahold store in
Massachusetts, the Stop and Shop, the chances of that product
being sent erroneously to Vermont are magnified many times so
that you have supermarkets that are operating in four or five
or six different states but the burden, at least in Vermont's
law, is on the manufacturer to make sure that your product is
not on those shelves.
It really becomes a liability to the manufacturer to even
ship to a grocery store who is doing business in many states.
So there are a whole bunch of repercussions that come out of
that system.
Mr. Bost. Just to continue and maybe even a statement as I
am continuing questions, as we deal with GMOs, okay, in our own
family, we have had to deal with gluten-free. My wife is
gluten-free. Companies automatically, voluntarily, mark their
products as gluten-free to encourage the sales of those to
those who are. What would be the difference here in this,
proposing that it would be voluntary?
Mr. Dempsey. A broader statement is that companies make
products to sell them, and whatever they can do to sell them,
to entice the consumer to purchase them, they are going to do,
whether it is to go for organic certification or whether it is
to go for GMO-free or to manufacture products that are gluten-
free. That information for that segment of the market is
available from a marketing perspective of those companies. I
see no difference between that and labeling everything else
that this does contain gluten which is already in the
nutritional----
Mr. Bost. That is right. Thank you, Mr. Chairman. I yield
back.
The Chairman. Thank you. The gentleman yields back. Mr.
Walz, for 5 minutes?
Mr. Walz. Thank you, Mr. Chairman, and thank you all for
your testimony. I think it is appropriate we are here.
Tomorrow, March 25, would have been the 101st birthday of
Minnesota graduate and researcher, Norman Borlaug, so the
discussion we are having falls directly into that. And I am
appreciative of all of your time and effort.
I would point out, and we are trying to get to the heart of
this, our responsibility in Congress and our responsibility I
would argue each of you is to define a problem, gather the
information, and then make correct assumptions to that, and
that is what we are trying to get at.
January 2015 Pew Research Center study came out and showed
that 89 percent of scientists believe that GMOs are safe, that
37 percent of the public did. And I am going to come back to
this. Yes, it is the 800 pound gorilla in the room, but the
science and the preponderance of the evidence on this seems to
warrant where we are headed. And we can get into this issue
with Norman Borlaug's position, with 12 billion people on the
horizon for 2100, with the idea of how we are going to feed
these people, but the problem we have in this place is you
can't be selective when the preponderance of the evidence shows
something. And we do that. And there better be some soul
searching on both sides of the aisle on this, as to let the
science and the research drive us to come up with conclusions
that work. And it is important, both for consumer safety and
sense of fairness.
The point was brought up, Mr. Clarkson's point about
ratcheting down the rhetoric is exactly it. But while I would
make the argument, and I respectfully say, that the Chairman
will run his Committee as he wants to. The questions that Mr.
McGovern brought up, there should be some dissenting voices
here or we end up in the situation like the outlandish
situation in Florida where state officials can't talk about
climate change. Well, you give a perception that there is
something you don't want people to talk about. The evidence is
clearly here that this is a way to feed people. It always has
been. It is as much about Mesopotamia as it is about Monsanto,
and that is the discussion that we have to have and have fairly
so that we can make good decisions.
And I am just troubled that we will go down a road. And
there are some interesting things. Dr. Federoff, you brought up
a good point. This one has always gotten me a little bit.
Orange juice, for example, the Florida citrus folks, and they
want to sell them. They label no GMOs on there. There are no
GMO oranges. But here is the thing. There may need to be soon
with the greening, the citrus greening disease, that is coming.
So they may regret that decision that we are going to end up
with those eventually, because of this new entrance into the
environment.
So I applaud all of you for being here. I would ask my
colleagues, this gives us an opportunity to reset on some of
these things. You can't say, wow. The preponderance of the
evidence and the scientific consensus is nearly whole on this
issue and then walk to another committee room and have the
exact same folks. Now, I get it. There is 11 percent of
scientists here. I bet you they are not egronimous that are
part of that. And to bring in someone else in an unrelated
field and use that, that is the outlier that Dr. Federoff said,
and we are going to base our decisions on that. Because I would
make this argument here as feeding the world's population,
continuing to advance, continuing to do. The things you do is
feed, clothe, and power the world, is going to involve a
simultaneous discussion on climate change as it deals also with
GMOs. And I wish we would have the maturity, the ability to be
able to do what you all have clearly laid out today.
And Ms. Lidback, I apologize for those people who would
question you because you have the audacity to talk about the
science. Trust me, it happens on other issues, too,
unfortunately. But your willingness to come here and speak
about this and talk about it, and the powerful thing here, too,
just hearing this, the organic folks can make three times more.
Well, good for them if they are going to be able to. And that
is where we are at. We are not trying to stop that.
But it is an important point and an important discussion
that we cannot drive policy, whether it is on labeling or how
we go about things that is not based on the evidence, that is
not based on research, because that will lead to bad outcomes
all the way around.
So I want to thank each of you for being here. I want to
ask my colleagues to have the courage to discuss these things
as they are and then to come up with good solutions. And that
shouldn't be all that difficult. The good news here is that our
producers continue to be the most productive in the world. Our
researchers continue to be the most innovative, and we are able
to provide the most abundant, safest, affordable food supply in
the world, and we can do that around the world. So this is an
important discussion. It is broad, it is important, and I
applaud each of you for continuing to bring it to the forefront
and hopefully we will get a good solution for you and for the
consumers. Thank you.
The Chairman. The gentleman yields back. Mr. Emmer, for 5
minutes?
Mr. Emmer. Thank you, Mr. Chairman. And first to the panel,
thank you for being here. And I apologize. I had to step out
and come back. This is quite an operation in this place. You
have several meetings all at the same time in different
buildings, and there must be a better way to run the train
station.
Be that as it may, I respect your time. Listening to my
colleague from Minnesota talk about there should be dissenting
voices in the room, most of us would agree that if the world
would just agree with our position, it would be a much better
place to live in. But that doesn't happen. And somebody can
correct me, but it was Bobby Kennedy that said something to the
effect that if you can get the American public, 80 percent of
the American public to agree on anything, that should be
considered unanimous. And in this case, when you have 90
percent of the science out there agreeing, that is pretty close
to being unanimous.
I want to go at this very quickly from a different--again,
forgive me if somebody has already done this. I wasn't here. So
please be patient with me. I want to go at it from the specific
costs and break it down by level.
Mrs. Lidback, you are running a dairy operation. You have
costs that are going to be added on for--you talked about the
inputs when I was here earlier. You were talking about the cost
of feed. Aren't there other costs in terms of having to manage
and record, get inspections, certification. Have you talked
about those already today?
Ms. Lidback. No. So beyond the feed, I mean, to keep milk
segregated from cows fed non-GMO feed versus feed with GM, you
would have to put in a second bulk tank and you have to put in
a second grain bin. And so you are talking about capital
expenditures, and as you can imagine, on a 50 cow dairy, there
is really not a whole lot of extra left to go around to sort of
fulfill those needs so that kind of consideration might be a
deal-breaker for us.
Mr. Emmer. Wow, and I was just thinking, labor. You and
your husband are going to have to have some more kids in order
to do this thing.
Mr. Dempsey and anybody else, I want to go to the next
level because we have the processors, those that have to put
these products out. You talked about two lines, but it is much
greater than that, isn't it? Aren't you going to have to hire
all kinds of new staff to keep track of all these things? And
then there are storage costs?
Mr. Dempsey. Yes. The answer is the two lines refer to just
having one state that mandated the labeling and everybody else
who didn't. So there is significant input, depending on the
number of states who have different regulations. But yes, all
up and down the line as we talked, our grain is kept in masa,
it is kept in separate silos. You have to have separate silos
for that. The distribution changes would be significant because
you have to keep track of various different strains of products
going to different states, the same product but labeled
differently. So the multipliers in cost come up with how many
different labels you have to keep and how many different
infrastructure you need to build to hold those.
Mr. Emmer. Very quickly because this just adds, it
compounds, as you go each level. And it wouldn't be fair if I
didn't go to the Minnesota guy with the time that I have left.
Mr. Policinski, farmers are interested in operating a
business, raising their families. They want to produce quality
product that can be sold the world over. I imagine in the
farmers that I know, they don't much care for the litigation
system if they can stay away from it. What are the concerns and
the costs that could be put into this at every level when you
talk about the legal ramifications? Aren't those just as big?
Mr. Policinski. Yes. First, farmers are pretty savvy
businessmen, and they have adopted this technology at record
pace. Of all the technologies over all the years, this has been
the one that has been adopted by farmers the most quickly and
it is because they see the benefits so clearly to their
operations, to the environment, less land and water, and to
cost, to consumers. I think farmers have voted.
What we are trying to do here in the discussion is preserve
their choice of how they want to farm as well as provide
consumer choice. And again, the Pompeo-Butterfield legislation
that was proposed clearly affords that opportunity through
developing a national standard----
Mr. Emmer. Right.
Mr. Policinski.--and a voluntary national standard. I think
your comment on legal costs would pass through the system to
ownership, and in our instance, we are a farmer-owned company.
Mr. Emmer. Right.
Mr. Policinski. We did have a discussion a couple of times
now on how onerous it is to have a state law or a series of
state laws, and if you chose not to serve those areas, the
implications of legal liability would be very onerous.
Ms. Lidback. Can----
Mr. Emmer. And at the end of the day, it all gets passed
onto the consumer. I am sorry, Ms.--
Ms. Lidback. No, it is okay. I just wanted to add, Mr.
Emmer, when I was trying to locate a non-GMO source for grain,
I first of course started my own grain company, and they simply
don't have the capacity either. They are already satisfying an
organic grain distribution system as well as conventional. So
they don't have the capacity for a non-GMO option, either
Mr. Emmer. And again. Thank you all. My time has expired.
Mr. Chairman and to the Ranking Member, thank you for having
this hearing because it seems like everybody here is interested
in a win/win for everybody.
The Chairman. Thank you. The gentleman's time has expired.
Mr. Costa, 5 minutes?
Mr. Costa. Thank you very much, Mr. Chairman. I think this
is not only a critical issue here in our country but also as it
relates to the labeling issues, a critical issue as we
negotiate these trade agreements, both with the European allies
and as well as in Asia.
I, Mr. Schmidt, was interested in your comments earlier on
in terms of the polling sampling that you have taken and
undergone, and what it really made me think about--and Dr., is
it----
Dr. Fedoroff. Federoff.
Mr. Costa. Dr. Federoff, is our lack of consumer education
related to risk assessment or risk management? If it were not
for all of the technology that we have employed post-World War
II with regards to food and food safety, we would not have the
longevity or the healthy lifestyle that we enjoy today. While
we have problems with obesity and other things, it is more
related to choices people make, as opposed to the quality of
the food that we have.
How can we do a better job in educating folks about the
better level of quality and the technologies that have been
employed to make foods healthier and safer today?
Mr. Schmidt. Well, thank you. I think you have identified
some of the things that have come forward today, that this is
not a science debate or a safety debate. It has come down to a
communications debate. And sometimes as you indicated, people
are faced with fear and risk, and it has almost become a cult
following among some to oppose this technology without any
demonstration of actual harm or safety risks.
And so there needs to be even more leadership, whether it
is Congress and the Administration, the industry, or academia
to speak up, to have the bravery like Ms. Lidback to be
steadfast with the facts, and there is strength in numbers. So
the more people----
Mr. Costa. A lot of the food processors and other companies
and agricultural associations have tried to do education. I
don't think it has been well-coordinated. But we do see that on
occasion.
When you talked about 97 percent of the scientists, Dr.
Federoff, were you talking about the safety of genetically
modified foods? The general perception is obviously not at that
level in terms of safety?
Dr. Fedoroff. Indeed. This is the pith hole that needs to
be addressed by scientists across the board. That includes
physicists and psychologists and economists and so forth. If
you polled the claims of biologists who have used these
techniques, you will be closer to 100 percent.
But that is not the issue. I think as Mr. Schmidt
identified, it is more about communication. And the problem is
that our current system which has very big regulatory costs to
get a GM product to market prevents academic scientists,
scientists in public research institutions, from getting
genetically modified----
Mr. Costa. This is a real challenge.
Dr. Fedoroff.--for example. Right.
Mr. Costa. Especially in Europe right now.
Dr. Fedoroff. You bet.
Mr. Costa. We have a process for it. We have only been able
to register a limited amount, and it is a lengthy and
cumbersome process.
Dr. Fedoroff. Correct.
Mr. Costa. Trying to get agreement on the best science is
always a challenge, and in some cases, let us be frank, it is
used for basically leverage purposes as it relates to trade.
Dr. Fedoroff. Absolutely. But let us just talk about here
in the United States. If we could manage to make the process
less onerous based on the accumulation of almost 40 years of
research now, it would be possible to vet genetically modified
fruits and vegetables. So a colleague of mine in England has
developed a beautiful wine red tomato which is better for you
because it has the same kinds of compounds in it that you have
in blackberries and blueberries which are good for you. When
people----
Mr. Costa. My time is almost up.
Dr. Fedoroff. Okay. So familiarity, we don't have those----
Mr. Costa. No, I know.
Dr. Fedoroff.--products in the market.
Mr. Costa. Ms. Lidback, as a person who grew up on a
Portuguese dairy farm, I want to commend you for your efforts
and encourage you to stay with it. I, too, know what to do
with, the word manure. I grew up in that same setting as you
and your family. I want to commend you and encourage you for
your efforts and your courage to testify here today.
The Chairman. The gentleman's time has expired. Mr. Yoho,
for 5 minutes.
Mr. Yoho. Thank you, Mr. Chairman, and Mr. Costa, being a
veterinarian, large animal practitioner that earned a living on
the south end of a north-bound horse or cow, it wasn't manure.
It was fertilizer until it hit the ground.
I appreciate you all being here, and we as the people in
government--because government is a non-entity. It is only as
good as the people that are involved in it, in all branches of
it, that we need to do a better job on educating both us and
government and the public on educating people and in public
venues to get the best, the current, and the correct
information out to the public that is updated and is based on
peer-reviewed science, and it is stemming from accurate
research. And we also need to do a better job of making current
the information and policies on a website of what a GMO is and
what it is not and keep agendas or politics out of it and let
the facts speak for themselves.
Dr. Federoff, if you could take us briefly through the
process of taking a genetically modified product from the
beginning to the market in less than a minute, I would be
really appreciative if you could. But just the research that
goes behind that before it is approved.
Dr. Fedoroff. Okay. Let me try to summarize it really
quickly. So to begin with, you have to identify the gene that
you want to introduce. You have to introduce it into the
organism. This is not a trivial process for a plant such as
corn. You make a lot of these, put them in the greenhouse,
figure out which ones and you take bits of the plant and you
analyze it genetically by DNA sequencing and so forth. But then
you have to check everything from testing the product of the
gene for toxicity and allergenicity to putting together all of
the dossiers that are required by the various agencies that
need to approve that product. In some cases it has to be the
EPA, the FDA, and the USDA.
Mr. Yoho. And the USDA.
Dr. Fedoroff. Okay? And in the case of animals, genetically
modified animals, like AquaBounty salmon, it is even more
onerous because the FDA has decided to regulate them like
drugs.
Mr. Yoho. And what you have done is adequate because it is
years of research, years of studies, years of feed studies, and
then the tissue samples and all those things that come with
that, and it costs millions if not billions of dollars, and it
finally does get the approval of USDA, the FDA, the EPA. We
have a variety in Florida of a papaya that they have been
working on for 10 years for rig spot virus. The EPA signed off
on it. But yet, it is still not to market because of this GMO
scare around it, and it needs to be approved.
With the studies, are you aware of any peer-reviewed real
studies that you know of that have proven to be deleterious or
detrimental effects on humans, animals, plants, or the
environment----
Dr. Fedoroff. None.
Mr. Yoho.--of a product.
Dr. Fedoroff. There are occasional----
Mr. Yoho. What was that?
Dr. Fedoroff. None.
Mr. Yoho. I just wanted to hear it again so----
Dr. Fedoroff. Yes.
Mr. Yoho.--so everybody heard that. None.
Dr. Fedoroff. None. There are occasional anecdotal reports.
Mr. Yoho. Anecdotal.
Dr. Fedoroff. Very often, the publication is retracted or
never gets published but gets into the social media and
Internet and stuff.
Mr. Yoho. Let me ask you all this. Would a GMO that had any
deleterious effects to humans, animal, plants, or the
environment ever get approved by the USDA, FDA, or EPA? So
there was really--the science is on our side on these
labelings. It is a marketing thing. So if a GMO has been
approved by the USDA, one should rest assured that that product
is as safe as any non-GMO product or it wouldn't be out there.
In addition, we have been doing GMOs for 20, 30, 40 years.
Mother Nature has been doing it since the beginning of time. We
would not have wheat had the plants not cross-pollinated to
form the wheat we have today, and tomatoes, as we know, comes
from a toxic source, so do potatoes, the Solana family. And
they are toxic. They are related to nightshade.
Dr. Fedoroff. You bet.
Mr. Yoho. Yet through genetic modification of Mother
Nature, they have healed themselves, and we have what we have.
And if we didn't have the GMOs today, I would hate to think
what the food security of this world would be. In my home State
of Florida when I graduated from veterinary college, we
produced about 75 bushels of corn. That was a great yield.
Today we are doing 250 to 275 bushels of corn on poor soil, and
therefore, the common sense of the sound science that leads to
the approval of the GMOs should not be overshadowed by the
environmental McCarthyism of the anti-GMO crowd. And I just
want to thank you for being out there, for being in the fight,
and for standing up, Ms. Lidback. Like last time when we talked
about this, we got a lot of hate mail. Hang tough because you
are on the right side of the science. Thank you.
Mr. Chairman, I yield back.
The Chairman. Ms. Adams?
Ms. Adams. Thank you, Mr. Chairman, and thank you to our
guests today. There has been a lot of confusion over what
qualifies as a label for food that contains ingredients derived
from a GMO. Consumers I believe deserve to know what is in
their food, but it is also necessary that FDA implement
regulations to ensure that the labeling of GMO products is fair
and standardized and transparent. Market-driven labeling
ensures that the information they demand about the food being
sold is clear and accurate without the confusion of dozens of
different labels.
Mr. Clarkson, your testimony indicated that the best way to
support consumers is through a national standard that includes
a voluntary labeling program. So if the program is voluntary,
how long would you expect for retailers and producers to begin
participating in the program?
Mr. Clarkson. Well, there are quite a few retailers and
processors participating in private programs right now that
would quickly switch to a national definition enforced by the
USDA. So I would expect within a year you would see very
significant movement toward the national standard usage.
Ms. Adams. As a follow-up, GMO crops are often sprayed with
high amounts of herbicide since they can survive being sprayed
in Round-Up. This may wash into lakes and streams. Mother
Nature eventually takes its course and weeds may become
resistant to a chemical, thus requiring the use of more toxic
herbicides.
Here is my question: how can we work with farmers to
improve crop rotation so that weeds don't become resistant to
herbicides so quickly?
Mr. Clarkson. That would involve using multiple approaches
to weed control rather than a single approach. It would involve
rotations of crops. It would involve use of cover crops, all of
which are projects that are under way. And we are starting to
see benefits from those.
Ms. Adams. Thank you. Mr. Schmidt, last summer your group
conducted a survey to engage Americans' views of foods
containing bioengineered ingredients. How do consumers view the
current FDA policy allowing voluntary labeling for food
products through biotechnology?
Mr. Schmidt. Thank you, Ms. Adams. Our survey found that 63
percent of U.S. consumers support the current FDA policy that
says that there should not be any special labeling of foods
produced through biotechnology unless there is a change in the
nutritional content, introduction of a safety issue such as an
allergen, and even then, you would identify what that change
was, not the process used to produce the product. And so
Americans do--so it is a case of when you explain information
and give consumers credit, they tend to understand it and
support it.
Ms. Adams. All right. Thank you very much, and Mr.
Chairman, I yield back.
Mr. Austin Scott of Georgia [presiding]. Thank you for
being here, ladies and gentlemen, and I will try to be brief.
One of my concerns is not only that this labeling stop at the
state level but that you could actually see individual counties
and municipalities trying to come up with their own labeling
standards. And therefore, you have six, seven, eight different
standards in any given state. That would obviously have a
tremendous impact on business owners, the grocery retailers, on
the one side of the county line or city limit sign versus those
who were on the other side.
I would typically steer toward states' rights on these
issues. This is one where I do believe that without a uniform
standard, we are going to see tremendous increases in the cost
of groceries for the American citizen.
I will also tell you that this is a perception issue, and
the more times we use the initials GMO or genetically modified,
the worse it is for us. The term biotechnology, is a more
accurate description of what we are using to get across where
we actually use less pesticides and less herbicides. We don't
want to put those things on our land. They cost money to apply
them, and we as farmers want a clean environment as well.
It is interesting this past week as I listened--my wife and
I were blessed to have a little girl, and I listened to the
midwife as she was talking about groceries in making sure that
they had no GMOs, and at the same time she turned around and
recommended a tremendous number of things that were also
products of biotechnology. And my wife suggested I shouldn't
say anything to her because she might be delivering our
daughter, but now that our daughter is here, I am free to say
some of those things.
But the misperception out there has to be addressed.
Biotechnology has made our life better, whether it is through
pharmaceuticals or whether it is through our crops. And if I go
to the Land O' Lakes' website, I can look up Land O' Lakes
butter, and I know exactly what is in the products that I am
consuming. This isn't about what is in the products that we
eat. It is about what is in the seed that is planted. And I
wonder if the same advocates for the labeling of our food
supply, why aren't they suggesting that it should be done in
our pharmaceutical supply as well because those are the things
that we ingest.
So again, just reiterating, and Mr. Schmidt, I will go to
you since we are down to 2 minutes. The use of biotechnology
for our food and agriculture and pharmaceutical products have
made our lives better. We are living longer than we ever have.
Americans eat hundreds of millions of meals a day, literally.
And my question is, how would it impact our ability to provide
affordable and nutritious food to the American families, and
would it not raise the cost of food, thereby hurting low-income
Americans more than anybody, if we are not able to come up with
a uniform labeling standard?
Mr. Schmidt. I have to say we have not done the economic
studies ourselves, but you have heard some very compelling
testimony from the panel regarding the economics of this, I
just think in general everyone wants to provide an informed
choice for consumers, but that word informed is critical. And
too often we are allowing misinformed choices out there by not
standing up and correcting misinformation in the marketplace.
So that is the opportunity to be transparent, to provide as
much information as possible that meets consumer interest and
demand, while also keeping the marketplace fair for accurate
information on food and nutrition.
Mr. Austin Scott of Georgia. Do you see any movement to
label anything other than agricultural products with the same
type of skull and crossbones, if you will?
Mr. Schmidt. Yes. As a communications group we hear ideas
about labeling lots of different things. We know other
industries--there has been some discussion about the alcohol
industry, some calling for labeling there as well. You can ask
consumers in general, would you like X to be labeled, and if
you make it sound scary enough, everyone is going to say yes.
And that is the thing about technology. It is easy to make it
sound scary. Maybe it is less interesting to say that it is
safe and effective, but those are the facts.
Mr. Austin Scott of Georgia. Well, the fact that Americans
eat hundreds of millions of meals a day and we spend less for
food than virtually any other industrialized nation out there
is proof that what we have been doing is working, and if it
wasn't, our life expectancy wouldn't be continuing to expand.
So thank you very much for being here. With that, I will
turn it back over to the big Chairman.
The Chairman [presiding]. I want to thank the panel for
being here today. Dr. Federoff, a couple of things.
You were about to finish your comments about Round-Up and
also from responding to Ms. Adams' comments--she had some
question about Round-Up or glyphosate that you were going to
answer. Did you have any comments about that one statement that
came out Friday?
Dr. Fedoroff. Only that the preponderance of studies shows
it to be safe and not carcinogenic. The current ruling of the
UN body, the cancer, IARC or something like that, is not based
on any new information.
The Chairman. Okay. The overall weight, just to be crystal
clear, the overall weight, the preponderance of the evidence,
is that--and I am going to get with Mr. Schmidt. I want to use
your bioengineered, genetically engineered--the weight, Dr.
Federoff, is that it is safe and that it is--I am just using in
reference to Mr. Schmidt because he told me to use something
other than GMO because that is fairly pejorative.
Voice. He wants you to----
The Chairman. Let us just stay with you, Dr. Federoff. The
preponderance of the science is that bioengineered--
Dr. Fedoroff. The food----
The Chairman.--processing is safe.
Dr. Fedoroff. The current biotechnologically altered food
crops and potentially animals are as safe as their non-GM
counterparts.
The Chairman. All right.
Dr. Fedoroff. I am afraid that GM label is going to stick.
It is the fastest thing to call it.
The Chairman. I got you. Well, again, we thank the panel
for coming today and spending your time with us. Ms. Lidback, I
hope it doesn't repeat your experience from last year, and if
it does, well, it is a shame. It is unfortunate, because we
could all have differences of opinion. Dr. Federoff, you said
those opinions ought to be based in fact. We don't have any
requirement for that, but it ought to be the case, and we hope
that this hearing today sheds some light on a really important
issue.
Well, for those on the Committee, the record of today's
hearing will remain open for 10 calendar days to receive
additional material and supplementary written responses from
the witnesses to any questions posed by a Member. This hearing
of the Committee on Agriculture is adjourned.
[Whereupon, at 12:12 p.m., the Committee was adjourned.]
[Material submitted for inclusion in the record follows:]
Submitted Articles by Hon. James P. McGovern, a Representative in
Congress from Massachusetts
International Agency for Research on Cancer (IARC), World Health
Organization
IARC Monographs Volume 112: Evaluation of Five Organophosphate
Insecticides and Herbicides
20 March 2015
Lyon, France, 20 March 2015--The International Agency for Research
on Cancer (IARC), the specialized cancer agency of the World Health
Organization, has assessed the carcinogenicity of five organophosphate
pesticides. A summary of the final evaluations together with a short
rationale have now been published online in The Lancet Oncology,* and
the detailed assessments will be published as Volume 112 of the IARC
Monographs.
---------------------------------------------------------------------------
* Editor's note: the referenced summary is included as attachment.
---------------------------------------------------------------------------
What were the results of the IARC evaluations?
The herbicide glyphosate and the insecticides malathion and
diazinon were classified as probably carcinogenic to humans (Group 2A).
The insecticides tetrachlorvinphos and parathion were classified as
possibly carcinogenic to humans (Group 2B).
What was the scientific basis of the IARC evaluations?
The pesticides tetrachlorvinphos and parathion were classified as
possibly carcinogenic to humans (Group 2B) based on convincing evidence
that these agents cause cancer in laboratory animals.
For the insecticide malathion, there is limited evidence of
carcinogenicity in humans for non-Hodgkin lymphoma and prostate cancer.
The evidence in humans is from studies of exposures, mostly
agricultural, in the USA, Canada, and Sweden published since 2001.
Malathion also caused tumours in rodent studies. Malathion caused DNA
and chromosomal damage and also disrupted hormone pathways.
For the insecticide diazinon, there was limited evidence of
carcinogenicity in humans for non-Hodgkin lymphoma and lung cancer. The
evidence in humans is from studies of agricultural exposures in the USA
and Canada published since 2001. The classification of diazinon in
Group 2A was also based on strong evidence that diazinon induced DNA or
chromosomal damage.
For the herbicide glyphosate, there was limited evidence of
carcinogenicity in humans for non-Hodgkin lymphoma. The evidence in
humans is from studies of exposures, mostly agricultural, in the USA,
Canada, and Sweden published since 2001. In addition, there is
convincing evidence that glyphosate also can cause cancer in laboratory
animals. On the basis of tumours in mice, the United States
Environmental Protection Agency (http://www.epa.gov/opp00001/
chem_search/cleared_reviews/csr_PC-103601_30-Oct-91--265.pdf) (U.S.
EPA) originally classified glyphosate as possibly carcinogenic to
humans (Group C) in 1985. After a re-evaluation of that mouse study,
the U.S. EPA changed its classification to evidence of non-
carcinogenicity in humans (Group E) in 1991. The U.S. EPA Scientific
Advisory Panel noted that the re-evaluated glyphosate results were
still significant using two statistical tests recommended in the IARC
Preamble (http://monographs.iarc.fr/ENG/Preamble/index.php). The IARC
Working Group that conducted the evaluation considered the significant
findings from the U.S. EPA report and several more recent positive
results in concluding that there is sufficient evidence of
carcinogenicity in experimental animals. Glyphosate also caused DNA and
chromosomal damage in human cells, although it gave negative results in
tests using bacteria. One study in community residents reported
increases in blood markers of chromosomal damage (micronuclei) after
glyphosate formulations were sprayed nearby.
How are people exposed to these pesticides?
Tetrachlorvinphos is banned in the European Union. In the USA, it
continues to be used on livestock and companion animals, including in
pet flea collars. No information was available on use in other
countries.
Parathion use has been severely restricted since the 1980s. All
authorized uses were cancelled in the European Union and the USA by
2003.
Malathion is currently used in agriculture, public health, and
residential insect control. It continues to be produced in substantial
volumes throughout the world. Workers may be exposed during the use and
production of malathion. Exposure to the general population is low and
occurs primarily through residence near sprayed areas, home use, and
diet.
Diazinon has been applied in agriculture and for control of home
and garden insects. Production volumes have been relatively low and
decreased further after 2006 due to restrictions in the USA and the
European Union. Only limited information was available on the use of
these pesticides in other countries.
Glyphosate currently has the highest global production volume of
all herbicides. The largest use worldwide is in agriculture. The
agricultural use of glyphosate has increased sharply since the
development of crops that have been genetically modified to make them
resistant to glyphosate. Glyphosate is also used in forestry, urban,
and home applications. Glyphosate has been detected in the air during
spraying, in water, and in food. The general population is exposed
primarily through residence near sprayed areas, home use, and diet, and
the level that has been observed is generally low.
What do Groups 2A and 2B mean?
Group 2A means that the agent is probably carcinogenic to humans.
This category is used when there is limited evidence of carcinogenicity
in humans and sufficient evidence of carcinogenicity in experimental
animals. Limited evidence means that a positive association has been
observed between exposure to the agent and cancer but that other
explanations for the observations (called chance, bias, or confounding)
could not be ruled out. This category is also used when there is
limited evidence of carcinogenicity in humans and strong data on how
the agent causes cancer.
Group 2B means that the agent is possibly carcinogenic to humans. A
categorization in Group 2B often means that there is convincing
evidence that the agent causes cancer in experimental animals but
little or no information about whether it causes cancer in humans.
Why did IARC evaluate these pesticides?
The IARC Monographs Programme has evaluated numerous pesticides,
some as recently as 2012 (anthraquinone, (http://monographs.iarc.fr/
ENG/Monographs/vol101/mono101-001.pdf) arsenic and arsenic compounds
(http://monographs.iarc.fr/ENG/Monographs/vol100C/mono100C-6.pdf)).
However, substantial new data are available on many pesticides that
have widespread exposures. In 2014, an international Advisory Group
(http://www.thelancet.com/journals/lanonc/article/PIIS1470-
2045%2814%2970168-8/fulltext) of senior scientists and government
officials recommended dozens of pesticides for evaluation. Consistent
with the advice of the Advisory Group, the recent IARC meeting provided
new or updated evaluations on five organophosphate pesticides.
How were the evaluations conducted?
The established procedure for Monographs evaluations is described
in the Programme's Preamble (http://monographs.iarc.fr/ENG/Preamble/
index.php). Evaluations are performed by panels of international
experts, selected on the basis of their expertise and the absence of
real or apparent conflicts of interest. For Volume 112, a Working Group
of 17 experts from 11 countries met at IARC on 3-10 March 2015 to
assess the carcinogenicity of tetrachlorvinphos, parathion, malathion,
diazinon, and glyphosate. The in-person meeting followed nearly a year
of review and preparation by the IARC secretariat and the Working
Group, including a comprehensive review of the latest available
scientific evidence. According to published procedures (http://
monographs.iarc.fr/ENG/Preamble/index.php), the Working Group
considered ``reports that have been published or accepted for
publication in the openly available scientific literature'' as well as
``data from governmental reports that are publicly available''. The
Working Group did not consider summary tables in online supplements to
published articles, which did not provide enough detail for independent
assessment.
What are the implications of the IARC evaluations?
The Monographs Programme provides scientific evaluations based on a
comprehensive review of the scientific literature, but it remains the
responsibility of individual governments and other international
organizations to recommend regulations, legislation, or public health
intervention.
Media inquiries: please write to [email protected]. Thank you.
attachment
www.thelancet.com/oncology Published online March 20, 2014 http://
dx.doi.org/10.1016/S1470-2045(15)70134-8
News
---------------------------------------------------------------------------
Lancet Oncol. 2015 Published Online March 20, 2015 http://
dx.doi.org/10.1016/S1470-2045(15)70134-8.
For more on the IARC Monographs see http://monographs.iarc.fr.
Upcoming meetings
June 2-9, 2015, Volume 113: Some organochlorine insecticides and
some chlorphenoxy herbicides
Oct. 6-13, 2015, Volume 114: Red meat and processed meat
Monograph Working Group
Members
A. Blair (USA)--Meeting Chair; L. Fritschi (Australia); J.
McLaughlin; C.M. Sergi (Canada); G.M. Calaf (Chile); F. Le Curieux
(Finland); I. Baldi (France); F. Forastiere (Italy); H. Kromhout
(Netherlands); A.`t Mannetje (New Zealand); T. Rodriguez [unable to
attend] (Nicaragua); P. Egeghy [unable to attend], G.D. Jahnke; C.W.
Jameson; M.T. Martin; M.K. Ross; I. Rusyn; L. Zeise (USA)
Invited Specialists
C. Portier (Switzerland)
Representatives
M.E. Gouze, for the French Agency for Food, Environment and
Occupational Health and Safety (France); J. Rowland, for the U.S.
Environmental Protection Agency (USA)
Observers
M.K. Boye Jensen, for Cheminova (Denmark); B. Fervers, for the
Leon Berard Centre (France); E. Giroux, for University Jean-Moulin Lyon
3 (France); T. Sorahan, for Monsanto Company (USA); C. Strupp, for the
European Crop Protection Association (Belgium); P. Sutton, for the
University of California, San Francisco (USA)
IARC/WHO Secretariat
L. Benbrahim-Tallaa; R. Carel; F. El Ghissassi; Sonia El-Zaemey;
Y. Grosse; N. Guha; K.Z. Guyton; C. Le Cornet; M. Leon; D. Loomis; H.
Mattock; C. Scoccianti; A. Shapiro; K. Straif; J. Zavadil
For the Preamble to the IARC Monographs see http://
monographs.iarc.fr/ENG/Preamble/index.php.
For declarations of interests see http://monographs.iarc.fr/ENG/
Meetings/vol112-participants.pdf.
---------------------------------------------------------------------------
Carcinogenicity of tetrachlorvinphos, parathion, malathion, diazinon,
and glyphosate
In March, 2015, 17 experts from 11 countries met at the
International Agency for Research on Cancer (IARC; Lyon, France) to
assess the carcinogenicity of the organophosphate pesticides
tetrachlorvinphos, parathion, malathion, diazinon, and glyphosate
(table). These assessments will be published as volume 112 of the IARC
Monographs.\1\
The insecticides tetrachlorvinphos and parathion were classified as
``possibly carcinogenic to humans'' (Group 2B). The evidence from human
studies was scarce and considered inadequate. Tetrachlorvinphos induced
hepatocellular tumours (benign or malignant) in mice, renal tubule
tumours (benign or malignant) in male mice,\2\ and spleen haemangioma
in male rats. Tetrachlorvinphos is a reactive oxon with affinity for
esterases. In experimental animals, tetrachlorvinphos is systemically
distributed, metabolised, and eliminated in urine. Although bacterial
mutagenesis tests were negative, tetrachlorvinphos induced genotoxicity
in some assays (chromosomal damage in rats and in vitro) and increased
cell proliferation (hyperplasia in rodents). Tetrachlorvinphos is
banned in the European Union. In the USA, it continues to be used on
animals, including in pet flea collars.
For parathion, associations with cancers in several tissues were
observed in occupational studies, but the evidence in humans remains
sparse. In mice, parathion increased bronchioloalveolar adenoma and/or
carcinoma in males, and lymphoma in females. In rats, parathion induced
adrenal cortical adenoma or carcinoma (combined),\3\ malignant
pancreatic tumours, and thyroid follicular cell adenoma in males, and
mammary gland adenocarcinoma (after subcutaneous injection in
females).\4\ Parathion is rapidly absorbed and distributed. Parathion
metabolism to the bioactive metabolite, paraoxon, is similar across
species. Although bacterial mutagenesis tests were negative, parathion
induced DNA and chromosomal damage in human cells in vitro. Parathion
markedly increased rat mammary gland terminal end bud density.\4\
Parathion use has been severely restricted since the 1980s.
The insecticides malathion and diazinon were classified as
``probably carcinogenic to humans'' (Group 2A). Malathion is used in
agriculture, public health, and residential insect control. It
continues to be produced in substantial volumes throughout the world.
There is limited evidence in humans for the carcinogenicity of
malathion. Case-control analyses of occupational exposures reported
positive associations with non-Hodgkin lymphoma in the USA,\5\
Canada,\6\ and Sweden,\7\ although no increased risk of non-Hodgkin
lymphoma was observed in the large Agricultural Health Study cohort
(AHS). Occupational use was associated with an increased risk of
prostate cancer in a Canadian case-control study \8\ and in the AHS,
which reported a significant trend for aggressive cancers after
adjustment for other pesticides.\9\ In mice, malathion increased
hepatocellular adenoma or carcinoma (combined).\10\ In rats, it
increased thyroid carcinoma in males, hepatocellular adenoma or
carcinoma (combined) in females, and mammary gland adenocarcinoma after
subcutaneous injection in females.\4\ Malathion is rapidly absorbed and
distributed. Metabolism to the bioactive metabolite, malaoxon, is
similar across species. Malaoxon strongly inhibits esterases; atropine
reduced carcinogenesis-related effects in one study.\4\ Malathion
induced DNA and chromosomal damage in humans, corroborated by studies
in animals and in vitro. Bacterial mutagenesis tests were negative.
Compelling evidence supported disruption of hormone pathways. Hormonal
effects probably mediate rodent thyroid and mammary gland
proliferation.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Activity (current status) Evidence in humans (cancer sites) Evidence in animals Mechanistic evidence Classification *
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Tetrachlorvinphos Insecticide (restricted in the EU and Inadequate Sufficient 2B
for most uses in the USA)
Parathion Insecticide (restricted in the USA and Inadequate Sufficient 2B
EU)
Malathion Insecticide (currently used; high Limited (non-Hodgkin lymphoma, prostate) Sufficient Genotoxicity, oxidative stress, 2A
production volume chemical) inflammation, receptor-mediated
effects, and cell proliferation or
death
Diazinon Insecticide (restricted in the USA and Limited (non-Hodgkin lymphoma, Limited Genotoxicity and oxidative stress 2A
EU) leukaemia, lung)
Glyphosate Herbicide (currently used; highest Limited (non-Hodgkin lymphoma) Sufficient Genotoxicity and oxidative stress 2A
global production volume herbicide)
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
EU=European Union. * See the International Agency for Research on Cancer (IARC) preamble for explanation of classification system (amended January, 2006). The 2A classification of diazinon
was based on limited evidence of carcinogenicity in humans and experimental animals, and strong mechanistic evidence; for malathion and glyphosate, the mechanistic evidence provided
independent support of the 2A classification based on evidence of carcinogenicity in humans and experimental animals.
Table: IARC classification of some organophosphate pesticides
Diazinon has been applied in agriculture and for control of home
and garden insects. There was limited evidence for diazinon
carcinogenicity in humans. Positive associations for non-Hodgkin
lymphoma, with indications of exposure-response trends, were reported
by two large multicentre case-control studies of occupational
exposures.\5\, \6\ The AHS reported positive associations
with specific subtypes, which persisted after adjustment for other
pesticides, but no overall increased risk of non-Hodgkin lymphoma.\11\
Support for an increased risk of leukaemia in the AHS was strengthened
by a monotonic increase in risk with cumulative diazinon exposure after
adjustment for other pesticides. Multiple updates from the AHS
consistently showed an increased risk of lung cancer with an exposure-
response association that was not explained by confounding by other
pesticides, smoking, or other established lung cancer risk factors.\12\
Nonetheless, this finding was not replicated in other populations. In
rodents, diazinon increased hepatocellular carcinoma in mice and
leukaemia or lymphoma (combined) in rats, but only in males receiving
the low dose in each study. Diazinon induced DNA or chromosomal damage
in rodents and in human and mammalian cells in vitro. Some additional
support for human relevance was provided by a positive study of a small
number of volunteers exposed to a diazinon formulation.\13\
Glyphosate is a broad-spectrum herbicide, currently with the
highest production volumes of all herbicides. It is used in more than
750 different products for agriculture, forestry, urban, and home
applications. Its use has increased sharply with the development of
genetically modified glyphosate-resistant crop varieties. Glyphosate
has been detected in air during spraying, in water, and in food. There
was limited evidence in humans for the carcinogenicity of glyphosate.
Case-control studies of occupational exposure in the USA,\14\
Canada,\6\ and Sweden \7\ reported increased risks for non-Hodgkin
lymphoma that persisted after adjustment for other pesticides. The AHS
cohort did not show a significantly increased risk of non-Hodgkin
lymphoma. In male CD-1 mice, glyphosate induced a positive trend in the
incidence of a rare tumour, renal tubule carcinoma. A second study
reported a positive trend for haemangiosarcoma in male mice.\15\
Glyphosate increased pancreatic islet-cell adenoma in male rats in two
studies. A glyphosate formulation promoted skin tumours in an
initiation-promotion study in mice.
Glyphosate has been detected in the blood and urine of agricultural
workers, indicating absorption. Soil microbes degrade glyphosate to
aminomethylphosphoric acid (AMPA). Blood AMPA detection after
poisonings suggests intestinal microbial metabolism in humans.
Glyphosate and glyphosate formulations induced DNA and chromosomal
damage in mammals, and in human and animal cells in vitro. One study
reported increases in blood markers of chromosomal damage (micronuclei)
in residents of several communities after spraying of glyphosate
formulations.\16\ Bacterial mutagenesis tests were negative.
Glyphosate, glyphosate formulations, and AMPA induced oxidative stress
in rodents and in vitro. The Working Group classified glyphosate as
``probably carcinogenic to humans'' (Group 2A).
We declare no competing interests.
Kathryn Z Guyton, Dana Loomis, Yann Grosse, Fatiha El Ghissassi,
Lamia Benbrahim-Tallaa, Neela Guha, Chiara Scoccianti, Heidi Mattock,
Kurt Straif, on behalf of the International Agency for Research on
Cancer Monograph Working Group, IARC, Lyon, France International Agency
for Research on Cancer, Lyon, France
Endnotes
\1\ International Agency for Research on Cancer Volume 112: Some
organophosphate insecticides and herbicides: tetrachlorvinphos,
parathion, malathion, diazinon and glyphosate. IARC Working Group.
Lyon; 3-10 March 2015. IARC Monogr. Eval. Carcinog. Risk Chem. Hum. (in
press).
\2\ Parker C.M., Van Gelder G.A., Chai E.Y., et al. Oncogenic
evaluation of tetrachlorvinphos in the B6C3F1 mouse. Fundam. Appl.
Toxicol. 1985; 5: 840-54.
\3\ National Toxicology Program. Bioassay of parathion for possible
carcinogenicity. Natl. Cancer. Inst. Carcinog. Tech. Rep. Ser. 1979;
70: 1-123.
\4\ Cabello G., Valenzuela M., Vilaxa A., et al. A rat mammary
tumor model induced by the organophosphorous pesticides parathion and
malathion, possibly through acetylcholinesterase inhibition. Environ.
Health Perspect. 2001; 109: 471-79.
\5\ Waddell B.L., Zahm S.H., Baris D., et al. Agricultural use of
organophosphate pesticides and the risk of non-Hodgkin's lymphoma among
male farmers (United States). Cancer Causes Control 2001; 12: 509-17.
\6\ McDuffie H.H., Pahwa P., McLaughlin J.R., et al. Non-Hodgkin's
lymphoma and specific pesticide exposures in men: cross-Canada study of
pesticides and health. Cancer Epidemiol. Biomarkers Prev. 2001; 10:
1155-63.
\7\ Eriksson M, Hardell L, Carlberg M, Akerman M. Pesticide
exposure as risk factor for non-Hodgkin lymphoma including
histopathological subgroup analysis. Int. J. Cancer 2008; 123: 1657-63.
\8\ Band P.R., Abanto Z., Bert J., et al. Prostate cancer risk and
exposure to pesticides in British Columbia farmers. Prostate 2011; 71:
168-83.
\9\ Koutros S., Beane, Freeman L.E., et al. Risk of total and
aggressive prostate cancer and pesticide use in the Agricultural Health
Study. Am. J. Epidemiol. 2013; 177: 59-74.
\10\ U.S. Environmental Protection Agency. Peer review of
malathion: 18-month carcinogenicity study in mice. http://www.epa.gov/
opp00001/chem_search/cleared_reviews/csr_PC-057701_undated_004.pdf
(accessed March 6, 2015).
\11\ Alavanja M.C., Hofmann J.N., Lynch C.F., et al. Non-Hodgkin
lymphoma risk and insecticide, fungicide and fumigant use in the
agricultural health study. PLoS ONE 2014; 9: e109332.
\12\ Jones R.R., Barone-Adesi F., Koutros S., et al. Incidence of
solid tumors among pesticide applicators exposed to the organophosphate
insecticide diazinon in the Agricultural Health Study: an updated
analysis. Occup. Environ. Med. 2015 (in press).
\13\ Hatjian B.A., Mutch E., Williams F.M., Blain P.G., Edwards
J.W. Cytogenetic response without changes in peripheral cholinesterase
enzymes following exposure to a sheep dip containing diazinon in vivo
and in vitro. Mutat. Res. 2000; 472: 85-92.
\14\ De Roos A.J., Zahm S.H., Cantor K.P., et al. Integrative
assessment of multiple pesticides as risk factors for non-Hodgkin's
lymphoma among men. Occup. Environ. Med. 2003; 60: E11.
\15\ WHO/FAO. Glyphosate. Pesticides residues in food 2004 Joint
FAO/WHO Meeting on Pesticides Residues. Part II Toxicological. IPCS/WHO
2004; 95-162. http://www.who.int/foodsafety/areas--work/chemical-risks/
jmpr/en/ (accessed March 6, 2015).
\16\ Bolognesi C., Carrasquilla G., Volpi S., Solomon K.R.,
Marshall E.J. Biomonitoring of genotoxic risk in agricultural workers
from fi ve Colombian regions: association to occupational exposure to
glyphosate. J. Toxicol. Environ. Health A. 2009; 72: 986-97.
______
Submitted Article by Hon. K. Michael Conaway, a Representative in
Congress from Texas
Bundesinstitut fur Risikobewertung
Does glyphosate cause cancer?
www.bfr.bund.de
BfR Communication No 007/2015, 23 March 2015
In its recent evaluation from March 2015, the International Agency
for Cancer Research (IARC), as the specialized cancer agency of the
World Health Organization (WHO), came to the conclusion that glyphosate
should now be classified as a carcinogenic substance in Group 2A
(probably carcinogenic to humans), based on ``limited evidence'' in
human-experiments and ``sufficient evidence'' in animal-experiments.
This classification was published in a short report in the ``Lancet''
journal on 20 March 2015.
As the ``Rapporteur Member State'' for the active substance
glyphosate within the framework of EU re-evaluation, the Federal
Institute for Risk Assessment (BfR) was responsible for the human
health risk assessment and has assessed glyphosate as non-carcinogenic.
This was supported by competent national, European and other
international institutions for health assessment including the WHO/FAO
Joint Meeting on Pesticide Residues (JMPR). BfR is therefore issuing
its comments on this classification by IARC based on the published
short report.
The International Agency for Research on Cancer (IARC) is the
specialized cancer agency of the World Health Organization. The main
objective of the IARC is to promote international collaboration in
cancer research. The evaluations of carcinogenic risk are made by
international working groups of independent scientists and are
qualitative in nature. No recommendation is given for regulation or
legislation. For this reason, 17 experts from 11 countries met at the
International Agency for Research on Cancer (IARC; Lyon, France) in
March 2015 in order to assess the carcinogenic or potentially
carcinogenic effects of four organophosphates and glyphosate. The
working group classified glyphosate as ``probably carcinogenic to
humans''. This assessment will be published as volume 112 of the IARC
Monographs.
In the opinion of BfR, the classification of glyphosate as
``carcinogenic in Group 2A'' (probably carcinogenic to humans) as
published in the 20 March 2015 issue of the ``Lancet'' journal comes as
a surprise, since other evaluations performed by supranational bodies
such as the WHO-Panel of the Joint Meeting of Pesticide residues (JMPR,
2004), and also by national regulatory agencies such as the U.S. EPA
had concluded the contrary, i.e., that glyphosate was not carcinogenic.
Unfortunately, the database on which the IARC evaluation is based is
not known, since a background monograph that is usually produced by
IARC following the evaluation meetings has not yet been released.
Therefore, a comprehensive and scientifically sound consideration of
the data and arguments that led to the IARC- conclusion is simply not
possible at the moment.
In addition, Germany is the ``Rapporteur Member State'' in the
ongoing reevaluation process of glyphosate in the EU. For this purpose,
an extensive ``Renewal Assessment Report'' (RAR) was provided in 2013
and has been revised in 2014 and again in 2015. The 2013 report was
circulated by EFSA to the EU Member States and was made available for
public consultation in 2014. Revisions were made to take into account
the several hundred comments and remarks. The toxicological and residue
chapters of the report have been prepared by the Federal Institute for
Risk Assessment (BfR). For this purpose, BfR has compiled the most
comprehensive toxicological database, presumably worldwide, for
glyphosate. This database comprises hundreds of studies that were
performed by or on behalf of the many manufacturers of glyphosate and
thousands of references from the open literature. This huge amount of
data makes glyphosate nearly unique among the active substances in
plant protection products. BfR thinks that the entire database must be
taken into account for toxicological evaluation and risk assessment of
a substance and not merely a more or less arbitrary selection of
studies.
In the absence of more reliable information from IARC, BfR has
tried to allocate the findings that are mentioned in the brief
``Lancet'' publication to certain studies in our database and, by doing
that, to put them into perspective.
The new IARC classification for glyphosate as a carcinogenic
substance is based firstly on ``limited evidence'' in humans. This risk
is derived from three epidemiological studies in the USA, Canada and
Sweden based on a statistical correlation between exposure to
glyphosate and an increased risk of non-Hodgkin lymphoma. However, this
assessment was not confirmed in a very large cohort of the also cited
``Agricultural Health Study'' or in other studies. A recent publication
from 2012 has reviewed the epidemiologic literature to evaluate whether
exposure to glyphosate is associated causally with cancer risk in
humans and the relevant methodological and biomonitoring studies of
glyphosate. The review found non-consistent patterns of positive
associations indicating a causal relationship between total cancer or
any site-specific cancer and exposure to glyphosate. The current report
of BfR to the EU based on the evaluation of over 30 epidemiological
studies came to the overall assessment that there is no validated or
significant relationship between exposure to glyphosate and an
increased risk of non-Hodgkin lymphoma or other types of cancer.
Secondly, IARC points to findings of studies based on animal
experiments submitted by the producers of glyphosate as evidence for
the carcinogenic effect of glyphosate. All these findings were also
considered in the glyphosate assessments of BfR, which did support the
conclusion of the Joint Meeting on Pesticide Residues (JMPR) of the
FAO/WHO responsible for the assessment of active substances in
pesticides: ``In view of the absence of a carcinogenic potential in
animals and the lack of genotoxicity in standard tests, the Meeting
concluded that glyphosate is unlikely to pose a carcinogenic risk to
humans''. BfR does not have any information as to how many of the 11
long-term studies on rats and mice that were assessed as valid were
available to IARC.
Moreover, IARC concluded that a glyphosate formulation promoted
skin tumours. In general, testing of formulations should not be used
for toxicological evaluation of active substances because co-formulants
may alter the outcome to a large extent. Therefore, the claim, based on
this two-stage cancer model in mice, that a highly concentrated, skin-
irritating formulation containing the active substance promotes skin
tumours is not considered by the institutions in the EU to be evidence
for the carcinogenic properties of glyphosate.
It is not possible to fully examine the indications for the
genotoxic potential of glyphosate based on the short report published
by IARC, in particular due to the fact that the assessment included
studies using formulations that are not specified in any detail.
The fact that different bodies assess issues differently due to
differing information and assessments of experimental data is part and
parcel of the risk assessment process. BfR will therefore perform a
thorough review of the classification issued by IARC once the monograph
becomes available.
______
Submitted Letter by Hon. Ann Kirkpatrick, a Representative in Congress
from Arizona
Pontificium Consilium de Iustitia et Pace
The World Food Prize
Borlaug Dialogue International Symposium
17 October 2013
On behalf of the Pontifical Council for Justice and Peace, I thank
you warmly for your very kind invitation to participate in the World
Food Prize event of this year, and for your warm welcome.
As you may know, about 50 years ago, the Second Vatican Council
carefully reviewed the mission of the Catholic Church in the modern
world. The Council found it urgent that the Church, with all her
resources, accompany humanity in its walk through history. She made her
own ``the joys and the hopes, the griefs and the anxieties of the
[people] of this age, especially those who are poor or in any way
afflicted.''\1\ Recently Pope Francis put it straightforwardly to a
meeting of the Food and Agriculture Organization of the United Nations
(FAO): ``the Catholic Church, with all her structures and institutions,
is at your side,'' \2\ that is, at the side of everyone who seeks in
good faith to meet the challenges of world hunger.
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\1\ Vatican II, Gaudium et Spes, 1.
\2\ Pope Francis, Address, 38th Conference of the Food and
Agriculture Organization of the United Nations, 20 June 2013.
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The Vatican Department that was mandated to study and to promote
the Church's accompaniment of humanity is the Pontifical Council for
Justice and Peace, which I preside over. And the spirit of our work--
and of my presence--is beautifully expressed by Vatican II with these
words: ``Giving witness and voice to the faith of the whole people of
God gathered together by Christ, this Council can provide no more
eloquent proof of its solidarity with, as well as its respect and love
for the entire human family, than by engaging with it in conversation
about these various problems.'' \3\
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\3\ Vatican II, Gaudium et Spes, 3.
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To engage in conversation about the problems of hunger that afflict
our world: that is why I join you at this International Symposium. When
we share a common commitment to conversation, we should be in a good
position to exchange views about concerns we have and positions we
take, even when they are at variance.
And yet because the stakes are high, tempers tend to run short, and
sharply divergent views make the conversation shrill. When that
happens, as Vatican II foresaw, we must courageously go even further
and deeper than conversation, into dialogue: ``The Church sincerely
professes that all [people], believers and unbelievers alike, ought to
work for the rightful betterment of this world in which all alike live;
such an ideal cannot be realized, however, apart from sincere and
prudent dialogue.'' \4\
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\4\ Gaudium et Spes, 21; cf. 40.
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And when you juxtapose the World Food Prize and the Occupy World
Food Prize, at first glance the divergence can appear and sound like
polar opposition. The urgency of world hunger and food insecurity
certainly cries out for ``rightful betterment'', and therefore calls
for dialogue. And for that I have come, too: to call for conversation
and to promote dialogue. The Church promotes listening, dialogue,
patience, respect for the other, sincerity and even willingness to
review one's own opinion. The Church encourages, orients and enriches
discussion and debate.\5\ It strives to indicate directions for the
work of those who are technically and politically responsible for
dealing with concrete problems.
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\5\ Cf. Pope Francis, Audience for Pontifical Council for Justice
and Peace Conference on Pacem in Terris, 3.10.2013.
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The Church Converses with the World Food Prize
Let me, then, begin the conversation: The earth, as Scriptures tell
us, was created as the home of the human family. The earth is
beautiful, good and perfect in serving its purpose of giving sustenance
to human life. Later, however, the Prophet Isaiah tells us that ``the
earth languishes and suffers'' \6\ from the sins of its human
inhabitants. In view of this pitiful situation, Saint Paul will
announce the hope of the earth's redemption, with man who was given
custody of it, through Christ.\7\
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\6\ Cf. Is, 24, 1-13.
\7\ Cf. Rm, 8, 21.
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Entrusted with the custody of the earth, the human family has a
mission to love God's creation, to accompany it towards its ultimate
perfection, and to make it fruitful: a fruitful creation that is to be
enjoyed by the present and future generations, and that satisfies all
the needs of humanity. That is why Pope Leo XIII says: ``that which is
required for the preservation of life, and for life's well-being, is
produced in great abundance from the soil, but not until [people have]
brought it into cultivation and expended upon it [their] solicitude and
skill.'' \8\ Similarly, the Compendium of the Social Teaching of the
Church observes: ``The Christian vision of creation makes a positive
judgment on the acceptability of human intervention in nature, which
also includes other living beings, and at the same time makes a strong
appeal for responsibility''.\9\
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\8\ Leo XIII, Rerum Novarum, n. 9.
\9\ Pontifical Council for Justice and Peace, Compendium of the
Social Doctrine of the Church, Libreria Editrice Vaticana, Citta del
Vaticano 2004, 473.
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In Catholic thought, then, ``nature'' is neither sacred nor divine,
neither to be feared nor to be revered and left untouched. Rather, it
is a gift offered by the Creator to the human community to be lived in
and used, entrusted to the intelligence and moral responsibility of men
and women. Therefore it is legitimate for humans with the correct
attitude to intervene in nature and make modifications. In the words of
the Compendium as applied to biotechnology: ``For this reason the human
person does not commit an illicit act when, out of respect for the
order, beauty and usefulness of individual living beings and their
function in the ecosystem, he intervenes by modifying some of their
characteristics or properties.'' \10\
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\10\ Ibid.
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``Intervening By Modifying'': The Church, Catholic Social Doctrine and
Biotechnological Research
There are no a priori limits on the notion of ``intervening by
modifying''. It does not even preclude actions taken on what may be
considered as the most intimate part of living organisms: the genome.
Blessed John Paul II, for example, in a speech to the members of
the Pontifical Academy of Sciences, expressed support for genetic
research, saying: ``It is also to be hoped, with reference to your
activities, that the new techniques of modification of the genetic
code, in particular cases of genetic or chromosomic diseases, will be a
motive of hope for the great number of people affected by those
maladies''.
He continued in a similar way about food production, saying:
``Finally, I wish to recall, along with the few cases which I have
cited that benefit from biological experimentation, the important
advantages that come from the increase of food products and from the
formation of new vegetal species for the benefit of all, especially
people most in need.'' \11\
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\11\ John Paul II, Address to the Members of the Pontifical Academy
of Sciences, 23.10.1982, 5-6.
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Again, addressing the 24th General Assembly of the FAO, where he
observed how hostile climate affects food production in poor countries,
he said: ``The findings of science must be put to use in order to
ensure a high productivity of land in such a way that the local
population can secure food and sustenance without destroying nature.''
\12\
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\12\ John Paul II, Address to the Participants in the XIV General
Assembly of the FAO, 13.11.1987, 5.
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Finally, at a study week of the Pontifical Academy of Sciences and
the Swedish Academy of Sciences on Tropical Forest and the Conservation
of Species, John Paul II referred to how ``other plants possess value
as sources of food or as a means of genetically improving strains of
edible plants.'' \13\
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\13\ John Paul II, Address to the Participants of the Study Week
organized by the Pontifical Academy of Sciences, 18.05.1990, 2.
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At this point in the conversation, and in the light of the above,
we should rejoice in the memory and achievements of Dr. Norman Borlaug:
He was awarded the Nobel Prize in 1970 in recognition of his lifetime
of work to feed the hungry of the world. He struggled endlessly to
integrate research and viable technologies into wheat production in
Mexico. His work extended from research stations to farmers' fields. In
the words of Pope Francis, Dr. Borlaug had `the smell of the sheep', or
in Iowan farmers' language: ``He had manure on his boots''. The result
was called the Green Revolution: the production of seeds with broad and
stable disease resistance, adapted to varying growing conditions and
with high yield potential; and he conceived and set up the World Food
Prize to encourage continued work towards food security and to meet the
zero hunger challenge.
This is also why we have reason today to congratulate our three
World Food Prize winners this year: Dr. Marc Van Montagu of Belgium
(http://www.worldfoodprize.org/en/laureates/2013_laureates/
#Dr._Marc_Van_),\14\ and Dr. Mary-Dell Chilton (http://
www.worldfoodprize.org/en/laureates/2013_laureates/#Dr._Mary-Dell_)
\15\ and Dr. Robert T. Fraley (http://www.worldfoodprize.org/en/
laureates/2013_laureates/#Dr._Robert_T._Fraley) \16\ of the United
States, and to commend them for carrying on the legacy of Dr. Borlaug,
putting biotechnology and research towards improving food production.
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\14\ Founder and Chairman of the Institute of Plant Biotechnology
Outreach at Ghent University in Belgium.
\15\ Founder and Distinguished Fellow of Syngenta Biotechnology.
\16\ Executive Vice President and Chief Technology Officer of
Monsanto.
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But times have also changed: Dr. Borlaug's achievements were
greeted with great enthusiasm, and the Green Revolution with great
optimism. Why then is there so much displeasure and distrust today, so
much skepticism and strong opposition? Never before, having accepted an
invitation, have I received so much mail, some of it urging me to
withdraw, a bit of it affirming the value of GMOs, much of it
recounting destruction and suffering in relationship with globalized
industrial agriculture promoting GMO crops. What can be going wrong,
seeing that Pope John Paul spoke positively about such research?
Let me now go back to Pope John Paul II to continue the
conversation. For when he encouraged genetic research to enhance food
production, he also clearly stated the parameters within which such
research may be carried out. ``In terminating these reflections of
mine,'' he said to the Pontifical Academy of Sciences, ``which show how
much I approve and support your worthy researches, I reaffirm that they
must all be subject to moral principles and values, which respect and
realize in its fullness the dignity of man.'' \17\
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\17\ John Paul II, Address to the Members of the Pontifical Academy
of Sciences, 23.10.1982, 6.
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It is clear, then, that in the mind of John Paul II, the various
operations that can be called ``genetic manipulation'' must be the
object of a true moral discernment. ``To speak the truth,'' he said on
another occasion, ``the expression genetic manipulation is ambiguous.''
While it is characterized by beneficial applications in the area of
animal and plant biology, very useful for food production, it can also
yield to adventurism.\18\ In the latter case, it can be arbitrary and
unjust, especially when it loses sight of the total well-being of the
human person. This is why, for John Paul II, it is absolutely necessary
to overcome the separation between science and ethics, and to discover
their radical unity.\19\
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\18\ Cf. John Paul II, Address to the XXXV General Assembly of the
World Medical Association, 29.10.1983, 6.
\19\ Idem.
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Accordingly, the desired dialogue will have to go very deep. It
will need to include the motivation and vision which guide biological
and genetic research and biotechnology--in other words, not only so-
called ``pure'' research but also the vision and motivation that guide
its translation into policies, commerce, agriculture and trade in many
different situations around the world. And for the dialogue to progress
in good faith, all the stakeholders must genuinely be represented and
meaningfully take part.
The Problem of Food Insecurity
Hunger in the world is a very serious injustice that shows
fundamental disrespect for human dignity. Pope John Paul II called it
``the first and fundamental form of poverty''.\20\ Persistent hunger,
starvation and malnutrition represent a global failure of humanity
that, to our shame, has dragged on for decades. It is a plague, and a
long-term indicator of a system that does not function properly. Some
point to the economic crisis of recent years as the reason why the
world cannot do better; but that is just an excuse--food insecurity has
persisted for decades, through prosperous times as well as more
difficult ones.
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\20\ John Paul II, Message, World Food Day 2001, 16.10.2001.
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But the problem is not, of course, an overall scarcity of food.
Today the world produces more than enough food to feed its seven
billion inhabitants, but the world has one billion hungry people (about
one in seven), the United States 50 million (about one in six). But
much is lost after harvesting or just thrown away: in a very recent
document, ``FAO estimates that each year, approximately \1/3\ of all
food produced for human consumption in the world is lost or
wasted''.\21\ Some estimates are even higher than \1/3\.
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\21\ FAO, Food wastage footprint, Impacts on natural resources.
Summary report, 2013, p. 6.
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Since the 1980s, the Popes, supported by FAO statistics, have
pointed out that the supply of food per capita on the planet is
steadily increasing. So it is clear that, in large part, hunger is a
problem of distribution of food or access to it. It does not reach some
people, or they cannot buy it. To others, however, it comes in
abundance, even from afar--abundant enough that they can waste it.\22\
In other cases, finally, the systems for storage of harvests or the
supply chains are deficient.
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\22\ Cf. FAO, Food wastage footprint, pp. 11-13.
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Let me suggest a little parable. A man is anxious to improve the
strength of his arms. A surgeon offers to transplant muscles from his
legs into his arms: ``This will quickly make your arms big and
strong''. ``What will happen to my legs?'' the man asks. ``They will
become much weaker,'' replies the surgeon, ``and may have to be
amputated.'' The man is horrified and rejects the surgeon's solution.
In some circumstances, the promise of food security merely through
higher agricultural productivity is similar. New technologies are
promoted with the claim of making more food available for everyone. But
that is not the whole picture. In reality, the innovations are so
designed or implemented as to benefit relatively few interests that are
already well-off.
Along the way, many small producers will inevitably be excluded
and/or moved off their land. They will be amputated from their
traditional occupations and way of life. The uprooting of individuals,
families and communities is not only a painful separation from land; it
extends to their entire existential and spiritual environment,
threatening and at times shattering their few certainties in life.
It should not surprise us if some populations reject certain
innovations, not because they are faulty or perceived as such, but
because the manner of their delivery entails unbearable costs to those
who are supposed to benefit from them. It is not they who are missing
the point. Rather, like the surgeon who thinks only of a set of arms,
not the whole person, whoever refuses to look at the whole food
insecurity picture--people and their dignity and their lives as well as
food production and distribution--will miss the point.
How does the Church ``know'' about world hunger, sustainable
agriculture or GMOs? First of all, the Church is in touch with the
direct experience of her people. Another important way that we know
about these topics is through members of the Church who are scientists
or professionals working in a wide variety of positions in
universities, government and industry. And a third way would be in the
work of different departments of the Roman Curia: the Pontifical
Academy for Life, the Pontifical Academy of Science, the Pontifical
Academy of Social Science, the Congregation for the Doctrine of the
Faith, the Holy See Missions to the World Food Organization and to
other international bodies, the Secretariat of State and our own
Pontifical Council for Justice and Peace.
In 2004 our Pontifical Council produced a Compendium of the Social
Doctrine of the Church. Nine of its 583 paragraphs are devoted to
biotechnology: not to the science or the industry, but to the ethical
criteria that people of good will should apply to the development and
use of these technologies. I warmly recommend this text to everyone
involved in working on GMOs.\23\
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\23\ Compendium of the Social Doctrine of the Church, 472-480.
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Broad Directions
Here is what I can offer to whoever tries to fight hunger,
especially in the field of biotechnologies applied to the agricultural
sector. I implore you, your colleagues, and others whom you influence
such as your students, to always proceed along an ethical path of
discernment.
It is common to find some scientists and advocates who strongly
hold one position and others who hold its opposite. They attack and
even ridicule the opposed views--perhaps not in scientific meetings and
journals, but certainly in the media. And all this attack, defense and
counter-attack leave the public deeply confused.
There is a different approach, which takes its stand in dialogue,
in the patient exchange of positions and objections. When there is
something as important to humanity as hunger, and something as
controversial as GMOs, let us encourage research under solid (not
flimsy) ethical guidelines, and then, sharing the results, let us do so
in a climate of listening and dialogue.
We know since Gaudium et Spes in the mid-1960s that the Church
accompanies science. This is because science cannot proceed without
ethics. Ratio goes along with fides, as Benedict XVI taught so clearly.
Bios, which means life, must be handled ethically and respectfully, and
maybe this is especially true with respect to biotechnology. It is
hazardous--and ultimately absurd, indeed sinful--to employ
biotechnology without the guidance of a deeply responsible ethics. For
instance, nearly 50 years ago, Pope Paul VI called for prudence,
responsibility and unselfishness in this domain:
By dint of intelligent thought and hard work, man gradually
uncovers the hidden laws of nature and learns to make better
use of natural resources. As he takes control over his way of
life, he is stimulated to undertake new investigations and
fresh discoveries, to take prudent risks and launch new
ventures, to act responsibly and give of himself
unselfishly.\24\
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\24\ Paul VI, Populorum Progressio 25.
Blessed Pope John Paul II was supportive of research in
biotechnology to feed the world. Moreover, when he visited Des Moines
in 1979, standing in a corn-bedecked fields, he challenged agriculture
in America and around the world to ``foster sustainability of the land
and water and plants, and to use the harvest to feed the hungry in the
world.'' \25\
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\25\ John Paul II, Address to the Rural Community of Saint Patrick,
Des Moines, 4.10.1979.
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The study-document preparing for the II Synod for Africa in 2009
identified the true problems of agriculture in Africa: ``the lack of
cultivatable land, water, energy, access to credit, agricultural
training, local markets, road infrastructures, etc.'' These true
problems should not be overlooked or side-stepped by those who promote
the planting of genetically-modified seeding as the definitive
solution.\26\
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\26\ Instrumentum Laboris of Synod for Africa, 19.03.2009, 58.
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In his important encyclical Caritas in Veritate of 2009, Pope
Benedict XVI counted food security among the urgent global issues which
require ``a greater degree of international ordering''. He asserted
that the problem of food insecurity ``needs to be addressed within a
long-term perspective, eliminating the structural causes that give rise
to it and promoting the agricultural development of poorer countries.
This can be done by investing in rural infrastructures, irrigation
systems, transport, organization of markets, and in the development and
dissemination of agricultural technology that can make the best use of
the human, natural and socioeconomic resources that are more readily
available at the local level, while guaranteeing their sustainability
over the long term as well. All this needs to be accomplished with the
involvement of local communities in choices and decisions that affect
the use of agricultural land.'' Having enumerated the many conditions
that cry out for improvement, Pope Benedict went on to welcome ``the
new possibilities that are opening up through proper use of traditional
as well as innovative farming techniques, always assuming that these
have been judged, after sufficient testing, to be appropriate,
respectful of the environment and attentive to the needs of the most
deprived peoples''.\27\
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\27\ Benedict XVI, Caritas in Veritate, 67.
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For Pope Benedict, it is clear that ever-increasing production as
the primary path--let alone the sole option--to reducing world hunger
is too narrow a vision and can lead to false solutions, which may
actually undermine food security in the long term.
Guidelines
I have quoted the recent Popes Paul VI, John Paul II, Benedict XVI
and now Pope Francis. Having considered the general directions they
laid out, let me now spell out more specific ethical orientations that
need to accompany work in science and technology, including
biotechnology, as well as international trade and commerce. This is
still not a Church position on GMOs as such, but rather, the assistance
of the Church in the form of guidance based on her Social Doctrine.
A. Spirit of courage: Face up to the reality of hunger decisively
and with genuine charity and openness of heart. In the
words of Pope Francis: ``Something more can and must be
done in order to provide a new stimulus to international
activity on behalf of the poor, inspired by something more
than mere goodwill or, worse, promises which all too often
have not been kept . . . There is a need to move beyond
indifference and a tendency to look the other way, and
urgently to attend to immediate needs, confident that the
fruits of today's work will mature in the future. We cannot
devise programs which are bureaucratic and antiseptic,
which do not work today.'' Keep on studying the causes of
world hunger as broadly and deeply as possible, seeking the
greatest variety of possible solutions, since we need ``a
complete knowledge of particular situations, suitable
preparation, and ideas which take into account every
individual and every community.'' \28\
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\28\ Pope Francis, Address to the 38th Conference of the Food and
Agriculture Organization of the United Nations in Rome, 10.06.2013,
2, 3, 4. For a comprehensive presentation of the principles here
mentioned, consult the Compendium, especially 472-80.
B. Ethics of all human endeavors: Some would claim that research is
ethically neutral, and only its application or
implementation may be good or bad. But any activity which
deserves the name ``human'' requires ethical guidance if it
is to serve the common good. Therefore, a researcher always
should work ``to satisfy the demands of justice, fairness
and respect for every human being''; \29\ not merely for
the sake of profit. The same criteria apply to those who
are responsible, in later phases of the process, for
industrial production, international trade, commercial
distribution, and so forth. There should be no ``washing of
the hands'' at any step along the way.
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\29\ Pope Francis, FAO, 1.
C. Prudence: The full costs and consequences of introducing
genetically modified organisms may emerge only with time,
in the long-term. Therefore let us apply the principle of
precaution or prudence by taking every reasonable measure
of caution beforehand, to avoid the risk of damaging human
health or the environment. Such prudence, I might add, is a
necessary element of any effort to advance the common good
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through public, that is governmental, action.
D. Transparency: Adopt the highest standards of communication with
the public, as well as rules of labeling in order to
guarantee producers' and consumers' right to information.
This is necessary for everyone to have a true choice. This
is the principle of transparency.
E. Access: Patents and intellectual property rights are legitimate,
but they need to be monitored and regulated. Fair ways must
be found to share the fruits of research and ensure that
developing countries have access both to natural resources
and to innovations. Otherwise whole populations can be
discriminated against, exploited and deprived of what they
rightly should have a share in.\30\
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\30\ Cf. Statement of the Holy See at the World Trade Organization
Council on Trade-Related Aspects of Intellectual Property Rights,
Geneva, 8 June 2010, 5-7.
F. Biodiversity: Bio-diversity is humanity's patrimony. It needs to
be protected, indeed privileged. The development of new
types should not require, or lead to, the disappearance of
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traditional species.
G. Subsidiarity: A very healthy principle of Catholic Social
Teaching is subsidiarity, which favors the exercise of
responsibility at every level and resists ``top-down''
approaches where inappropriate. It is often better to
support local efforts than to provide or even impose
solutions from elsewhere. And given the complexities of
globalization, effective coordination of efforts at all
levels is also increasingly required.
H. Commerce: Analyze, condemn and fight ``financial speculation,
which presently affects the price of food, treating it like
any other merchandise and overlooking its primary
function.'' Abandon any form of ``short-sighted economic
interests and the mentality of power of a relative few who
exclude the majority of the world's peoples, generating
poverty and marginalization and causing a breakdown in
society.'' \31\ And educate our youth to do the same. . . .
with criteria of justice and solidarity governing the
commercial and economic conditions, avoiding any
commercial-economic monopoly
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\31\ Pope Francis, FAO, 2.
I. Finally, conversation and dialogue. Sharp differences of opinion
(e.g., between WFP and ``Occupy'') about agriculture and
biotechnology show how important are these issues. Their
importance does not justify harshness (polemic) or
manipulation (bullying). At every level from the global to
the local, one might ask, what should be people's input
into research, agricultural and trade policies, development
policies, funding priorities, and so forth. ``Every
proposal must involve everyone,'' Pope Francis insists.
``To move forward constructively and fruitfully in the
different functions and responsibilities involves the
ability to analyze, understand, and engage, leaving behind
the temptations of power, wealth or self-interest and
instead serving the human family, especially the needy and
those suffering from hunger and malnutrition.'' \32\
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\32\ Pope Francis, FAO, 3.
I will stop here. There may be other desirable or even essential
criteria for serious, realistic, honest and courageous dialogue on this
topic. If so, let them be put on the table. For the diverse parties to
participate in good faith, they must hold themselves as well as others
to such criteria. The world needs everyone, the heirs of Bishop Maurice
Dingman and the heirs of Dr. Norman Borlaug, to stay at the table and
solve these issues, rather than abandon the dialogue and leave the
world's poor at an empty table.
Conclusion
The world's food security challenges are not to be overcome with a
referendum on science. Scientific research is good. It is right to
celebrate the achievements of our three World Food Prize Laureates. The
Church is not anti-science.\33\ Nor do we wish to promote a referendum
on technology or biotechnology. Nor even a referendum on business--the
Church is not against business or the market. In fact, while we have
critiqued some aspects of the world financial system--inattention to
the common good, disrespect for the rights of weaker members, tolerance
for monopolies and cartels--my Council has sponsored a major
publication that encourages the vocation of business leaders in
carrying out God's plan for humanity.\34\
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\33\ Far from it--where would genetics be without the contribution
of the Augustinian friar Gregor Mendel, where would pharmaceutical
knowledge be without the herbalists in countless monastery gardens!
\34\ Pontifical Council for Justice and Peace, Vocation of the
Business Leader: A Reflection. First published in 2011 and now
available in about a dozen languages, the handbook can be downloaded at
http://www.iustitiaetpax.va/content/giustiziaepace/it/archivio/
pubblicazioni/vocation-of-the-business-leader--a-reflection-.html.
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The Church sees the GMO debate as a complex choice among various
means--the means offered by advances in biotechnology and by
innovations in agriculture, as well as the human, natural and
socioeconomic means which can be developed locally and regionally.
Among the goals we embrace are food security for all, quality of life
of land-based populations, biodiversity and long-term sustainability.
We see many sides to the coin of ``world food''.
So we wish to promote meaningful dialogue amongst the stakeholders,
whether in the United States or in other parts of the world. All sides
of the controversy are using many of the same key phrases such as
``overcoming hunger'' and ``sustainable agriculture'', thus it will
only be by mutual and respectful listening, by a genuine desire to
learn from the other, indeed from all the stakeholders, that the better
and truly enduring, sustainable solutions will be found. May I cite my
own African experience of ``palaver''? Palaver is the extremely patient
and thorough exploration of a whole problem until one reaches
consensus. It means to talk and to talk, to listen and listen,
thoroughly to explore every facet of a complex issue, with mutual
respect and without hostility. Sooner or later, a truly consensual
conclusion will arise. But in order to find the best way forward, ALL
the stakeholders must be represented around the palaver circle--a
circle characterized by humble and respectful listening, honest
speaking, reconciliation of deep differences--a circle of true
collaboration.
Thank you for allowing me, in the name of the Church as convener
and teacher, to offer to facilitate some of the needed dialogue.
Cardinal Peter K.A. Turkson,
President, Pontifical Council for Justice and Peace.
______
Supplementary Material Submitted by Nina V. Fedoroff, Ph.D., Olsson
Frank Weeda Terman Matz PC (OFW Law)
Hon. K. Michael Conaway,
Chairman,
House Committee on Agriculture,
Washington, D.C.;
Hon. Collin C. Peterson,
Ranking Minority Member,
House Committee on Agriculture,
Washington, D.C.
Dear Chairman Conaway and Mr. Peterson:
Thank you, again, for the opportunity to testify on the importance
of biotechnology the potentially detrimental impacts of mandatory GMO
labeling. I really appreciated your questions and the interaction with
the Members. As several questions pertained to the recent glyphosate
study conducted by the International Agency for Research on Cancer
(IARC), please allow me to provide some materials for the record and
supplement my response. Glyphosate is the world's most widely produced
herbicide. Hence, the great interest in this chemical.
The IARC concluded that glyphosate is a probable carcinogen to
humans, yet noted there is limited evidence of such a link and, as I
mentioned at the hearing, the study does not contain any new research.
Moreover, the report contradicts the overwhelming consensus by the
world's most respected regulatory authorities and scientific
organizations, and the preponderance of all evidence where glyphosate
has been found not to present a carcinogenic risk to humans.
First, and foremost, the IARC results contradict conclusions
reached by the Joint Meeting on Pesticide Residues (the
Meeting), which is an internationally recognized expert body
administered jointly by the United Nations Food and Agriculture
Organization and IARC's parent body, the World Health
Organization (WHO). ``In view of the absence of a carcinogenic
potential in animals and the lack of genotoxicity in standard
tests, the Meeting concluded that glyphosate is unlikely to
pose a carcinogenic risk to humans.'' Joint Meeting of the FAO
Panel of Experts on Pesticides Residues in Food and the
Environment and the WHO Core Assessment Group, Rome, Italy 20-
29 September 2004.
In 2013, the U.S. Environmental Protection Agency (EPA)
``concluded that glyphosate does not pose a cancer risk to
humans'' and ``Therefore, a dietary exposure assessment for the
purpose of assessing cancer risk is unnecessary.'' 2013 Federal
Register Notice (FR 25396, Vol. 78, No. 84, May 1, 2013). The
EPA is also conducting a comprehensive re-review, which all
chemicals go through every fifteen years, and will consider all
new information that is scientifically based.
Germany's Federal Institute for Risk Assessment (BfR),
acting as Rapporteur Member State for the European Union's
renewal of approval for glyphosate, found that ``In
epidemiological studies in humans, there was no evidence of
carcinogenicity and there were no effects on fertility,
reproduction and development of neurotoxicity that might be
attributed to glyphosate.'' Glyphosate Renewal Assessment
Report, Germany as Rapporteur Member State for the European
Renewal of Approval for Glyphosate (2015) IARC's
classification, therefore, came as a ``surprise'' to BfR given
Germany's findings were based on ``the most comprehensive
toxicological database, presumably worldwide, for glyphosate.
This database comprises hundreds of studies that were performed
by or on behalf of the many manufacturers of glyphosate and
thousands of references from the open literature. This huge
amount of data makes glyphosate nearly unique among the active
substances in plant protection product. BfR thinks that the
entire database must be taken into account for toxicological
evaluation and risk assessment of a substance and not merely a
more or less arbitrary selection of studies.'' Germany Federal
Institute for Risk Assessment's Response to the IARC, BfR
Communication No 007/2015, 23 March 2015.
According to the Australian Pesticides and Veterinary
Medicines Authority, ``The APVMA currently has no data before
it suggesting that glyphosate products registered in Australia
and used according to label instructions present any
unacceptable risks to human health, the environment and trade .
. . The weight and strength of evidence shows that glyphosate
is not genotoxic, carcinogenic or neurotoxic.'' Australian
Government, Australian Pesticides and Veterinary Medicines
Authority (2013).
The Argentine Interdisciplinary Scientific Council found
that ``The epidemiological studies reviewed showed no
correlation between exposure to glyphosate and cancer
incidence, nor adverse effects on reproduction, or Hyperactive-
Attention Deficit Disorder in children. It is estimated that no
significant risks would exist for human health regarding
adverse effects on the genetic material. Under responsible use
conditions for this herbicide, the intake of food and water
would not imply risks for human health.'' ``Evaluacion De La
Informacion Cientifica Vinculada Al Glifosato En Su Incidencia
Sobre La Alud Humana Y El Ambiente,'' (``Assessment of
scientific information related to glyphosate and its incidence
on human health and the environment'') (2009).
The Canadian Pest Management Regulatory Agency reported that
``Health and Welfare Canada has reviewed the glyphosate
toxicology database, which is considered to be complete . . .
The submitted studies contain no evidence that glyphosate
causes mutations, birth defects or cancer.'' Doliner L.H.
(1991) Pre-Harvest use of glyphosate herbicide [Preharvest
application of glyphosate (Roundup) herbicide]. Discussion
Document D91-01. 98 pp. Pesticide Information Division, Plant
Industry Directorate, Agriculture Canada.
On reviewing all of the available data, both published and
unpublished, regulatory authorities have consistently concluded that
glyphosate does not cause cancer in either animals or humans.
In short, Mr. Chairman and Mr. Peterson, while I respect the WHO-
IARC, its report needs to be put in context. The IARC looks at whether
a substance has the potential to cause cancer, rather than the
probability it will considering the way it's used in the real world.
Furthermore, the IARC's recent conclusions appear to be the result of
an incomplete data review that has omitted key evidence, and so needs
to be treated with a significant degree of caution, particularly in
light of the wealth of independent evidence demonstrating the safety of
glyphosate.
Thank you, again, for this opportunity, and I remain available to
the Committee at any time.
Sincerely,
Dr. Nina Fedoroff.
______
Submitted Letter by Scott McGinty, President, Aurora Organic Dairy
March 24, 2015
Hon. K. Michael Conaway,
Chairman,
House Committee on Agriculture,
Washington, D.C.
Dear Chairman Conaway,
Aurora Organic Dairy is a leading supplier of USDA certified
organic milk to retailers nationwide. We operate farms in Colorado and
Texas, including a 3,000 acre farm in Erath County near Dublin, TX.
Established only 10 years ago, we employ over 500 people and market
milk from 25,000 cows thanks to strong demand for our products. These
herds consume roughly 70,000 acres worth of organic crops, giving rural
families the opportunity to participate in a growing sector of American
agriculture.
Consumers buy our products at leading mainstream grocers across
America, including Kroger, Costco, Walmart, BJs, Safeway, Giant and
many others. They buy organic milk because of the rigorous production
and monitoring practices required by the National Organic Program (NOP)
and they trust the USDA organic seal as a symbol of its certification.
This law strictly prohibits the use of synthetics such as antibiotics,
pesticides, herbicides, unapproved synthetics and genetically modified
organisms (GMOs) in the production of certified organic food. In
organic milk, this prohibition explicitly applies to the production of
the feed. In fact, for milk to be certified organic, each feed
ingredient in the animal's ration requires its own organic certificate
to verify production under these standards. Furthermore, each of these
USDA organic requirements adds significantly to the cost of our
company's milk production.
In turn, organic milk is frequently labeled with the specific
attributes of the USDA NOP rule to convey that the product is certified
organic. Common claims found on USDA organic milk are ``produced
without the use of GMOs'', ``produced without GMO ingredients'', and
``produced without synthetic pesticides or growth hormones.'' Consumers
buy this milk because they trust that these are not used anywhere in
the production of the product--not on the farm, not in the feed, and
not in the cow.
As stated above, the law requires organic producers to make very
large investments during conversion from conventional farms to organic
farms. Then, organic producers spend a great deal more to produce
organic food. Because certified organic feed costs so much and because
being organic means lower yields from organic farms and cows, the cost
of organic production per gallon of milk can be twice as much as
conventionally produced milk. In Aurora Organic Dairy's business, this
amounts to more than $50 million spent each year to comply with the law
on top of the estimated $80 million in one-time organic conversion
costs. The organic industry as a whole spends billions in incremental
production costs to comply with the USDA NOP in order to deliver
certified organic food to American families.
Given your consideration of biotechnology and GMO labeling
legislation, we ask the Committee to recognize that any requirements
for non GMO production under the NOP be extended to any new non GMO
definitions. Non-GMO production has been defined in the consumer
marketplace in accordance with the USDA's organic program and the term
should have the identical meaning under any new program. Any non-GMO
labeling claim on milk should mean a complete prohibition of GMO feed
use for consistency with NOP requirements. American families would
expect nothing less.
With the consumer in mind, we must avoid the confusion of
inconsistent non-GMO meanings on labels. Given consumer sentiment for
food transparency today, a conflicting non-GMO milk definition allowing
GMO feed or other inputs would result in harsh consumer criticism and
represent a large step backwards.
For farmers, it is equally important that any non GMO requirements
under one USDA program are the same as non GMO requirements under any
other under the USDA or the Food and Drug Administration (FDA). To
allow otherwise, would create a double standard and enable conventional
milk producers using GMO feed to ride on the coattails and pocketbooks
of certified organic farmers. A large class of producers would suffer
severe economic loss as a result.
We also believe that the introduction of a second USDA label for
non-GMO food would result in consumer confusion with the existing USDA
organic program and be a waste of scarce taxpayer dollars. As the
recent farm bill process clearly showed, there is hardly enough funding
for existing agriculture programs without creating new ones that
duplicate efforts.
To be clear, we do not oppose the use of biotechnology in food or
the effort by Congress to create national labeling standards. It is
very important labeling laws avoid unnecessary barriers to interstate
commerce. We believe in creating choices for consumers and agricultural
producers and applaud your support of USDA programs that stimulate such
choices and expand the economic opportunities for the American farmer.
For these programs to be trusted by their participants and American
families, the definition of non-GMO and its associated labeling claims
should remain free of any inconsistency.
To put this idea into a real context, imagine a young mother at the
grocery store. She is pushing a stroller, buying groceries for her
family at home and the toddler who is looking up at her from below.
With a glance at her shopping list, she says to herself ``frozen pizza,
diapers, and a gallon of milk:'' Smiling at her baby, she remembers how
she had avoided the pizza before she stopped nursing. She reaches the
milk section and comes across two brands; one of them is the organic
item she normally buys. The prices are quite a bit different so she
looks closer and sees that ``non-GMO'' is printed on both labels. She
thinks to herself, ``I'd love to save a couple dollars. Since they're
both made without GMOs, I think I will.''
Now ask yourself, would she know that the two GMO claims have
different definitions? Would she feel deceived to learn that the milk
she bought was produced using GMO feed? Our law-making decisions must
eliminate the potential for this sort of consumer deception.
For these reasons, we submit that H.R. 4432, as introduced in 2014,
would in fact create a double standard for the labeling of milk,
undermine existing organic law and mislead consumers. Its provisions
under section 103 clearly allow milk products produced with GMO feed to
be labeled ``non-GMO.'' This definition of such a claim under any
legislation would directly conflict with the definition of the term
under the existing organic program. We strongly urge the Committee to
consider this consequence and amend the language to preserve
consistency with current law.
We are grateful for the opportunity to submit this letter to the
hearing record and thank you for considering our comments. We look
forward to working with you and the Committee over the coming months
during this review of mandatory biotechnology laws in agricultural
production.
Sincerely,
Aurora Organic Dairy
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Scott McGinty,
President.
______
Submitted Questions
Response from Nina V. Fedoroff, Ph.D., Senior Science Advisor, Olsson
Frank Weeda Terman Matz PC (OFW Law)
Question Submitted by Hon. David Rouzer, a Representative in Congress
from North Carolina
Question. Dr. Nina Fedoroff, thank you for the information you
presented. Biotechnology is such a useful tool in the daily lives of
the public, even if they don't realize it. Genetic engineering helps to
diagnose, treat, and prevent diseases, such as cancer, arthritis,
diabetes, cystic fibrosis, sickle cell anemia, multiple sclerosis,
cardiovascular disease, Hepatitis B, meningitis, and whooping cough.
With that said, we hear from opponents to biotechnology that the
science is making natural plants unsafe. I would like to ask you about
poisonous, unsafe plants found in nature that science has been able to
modify into useful, safe tools that benefit people's health. I can
think of a few examples: chemicals found in the Rosy periwinkle have
been isolated and used in chemotherapy treatments; chemicals in the
black henbanehas have been isolated and used in prescription drugs
targeting muscle spasms and symptoms of Parkinson's disease; and
foxglove's chemicals are used in medicines for people with congestive
heart failure.
Can you please speak to any further examples you have of
biotechnology helping in this way? Also, can you please speak to how
this public shaming of biotechnology is putting these advancements of
science in danger?
Questions Submitted by Hon. Dan Newhouse, a Representative in Congress
from Washington
Question 1. Can you briefly explain what benefits we could
experience from a nutrition, food safety, and efficiency standpoint by
using biotechnology? Also, do you believe publicly shaming or
generating a culture of fear around these products jeopardizes their
possible benefits?
Question 2. Dr. Federoff, given the nature of the targeted,
specific modifications that this technology uses, do you believe we
actually know significantly more about the final, modified product in
these instances than we might know with conventional breeding?
Question 3. Dr. Federoff, in your experience, are plants that have
been genetically modified using modern biotechnology materially
different from their non-genetically modified counterparts?
Question 4. So based on that assessment, should the FDA distinguish
and regulate crops or livestock based on the method of modification or
the material composition and why? Also, if you had to speculate, how
difficult would it be for a farmer in the field to distinguish between
a modified seed and a non-modified seed? Would a worker in a grocery
store be able to tell the difference between a non-modified ear of corn
and a modified one?
Answers.*
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* Editor's note: the witness did not differentiate the submitted
responses; therefore they are printed as received.
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Medical Benefits
There are more than a hundred compounds originally derived from
plants that are currently used as drugs in one or more countries. The
following website has an excellent table that lists the chemicals,
their clinical uses and their plant sources: http://www.rain-tree.com/
plantdrugs.htm.
However, today's new drugs are increasingly proteins produced
through GM technology (also known as ``recombinant DNA'' technology).
That is, our knowledge of genes and proteins has advanced to the point
that we can make human proteins in large amounts in either cultured
cells or in lower organisms, such as yeast and bacteria. The classic
example is human insulin. Before GM technology, insulin was largely
derived from pigs and often had adverse effects in humans. Today's
insulin is human insulin produced in microorganisms through GM
technology. Other widely used human proteins produced in microorganisms
are human growth hormone, clotting factors for treatment of hemophilia,
and proteins used in vaccines.
Nutrition, Food Safety, Agricultural Efficiency
Many of the plants we use for food have a long history of genetic
modification to make them more suitable as food plants by making them
less toxic (potatoes, for example, contain toxic glycoalkaloids),
easier to grow and harvest (bigger, softer grains that stick to the
plant until harvest), and more appealing to eat (bigger, redder,
sweeter fruits and vegetables). This is called domestication and much
of it happened before we understood genes and genetics. But in the 20th
century, growing knowledge of genetics was put to work in plant
breeding by employing such scattershot methods of accelerating genetic
change as chemical and radiation mutagenesis. About half of the crops
on the market today have such a mutagenesis step in their history.
Genetic modification by modern molecular methods, what we now call GM
or GE, is just starting to be used to make nutritional improvements,
although the Bt corn that is now grown very widely makes corn safer by
decreasing contamination by fungal toxins (fungi get into the corn
through holes bored by insects. No holes, no fungi, no toxins).
GM foods in the pipeline that will offer advantages through
improved nutrition or decreased waste include oils with omega-3 fatty
acids, apples that don't turn brown when cut, potatoes that have lower
levels of a natural amino acid that turns into the toxic compound
acrylamide when the potatoes are fried in hot oil, and non-allergenic
peanuts.
However, perhaps the most important accomplishments of GM
technology have been, and will continue to be, in making it possible to
continue increasing the productivity of our (and our animals') primary
calorie sources (corn, soybeans, wheat, rice, canola) while decreasing
the environmental footprint of agriculture and making it more
sustainable by decreasing the use of toxic chemicals to control pests.
In this regard, the 18 year history of current GM crops has been
exemplary. As I reported in my initial testimony, a recent meta-
analysis revealed that GM crop adoption has increased yields by 22% and
farmers' profits by 68%, while reducing pesticide use by 37%. GM crops
have also been a major factor in decreasing topsoil loss by
facilitating no-till farming.
Safety of GM Techniques
The current, highly conservative regulatory process was developed
when little was known about the health and environmental impacts of
GMOs. Today, we have more than a quarter century's research on GM
biosafety, all of which shows that modification of organisms by GM
techniques is as safe as modification by older techniques and arguably
safer. Indeed, a number of recent studies have revealed that there is
much less genetic and epigenetic disturbance when plants are modified
by adding a gene than when they are modified through older techniques
such as genetic crosses (aka cross-breeding) or through either chemical
or radiation mutagenesis. This is because the older techniques either
bring together thousands of genes for the first time or cause damage
that can reverberate through the genome, while GM technology can
introduce just one or a small number of genes without disturbing the
genome in general.
What We Know About Today's GMOs
In addition to the fact that GM techniques cause less genetic
disturbance than older techniques, the GM crops currently on the market
are the most extensively studied crops ever to have entered our food
chain. This is in part because analytical techniques have improved with
the widespread development and use of techniques that allow monitoring
of all genes, gene expression levels, proteins and metabolites. It is
also because the current regulatory requirements are focused only on
crops modified by GM technology and require that the developer
demonstrate that the plant is substantially equivalent to the parent
plant and that the substance to be expressed in the GM plant be neither
toxic nor allergenic. That has never been required for a crop developed
using any previous genetic modification technique, including radiation
and chemical mutagenesis. Thus the answer to the question about whether
a crop modified by modern biotechnology is materially different from
its non-genetically modified counterpart is simply: no. They must be
shown to differ just in the added component and that added component
must be shown to be safe. That said, it must be kept in mind that
biological organisms are constantly changing genetically, people
included. So substantial equivalence does not mean genetic identity.
Should Regulation By FDA (and USDA and EPA) Be Process-Based?
More than 3 decades of biosafety research have failed to identify a
hazard unique to the use of modern GM techniques. Indeed, there is
growing evidence that modification of organisms by modern GM techniques
is less disruptive of genomic structure and function than older
methods. This means that regulation of organisms based on the
modification method is simply unwarranted. Genetically modified
organisms should be regulated based on their properties, not on the
method of modification.
The GM crops on the market today look identical to and are
nutritionally equivalent to their non-GM counterparts. Thus neither a
farmer nor a grocery store clerk could distinguish any of today's GM
crops from their non-GM equivalents by their appearance. Certain
identification requires a still-costly molecular test.
GMO Shaming
The issue of GMO shaming, which is better described as
vilification, is already serious and potentially calamitous. It is now
standing firmly in the way of easing the regulatory burden on plants
and animals improved through GM techniques, as the anti-GMO clamor
tends to slow down decision-making in the regulatory agencies, in part
out of fear of litigation. To give just one example of the slow and
cumbersome regulatory process, the GM Aquabounty salmon, genetically
identical to its wild progenitor except that it grows faster (and no,
it is not a threat to wild salmon as it will be produced as sterile
females only) has been in the regulatory approval process for more than
a decade. The company has complied with all of the FDA's requirements,
but the agency has simply failed to issue a decision, well past its own
decision timeline. Developers have experienced similar prolonged
decision-making stretching to years in the other agencies, the USDA and
the EPA, that regulate GMOs.
Why is the shaming/vilification of GMOs potentially calamitous? In
the larger scheme of the world's food supply, our population growth
rate is now clearly exceeding the rate at which agricultural
productivity is increasing. The extraordinary agricultural advances of
the 20th century have put humanity in a position to supply the entire
world's population with an adequate diet today, despite the rapid
growth of the human population over the previous century. Today's
hunger is the result of poverty, not an inadequate global food supply.
But productivity increases are lagging, the population continues to
grow, and climate warming is beginning to have a negative impact on
agriculture globally. Without the innovations, amongst which the
continued improvement of crop plants is arguably the most important, we
face a future of increased food-based strife.
Today there is a small, but extremely vocal and influential anti-
GMO lobby in the U.S., comprising individuals such as the self-
proclaimed expert Jeffrey Smith, organizations such as Greenpeace and
the organic food industry's marketers. These use any and all available
scare tactics to vilify GMOs (and conventional agriculture in general)
in order to maintain their revenue streams and, in the case of the
organic food industry, to increase their market share. The
preponderance of companies and public sector researchers developing GM
crops are U.S.-based today. The objectives of the anti-GMO
organizations and the organic food industry are to drive all GM foods
off the market and convert U.S. agriculture to ``organic.'' Success in
this endeavor could drive the major biotech industry players out of
crop improvement using GM techniques and is already creating an almost
complete impediment to public sector crop improvement using these
techniques because of the high cost of complying with the complex
regulatory requirements. This would compromise--and could even
terminally cripple--the world's efforts to achieve food security and
make agriculture sustainable. Hungry people bring down governments, as
we've already seen in recent food price spikes.
Response from Joanna S. Lidback, Owner, The Farm at Wheeler Mountain,
Westmore, VT; on behalf of Agri-Mark; National Council of
Farmer Cooperatives; National Milk Producers Federation
Question Submitted by Hon. Dan Newhouse, a Representative in Congress
from Washington
Question. Ms. Lidback, I'm a farmer myself and my state nearly
adopted a similar law to what Vermont is preparing to impose, so I can
deeply appreciate where you're coming from. How do you believe it might
impact your business if neighboring states like New Hampshire, or New
York, or varying municipalities throughout the Northeast adopt
mandatory, though inconsistent, labeling laws from each other?
Answer. Thanks for your question, Representative Newhouse. We often
work closely with folks in neighboring states. New England is a
relatively small area and it's very easy to cross state borders for
everyday tasks. In fact, we choose to have our Jersey beef processed at
a USDA facility versus state-certified so that we can bring our meat to
other states to sell it, should the opportunity arise. A state-
certified facility would only allow us to sell within Vermont. If each
state had its own law that was different than the others, it would pile
on regulations thereby increasing regulatory burden--burden we already
face in other areas where quite frankly, it is more warranted such as
water quality, food safety and labor management. We know currently if
the Vermont law is put into place, dairy products and meat would be
exempt from a label but we are not guaranteed that same consideration
in other states' laws. I believe it is important for farmers and others
to share their hands on experience with genetically engineered crops
with the general public so as to diffuse the stigma that has been
placed upon them from a very vocal minority. Increased costs associated
with a patchwork of biotech labeling laws would be felt most by those
who can least afford it. The potential unintended consequences of these
laws would be numerous.
Response from Lynn Clarkson, President and Founder, Clarkson Grain
Company, Inc.
Question Submitted by Hon. Dan Newhouse, a Representative in Congress
from Washington
Question. Mr. Clarkson, from your testimony it appears you support
a voluntary, standardized labeling regime, and your support for this
policy stems from your experience with the emergence of foods being
labeled as ``organic'' by producers. Can you tell me a bit more about
your experience with the ``organic'' label, and how that has influenced
your perspective regarding the need for a labeling standard?
Answer. Clarkson Grain began merchandising certified organic
products in 1994 at the request of a few organic farmers in Illinois
seeking better market access. At that time, there was no one national
standard for organic certification. Instead there were several private
groups and some states each certifying producers, handlers, and
processors to their own standard. Each state and each group claimed
that their standard was better than the others. That left buyers,
handlers and farmers all confused about which certifier to use.
Certifiers began competing with each other for business, some loosening
standards to attract farmers and handlers, others tightening standards
to attract more consumers. The grand challenge was to select the right
certification to match successful marketing passage through the entire
supply chain to the consumer. There were continual meetings as
certifiers tried to respond to pressure to harmonize their standard.
Since each wished to be unique, such efforts to standardize the
standards never seemed to work. Some certifiers failed due to internal
dissension or competitive pressure, throwing those who had chosen that
certifier into disarray and exclusion from markets. Finally, the
pressure to develop a national standard finally bore fruit thanks to
the lead of the USDA. Contrary to the fears of those long championing
organic production, the standards proposed and amended by the USDA
satisfied almost everyone--farmers, handlers, processors, retailers and
consumers. The openness of the regulations to citizen inputs allowed
for an evolution in the rules. Finally, one national standard managed
and enforced by the USDA helped organize supply chains that had the
confidence of the consumer. Once that national standard came into place
symbolized by the USDA's organic label, the organic market soared, even
growing during the recession. It continues to grow with all associated
players knowing in significant detail what the rules require.
Clarkson Grain has also been supplying non-GMO corn and soy to
buyers since 1994. Initial demand came from clients in Japan.
Unfortunately there is no clear GMO standard. The same confusion that
troubled organic markets before our national community defined
``organic'' now plagues non-GMO markets--domestic and international.
Some of our international clients have abandoned the U.S. as a supplier
of non-GMO corn and soy because there has been no government effort to
standardize the meaning of non-GMO or support labeling, either
voluntary or mandatory. There are already at least two private
certifiers of non-GMO with a host of states considering standards,
standards that vary by certifier. The largest private certifier lacks
the resources to handle national and international demand and suffers
internal conflicts as to its own standards. These markets would be
significantly rationalized and improved if there were a single national
standard managed by the USDA. Such a standard would support a label in
which buyers and suppliers could have confidence.
Should the label be mandatory or voluntary? Clearly some advocate
mandatory labeling of any food containing GMOs. If the underlying
consumer interest to be protected is the opportunity to choose non-GMO
products, then voluntary labeling of non-GMO products to a known
standard would certainly respect that choice. Targeted voluntary
labeling would also be much less intrusive than mandatory labeling of
almost every product in the grocery store. Since those currently
offering non-GMO as well as those wanting to offer non-GMO products
intend to label for market advantage, there would be no unnecessary
labeling costs. In my opinion, a national standard linked to voluntary
labeling would meet consumer needs and facilitate markets without any
unnecessary costs. A labeling program backed by the USDA with tolerance
levels openly established to meet consumer values would inspire more
confidence throughout the supply chain and among consumes than
competing labels offered by various private groups and government
entities.
Response from Thomas W. Dempsey, Jr., President and Chief Executive
Officer, Snack Food Association
Question Submitted by Hon. Dan Newhouse, a Representative in Congress
from Washington
Question. My home State of Washington narrowly defeated a mandatory
labeling ballot initiative in 2013. However, many other states and
municipalities have since passed initiatives, all of course with
different definitions, standards, and labeling requirements from each
other. Mr. Dempsey and Mr. Policinski--can you both briefly describe
what your companies or member companies would experience if this trend
continues? How would producers comply with a conflicting patchwork of
state and local labeling and production requirements?
Answer. First, I would like to again thank the House Agriculture
Committee for providing a forum for a balanced review of one of the
most critical issues facing the food industry today, the labeling of
genetically modified organisms (GMOs). The Snack Food Association
represents more than 400 companies who produce a wide variety of snacks
ranging from potato chips, to meat snacks, to crackers, to dried fruit
and nut mixtures. SFA members range from billion-dollar multi-category
companies such as Frito Lay and ConAgra Foods which have manufacturing
facilities in Washington, to small family owned and operated
businesses. More than half of SFA members have less than $100M/year in
sales and many are the primary employer in their community.
SFA is concerned both with the burden state-level GMO labeling
would put on interstate commerce as well as the increased costs that
could drive food companies out of business or increase food prices for
consumers while potentially limiting their options in the marketplace.
Over the last several years there have been a number of state
ballot initiatives calling for mandatory GMO labeling. While voters
have rejected ballot initiatives calling for mandatory GMO labeling in
four states including Washington, the Vermont state legislature
approved the nation's first mandatory GMO labeling law, Act 120, last
year. In addition, since January 2015, more than 20 states have
introduced nearly 70 different pieces of legislation calling for some
type of mandatory GMO labeling. If enacted, these rules would impact
nearly every aspect of SFA members' business, upping costs by requiring
increased product inventory, added complexity for packaging and
distribution processes, and extensive new regulatory and training
requirements.
As I mentioned during my testimony, the hardest hit by these new
burdens would be the small, family-owned companies with just one plant
with just a single line of production. Quite frankly, these costs could
put some companies out of business and thereby increase consolidation
in the industry. SFA does not have a single member company that
manufactures, distributes, and sells in just one state, which adds
additional layers of complexity if differing laws were enacted in
multiple states.
In order to avoid the need for duplicate labels, it is sometimes
assumed that companies could simply remove the GMO ingredients from
their products altogether. This is unrealistic because the availability
of non-GMO crops is very limited. One SFA member indicated that they
could not increase contracts for non-GMO corn for a minimum of 2 years.
Transitioning to GMO-free production could not happen overnight, or
even by 2016, as is specified in Vermont's Act 120.
Some food manufacturers may be forced to end the distribution of
their products in states that require mandatory GMO labeling. This
would have a ripple effect across the distribution chain, impacting
drivers, warehouse personnel, account executives, and field management.
And while consumers in some states, such as Vermont, may have the
option to cross state lines to shop for goods if products were pulled
from grocery shelves, however that is simply not feasible for everyone.
Additionally, if product made its way onto the store shelves, despite a
manufactures desire to cease distribution, the manufacturer, in the
case of the Vermont law would be held liable, not the retailer.
We agree with you that a national standard for GMO labeling--rather
than a state-by-state patchwork of arbitrary rules--is the best
approach. Absent a Federal GMO solution, manufacturers will have
essentially three options in order to comply with a patchwork of state
labeling laws. Those choices would be to order new packaging for
products, reformulate products so no labeling is required, or halt
sales to that state. As I have outlined, each option is difficult,
costly, time-intensive, and at worst, could eliminate jobs and consumer
choice in the marketplace.
For all of these reasons, I would also like to thank you Rep.
Newhouse for your leadership in supporting critical bipartisan
legislation, the Safe and Accurate Food Labeling Act of 2015 (H.R.
1599) which represents a dramatic step in the right direction to
address the problems associated with mandatory GMO labeling. SFA's
members appreciate that H.R.1599 balances the desire of some consumers
for an additional label with the recognition that mandatory labels
should be reserved for safety and nutrition concerns. Experts agree
that the safety of GMO products is not a concern. The safety of GMOs is
backed by FDA, USDA, EPA and 20 years of experience in the field.
Again, thank you for your consideration of our views. We hope this
lays the groundwork for a Federal solution to the threat of a costly
and confusing patchwork of state labeling rules. SFA would be happy to
be a resource should you have any additional questions.
Sincerely,
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Tom Dempsey,
President and CEO,
Snack Food Association.
Response from Chris Policinski, President and Chief Executive Officer,
Land O' Lakes, Inc.
Question Submitted by Hon. Dan Newhouse, a Representative in Congress
from Washington
Question. My home State of Washington narrowly defeated a mandatory
labeling ballot initiative in 2013. However, many other states and
municipalities have since passed initiatives, all of course with
different definitions, standards, and labeling requirements from each
other. Mr. Dempsey and Mr. Policinski--can you both briefly describe
what your companies or member companies would experience if this trend
continues? How would producers comply with a conflicting patchwork of
state and local labeling and production requirements?
Answer. Our farmers have embraced biotechnology faster than any
technology in history. They've done that because of the benefits to
their economics on farm, the environment, less land and water use, and
less crop protection products used. Simply put, they are safe, and
beneficial. Stigmatizing GMO foods through a patchwork of state
labeling mandates, or even mandatory federal labeling, jeopardizes
innovation and threatens the future development and use of technology
in agriculture and the availability of these tools to our growers. The
challenges from a food industry perspective are no less significant
than those faced on the farm. Each state where mandatory labeling
legislation is pending has a different labeling requirement. For
example, in Washington State the ballot initiative would have required
products that contain any ingredients grown from biotech seeds as
``partially produced with genetic engineering'' or ``may be partially
produced with genetic engineering.'' Meanwhile, proposed legislation in
other states would require labels to say ``contains genetically
engineered ingredients.'' Additionally, the state regulatory body
charged with drafting and enforcing these standards also varies
depending on the state legislature, as does the scope of food products
covered or exempted and the penalties imposed. The three choices we see
under a state-by-state regulatory scheme are: (1) to stop selling in
the state, (2) to relabel our products at considerable expense, and (3)
to re-engineer our supply chain and reformulate our products at even
greater expense. None of those are good choices. All of those choices
would result in either denying consumer's access to products or raise
consumer costs. According to a Cornell University study, families may
pay up to an average of $500 per year more per year in food costs due
to mandatory labeling. That's why we strongly support a voluntary
national labeling standard, as proposed by the Safe and Accurate Food
Labeling Act.
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