Tuesday, July 24, 2012

Genetically-modified sugar beets, food labeling, and related issues

A few days ago, the US Department of Agriculture announced its decision after one year of studying the potential impact of genetically modified sugar beets. The specific sugar beets that they were studying are officially known as "Glyphosate-Tolerant H7-1 Sugar Beets."

These transgenic sugar beets were first tested in the US beginning in 1998 under close regulation and supervision, and approved for nonregulated planting and harvesting in 2005 by the USDA's Animal and Plant Health Inspection Service (APHIS).

However, in January of 2008, four citizen groups (the Center for Food Safety, the Sierra Club, the Organic Seed Alliance, and High Mowing Organic Seeds) filed a lawsuit in the US District Court of the Northern District of California challenging this determination of nonregulated status. That court ruled in September of 2009 that the earlier ruling had failed to consider certain potential impacts of this genetically-modified crop, and in August of 2010 vacated the earlier decision, making H7-1 sugar beet planting again subject to certain regulations which require permits before planting or transporting this crop (among other regulations).

An Environmental Impact Study was then undertaken in order to present the regulatory agency's decision-maker with extensive details about the case, and the pros and cons of three different alternatives: in the first alternative, the agency would take no action and H7-1 would remain regulated; in the second alternative the H7-1 sugar beet would be fully deregulated; and in the third alternative the production of these genetically-engineered sugar beets would be partially deregulated.

The study was completed in May of this year and it is 801 pages long. You can read the entire thing online or download it onto your own storage at the USDA APHIS website here. The report recommends option 2 -- full deregulation -- as its "preferred alternative").

Four days ago, the USDA regulatory decision-maker announced their decision, which was to fully deregulate H7-1 sugar beet production and usage in the US.

As the 801-page USDA report explains, about 60% of the sugar consumed in the US comes from sugar beets. This means that much of the sugar found in US food products (and it is found in an astonishing number of US food products) will potentially be derived from genetically-modified sugar beets in the future.

I have already published a fairly extensive post discussing genetically modified food earlier this year, which started out with the statement: "This post does not purport to tell you what to think about genetically-modified crops (although I have come to some of my own conclusions about the subject, some of which you might detect as you read on)."

There are reasons why genetically modified sugar beets are desired by some farmers, and it is a complicated issue (have a look at the 801-page report for a full rundown). Sugar beets are very susceptible to weeds and do not compete well with them, and thus almost all those who grow sugar beets spray the area heavily with herbicides.

The genetically-modified H7-1 variety is resistant to glyphosate, which enables growers to use less of other chemicals (because they can now simply spray glyphosate over the entire field, beets and all, knowing that the beets are engineered to be glyphosate-resistant).  Some of the chemical herbicides which glyphosate replaces do seem to be much more toxic to animals and humans than glyphosate according to the 801-page report, although glyphosate itself is not something you want to consume either. When fed to lab animals, glyphosate caused the following damage:
Rabbits exposed to glyphosate showed mortality, diarrhea, and nasal discharge at 350 mg per kg per day in a developmental toxicity study. A developmental study in rats showed incomplete development of the sternebrae (a structure similar to the sternum or breastbone in humans) and decreased body weights in the offspring of mothers exposed at 3,500 mg per kg per day. At the same dose, the mothers were found to have mortality, decreases in the total number of viable offspring, decreases in implantation of fetuses in the uterus, decreased body weight gain, diarrhea, inactivity, and red matting on the head, forelimbs, nose, and mouth. On the basis of developmental studies in rats and rabbits and reproductive findings in rats, glyphosate exhibited no evidence of increased qualitative and quantitative susceptibility. page 364 of the USDA report.
More concerning perhaps is the introduction into the plant of foreign genetic material (hence the term "transgenic"), which in the case of the H7-1 sugar beet, as in most other genetically modified organisms (or GMOs) is accomplished through the mechanism of bacteria and viruses, since bacteria and viruses make a living by invading the cellular material of other organisms.

The genetic material that alters conventional sugar beets to create the glyphosate-tolerant H7-1 sugar beet consists of a "promoter sequence" from the genetic material of the figwort mosaic virus, a "chloroplast-targeting sequence" from the arabidopsis thaliana or mouse-ear cress plant, and a "coding sequence" and a "terminator sequence" from the agrobacterium sp strain CP4 and E 93'.

As the USDA report explains, the modified DNA in the sugar beet does not seem to make its way into the sugar that is produced from these sugar beets, and when Japanese regulators were looking into the labeling of sugar from genetically-modified beets they decided that it was impossible to detect what sugar came from what kind of beets, and so the health threat to humans may be negligible from sugar produced by these beets (pages 343-344 of the APHIS report).

However, there are other potential concerns, including the fact that these sugar beets are also fed to animals that end up in the food chain (and fed to them without being turned into sugar, so that their  genetically-modified DNA does make its way into their gut), as well as the real likelihood that genetically-modified sugar beets will cross-pollinate or "outcross" with other members of the beet family, including table beets and swiss chard (all of which are sexually compatible with sugar beets).

There is also the concern that the potential impacts of the consumption of genetically-engineered food are not fully understood, and may pose unforeseen dangers for human beings, for the beneficial bacteria that live in our guts and which are essential to our health and perhaps our survival, and for all kinds of ecosystems including those that sustain our agricultural activities.

The other major problem with the ongoing proliferation of genetically-modified organisms in the food chain is that many consumers may be completely unaware that the food they are consuming now contains GMOs. Genetically-modified plants are a fairly recent development, and were not in the food supply at all when I was growing up. They have not been explained to the public by any means, and many will undoubtedly be surprised to learn that much of the sugar found in their food already comes from genetically-engineered sugar beets, and that more will no doubt come from genetically-modified sources in the future. Sugar is found in an amazing array of foods, and unless the list of ingredients specifies that it comes from sugar cane, it often comes from sugar beets (more than 50% of the time, in the US).

Below is a photo of the ingredients of a peanut-butter jar prominently labeled as "natural," with "sugar" listed as the second ingredient. The source of the sugar (whether from cane or beets) is not specified, and since this "natural" peanut butter is not organic, there is certainly the possibility that it came from genetically-modified sugar beets.

However, there is really no way for the consumer to know (short of calling the company), and for the consumer to thus make an informed decision as to whether he or she should purchase this peanut butter for a certain price, or search for a different peanut butter at possibly a higher price if the consumer wishes to avoid feeding genetically-modified foodstuffs to his or her children (or to himself or herself). As it stands, he or she must assume that anything that says simply "sugar" may contain GMOs, if he or she feels strongly about the subject.

There are ballot initiatives in the US which would make it mandatory to label ingredients as GMO when they are present in foods, so that consumers can avoid them if they want to. This is not the same as prohibiting GMO foods -- consumers would have a choice to buy what they wanted to buy, and farmers would have a choice to grow what they wanted to grow, and food companies could decide to make foods with GMO ingredients and without GMO ingredients to appeal to different segments of the market, if they so desired.

One such ballot initiative was recently approved for vote in California, having gathered nearly a million signatures, and voters can find it as Proposition 37 when they go to the polls this November. The initiative language can be found here. It would require that a food made with a GE ingredient must carry a label stating that the product may contain genetically modified ingredients, effective July 01, 2014. There are certain exemptions, such as alcoholic beverages, animals that have not been genetically modified themselves regardless of whether they were fed or injected with genetically modified substances, and food crops that were not "knowingly and intentionally genetically engineered."

Who could possibly be against labeling so that consumers could know whether or not their sugar or other ingredients came from genetically engineered sources? Well, it turns out that a lot of people could and are. Some of them may have financial incentives for being against it (just as some who are for it may have financial incentives to be for labeling).

The best philosophical argument against the initiative, in my opinion, is the argument that companies can already choose to label their products as GMO free (if they truly are), and consumers can exert pressure with their own purchasing decisions, without the government getting involved with laws and regulations forcing such labeling.  This argument is philosophically better than others, in my opinion, because it takes the perspective that the individual is an adult, without the need of a paternalistic government which constantly passes laws to interfere with issues that the individual should be able to decide for himself or herself.  It assumes that individuals who care about GMOs will make the effort to become informed, and avoid ingredients that might contain transgenic ingredients, and that corporations run by other individuals may make the decision to cater to those GMO-avoiding individuals without having to be told to do so by the heavy hand of government.

However, as we've already seen, the array of foods derived from genetically-engineered crops is truly stunning. It is very unlikely that any but a very small minority of consumers are aware that more than half of sugar in the US is derived from beets, and that transgenic sugar beets have been used to produce some of that sugar for years.  While a small percentage of consumers may be aware of their potential exposure to GMOs, it is so difficult to avoid them (and becoming more difficult, especially with the addition of most sugar to the list) that the individual is at a severe disadvantage in this case.

Similarly, over 80% of corn and over 90% of soy produced in the US is genetically modified, according to some information sources. The number of products containing corn and corn derivatives in the food supply is truly staggering. Because this change has taken place without any real widespread perception by the public that consumes that food, what I believe to be the best philosophical argument against mandated labeling loses some of its force.

There are many interests that might have a financial reason to oppose labeling, including producers of food that contains genetically-engineered ingredients, who may fear that such labels will place them at a competitive disadvantage. Those who argue publicly against labeling of GMO ingredients typically argue from one or more of these three positions: 1) that because transgenic organisms are safe, there is no need for such labels, 2) that such labels will raise food prices due to the costs involved with regulating and labeling, and 3) that such labels will "scare consumers" unnecessarily.

Here is the website of an organization that donated a significant sum of money to oppose California's upcoming Proposition 37. While their specific argument against the idea of providing consumer labeling for free choice is not specified on their website (even on their "Resources and Information" and "Issue Briefs" and "Fact Sheets" sections), they do provide a link to an argument from a state senator from a state other than California arguing against the concept of labeling GMO products.

That page provides a link to the state senator's full argument, which argues that if states are allowed to mandate their own labeling for food, "our food would start to cost more" and some parts of the country might try to scare consumers with "skull-and-crossbone images." Moreover, he argues that "The labels wouldn’t make food safer because biotech ingredients are already 100-percent safe." Finally, he calls the efforts of his opponent's an "anti-scientific agenda that will make it harder for families to feed themselves."

The use of the term "anti-scientific" is often employed by those who want to undermine the arguments of their opponents, even if their opponents are using arguments that are based on evidence, or that are calling for more studies before dogmatic assertions are accepted without question. Which is more scientific -- to say that some evidence appears to support other possible conclusions and to ask that such evidence be examined, or to declare that there is no opposition to the conventional wisdom and that any arguments to the contrary do not deserve to be examined?

Further, the idea that people should not be informed because some segment of the population might become "scared" (and that because of this, information should be withheld from everybody else) is actually the truly frightening prospect for the elected leaders of a free people to be arguing.

I personally do not find any of these arguments against the requirement to label GMO ingredients to be convincing. Further, unlike the first objection highlighted above, which is philosophically superior in that it argues from the position that the individual is an adult who can figure things out himself without regulated labels, all of these arguments take the philosophically distasteful position that the people are like immature children, who need to be told what to do and who are incapable of reasoning on their own.

The argument that labels might "scare" consumers argues that the mass of the people are like sheep, too irrational to make an informed decision.  The argument that "biotech ingredients are 100-percent safe" is not really an argument at all -- it is a pronouncement, like a parent telling a child "the way it is" and that no questions will be tolerated. 

This issue is very analogous to the debate over alternative theories regarding mankind's ancient past, in which those who want to examine the massive amount of evidence suggesting that the conventional wisdom is wrong are reflexively labeled as "anti-scientific" or purveyors of "pseudoscience." However, I would argue that swallowing a false narrative about ancient history can be as dangerous as ingesting food that contains DNA from bacteria and viruses whose effects on the human body cannot possibly be fully understood at this time.

The recent decision by the USDA to allow the full unregulated production of genetically-modified sugar beets makes the need for labeling seem more important so that consumers who care can make more informed purchasing decisions, which may create market pressures for alternatives to such ingredients.

These are important issues and they highlight the need for good analysis in every area of our lives.