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Vermont-Driven GMO Labeling Could Have Troubling Unintended Consequences

This small state may soon alter the food supply for all Americans

(This post originally appeared on Forbes on 3/26/16)

Over the past week and a half, Mars, General Mills, ConAgra Foods and Kellogg announced that they had decided to start labeling whether their products contain GMOs nationwide, in compliance with a pending Vermont statute. They see this as a way to avoid the cost of maintaining multiple systems for different states.


These companies clearly state that they agree with the scientific consensus that there are no safety issues with biotechnology as it has been applied to crops. Nonetheless, many observers believe that the ultimate impact of the Vermont labeling law will be to encourage companies to seek to use more non-GMO ingredients. That would, of course, be a major victory for the organizations that have promoted labeling and who are actually quite transparent about their agenda of eliminating use of the technology all together.

However this scenario plays out, there are three interesting questions to consider.
  1. Why do so many consumers say they want GMO labeling?
  2. Why was anyone against labeling in the first place?
  3. What might be the long-term effects of this labeling requirement on our food supply?

Why do so many consumers say they want GMO labeling?


This has much to do with how you ask the question.  The term "GMO" is a misleading title made up by anti-GMO activists in Europe in the mid 1990s.  It stands for "Genetically Modified Organism," which isn't a very good term to use since virtually every crop and animal used for food today has had its genetics dramatically modified from what ever it once was in the wild.  However, since few consumers realize this, the term "GMO" has the negative emotive effect that was intended.

The genetic modifications of these plants were vastly 
more dramatic than any modern “GMO crop”

If you use emotive language to ask people about other scary-sounding foods, you can get the same reaction. I've asked many people, "do you think cloned fruit should be labeled?" Virtually everyone says "yes!" Then I explain that all fruit is "cloned" in the sense that it is vegetatively propagated by budding or from cuttings because if you grew it from seed you wouldn't get the same variety. People have been doing this for millennia, but if I use the emotive term "cloned" I can get a "label it" response.

I also sometimes ask, "do you think that food grown with products made from animal excrement should be labeled?"  Most people again say "yes" because I used an emotive term. In that case there is a small, but finite food safety risk associated with manures and composts, but we don't label it.

In any case, after 20 years of active efforts to create fear around plant biotechnology, the label is nearly guaranteed to be seen as a negative by many consumers. Again, that is exactly what certain parties hope.

Why was anyone against labeling in the first place?

On the surface this seems like a logical question, but there were rational reasons to oppose these labels. The FDA wants to reserve the exercise of its labeling authority for things with real, documented risk issues such as food allergies, not for something like biotech crops for which extensive studies show no unique risk.  Realistically, this has become a moot point. By allowing "non-GMO" and "GMO-free" labels, consumers are already being successfully recruited to buy this next example of "non-existence" food, following trends like "gluten-free," "fat-free," "zero cholesterol" and the like.  American consumers are so used to buying food for what it is not that we don't even see the absurdity.


Much of the non-GMO labeling is for products
from crops which have no commercial biotech versions anyway


The reason that the processed food industry opposed labeling for biotech crops has to do with the costs and liabilities associated with maintaining distinct product flows in these very large scale, very low profit margin businesses. It costs money to clean out all the equipment, bins, trains and trucks used for bulk handling.
Grain harvesting equipment and later handling 
are not conducive to easy segregation

Depending on tolerances, it also opens companies up to liabilities for "adventitious presence.”  In the absence of real risk, the costs just don’t make sense. “Identity preservation” of high value crops like apples, oranges or wine grapes is far more feasible, and it is routinely done, but for issues that matter like variety, appellation etc.

What might be long-term effects of labeling on the food supply?

This really depends on whether food companies have the courage to trust their customers enough to continue to use biotech-improved items even in the face of activist pressure. Will they stand-up for their decision (as the Girl Scouts have), or will they give in and start shifting to non-GMO ingredients?

Evidence suggest that many players will take the latter path and that will mean asking farmers to forgo crop traits that they have found to be very helpful. Returning to non-biotech will also make it harder for farmers to use environmentally-sound approaches like minimum-tillage. It will increase the need to spray for insect pests once controlled by Bt traits in the crops. The cost of those non-GMO ingredients will be higher, partly because of these disadvantages, but also because of what it will take to "identity preserve" the non-GMO harvest all the way down the handling, storage and processing stream.

Of greater concern is the possibility that food companies will be tempted to source cheaper version of these non-GMO ingredients from other countries. This has happened all too often for organic.  That will open up the U.S. consumer to environmental pollutants (e.g. heavy metals) and to pesticides that have long been banned here, but which are still made and used in places like China and India.  It will also mean getting items from regions that are much less attuned to the need to detect and exclude dangerous mycotoxins from the food supply.

If Vermont ends up initiating a trend towards more non-GMO products, we should be asking participating food companies to go on record promising that they won't import the ingredients if they are available from the U.S. or other countries that enjoy a general context of sound environmental, food safety, and pesticide regulation. Without such assurances, we could have a serious case of unintended consequences.

You are welcome to comment here and/or to email me at savage.sd@gmail.com
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Why I Don't Buy Organic, And Why You Might Not Want To As Well

Some delicious, conventional Asian Pears

Originally Posted On Forbes 3/19
I don’t buy organic foods. In fact I specifically avoid doing so. It’s not my place to tell anyone else what to do, but I’d like to lay out three, seriously considered factors that have shaped my personal stance on organic:

  1. Informed confidence that we are safe buying “conventional” foods
  2. Recognizing that some of the best farming practices from an environmental perspective are not always allowed or practical under the organic rules
  3. An ethical problem with the tactics that some organic advocates and marketers employ which seriously misrepresents their “conventional” competition
For the last 40 years my wife and I have shared the shopping and cooking for our mostly home-based meals. We have always gardened, but also buy much of our fruit- and vegetable-rich diet from stores. When I say I don’t buy organic, that involves frequent decisions.

By all rights I should be an enthusiastic advocate and consumer of organic. I was a child of the generation influenced by “Silent Spring.” I was a dues-paying member of the Wilderness Society in high school. I grew up helping my beloved grandfather in his organic garden in the 1960s.  Some of our best friends in the late 1970s were pioneers in the development of the commercial organic industry. I’ve spent a significant proportion of my career developing biological and natural product-based pesticides which are applicable to organic. I fully appreciate the contribution that the organic movement made in the early 20th century when it highlighted the importance of fostering soil health. My problems with institutional organic are not at all about its founding ideals or about organic farmers, but rather about organic's self-imposed limitations and about the ethics of a sub-set of its promoters.

Confidence in the Conventional Food Supply
The USDA, which oversees the foods labeled as "Certified Organic", states quite clearly on its website about its role in organic,  that "Our regulations do not address food safety or nutrition."  Foods labelled "Certified Organic" must adhere to certain rules and regulations but aren't endowed with any particular nutritional or safety features. However, many consumers believe that the Organic label means the food has superior nutrition and is safer, especially in regard topesticide residues.  This is not true. Studies have shown no appreciable difference in nutrition between crops grown either organically or conventionally.

As for the safety issue. When most people hear the word “pesticide,” they imagine something scary in terms of toxicity to humans and the environment. The reality is that modern agriculture employs an integrated suite of non-pesticidal control measures, and the actual pesticides used today are mostly relatively non-toxic to humans. Organic farmers also use pesticides, and the products they are allowed to use are constrained with few exceptions by whether they can be considered “natural.” That is not a safety standard since many of the most toxic chemicals known are “natural.” Like all pesticides, these natural options are subject to EPA scrutiny, and so the pesticides that organic farmers are allowed to use are “safe when used according to the label requirements” which is the same standard for synthetic pesticides allowed on conventional crops. When it comes to pesticide residues on our food, there is a USDA testing program that demonstrates year after year that the pesticide residues on both organic and conventional foods are at such low levels that we need not worry about them. I confidently buy non-organic foods based on this public data that demonstrates that our system is working and that we consumers are well-protected.
My granddaughter enjoying "conventional" raspberries (yes, she did then eat them)



What the USDA data demonstrates is that the environmental movement was not a failure - it effected real change over the past 5 decades! We don’t have a two-tiered food supply in terms of safety in which only those who can afford the premiums get safe food. I also believe the global scientific consensus that“GMO” foods are safe, and so I don’t need to buy organic to avoid those.
This No-Till Field is good for the environment and the food supply 
Environmental Idealism

I have always been concerned about the human impact on the environment, and particularly about the impact of farming since that industry has the largest “footprint” in terms of land area. I spend a lot of time reading the scientific literature concerning agriculture and the environment. Some of the farming practices that are commonly employed on organic farms are very positive from an environmental perspective, but those practices are also used by progressive “conventional” growers. There are also quite a few farming practices with excellent environmental profiles which are difficult to implement under the organic farming rules (e.g. no-till farming,spoon-feeding of nutrients via irrigation). Compost, which is a major input for organic farms, has a shockingly high “carbon footprint” because of methane emissions. The carbon footprint of “synthetic” fertilizer is much smaller.
From an environmental perspective, the biggest issue for organic is that it requires significantly more land to achieve the same level of production. Were organic to become more than a niche category, this yield gap would be highly problematic from an environmental point of view.  I would much rather buy food from "land-sparing" farmingsystems.

Organic yields are substantially lower for many major crops



Ethical Issues

My third reason for not buying organic has to do with ethics. Organic exists as a sort of “super brand” that transcends anyone marketing under that banner. Unfortunately, within the organic realm there are certain major marketers (and advocacy groups they fund) who employ fear-based and falsehood-based messages to demonize “conventional” foods.  They use these methods as a means to promote organic. One of the most egregious examples is the “Old McDonald/New McDonald” video funded by Only Organic – a consortium of very large organic marketers. This bizarre publicity piece exploits children to depict a completely distorted view of mainstream farming.  I consider it to be "hate speech for profit."

Another example is the organic-industry-funded Environmental Working Group which grossly distorts that transparent, USDA, public database documenting the safety of the food supply and turns it into a “dirty dozen list” designed to drive organic sales. These are extreme examples, but the organic marketing community as a whole quietly benefits from this sort of propaganda and does nothing to correct the “convenient fiction” that organic means no pesticides. I realize that only part of the organic industry funds and promotes the most vicious sort of disinformation, but I rarely see organic representatives standing up and objecting to the sort of fear-mongering that ultimately benefits the sales for the entire super-brand.

The fear-based messaging drives the intense social pressure, that parents in particular feel, about whether they need to buy organic. I don’t want any part in rewarding this sort of fear/shame-based marketing. In the absence of a significant objection from more of the organic community, I don't want to support the "super brand."


So, these are my reasons for not buying organic products. I feel perfectly comfortable buying the alternatives that align with my practical, idealistic and ethical standards.

Please feel free to comment here and/or to email me at savage.sd@gmail.com

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Ten Thousand New Reasons Not To Worry About Pesticide Residues

(Originally posted on Forbes 3/1/16)

Each year, the farmers around the world who produce our food (fruits, vegetables, grains) get the equivalent of a “grade” on a giant “group project.”   For 2014 they got another A+ as they have for many years.  The “test” entails thousands of food samples, which the USDA collects from normal US food channels and then scrutinizes for pesticide residues using extremely sensitive laboratory testing methods. They are checking for any detectable residues (41% of samples have none) and whether any of the detectable residues exceed the conservative “tolerances” set by the EPA (99.6% of the samples met that exacting standard). This means that our regulatory/farming system is working extremely well! Farmers are able to produce crops without the inefficiency and quality issues associated with excessive pest damage, and consumers are able to safely enjoy what they grow. The official conclusion from the USDA is “These Pesticide Data Program data show that, overall, pesticide residues found on foods tested are at levels below the tolerances established by the U.S. Environmental Protection Agency (EPA) and pose no safety concern.”


Chemical pesticides are only one part of the pest control regime, but an important one. The chemical pesticides in use today are predominantly low in mammalian toxicity, but for all pesticides the EPA sets detailed rules for how they can be used (e.g. maximum rates, periods of time before harvest…). These are designed to ensure that any residues that remain at the consumer level are below a “tolerance” based on a rigorous, multi-factorial risk assessment by the EPA. The tolerance is generally 100 times less than a dose that could cause any ill effect.  The allowed residues are also lower than the levels of natural pesticidal compounds that many crops make to defend themselves.

The 2014 USDA “test” is called the Pesticide Detection Program or PDP, and it has been conducted every year since 1991. For 2014 tests were done on 10,750 samples including 21 types of fruits or vegetables, two grains, two types of infant formula and salmon. The scientists detected a total of 22,890 specific pesticide residues of which 98.5% were below tolerance or at such low levels they couldn’t even be properly quantified (see table below).


I appreciate the fact that the USDA makes this data available and transparent. It allows us to see that not only are most of the residues below tolerance, a great many of them are more than 10, 100 or even 1,000 times lower than the tolerance (see column chart below - all to the left of the center bar are no-issue detections, but 84% are far below).


There are some minor differences between crops. In the two charts below, the light green bars show how many of the detections in a given crop were below tolerance, and the dark green bars show what percent were 10 or more times lower than the tolerance. The samples of infant formula had, happily, either no detections (dairy-based formula) or a few detections that were between 1000 and 5000 times lower than the very low tolerance (soy-base formula, 7 of 527 samples). Oats and rice also had few detections and those at very low levels.

Unfortunately, the very transparency which documents the safety of our food is grossly misused by an organic industry-supported organization called the Environmental Working Group. EWG conducts its own “analysis” of the data in which they completely ignore how the detections differ from one another and how they relate to the tolerances. Their choice to represent as “dirty” any residue, no matter how low or non-toxic, conveniently ignores the fact that similar pesticide residues are also regularly detected on the organic options that they promote. Hopefully they will refrain from such irresponsible fear-mongering this year.
So, at the risk of being like a parent who only focuses on an A- on a report card of all A+s, I looked in detail at the 1.5% of residues were of any potential concern. For the few detections that exceeded tolerance, most were only marginally higher and thus of very minor concern.  There were some residues detected for which there was not a tolerance for that specific crop, but in most of those cases the levels were lower than the tolerances for other crops.  The EPA also tests for some old, long-banned pesticides notorious for their environmental persistence. There were 18 detections of such materials, including three from organic samples.  Of those 18, 17 were at extremely low levels and only one was very significant (0.46ppm monocrotophos in a squash sample from Mexico).  All in all, I could only find 11 residue examples of moderate concern, which is an amazingly small number (0.045%).  I have posted a much more detailed analysis on Scribd.  If anyone is interested I'll be happy to email you that full summary.
So once again, the take-home message is that we have another 10,000+ reasons to confidentially enjoy our American food supply.  My congratulations to those who produce it for us.

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Using DNA To Fight Fabric Fraud

California Pima Cotton
(This post originally appeared on Forbes 2/13/16)

The most desirable cotton is distinguished by having extra-long staple fibers (Egyptian, Pima) and such cotton commands a price premium. But as the cotton moves around the world, and through the fabric value chain, there is the potential for it to be diluted with or fraudulently replaced with lower price, lower quality materials. Clothing manufacturers like to make quality-related or sourcing claims, but the closer an item gets to the retail shelf, the more difficult it is to certify that the garment is really made from the type of cotton they intended. A company based on Long Island called Applied DNA Sciences (NASDAQ: APDN) has developed ways to identify what is real and what is not in this market. They can verify cotton items by identifying the native cotton species via DNA testing. Their methods can tag and test cotton textiles and finished goods using DNA technology to provide a means for traceability to the source were the cotton was grown and harvested. They employ sophisticated DNA testing of the type typically used in human forensics – the kind of thing you might see on an episode of CSI.


Scanning Electron Micrograph of Cotton Fibers (Wikipedia)


How does this work? Each cotton fiber was originally a living plant cell, and so it had the full compliment of cotton genes. By the time the cotton boll has matured, the cells are no longer viable and the DNA begins to degrade, something that continues during the many steps of ginning, spinning, weaving, dying etc. Still, enough DNA fragments remain to allow ADNAS to detect important elements of its genetic signature. They can already tell the difference between something like the premium Pima varieties and common upland cotton also known as fiberTyping Recently ADNAS has partnered with the Agricultural Research Service Genetics Unit of the US Department of Agriculture to genetically verify multiple types of individual cotton cultivars, and assist the cotton industry in protecting quality, traceability and economic investments. The USDA scientists have an extensive collection of cotton germplasm from around the world. Like many crops, the cotton has to be adapted to the growing conditions in each region. That means that cotton grown in India, China, Spain, Egypt or Uzbekistan may have unique and detectable differences in their DNA. In the near future a clothing company may be able to make label claims about cotton quality and origins no matter how convoluted the path has been from the farm to the store. In addition to quality issues, responsible clothing manufacturers want to be able to avoid sourcing their cotton from parts of the world where undesirable practices like forced child labor are known to happen. This will also protect the farmers who grow the high quality product. There are many other logical applications of this sort of technology such as olive oil, premium wine or the dietary supplement industry.

Applied DNA Sciences has an additional system that it calls “SigNature-T” which can be used to intentionally “tag” cotton or other commodities for aspects of how they were produced - things that go beyond anything specific to the plant’s own genetics. For instance an on-the-ground certifier could inspect a crop to document the fact that it was grown with sustainable farming practices like no-till and cover cropping. ADNAS has identified certain unique, botanically-derived, DNA tags which they can produce, and then apply in tiny amounts to the cotton at a step like ginning. Later, that DNA signature can be detected to say, “yes, this cotton was produced with x,y or z desirable methods” because those specific DNA tags can only be there if the certifier allowed it. The same thing could be done in many crops to verify a variety of claims.

USDA-ARS Shot Of No-Till Cotton


Cotton has been a logical place for ADNAS to begin because it represents literally hundreds of millions of tons of product from around the world, and they have the capacity to do the tracking for that kind of volume. But all plant-based products carry with them distinctive “stories” written in their own DNA or which could be added as micro amounts of DNA tags. Through the incredible advances in the field of molecular biology, those stories can now be used to encourage and reward “integrity” in the system.

You are welcome to comment here and/or to email me at savage.sd@gmail.com
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Why The Current Round Of Ag-Chem Consolidations Worries This Agricultural Scientist

This no-till field is good for the environment and the food supply.
Such innovations involve many expert contributions

I am concerned that we may be on the verge of a major loss of knowledge and experience in the agricultural sector. In the 40 years I have worked with agricultural technology companies I have witnessed many changes. There was a major round of consolidation in the late 1990s and that is happening again today. There are reasons that these trends can make business sense and can be good for shareholders. There can also be problematic aspects of consolidation. Many expressed concerns with antitrust issues in the Monsanto-Syngenta connection, which didn't end up happening, and now with the Dupont-Dow merger, which looks like it will.

That isn't what worries me -- it will still be a competitive sector. I'm concerned about a likely loss of expert knowledge about agriculture.

When companies merge there is a seemingly irresistible financial incentive to get the most experienced (and thus highly paid) employees to take early retirement as a way to deal with "redundancies." Perhaps this won't be as much of an issue with Syngenta, a chemical discovery and biotech company that agreed Wednesday to be bought by ChemChina, a generics player. However, if the retirement strategy is employed in this or the rest of the current wave of consolidations, it will lead to a loss of deep knowledge and experience that could not come at a worse juncture in the history of the food supply.  (Let me be clear that I have no insider information about any of the pending deals or corporate employment plans.  I have consulted across the industry since 1996, but at the mid-level technology level, not in corporate strategy or financial circles).
Between 1960 and 2010, agricultural output increased mainly through higher yields.
That required a great deal of technical and farmer innovation driven by knowledge
(based on FAOStats data)

Global agriculture is a diverse and complex phenomenon that involves unique challenges and unpredictable risks. The extraordinary success of this industry in meeting food demand while improving sustainability relies on a combination of business understanding and technical knowledge that is not easily learned. People with decades of experience on either the business or science side (or often both) are critical to negotiating the threats and opportunities before us. It will be far from trivial to meet the food demand of the growing population and the consumption desires of the expanding middle classes in previously poor regions. To do this without needing to expand the base of farmed land will require talent and expertise. This increased demand is happening with the added uncertainty of climate change and the spread of "exotic" pests in an ever more connected world. A major wave of retirements could seriously compromise our resources of skill, experience and wisdom needed to meet these challenges.

This likely retirement scenario is even more concerning because of the lack of new, skilled talent coming into the agricultural industry. Ag technology companies have been having an extraordinarily difficult time finding qualified new hires because very few young people today are interested in the scientific fields that are critical for agriculture (entomology, agronomy, soil science, plant pathology, plant breeding...).  I don't know the reasons, but I suspect that the widespread demonization of "industrial agriculture" has much to do with this phenomenon. As it is, companies are having to hire people with other degrees (e.g. environmental sciences or even the humanities) and train them from scratch. That isn't impossible with bright and willing people, but if many of their best potential mentors are departing, it becomes far more difficult.

I don't want to imply that the sky is falling. There are still a great many talented people who will be involved in advancing agricultural technology.  However, I do think that the industry and/or society needs to consider some creative ways to allow continued access to the collective experience of those who may soon "retire".  Consulting or some sort of part time "emeritus" status might be possibilities, but those can have tax and retirement income problems. For many industries we would be wise to fix our system so we don't dis-incentivize a graceful wind-down of careers. Perhaps some of the retirees can be hired by other AgChem companies who need their expertise. With modern life expectancies, retirement in one's 60s can easily mean 20 years of lost contribution potential.  It's not that I begrudge my slightly older colleagues a well deserved rest or the chance to start a new chapter in their lives. I just don't want society to lose the unique aspects of what they know.

Your thoughts and comments are welcome here and/or via email (savage.sd@gmail.com)

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