Everyone seems to want GMO labels¹. Since there is little reason to believe current GM foods are unsafe², the only justification is that a consumer needs that information to make ethical purchases. “GM” is just a proxy — and not a good one — for a whole host of problems with our agricultural system that are far more deserving of ethics-based labels. Pesticide and fertilizer runoffs, overuse of water resources and mistreatment of workers are far more troubling problems in our agricultural system, but they get little attention. If consumers need a label to avoid GM food, then I submit consumers should have a way to chose producers who treat their workers better, pollute less and use resources better.

Note: This post is part of a short series on issues around GMO labeling. See the intro post for more information.

Pesticides

Almost all foods we grow involve using pesticides at some point. Even organic methods usually involve pesticides at some point. One of the poster children for anti-GM sentiment is Bt corn which is a genetically engineered corn variety that expresses one or more proteins that are harmful to a small set of insects. Those same proteins are used in a pesticide application in organic farming. Our current agricultural system depends on pesticides to guarantee high yields and even safe food³.

Many pesticides are toxic to those who apply them — often underpaid and overworked. Mother Jones just published a story about farm workers who are being poisoned and don’t know it and even being fired when they file complaints. Further, most pesticides will affect more than the target pest and many can persist in the environment. We’re getting better at using less and more targeted pesticides but there’s plenty of room for improvement.

Why don’t we label which pesticides might have been used to produce a food product? Almost certainly that would be too complicated to implement, but we could label some kind of approximation of the impact of applied pesticides. Academically, one such measure is EIQ. The implementation would be complicated and wouldn’t directly be EIQ, but we might be able to invent a rating system that presents an abstract approximation of something like it. An abstracted rating could be efficient enough to be practical but still present enough information to be useful to a consumer. The label would have to be more than “pesticides used in production” though!

I submit pesticide information would be far more useful for making ethical food purchases than whether a crop is GM. The only reason I tend to buy organic is not out of fear for myself, but because I have no way to distinguish different producers’ use of pesticides or how they might treat their workers. Organic is generally likely to have a lower impact (though not always) and I can afford it. I would prefer to buy food produced in other ways, but there’s no information for me to make a decision on.

Fertilizers

Organic uses composts and manures. Conventional systems use nitrogen fertilizer. Both of them can result in harmful runoffs, though unsurprisingly far more harmful nitrogen runs off from conventional farms. A major problem in the midwest of the United States are fertilizer runoffs in the Mississippi watershed eventually enter the Gulf of Mexico and have created a dead zone. Similar coastal affects can be found world wide. Fertilizers also pollute local waterways such as lakes and rivers causing algae blooms that can kill other life.

Producers can reduce harmful runoffs by better techniques including using fewer fertilizers, timing them better, tilling less or not at all, irrigating better and so on. Considering the massive effects of fertilizers on the environment — far greater than GM crops⁴ — why shouldn’t that be labeled? As with pesticides, we would probably need some kind of rating system to make non-confusing labels. But I would love to know my corn comes from a farm where better efforts were made to reduce fertilizer runoff.

Water Usage

Agriculture uses most of our fresh water. Climate change will likely only increase pressures on water supplies. Agricultural methods that use less water but produce comparable amounts of food are important. Even now major aquifers are being depleted.

Unsurprisingly, there are ways to reduce water use in agriculture. Not over-watering is an obvious requirement and we are building technology to make it easier for farmers to know how much water they need. Using alternate irrigation systems (e.g. buried drip systems) require less water. We can reuse water multiple times (“grey water”).

The point again is that we can improve how we use our resources and reduce impacts on the rest of the environment. Why shouldn’t that be labeled? Why can’t I choose producers who use less waters than their competitors? Reducing depletion of the Ogallala Aquifer is more important to me than any current problem with GM crops.

Fair Trade & Worker Rights

If you buy coffee, you’ve probably seen products voluntarily labeled as being “fair trade”. There are various systems with varying degrees of validity used for different crops, but the goal of these systems is to allow consumers to buy food that supports the growers. The fair trade systems are a good example of voluntary labeling for niche demand for information (NonGMO Project exists for GM products) that consumers want to make ethical choices.

But why is it only voluntary? Why is information that allows me to support workers on coffee and chocolate plantations optional? Why do we usually only see voluntary worker treatment labels on products like coffee and chocolate? What about workers in the United States? What about workers for commodity food crops like corn and wheat?

As noted in the pesticides section, farm workers are often exposed to harmful levels of pesticides. Even in the United States, farm workers are often overworked, underpaid and rarely have health insurance. In the United States, labor laws exempt farm workers from many of the protections other workers enjoy like the right to organize, overtime pay and so forth.

The market in the United States is not providing a voluntary label that gives me any idea what food products I should buy. Despite widespread perception, buying organic doesn’t mean workers are treated better. Voluntary domestic “fair trade” certifications are growing. But it’s a small part of the market.

Conclusion

Consumers are clearly concerned about how are food is produced. GM fears are often a proxy for other concerns: farmers beholden to large agribusiness, scary chemicals in our food and environment, and so on. We should create labels to provide information about the underlying concerns. If consumers are worried about pesticides and fertilizers, then provide a way to choose products that were produced in less harmful ways. If a consumer cares about worker or farmer rights, then provide labels that tell them how labor was treated in production. GM labels are a very poor substitute for real information about our agricultural systems.

Honest opponents of genetically modified¹ foods do not actually claim that GM foods are unsafe. Instead they write about the lack of long-term safety studies or a lack of evidence for safety. Less scrupulous opponents will claim that very scary results have been seen from GE foods. This post is about a few of them and why they aren’t nearly so scary as they seem or in some cases are likely not even there.

Note: This post is part of a short series on issues around GMO labeling. See the intro post for more information.

Scary Claim #1: GM potatoes were toxic in rats!

This is almost always a reference to the work of Árpád Pusztai who did some work on rats and a GM potato variety. The Lancet published his work but it was immediately criticized for major flaws including feeding the test animals inappropriately (the experiment and control potatoes differed in protein content). The Royal Society reviewed the work and found it unconvincing. As far as I know the work has not been replicated. You can read more about it at biofortified. The point here is not to claim there are no problems with this GM potato, but that a single heavily criticized study is insufficient to make a health claim about a single GM food, much less all of them as is often the case.

Scary Claim #2: GM toxins were found in the blood of pregnant women!

I’ve previously discussed the origin to this claim in my post about Senator Sanders’ bad GM label amendment. I don’t want to rehash the content of that post but, in summary, the researchers used a likely invalid method to detect Bt toxins (“Cry” proteins) in blood. Beyond the problems with the study itself is that it is used to claim some negative affect on people when the study (at best) just showed a very tiny level of the protein in blood. Moreover, the researchers did not attempt to trace the origin of the toxin (was it GM corn? or Bt residue from external application). Bt toxins have not been found in the blood of other mammals even though researchers have tried in both pigs and cows. The important point remains that this scary claim implies that some harm comes from the presence of the toxin when this is not the case. We haven’t seen harm despite over 50 years of Bt toxin use: more than a single study is needed to show a problem with Bt trait crops.

Scary Claim #3: GM corn causes kidney (or organ) failure

This claim usually refers to the work of Séralini, usually this paper. The problem here is that the authors used data from Monsanto itself, re-analyzed it and claimed statistical effects. But no one has found any any mechanism for the claimed effects (which weren’t even organ failure despite the scare story). His work has been repeatedly criticized, including by the European Food Safety Authority. One major problem with this study includes statistical effects at lower doses not seen at higher doses (see Table 2 in the original paper, for example) with no explanation of why this might be the case. Moreover, there are numerous other studies showing no similar effects. To claim that GM corn causes organ failure on the basis of one lab’s unreplicated work is not sound.

But are they safe?

This post isn’t meant to be exhaustive proof that GM foods are safe. Indeed, no such proof is possible — absolute safety just isn’t something that science can prove. All we can do is say the preponderance of evidence suggests one thing or another. In the case of current genetically modified foods, it appears they are safe to eat. When you read a scary story about safety of GM foods, consider looking for contrary evidence: it might not be as scary as it seems. Strong claims require strong evidence.

Note: This post is part of a short series on issues around GMO labeling. See the intro post for more information.

So here I’m going to be sometimes silly and sometimes perfectly earnest and list some labels I think would be at least as informative as proposed GMO labels — and sometimes just as misleading!

“This product contains genes”

Most food products contain genes. Exceptions include inorganic flavorings (e.g. salt), highly purified substances (e.g. corn or canola oil) and additives like food colorings. Such a label would be extremely informative, given that it appears around half of consumers don’t realize their food contains genes.

“May contain insect parts”

Did you know many foods contain bits of insects? There are in fact legal limits for many foods that set the allowed amount of “foreign” matter (including insects) allowed in that product. Chocolate, for example, can contain up to 60 or more insect fragments per 100 grams. This is, incidentally, one reason food irradiation is used extensively with spices: irradiating spices tends to kill any harmful micro-organisms that might be hosted on the “insect filth”.

“Fluoridated water used in production”

Manufacturers using municipal water supplies are probably using fluoridated water. Some people think fluoridation is dangerous, though, and might want it labeled even if the final product doesn’t really have much added fluoride. I include this one because I find the California initiative’s exemption on products derived from animals who are fed genetically engineered ingredients laughable.

“This heirloom variety has not been tested for safety”

A major criticism of GE food products is that they aren’t specifically tested for safety. While there are many feeding trials with animals and other ways of judging safety (including specific allergen testing), regulators generally approve them on the basis that they are materially similar to an existing food. For example, a new GM (e.g. Bt trait) corn variety is tested to show it has a similar nutritional profile as the non-GM corn it was derived from, as well as testing for unexpected allergens.

But it turns out that no food safety testing is done on new crop varieties made via “conventional” methods. Heirloom tomatoes (which aren’t all centuries old varieties, despite the name) are thus not tested for safety. A farmer could cross a couple tomato varieties he has right now and sell it next season. Of course, we allow this because it’s assumed that the offspring won’t be materially different than the parent crops when traditional breeding methods are used. But that is exactly the reasoning behind how proposed GM foods are assessed¹.

“May contain fecal coliforms”

So this one is pretty much true for any meat or raw vegetable. That’s why they tell you to cook your meat to the right temperature and wash all your veggies. Putting this on a label would be absolutely true, but is absolutely unnecessary to an informed consumer.

“This organic product grown with pesticides”

Very misleading, but strictly true. Most organic growers do actually use pesticides but they use a different list than conventional growers. Many are relatively low impact, but others are not. “Organic” doesn’t necessarily mean safe for the environment.

“Grown using synthetic pesticides and fertilizers”

For the overwhelming majority of food on the market this is true, so it would be pretty much useless as a label. But it’s definitely true! And about as informative as a “contains genetically engineered ingredients” on a product that contains corn or soy.

“Grown using methods that expose farm workers to poison”

Similar to the above, this is noting a major problem with many applied pesticides: many are broad-spectrum, affect humans and farm workers are the ones who are hurt, not consumers who are expose to near infinitesimal amounts. The adoption of GM Bt cotton in China likely reduced worker exposure to dangerous pesticides.

You probably get the idea. In case it wasn’t clear, none of the above labels are necessary for the health or safety of the consumer and I don’t actually suggest such vague and useless labels. I do think it interesting to note what we don’t label because usually we let regulators decide what is actually necessary for consumers to make safe and healthy choices.

Note: This post is part of a short series on issues around GMO labeling. See the intro post for more information.

The current proposals to label genetically engineered foods¹ don’t actually give the consumer more information than they could have now with only a small amount of thought. Moreover, I think widespread ignorance and general fear of technology means that few consumers will actually become more informed as a result of labeling. The result might be a reduction of genetically engineered foods in the market for human consumption, leaving the even cheaper animal feed market to be fought over by large agribusiness. This could be bad for civilization as it makes it harder to use a particular tool to solve problems.

Update on 2012/08/08 07:45: I mistakenly thought that the California initiative requires labels of GMO ingredients on the front of packaging. This is only true for whole foods (e.g. produce). For processed foods it is required to be conspicuously labeled on either the front or back. I’ve made notes in the text to clarify this.

No More Information With Labels

While may of the proponents of the California genetic engineering labeling initiative are obviously using fear tactics and exagerated (or outright false) claims of dangers to human health (see below), the argument I actually find appealing is a general “right to know”. People should be able to know how their food was grown and processed. People will be more informed about how their food! How can anyone disagree?

But I think there is a combination of disingenuity and willfull blindness that leads people to believe a simple “contains genetically engineered ingredients” label will actually give consumers more information or it will lead to people being better informed. For the informed consumer, such a simple label gives no more information than currently available. You can easily determine using the organic standard labels and ingredients lists to figure out if a product might contain material derived from a GE organism. It’s a simple process:

Does this product contain ingredients from this list: corn or corn sugars, soy, canola, cottonseed oil, papaya, beet sugar (or unspecified “sugar”) or zucchini? If yes and there isn’t a “contains no GMO” label or the items aren’t labeled organic, then the product probably has at least some quantity sourced from a grower who uses a GE variety. Otherwise, no GE ingredients.

No, really, that’s it. The proportion of genetically engineered varieties used in the corn, soy and canola markets is so large that it’s essentially a given that anything that doesn’t explicitly label itself otherwise contains a GE ingredient. Zucchini is a marginal case as it only controls less than 20% of the market, but that’s still pretty high. It really doesn’t seem like it takes much effort to know. In any case, one can always ask and there is already a very robust “contains no GMOs” labeling system taking hold.

Other Labels

If the proposed label isn’t going to add information, what will it do? I think the most common effect will actually be to make more people afraid of genetically engineered food. Why do I think this? First, let me give two examples where labeling is used or required and why.

• Dairy from cows that have not been treated with bovine growth hormone (rBST) may label said fact, but most also voluntarily (on FDA recommendation) include the label “FDA states: No significant difference in milk from cows treated with artificial growth hormones.” The reason is that the FDA has the position that dairy from cows given rBST is not dangerous to human health. Without the clarification, a uninformed consumer might think that a dairy product without such labels is unsafe. In general, the FDA tries to restrict package labels that would encourage consumers to be driven by bad information.
• Food irradiation is legal and safe and approved for a wide variety of foods. However, it requires labeling. Very little food on the market is irradiated, despite there being significant safety benefits. In general, retailers think there is a stigma attached to it and irradiation is largely limited to dry spices and imported tropical fruit, which have few alternatives (and in the case of spices used in mixtures, don’t require labels at all). Labeling combined with ignorance may be a big part of it²: many Americans believe food irradiation makes the food radioactive so why would they buy a product that says it was?

The point here is not actually to promote either of these food production or handling methods. Rather, I’m noting that labels and consumer ignorance do interact. Tellingly, in the EU, mandatory labeling has nearly driven genetically engineered foods off the market even though the regulators admitted they were perfectly safe. Could that happen here?

Becoming Informed

Americans are profoundly ignorant about genetics and agriculture. In 2003, 43% of Americans in a poll believed ordinary tomatoes do not contain genes. In 2010, 47% believed the same thing. A third in 2003 even believed that eating genetically modified fruits would modify their own genes! How is a label saying “contains genetically engineered ingredients” going to inform those Americans?

Let’s assume the best: someone not very knowledgeable on the subject might go search the internet to try to inform themselves. What will they find? Here are the first 5 results in Google for “genetically engineered food”³:

1. Global Issues page on genetically engineered foods contains at first glance several outright falsehoods, a lot of misleading text and general anti-corporate sentiment being used to bolster an anti-GE argument. I would not recommend this link to someone I wanted to genuinely inform.
2. Wikipedia is thankfully fairly balanced though it sadly includes information from several studies claiming dire ill-effects whose results are oversold and are commonly used by anti-GM activists to argue against the much larger body of research suggesting genetically engineered foods are largely safe to eat.
3. CSA seems to be competing with wikipedia to some degree and is fairly balanced.
4. Food and Water Watch seems to be seemingly responsible language but is clearly biased. The page contains this whopper: “Organic farming, which does not allow the use of GE, has been shown to be safer and more effective than using modified seed.” Few studies have been done comparing the safety of organic farming versus equivalent genetically engineered (or just straight conventional hybrids) and if effectiveness is measured on yield, then regular hybrid fields that use modern pesticides and fertilizers continue to outpace organic farming methods for production of commodity crops like corn and soy.
5. Center for Food Safety is frankly completely against GE in general. The text on this page is fraught with falsehood, exaggeration and misleading statements including a litany of scary-sounding GE organisms (“super” pigs!) that are not actively being pursued instead of listing the actual current uses of GE technology such as pesticide resistance and so forth.

So our hypothetical uninformed consumer may become more informed if he were to google this search term. But this is his food, I think it far more likely he would google “is genetically engineered food safe”. The results:

1. WebMD actually claims the EU’s position is that they are unsafe, but in fact the EU-wide regulatory bodies consider current genetically engineered foods safe to eat! WebMD is relatively balanced, but stretches to include information on allergen risks when so far none have cropped up (that weren’t found before marketing for public consumption).
2. PBS has a back and forth between various experts and I’m not sure that a poorly informed reader would get much out of it, especially with claims of hamster genes in food mentioned.
3. NewsMax Health is full of scary “facts” and cites several debunked studies and generally recommends not eating genetically engineered foods.
4. The World Health Organization is quite fact-based, but given some Americans distrust of international organizations, it might not be a very convincing source. It is however pretty good and balanced.
5. The Global Issues page is essentially propaganda: claims of no adequate testing (false), cites extremely biased sources, claims genetically modified crops have lowered yields and so forth. It also strangely doesn’t really say much about safety despite the title.

Also, I note that none of these are for governmental regulatory bodies that are actually charged with food safety which might be critical to some readers. Obviously if a labeling scheme went into effect, there would probably be a regulatory body charged with providing information (maybe even included as a link with the label). Hopefully that information would be fair and not confusing.

But this is the best case. Considering how ignorant many consumers are, I think it likely a large segment of the market will just avoid foods labeled as containing genetically engineereed ingredients out of fear (they might modify your genes after all). When you add in that the government doesn’t demand front-of-package labels (as with the California initiative [correction: front is only required for whole food items]) except for very important information (such as allergens), a consumer could be forgiven for assuming the label means the food might be dangerous.

Using Ignorance to Drive Fear

One big reason I think that a labeling scheme as simple as the California initiative⁴ is going to lead to more consumer fear is that the very campaign to get it passed is using fear tactics that require consumer ignorance to be effective. LabelGMOs.org uses this image in their campaign and it appears on their homepage:

The pesticide they are referring to are the Bt toxins and they are considered very safe. They are heavily used in organic agriculture as a spray (made of the soil bacteria the Bt genes were found in). But this image is clearly trying to make you think your children are eating harmful pesticides, when in fact the pesticide in question is considered basically safe. That’s a fear-tactic that depends on your ignorance.

Another organization supporting the California initiative is Just Label It. Consider this infographic. Half the infographic is about labeling in other countries but the rest is devoted to basically three things: GE salmon, the Aris & Leblanc study showing Bt toxin in the blood, and the GE potential to introduce allergens or toxins. GE salmon is not on the market and may get a label on its own (in any case, avoid farmed salmon⁵). Bt toxin in the blood is not an issue of public safety if it is not demonstrated to cause harm (which it hasn’t been). The infographic does not include the fact that the toxin in question is used heavily in organic agriculture as well. Genetic engineering can of course introduce allergens or toxins to the food supply, but then so can conventional agriculture.

Curiously, the Just Label It campaign admits that you can easily avoid genetically engineered foods now, even providing a guide to do so. They even suggest calling the manufacturer if unsure.

California Law Not About Right to Know

Current GE foods on the market are safe to eat (or as safe as anything is). But there are other reasons I might want to avoid genetically engineered foods. The market is admittedly dominated by players like Monsanto which I might object to. I might find the entire idea of modern genetic engineering to be morally repugnant and would avoid any GE products. And so on. But tellingly, the California initiative exempts the following from labeling:

• Meat or animal products from animals fed or treated with genetically engineered ingredients do not have to be labeled. A majority of corn grown in the United States feeds animals and most of that is currently a genetically engineered variety.
• Enzymes and similar used in processing food that may be created from genetically engineered organisms but are not themselves present in the final result or are chemically similar to non-GE origin substances. This and the above saves many California cheeses from having to be labeled.
• Raw foods that are “contaminated” with GE unintentionally. That is, if it’s discovered after the fact (perhaps via testing) it doesn’t have to be labeled.
• Alcoholic beverages are basically exempt, even though yeasts are sometimes genetically engineered.
• Food products with very small amounts of GE ingredients (less than 0.5% by weight and no more than ten such ingredients) until 2019 anyway.
• A weird exemption exists for food that an independent organization has determined hasn’t been “knowingly and intentionally produced from … genetically enginereed seed” and goes on at some length. I’m not sure which industry this is trying to protect.
• USDA organic food does not need a label even though the USDA allows significant non-organic ingredients (more than 0.5%). It’s unlikely a producer would make something with 98% organic ingredients and 1% GE ingredients, but this exemption says they wouldn’t need the GE label.
• Restaurants do not have to provide labels or indicate whether they use GE ingredients. Neither does food packaged for immediate consumption (e.g. the grocery deli section).

This law has so many exemptions that a moral objector to genetically modified organisms is still stuck with buying only organic (and probably being a teetotaling vegan who never eats out). I’m not sure what this law is really about, but it definitely doesn’t seem to be about truly informing consumers. Exempting restaurants and food packaged for immediate consumption allows large amounts of food to go unlabeled (half the market in terms of money spent is spent out of the home). The requirement to build alliances in politics probably explains this exemption (and the organic exemption), but it means the result is not a law that creates a consumer right to know, it creates a consumer right to know sometimes.

Why Do I Care?

In short, I care because the GE market is already dominated by large players like Monsanto. In Europe, general opposition to GE has driven smaller companies to do their research elsewhere (or pull out entirely). If the California label scheme takes hold (and the California market can drive the national market) and GE foods mostly disappear off the market, that means the only market in the US for GE crops will be for animal feed. The animal feed market is a cheap market, driven by lowering costs. Low costs means less money to spend on doing research, which means large companies with a good market position can easily continue to dominate. That’s not really good for society or humanity.