Golden Rice ‘Restrictions’ Are Reasonable

Food and Water Watch responded to my questions about their post. As you might guess, I think they exaggerate problems while ignoring the very real similarities between Golden Rice and other bio-fortification projects.

Their first objection is that there is a $10,000 limit on farmer income for free of charge distribution of a Golden Rice variety (as mentioned before, there will in fact be many Golden Rice varieties) and that Syngenta (who are not actually the only patent holders licensors1) will charge farmers who make more than that and haven’t actually guaranteed they will keep giving away their patent rights licensing the traits1. Their objection shows they either haven’t read (or believe false) the IP page provided by the Golden Rice project.

Updated 2013-03-15, morning: I incorrectly said Syngenta owned the Golden Rice patents. In fact they licensed it from the inventors. See footnotes.

Food and Water repeatedly says “Syngenta” but it is not only Syngenta that had to grant royalty-free licenses for Golden Rice to work. There are at least four other companies involved. While it’s unfortunate (in my mind) that a humanitarian project has to worry about intellectual property laws, it would risky for them to ignore it. However, I don’t think it likely Syngenta or any other company involved would withdraw support at this point. With so many companies involved and so much history, any denial of reasonable license terms would result in strong public backlash.

The main concern however is that the $10,000 limit on farm income for royalty-free seeds may force some farmers to pay royalties. While this may seem like not very much money to Americans2, in poor countries with significant vitamin A deficiency problems, $10,000 is more than most farmers who would benefit from Golden Rice would make. For example, in the Philippines, $10,000 a year income is five times the per capita income. Since the Philippines has significant wealth inequalities, the income of a typical farmer is likely far less. Farmers making more than $10,000 probably don’t need Golden Rice. But even if that $10,000 limit were too small, isn’t the proper response to ask the Golden Rice project to raise the limit?

Food and Water Watch is also concerned that “landrace varieties of rice grown in the area could be tainted or lost due to gene flow”3. Landraces are not fixed crop varieties. A landrace is a variety that is constantly changed and improved by farmers themselves. Seeds that show desirable traits are kept from year to year and new features are added (and removed) over time. A landrace cannot be “lost” just because a handful of genes are added to it. The word “taint” is itself a loaded word as it implies the genes “tainting” the landrace variety are not desirable to the farmer. If Golden Rice traits did appear in landraces, it would be because farmers wanted to keep those traits. Unlike other biotech traits, it would be obvious to farmers: there are no yellow rice grains in the wild. Farmers who do not want their rice to be Golden Rice cannot be tricked or forced into adopting it.

Finally, Food and Water questions the sustainability and cost effectiveness of the program. They support programs for “working with small-holder farmers in the at-risk developing countries to help them grow vitamin-A-rich foods themselves.” Of course, those projects have been ongoing. Oxfam and other major organizations have been working on this issue for, quite literally, decades. One reason why Golden Rice is promising is that it can fill in where other solutions have fallen short (again, no one solution is a “silver bullet”). That’s why organizations like HarvestPlus are trying to bring micronutrient-improved varieties of crops to farmers4. The sweet potato (one Food and Water praised in their original post) is actually one of their target crops. HarvestPlus estimates that the development costs for biofortified varieties are less than one year of traditional fortification (around USD $75 million). A 2006 paper has Golden Rice development costing less than $30 million5 but overall estimates that it will be very effective for the dollars spent6. Why is it cost effective to encourage farmers to grow sweet potatoes or other improved crops but not Golden Rice? The numbers aren’t that different.

So what is the difference between orange-fleshed sweet potato and Golden Rice? I can’t help but believe that if some breeder had found a rice variety that already produced beta carotene we wouldn’t be having this discussion.

  1. Ralf Reski corrects me on twitter. Syngenta doesn’t own the Golden Rice patents. The inventors Potrykus and Beyer own the patents and they’ve licensed them to Syngenta because it’s easier for a large company to bring it to market. 2
  2. Although, $10,000 is nearly the federal poverty line for a single individual in the United States so it’s not that small!
  3. That same paragraph also contains a claim by Food and Water Watch that Bt cotton in India is viewed unfavorably by farmers — it has actually been wildly popular.
  4. Most of HarvestPlus’ project crops are not genetically engineered, although they don’t rule out modern biotech methods of crop development.
  5. No doubt the cost estimates have increased but it still seems likely to be cost effective.
  6. There is a very wonky measure (started by the World Health Organization) of the cost effectiveness of an intervention involving monetary cost per disability-adjusted life years (DALY) that I didn’t want to go into. That paper describes a bit how they calculate it for Golden Rice.

A Story about Anti-GMO Activists Should Have a Few More Facts

The headline was so promising: Anti-GMO Grass-Roots Effort Gains Ground in U.S. I hoped it would be about just how strange the alliances in the anti-GMO movement are. We have groups like the Environmental Working Group or the Union of Concerned Scientists along side organic industry boosters, organic food companies and off to one side (but louder and shriller than most) groups that claim dire risks from GMO foods. It’s a topic that deserves more attention.

Instead, I found a piece that repeated — almost without challenge — misleading claims about GMOs as given by anti-GMO activists. Most of these claims are at best half-truths. Let me be up front: I can’t write about everything I think is misleading in this piece. There’s just too much. But, there are a few ideas that are commonly repeated uncritically which are far more interesting than this piece lets on.

This piece is a slightly edited version of a rebuttal I wrote for Keith Kloor’s Collide-a-scape blog. Thanks to Keith for offering me the opportunity to get this to a wider audience. He also helped me tighten this up quite a bit from the original draft. Please have a look at the conversation on Collide-a-scape.

Probably the most common claim of anti-GMO activists is that GMOs are untested and unsafe. Charles Benbrook, an organic proponent (why is a proponent of organic and opponent of GM merely labeled an “agricultural policy expert”?) is quoted: “science just hasn’t been done”. That’s just not true. There are hundreds upon hundreds of studies. Genetically engineered crops are some of the few foods tested before they come on the market and all the data is on the EPA’s website. This testing is not typically the case for non-biotech foods. In the 1950s, the kiwifruit was introduced to the US without testing. We’ve since learned that it’s allergenic. More recently, new celery varieties have resulted in contact rashes in workers due to increased amounts of natural toxicants called psolarens (similarly, new potato varieties sometimes develop excess toxic solanine).

But there’s a kernel of truth behind the claim. David Schubert (who is given as a biologist without noting his association with noted anti-GMO campaigner Jeffrey Smith) is very careful when he says: “no significant safety testing is required by FDA.” That is absolutely true. All safety testing done on GMO crops is voluntary. But even though it’s voluntary every company has complied! The lack of mandatory testing does unnecessarily worry people: what good is the FDA if it can’t even require safety testing for food? This is perhaps why the American Medical Association recommended mandatory safety testing, despite also saying current GMO foods are safe and labeling is unnecessary. Pre-market testing should probably be mandatory, but it’s just not the case that GMOs are untested before going to market.

GMO foods are also subject to repeated studies by scientists after they come on the market for toxicity and other risks. Overwhelmingly, these studies show no problems for human health. You wouldn’t know that from this piece, since it chose to mention problems found by a small minority of researchers, often heavily criticized. The piece wiggles around the topic by noting it’s hard to prove a causal link in humans. The reality is links aren’t even proved in animals.

But what about those “superweeds”? And that toxic Roundup? There’s context missing here too. Roundup is indeed toxic — to most plants and marginally to some animals — but it is one of the safer herbicides we have. While the term “superweeds” is not one scientists use, preferring phrases like “herbicide resistant”, they are a real problem. We have seen an increase in weeds resistant to glyphosate (the active ingredient in Roundup). But what this piece is not telling us is this is normal and expected: any herbicide used heavily for years will naturally select for weeds that can survive it. The most important missing context though, can be found in this graphj, which shows cases of herbicide resistant weeds, grouped by site of action.

One herbicide deserves special mention. Atrazine (a member of the triazine family) doesn’t harm corn, so it’s been used for decades to control weeds in corn fields. Unsurprisingly, that class of herbicides has had significant weed resistance for much longer than Roundup. The point here is emphatically not to deny the problem of herbicide-resistant weeds. That is a real problem. But it’s not a problem with genetically engineered crops per se, but with management practices. Roundup Ready crops could have been banned ten years ago and farmers would still have weeds resistant to herbicides. You just wouldn’t hear about them from anti-GMO campaigners.

There’s a real story in the alliance of anti-GMO groups and how, in the United States, they are using the political system, instead of vandalism (as in Europe) to advance their agenda. This story isn’t it; instead, it prefers to repeat myths and exaggerations about GMO foods in a one-sided manner.

There are some good questions about GMO activism springing up in the U.S. For example, why do organic food growers care so much about labeling GMO ingredients when transgenic crops are not allowed in organic products? Why is the anti-GMO campaign only now gaining traction in the United States? What’s behind that? Those would be interesting questions to explore a story.

The Double Standard for Golden Rice

When I saw that NPR was doing a story on Golden Rice I was glad. I was even more happy when it aired on their national morning show. While I could quibble with parts of it, it was overall good. Sadly, one idea went unchallenged. In the story, a Phillippines-based member of the ETC Group is paraphrased saying that Golden Rice “will be more expensive and less effective than traditional nutrition programs”. A Food and Water Watch post even repeated a common claim in their headline: “Here’s Why Golden Rice Is Not A Golden Bullet”. Nothing in agriculture or social policy is a golden (or silver) bullet. So, why is Golden Rice held to this standard? Why must it work perfectly and always better than alternative solutions? Why is it held to this arbitrary unfair standard?

I’ve written about Golden Rice before and made some of these same points, but it deserves repeating. Let’s take the cost question first. It’s a common claim by people who oppose Golden Rice that it’s too expensive. Golden Rice, should it ever become available, will either be given to farmers free of charge or at no more than the cost of local, regular rice. So Greenpeace and ETC can’t mean cost to farmers. Perhaps they mean the costs of developing Golden Rice to non-profit organizations. That is admittedly a high cost. But by that standard, supplementation and fortification program costs would have to include the research and development costs for those programs. That’s clearly unreasonable.

But what about effectiveness? Studies have already shown that the beta carotene is effectively taken up in the body and turned into vitamin A. There are other studies to perform, but let’s assume the science checks out: a vitamin A deficient individual eating Golden Rice will become significantly less deficient, similarly to deficient individuals offered other high beta-carotene foods. Effectiveness is then a matter of convincing enough families to grow and eat it. This is admittedly a tricky problem, but at least once a family is given Golden Rice seed, they can keep growing it year after year. The typical solutions offered by Food and Water Watch, Greenpeace and the ETC Group — which I emphatically support — are supplementation programs (vitamin shots and pills), industrial food fortification (like many foods in developed countries) and diet diversity (eat more high beta carotene foods). Those solutions don’t (and likely never will) reach every individual held back by deficiency illnesses. Food and Water Watch even suggests sweet potatoes combined with fat supplementation (to increase uptake of beta carotene). If that solution is okay for people who prefer to eat sweet potatoes, why isn’t Golden Rice reasonable for people who prefer to eat rice?

Golden Rice is held to an unfair standard. No solution is a silver bullet. We need everything on the table. Opposing Golden Rice because it’s won’t solve all problems is an unfair standard. If it prevents only some deaths and blindness in children, I see it as worth trying.

The link about costs to farmers for Golden Rice was corrected after posting.

Not Everything Is Worth the Same Outrage Even If It Says Rape

I started seeing the tweets on Friday. Apparently there was a shirt that said “Keep Calm and Rape A Lot” being sold on Amazon’s UK website by a third-party company called Solid Gold Bomb. People were outraged. Initially so was I, but I’ve been trying not to just knee-jerk retweet. I didn’t have a lot of time, but it was quickly apparent to me this was a case of an automated process gone wrong. I didn’t give it much more thought. As it turns out, the shirt was in fact produced by an automated process, the company has apologized, the shirt is no longer available … but people are still outraged.

Not everything is worth the same level of outrage. Even things that have rape messages on them. In a world where GoDaddy produces the same slick, bullshit Superbowl ads every year, I just can’t care much that some — admittedly lazy and poorly thought out — automated t-shirt slogan generator produced some bad slogans. Entire product lines of clothes are still being produced that sexualize pre-teen girls. Women’s magazines and men’s magazines are published every day enforcing gendered stereotypes that worry me. Rape jokes in movie and television are still common (many people still think it’s okay to joke about prison rape.) Liquor ads that demean women appear in nearly every glossy magazine I’ve ever seen. Now that’s pervasive!

But they should have filtered the word list! Of course, they should have filtered it. It’s even possible some foolish person intentionally left “rape” in because they thought it might be funny. But I doubt they gave it much thought. The entire product line was clearly done with as little attention as they could get away with. Products or advertising reviewed by multiple people from large companies with influence and staff are far more harmful than a t-shirt that got almost less review than a tweet. But they should be reviewing the shirts the program generates! Again, I agree, they probably should have. They made a mistake. They aren’t likely going to do it again.

I’m disappointed that the Miss Representation organization pushed this story so hard, even putting AmazonUK on their leader board of worst offenders. The Miss Representation documentary is intense. Go see it. I’ve actually tweeted #NotBuyingIt before for products I’ve run into with sexist messages. I support this method of improving culture (and aside from GoDaddy it seems to work pretty well). However, their promotion of this story — the first tweet I saw was from the @RepresentPledge account run by Miss Representation — greatly amplified a story that doesn’t have much to it. What does it say when automated software errors and a very small bad decision (to not think about the word list better) is being treated the same as sexist, misogynist Superbowl ads made by huge companies like Budweiser and Audi?

Miss Representation has some choice on what outrages they spotlight. This one isn’t that outrageous and probably could have been cleared up with a quick note to the people selling the t-shirts (who appear to be genuinely mortified1). It diminishes the message Miss Representation is trying to get across when products of unintentional error are lambasted with the same harsh outrage given to gleefully sexist GoDaddy ads or routinely degrading magazine ads. Frankly, I’m just not buying it.

  1. If they were the evil misogynists some on twitter and other comment threads claim they are, would they really have bowed to public pressure in less than twenty four hours? Surely they would have held out longer! Moreover, as far as I can tell, the first tweet I saw from @RepresentPledge was at 3PM my time on Friday and that shirt was taken down less than two hours later. Further awful (and automatically generated) t-shirts were still up but it takes time to take everything down.

Dead Bees and Research Ethics

Ugh. I did put “pureed bee heads” in a title, didn’t I? How did I not see I was titillating to get attention, not to inform? A friend called me out on my last post. I was aiming to get across the awe I’d felt reading that paper and learning the very amazing ways scientists learn new things — such as testing the effects of chemicals on neurons by isolating them from the animal and measuring electrical activity. Amazing! My friend, however, saw a crass post encouraging a simplistic view of the complexities of research (especially the last line). By focusing on the gross-out aspect, I was encouraging a kind of science conversation that can’t talk about how and why we do research in favor of “shiny!” or “gross!”

So I screwed up (a bit). But the bonus is that now I have to write about research ethics. This post looks at animal research ethics by example: here’s a study and what they did and whether or not it seems ethical to me. For now, I’m going to avoid well-known historical examples: there are numerous cases of inappropriate methods on humans and other animals as well as good discussions for what went wrong. I’m also going to avoid (in this post) looking at ethics of research on humans in favor of focusing on how we treat animals.

Case: Does killing a small number of bees to study imidacloprid seem ethical?

First up, let’s take the research in the last post. One guiding principle in research ethics is that more intrusive or harmful methods need to be justified with strong societal benefits. In this case, the researchers wanted to better understand how the insecticide imidacloprid affects bees. By the time they were doing their study, the insecticide was already being used widely and there were concerns that it might be more dangerous to bees than other insects. Our agriculture is dependent on insecticides to maintain yields in the face of pest species so we (in general) need to allow their use. However, we must test them: instead of intentionally harming a small number of research animals and any target pests, we would be exposing all animals (including ourselves) to unknown risks. Research on insects and other animals to determine the effects of pesticides thus seems generally ethical.

However, just because we have a strong societal benefit to doing this research, still doesn’t mean it’s okay to kill these bees. Is this the only way we can figure out this question? In this case, the researchers are trying to understand how the chemical (and some other closely related chemicals) affect bee nervous systems which could help us mitigate harm to bees in the field. While I’m not an expert, it seems fairly hard to figure out the exact mode of action in the bee nervous system without isolating parts liked neurons and testing them. I can imagine that someday we might be able to grow bee neurons that never came from actual living bees and use those for research, we don’t have that today (so far as I know).

Finally, while bees are not exactly like us in their capacity to feel pain, it fits my sense of ethics that we should still minimize the harm we impose. In this study, the researchers used bees that were raised under proper conditions. The bees that were to be killed for my gruesome headline were frozen using dry ice which is, I’m given to understand, likely a low pain way for a bee to die. However, we really don’t know that much about invertebrates and pain. Moreover, while vertebrate research subjects (mammals, birds, etc.) have long had some legal protections on what is permitted to be done to them for research (and those protections have grown stronger over time), invertebrates have not historically been protected though it’s starting to change. That should help encourage more research to find ways to do research more ethically.

Overall, this research seems fairly useful to society, there don’t seem to be practical alternative methods and the bees were cared for in a humane way as far as we know. I’m comfortable saying these research methods were ethical.

Case: Was raising cancer-prone rats to test the effects of glyphosate-tolerant corn ethical?

You may remember a kerfluffle last fall when a study by a group of French researchers claimed that transgenic, glyphosate-tolerant corn (and glyphosate itself) caused cancer in a long-term feeding study. The study was widely criticized for poor experimental methods that likely made the results useless, as well as breathtaking media manipulation. Was it ethical to raise those rats and (ultimately) euthanize them for this study? Some were questioning whether the study was conducted in an ethical fashion right after it came out. Several of the many responses by other scientists specifically questioned the ethics of the study.

The first point to bring up is related to the criticized study design. In this study, the researchers raised animals that are prone to tumors well into their old age, then euthanized them for various samples. If we’re going to raise animals in captivity and then kill them, we should be sure we’re at least producing strong results. A widely criticized aspect of their study design was that they only used one control group for nine experimental groups per sex with variation in what the animals were fed (different amounts of GMO corn and amounts of glyphosate). Since each group had ten rats, that means there are 90 animals getting experimental treatments and only ten control animals to compare. Simply rolling dice will show you how easy it is for one or more of the nine groups of cancer-prone rats to show problems with an apparently more healthy control group. Nothing in the paper (or subsequent responses) have changed my mind that the study simply had poor design of experimental groups. If they couldn’t use more animals (fewer animals killed is better), they could have reduced the number of different treatment groups. Instead of having groups of rats each getting 11%, 22% and 33% of the GMO corn, they could have just done one percentage. That would have allowed more animals to be raised as controls, improving the study quality and ethics.

The second point was raised by several animal research ethicists. The Sprague-Dawley rat line used in this study are very prone to tumors: up to 80% or more will develop tumors over the period these rats lived, regardless of treatments. This raises an important ethical consideration: large tumors can be painful, cause skin lesions and impair movement of the subject animals, requiring that we do something to make them more comfortable. Sadly, the main option is often euthanasia and animal welfare guidelines for research purpose require that animals that are in significant pain be euthanized if they cannot be cured. The final study as published included photographs of some of the rats in the study, showing significant tumors. Many scientists who commented on the ethical issues noted that the photographs showed that the rats were not euthanized when they should have been. For example, one group of research pathologists wrote:

As most members of the ESTP are veterinarians, we were shocked by the photographs of whole body animals bearing very large tumors. When looking at the lesions, we believe those animals should have been euthanized much earlier as imposed by the European legislation on laboratory animal protection ( = OJ:L:2010:276:0033:0079:EN:PDF).

A similar response from a French group:

Last but not least, we were shocked at reading the ethical rules followed for euthanasia (“25% body weight loss, tumors over 25% body weight…” leading to euthanasia; Anatomopathology, §2.5) and at looking at Fig. 3J–L: the size of the tumors, with skin erosions and ulcerations, having certainly an impact on movement, feeding and pain, is unacceptable under well-known guidelines (Workman et al. 1998). This should have led to a much earlier euthanasia with respect to ethical humane concerns and casts doubts about the “careful monitoring” (Anatomopathological observations, §3.2) of animals. No argument, apparently to leave tumors develop as much as possible, should have prevailed. Again this demonstrates a lack of understanding of animal physiology and ethics, and a lack of supervision by the Ethical Committee and by a site veterinarian (“vétérinaire sanitaire”, a function mandatory under French law, see Article R203-1 5°). We are surprised that these major ethical issues were not clarified during the review that the paper underwent before approval for publication.

I don’t think this study was ethical. While there is public value in doing long-term studies on the effects of new foods, such studies must be done in an ethical manner. If this study had used proper experimental groups and the animals cared for appropriately (including appropriate euthanasia), I would probably have considered it ethical. The research team responded to some of the ethical concerns published in response to their original paper. I find their responses unconvincing and only increase my belief that this study was not run in an ethical manner.

Case: Is it right to capture and kill around 4% of the bats living in a cave to study a rare, but deadly, human disease?

Finally, I want to tell you about a borderline case where I’m just not sure. A major focus of the book Spillover by David Quammen are the behavior of possible reservoir species. Reservoir species are non-human animals who naturally carry an infectious organism (it may or may not cause significant disease in the animal) that can be transmitted to humans and ultimately causes disease. The rabies virus has a natural reservoir in bats which turn out to be very common reservoirs for diseases we get from animals.

In the book, Quammen describes cases where European or American tourists visited a Ugandan cave (called Python Cave — you can guess the attraction), went back home and subsequently became very ill or died. The disease they contracted is called Marburg virus (which is related to Ebola) and it causes significant, life-threatening illnesses. The likely reservoir for Marburg virus are bats but little is known about how Marburg virus infects bat populations Spillover is well-referenced, so I was able to look up one study on the bats in Python Cave.

The methods in this study are straightforward: go to the cave, collect a certain number of bats, and run tests on samples to try to detect Marburg virus in different tissues. However, these tests included taking samples (liver and spleen) that require killing the collected bats. Unlike the previous study, the authors are very forthright about the protocols they are conforming to and I have no reason to think the animals were mistreated thru improper techniques or inattention. All due care seems to have been taken.

However, the researchers collected 1,622 bats out of an estimated 40,000 bats living in this cave. That’s about 4% of them. That’s a lot of bats to kill. Was it absolutely necessary to collect so many bats? In order to get their exact results, it seems they did. The overall rates of infection they found were pretty low: out of those 1,622 bats, they only found 40 that seemed actively infected. The researchers were also able to identify different strains of the virus. This allowed them to show that the bats (or the virus at least) travel further than expected, including populations in Gabon. Further, the wide variety of strains in this single population of bats supports the idea that bats are the long-term reservoir of the virus. If they had collected fewer bats they might not have gotten a large enough sample to do this analysis.

But the question sticks in my head: could they have done it another way? Did they have to kill so many bats, who definitely feel pain and know when they are being hurt? Even more, Marburg is a relatively rare disease in humans. While it has a very high fatality rate (up to 88%), the number of known human fatalities is less than 400 cases since the 1960s. The earliest described cases are in Europeans handling infected primates with inappropriate safety protocols: those problems are largely fixed. Most of the ongoing cases are in people who work in caves (in generally awful conditions) in sub-Saharan Africa. Before this study, it was already known that the primary way humans are getting infected is by close contact with bats in caves. The solution would be for people either to not work in bat caves or to wear safety equipment. Knowing that Marburg virus is transmitted further than expected or having greater assurance that bats are a reservoir doesn’t help solve the social and economic problems that result in humans working without safety equipment in bat caves. That makes it harder for me to support killing so many animals for research.

But, I come back to what they are finding out. It’s really pretty interesting (and that paper is surprisingly readable). Maybe knowing more about how Marburg virus is transmitted in bats, including the different varieties of it, will eventually help us figure out effective treatments. But I’m conflicted. 1,622 bats dead is a lot of dead animals.


Updated 2013/03/08: The link to critical responses to the GMO corn feeding study was fixed.