- Ms. Andrea HubertyRegulatory Analysis and Development, PPD, APHIS, USDA
Stop GMO Contamination of Organic!
Herbicide-loving alfalfa and sugar beets, Monsanto's new GMOs (genetically modified organisms), have been blocked by the courts because Bush's USDA failed to consider their environmental impacts, including whether they would contaminate organic crops. Obama's USDA has a plan to get Monsanto's new GMOs out of the courts and into the fields. USDA Secretary Tom Vilsack, former biotech governor of the year, calls the plan "coexistence." The Organic Consumers Association calls it "contamination" and we say, "Hell no! No new GMOs!" The USDA is currently accepting public comments on an Environment Impact Statement that would be the basis for the commercialization of Monsanto's "RoundUp Ready" GMO alfalfa, the first-ever genetically engineered perennial. The USDA should put a hold on the agricultural use of genetically modified organisms until health and environmental safety can be assured. Thus far, regulation of agricultural GMOs has been so lax that instances of contamination and environmental destruction are the norm rather than the exception. Examples include:
- Monsanto's Bt corn toxins active in ecosystems where they are deadly to aquatic species
- Non-approved varieties of GMO canola established wild populations in North Dakota
- Numerous weeds have developed herbicide resistance since the introduction of GMO crops
- Pesticide compounds from GMO crops found in non-GMO crops and products
- Consumers eating GMO foods that have not been adequately tested for their health impacts, without their knowledge or consent
What would it take for the USDA to adequately protect traditional farming, the environment and consumers from the harms of genetically modified organisms used in agriculture?
- Establishment of a fully distinct and separate USDA public cultivar and breeds Institute to ensure that farmers have elite public cultivar and breeding choices that are not genetically modified and that germplasm collections are free of GMO contamination.
- Creation of a Contamination Compensation Fund in FSA or RMA funded by GMO patent holders and based upon their strict liability. This would provide immediate assistance to all farmers and other supply chain participants contaminated by GMOs, pending further necessary remedies of law and equity. Such a Fund would establish costs associated with the prevention of GMO commingling and contamination from seed to table and would include both perpetual type costs as well as identity preserved price differential costs for organic and other non-GMO.
- Ongoing GM crop regulation, including the complete elimination of deregulated GM crop status; including prior deregulations and on-going oversight and public evaluations of compliance and enforcement.
- Comprehensive, independent, longitudinal studies on the health impacts of eating GMOs and on the environmental and socio-economic impacts of release prior to GM crop approvals.
- Prohibition on the growing of GM crops that are deemed too promiscuous to prevent GMO Contamination.
- Mitigation of food security risks associated with the concentration of any sector of our food system in the hands of a few companies or with the use of one food production technology or patented seeds or genotypes to the near exclusion of all others.
- Institution of an immediate labeling protocol for all GM crops, products, and ingredients in close collaboration with other agencies as required.
- Regulatory Analysis and Development, PPD, APHIS, USDA
Ms. Andrea Huberty
I am writing with concerns regarding the USDA's Environmental Impact Statement on genetically engineered alfalfa, which paves the way for the commercialization of Monsanto's Roundup Ready alfalfa, as early as spring 2011.
I avoid foods that contain, or are produced with the use of, GMOs (genetically modified organisms). GM alfalfa sprouts should be labeled, along with milk and meat from animals fed GM hay and honey from bees that feed on GM alfalfa nectar, as well as dietary supplements and herbal remedies that contain GM alfalfa. Mandatory GMO labels are necessary for consumers like me to make informed food choices.
In addition to mandatory GMO labels, consumers like me need assurance that non-GMO foods, conventional and organic foods alike, aren't contaminated with GMOs. If I were informed that GMO traits had been found in conventional and organic food, I would avoid that food until I could locate a non-GMO source. Fear of inevitable contamination is what is already driving voluntary systems like the Non-GMO Project.
The USDA needs to put measures in place to prevent contamination of conventional and organic foods. A moratorium on all GMOs is the only way to guarantee they won't infect the food supply. Short of that, geographic restrictions and buffer zones to prevent GM contamination by bee pollination is a good start, but it's not enough. Alfalfa is a hardy perennial and volunteers are likely to crop up long after the crop has been harvested. The only way to make sure GM contamination is minimized is to hold Monsanto strictly liable for the presence of their GMO traits in conventional and organic alfalfa and for Monsanto to fund a testing program to monitor for contamination.
The costs of avoiding GM contamination must be borne by Monsanto, not the conventional and organic producers who are put at risk by the commercialization of Monsanto's products. If the costs of avoiding contamination are the burden of conventional and organic producers, this will make non-GMO products more expensive, or, worse, if the costs can't be passed on to the consumer, non-GMO producers might be forced out of business by increased costs. Either way, consumers will have reduced access to non-GMO foods.
Aside from the issues of contamination that the courts have required the USDA to address, there are many reasons to reject the deregulation of GM alfalfa.
Consumers who ingest Roundup Ready alfalfa genes are risking their health; according to the Environmental Impact Statement, "acute toxicity in mice was observed."
According to the EIS, consumers who ingest Roundup may experience "general and non-specific signs of toxicity from subchronic and chronic exposure to glyphosate includ[ing] changes in liver weight, blood chemistry (may suggest mild liver toxicity), liver pathology, and weight of the pituitary gland."
The EIS warns that, "Based on upper estimates of exposure ... infants consuming fruit and all age groups consuming vegetables may be at risk of adverse effects associated with acute exposure to glyphosate residues."
Consuming milk and meat from animals fed crops that are genetically engineered is also risky. In a survey of milk products sold in stores in Italy, results from the screening of 60 samples of 12 different milk brands demonstrated the presence of GM maize sequences in 15 (25%) and of GM soybean sequences in 7 samples (11.7%).
Consumers are going to want to avoid Roundup Ready alfalfa, but according to the EIS, we don't have that right because, "At the present time, there is no policy regarding the unintended presence of GE material in organic products or food, consistent with the fact that the NOP is a process-based program for certifying a farm or production system as organic, and not a product-based program that tests or certifies individual products as organic."
GM alfalfa hasn't been proven safe, so the USDA shouldn't approve it, but if it does, geographic restrictions and isolation distances, while important, aren't enough to prevent GM contamination of organic, or to protect consumers trying avoid eating GM foods.
The USDA should hold Monsanto strictly liable for all harms caused by its products, including contamination of organic crops, and GM alfalfa sprouts, as well as milk and meat from animals fed GM alfalfa, need to be labeled.
Thank you for the opportunity to submit these comments.
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