A Failure of Mission – The USDA, GE Alfalfa and the disregard for the Precautionary Principle.

The concept of the precautionary principle chart

” We provide leadership on food, agriculture, natural resources, and related issues based on sound public policy, the best available science, and efficient management ” - USDA Mission Statement.

THE PRECAUTIONARY PRINCIPLE: The precautionary principle can be described as a loosely accepted means of: proceeding cautiously with scientific advancement in the face of scientific uncertainty; taking into account alternatives to what could lead to harmful results; putting the burden of proof on the proponents of the advancements rather then those that might be or are later harmed by it. In other words; “If we’re going to do this, let’s do it right and let’s do it safely.”

In what could be seen as an aggressive attempt to live up to President Obama’s vow to remove some “outdated and unnecessary regulations” the USDA, via Agriculture Secretary Tom Vilsack, recently deregulated three genetically engineered (GE) crops: Roundup Ready alfalfa; Roundup Ready sugar beets; and GE seed-based ethanol corn. In all three cases it has done so in the face of serious misgivings by some in the scientific, organic, and conventional (non-GE crop) farming communities. One of those concerns centers around the high probability that GE crops will contaminate (commingle with) organic crops in nearby fields. As Albert Straus of the Straus Family Creamery — the first certified organic dairy west of the Mississippi River — had to
say
:

This USDA decision puts our business at risk and also the entire supply of organic dairy products that Americans have come to count on. Organic dairy is the second-most commonly purchased organic food group (after fruits and vegetables). Consumers of all ages who care about healthy foods and the environment have come to rely on organic dairy products as a staple of their diet.

Alfalfa is an essential feed for our dairy cows. Because of the way alfalfa is pollinated, the potential for contamination of organic alfalfa by GM alfalfa is high.

The Straus family, and their partner businesses, have much to worry about. Evidence is mounting that prevention of crop commingling is likely impossible. To put it simply, it is the dominion of nature to commingle and mutate. It is an absolute condition of life on earth. And it is the inevitable conclusion to the introduction of genetically engineered organisms (GEO) into the environment that such mutation and commingling will occur.

That being the case, not only do GEO present a threat to the businesses engaged in organic food production, but to those hoping to purchase organic, GEO-free products. That is to say, given the likelihood that cross-contamination will occur, with enough time it will eventually become so complete as to assure the contamination of all organic foods. The choice for people to opt out of genetically engineered foods in their diets would no longer exist. Such a right would, by all rights and means, vanish in the winds of time.

Even today, where upwards of 90% of all soy crops are genetically modified, it’s almost impossible to avoid eating soy based products without it being genetically modified’ soy.

Currently, up to 40 percent of U.S. corn is genetically engineered as is 80[sic] percent of soybeans. It has been estimated that upwards of 60 percent of processed foods on supermarket shelves–from soda to soup, crackers to condiments–contain genetically engineered ingredients.

And the opposition to GEO doesn’t end with the organic community of growers, ranchers and consumers. In fact the threat of commingling of genes from GE crops with non-GE is so wide-ranging that, in the case of the genetically modified ethanol corn, five major U.S. trade associations have released a joint statement declaring “disappointment” in the USDA’s decision. These very agencies are generally in favor of crop manipulation through biotechnological means, but see in the USDA ruling, a direct threat to their members’ export businesses.

From the Corn Refiners Association, National Grain and Feed Association, North American Millers’ Association, Pet Food Institute and Snack Food Association, joint statement:

“We believe USDA failed in its first opportunity to devise a policy that would be appropriate for biotech-enhanced traits whose unique properties are functionally different from other biotech or conventional commodities, ” the organizations say. “We do not believe USDA’s decision adequately considers the impact on food and feed processing that will result if this particular biotech corn, through pollination or other means, becomes commingled in the general commodity stream.”

Such a statement from otherwise politically conservative associations make it clear concern about GEOs and their potential to undermine various age-old farming and ranching sectors of our economy are becoming wide spread. And yet the USDA goes full steam ahead deregulating with reckless abandon. In an effort to offer an alternative approach to the process of dealing with genetically engineered organisms, a small organization known as the National Organic Coalition has devised a series of steps it thinks could be the very least the USDA should and can do to deal with the potential harm, areas of responsibility, and means of redress for those harmed. Called the “Principles To Drive GMO Contamination Prevention Strategies (pdf)” they are outlined as such:

  • Consumer choice – Consumers have the right to choose non-GMO food.
  • Consumer right to know – Consumers have the right to know where and how their food was grown.
  • Farmers Entrepreneurial Choice – Farmers must have the right and opportunity to grow food, feed, fiber, livestock, and fish that serve important and lucrative domestic and foreign markets.
  • Fairness – Personal and corporate responsibility must be upheld. If you own it and are profiting from it you are responsible for the costs associated with contamination prevention and any resultant damage from contamination.
  • Liability – Testing for contamination, establishing buffers, reimbursement for lost sales, loss of organic product premiums, clean-up and removal are the costs of doing business that must be borne by the GMO patent holder.
  • Precaution – The pre-market burden of proof of safety is on the patent holder. This includes comprehensive evaluation of health, socio-economic, and environmental impacts of GM crops and technologies.
  • Sustainability – Agricultural technologies and systems must be assessed for sustainability and those that facilitate further declines in family farming or erode the human and environmental foundations of American agriculture must not be allowed.
  • Health, Environmental and Economic Evaluation – Technologies that pose environmental, economic, and health risks should be evaluated before commercialization and tough choices must be made about whether their overall societal benefits outweigh their costs.
  • Parity – There must be a long-term commitment to supporting the vitality of diverse agricultural enterprises, including parity of public investment, infrastructure,
    marketing, technical assistance, research, and funding.
  • Transparency – Ongoing documentation, tracking and labeling systems must be established to monitor the movement of GMOs in the environment, seed banks, non-GMO seed stocks, and food.
  • Diversity – Society and agriculture will greatly benefit from the rapid reinvigoration of public cultivars and breeds to restore genetic diversity on farms, ensure greater farmer seeds/breeds choices, and to enhance national food security.

They go on to list what they see as the “development of strict and long-overdue GEO regulations“ which they add “should specifically include at least “

  • Labeling of GM (genetically modified) crops and product ingredients.
  • Liability assignment to the GMO (genetically modified organisms) patent holder.
  • Contamination Compensation Fund in FSA or RMA through a fee on GMO patent holders, which would provide immediate assistance to farmers pending further necessary remedies of law and equity.
  • Ongoing GM crop regulation and the complete elimination of deregulated GM crops.
  • Comprehensive, independent health, environmental, and socio-economic assessments prior to making a decision on GM crop approvals.
  • Prohibition on the growing of GM crops that are too promiscuous to prevent GMO contamination, such as GM alfalfa, GM sugar beets, GM corn, and GM canola.
  • Evaluation 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 seed to the near exclusion of all others.
  • Establish infrastructure to prevent GMO commingling and contamination during post-harvest handling.
  • Patent holder should be responsible for full segregation and traceability, from seed to plate

These are sound and responsible steps that would make sense in a world where doing business also meant doing no harm. But from the moves the USDA recently made in irresponsibly deregulating a slew of GM crops, it becomes clear they are helping create a world where causing potential harm takes a back seat to making profit and in so doing are, in our opinion, failing in their stated mission to “provide leadership…based on sound public policy,[and] sound science”. We only ask that the USDA and all food oversight agencies take the time to conduct independent research to ensures our food, environmental and personal safety. The stakes at hand are worth at least that precaution.

What can you do to help turn the tides on GEO contamination of organic food production?

You can help fund the latest legal challenge by the Center for Food Safety in their on-going effort to “preserve the integrity of organic, protect the consumers’ right to know, stand up for organic and conventional farmers, and protect our environment from the hazards of GE crops”.

Or you can sign one of the online petitions like Care2′s “Oppose GE Alfalfa”.

Or by simply contacting your Senators, Representative, or the Obama Administration directly and letting them know you deserve the right to choose GE-free foods and that it is their job to assure you can.

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