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Fighting to Save the Family Farm!
By Barbara H. Peterson
Yes, it’s true. There are most likely GMOs in our organic foods. Not because they are “allowed,” because they aren’t, but because contamination is widespread throughout the agricultural industry, and the USDA’s National Organics Program (NOP) is designed so that GMOs can enter USDA Certified Organics through “accidental contamination.”
You see, the program is “process based.” That means that as long as the approved process of growing the organic crop is followed, then there is no reason to believe that contamination exists, and therefore, no reason to conduct a test for GMOs. According to NOP preharvest and postharvest testing rules:
The main objectives of the residue testing program are to: (1) ensure that certified organic production and handling operations are in compliance with the requirements set forth in this final rule and (2) serve as a means for monitoring drift and unavoidable residue contamination of agricultural products to be sold or labeled as organically produced. Any detectable residues of a prohibited substance or a product produced using excluded methods found in or on samples during analysis will serve as a warning indicator to the certifying agent.
The Administrator, SOP’s governing State official, or certifying agent may require preharvest or postharvest testing of any agricultural input used in organic agricultural production or any agricultural product to be sold or labeled as “100 percent organic,” “organic,” or “made with organic (specified ingredients or food group(s)).” It is based on the Administrator’s, SOP’s governing State official’s, or certifying agent’s belief that an agricultural product or agricultural input has come into contact with one or more prohibited substances or has been produced using excluded methods.
Certifying agents do not have to conduct residue tests if they do not have reason to believe that there is a need for testing. Certifying agents must ensure, however, that certified organic operations are operating in accordance with the Act and the regulations set forth in this part.
To make matters worse, there is no threshold set for the amount of acceptable contamination.
Many commenters suggested that we establish a “threshold” for the unintended or adventitious presence of products of excluded methods in organic products. Some commenters argued that a threshold is necessary because, without the mandatory labeling of biotechnology-derived products, organic operations and certifying agents could not be assured that products of excluded methods were not being used. Others argued that, without an established threshold, the regulations would constitute a “zero tolerance” for products of excluded methods, which would be impossible to achieve.
We do not believe there is sufficient consensus upon which to establish such a standard at this time. Much of the basic, baseline information about the prevalence of genetically engineered products in the conventional agricultural marketplace that would be necessary to set such a threshold-e.g., the effects of pollen drift where it may be a factor, the extent of mixing at various points throughout the marketing chain, the adventitious presence of genetically engineered seed in nonengineered seed lots-is still largely unknown. Our understanding of how the use of biotechnology in conventional agricultural production might affect organic crop production is even less well developed.
Also, as was pointed out in some comments, the testing methodology for the presence of products of excluded methods has not yet been fully validated. Testing methods for some biotechnology traits in some commodities are becoming commercially available. Without recognized methods of testing for and quantifying of all traits in a wide range of food products, however, it would be very difficult to establish a reliable numerical tolerance.
Since the USDA’s NOP program makes it clear that it is not the intent of the USDA to set a “zero-tolerance” standard, this means that whatever the “acceptable” level of GMO contamination may be at any given time, it is definitely not zero.
…these regulations do not establish a “zero tolerance” standard. As with other substances not approve for use in organic production systems, a positive detection of a product of excluded methods would trigger an investigation by the certifying agent to determine if a violation of organic production or handling standards occurred.
One would think that if for some reason, testing does occur and GMO contamination is found, then surely the company who produced the contaminated products would not be able to sell them as organic, but that is not necessarily the case.
The presence of a detectable residue alone does not necessarily indicate use of a product of excluded methods that would constitute a violation of the standards…
In the case of residue testing and the detection of prohibited substances in or on agricultural products to be sold, labeled, or represented as “100 percent organic,” “organic,” or “made with…,” products with detectable residues of prohibited substances that exceed 5 percent of the EPA tolerance for the specific residue or UREC cannot be sold or labeled as organically produced.
As stated earlier, there is no contamination threshold for GMOs, and no EPA tolerance for residue as there is for other prohibited substances such as certain pesticides. So what is the acceptable limit? If it is not zero, then what is it?
…the national organic standards, including provisions governing prohibited substances, are based on the method of production, not the content of the product.
Here is the International Federation of Organic Agricultural Movement’s (IFOAM) position on GMO contamination:
“Organic certification shall not imply it is a ‘GE-free’ certification. Rather it shall be presented as guaranteeing ‘production without GE/GMOs’. As there is no guarantee that organic products are 100% free …Organic producers and associations shall actively inform the consumers of this fact to insure fair marketing claims and to avoid future debates about consumer deception.”
So it seems that when we buy “Organic,” we are buying products that are guaranteed to be produced without GMOs, but not guaranteed to be 100% GMO-free!
I called the USDA NOP program headquarters to find out from the horse’s mouth, if this information is correct. I spoke to Shannon Naley, an Agricultural Marketing Specialist, and she confirmed that NOP regulations do not provide for GMO testing unless there is a reason to believe that contamination has occurred, and there is no threshold for contamination in NOP regulations. When I asked her to please issue a statement regarding that affirmation, she referred me to Soo Kim of the Public Affairs Office, who promptly got rid of me without admitting a thing. All subsequent e-mails and phone calls to her regarding my specific questions were summarily dismissed. Here is Soo Kim’s contact information:
Department of Agriculture
Agricultural Marketing Service
Public Affairs Office
202-720-7476
As Nicole Johnson so aptly puts it,
USDA NOP’s rules, relate only to process standards and not outcome. While the public believes they are buying GE/GMO-free product if it has the USDA organic seal, NOP standards only guarantee that the item is produced without GE/GMOs. USDA’s NOP is fundamentally flawed in that it guarantees, over the long-term, GMO contamination of organic crops and products, a sleight of hand it achieved by failing to define a threshold for GE/GMO contamination and any GE/GMO testing requirement of organic crops and products, because vested interests wanted to avoid such requirements. USDA policy is “Don’t ask, don’t tell, don’t test, don’t know.” (Nicole Johnson)
Non-GMO Project
To fill the gap left by the USDA NOP, the Non-GMO Project ushered in a program that sets a threshold for GM contamination at .9%, the same as the European Union (EU). This is better than the USDA regulations that set no threshold, which ultimately means “the sky’s the limit” or “whatever the public will allow,” but it is alarming in that with the level of contamination that we already have, even prior to the anticipated release of GM Alfalfa, a highly prolific forage, 100% seed purity in certain grains that have been all but overtaken by GMOs cannot be guaranteed. Therefore, even with a “Non-GMO Project Verified” seal, you can still have .9% GMO contamination in what you think is your GM-free food!
So what does “Non-GMO Project Verified” mean? First of all, we want you to understand what it doesn’t mean. It is not a guarantee that the product is 100% GMO free. The reason for this is that our program is process-based, using a set of best practices to avoid contamination. We do require testing of all ingredients (everything being grown in GMO form in North America), but we don’t require testing of every single finished product. Instead, testing can be done at any one of a number of places in the production chain, for example right after harvest. Following the test, which must indicate that the ingredient is below 0.9% GMO (in alignment with laws in the European Union), we require rigorous traceability and segregation practices to be followed in order to ensure that the tested ingredients are what get used in the product.
Coexistence or hostile takeover?
Lately the USDA and Monsanto have been stressing “coexistence” between GMOs and what they refer to as Identity Preserved crops. It is not GMO crops that are in danger of contamination, but organic and conventional crops that are in danger of widespread contamination with genetically engineered transgenes from GMO crops, converting them to GMOs. The call for coexistence becomes merely a stepping stone to extinction for the crops being taken over by this dominant and invasive technology.
As the genetic modification of our world increases exponentially, we must understand that we are in a war zone. One of the best ways to overtake an enemy is to keep that enemy focused on outside forces such as the impossible possibility of “coexistence” as a distraction from the clear and present danger that exists due to corruption from within government agencies such as the USDA by biotech interests. Monsanto and it’s biotech cohorts are masters of infiltration, which is the best method of overtaking an organization without making a spectacle of oneself and getting noticed. When the infiltrators outnumber the good guys, viola! you have a silent coup, with no one the wiser. Much less the public whom you claim to serve, who depend on your organization to keep them abreast of important policy decisions.
In the case of the USDA, the takeover is complete. Monsanto quite literally has taken over the USDA. So, how can we expect any USDA program such as the NOP to be free from its influence? We cannot.
Furthermore, the advent of NOP standards ushered in the consolidation of the organic market in which formerly independent organic companies were purchased by big industrial players, who have every incentive to try to water down the standards. Now, the very companies consumers are trying to avoid buying products from are the ones they are unknowingly patronizing, as parent company ownership isn’t transparent on product labels! (Nicole Johnson)
Whom do we trust?
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It is quite apparent that there are people who care about the integrity of our organic food, and those who simply put on the USDA Certified Organic label as a facade, without a commitment to organic purity. Those who care do not look for loopholes in regulations in order to justify GMO contamination. They are committed to producing the best food they can, GMO-free. Others such as Cargill, who acts as an organic food processor might not be so picky considering its relationship to Monsanto, and its propensity for getting rid of its toxic waste into public drinking water and making a profit from it.
Monsanto and Cargill are in a 50/50 joint venture partnership. Monsanto makes the seeds, which make the crops, and Cargill makes the fertilizer. Cargill also just happens to be responsible for 70-75% of the hazardous waste hydrofluosilicic acid used in fluoridation programs. (Farm Wars)
Independent companies who care are taking it upon themselves to test for the presence of GMOs. “People are thinking more proactively now to protect their seed and crop,” said Arran Stephens, chief executive officer of Nature’s Path Foods Inc. Yet, a .9% contamination threshold seems to be acceptable, even with the Non-GMO Verified Project. For whom? Not the customer. Not you or I, but for companies who cannot afford the litigation arising out of a guarantee that they simply cannot keep due to widespread GM contamination perpetrated by the very agency that is supposed to be “protecting” our organic standards – the USDA.
Sourcing to other countries
In 2007, the following incident occurred:
In mid-April, Chris, who owns a soy processing facility, received a call from a customer saying that his soy ingredient tested positive for GMOs. Chris was shocked. His processing facility is 100% organic. He thought, “How could there be a problem?”
He then tried to trace the source of the contamination. He took samples from a railcar of organic soybeans sent from his supplier and sent them to a lab for testing.
The lab results stunned him. The samples tested positive at 20%, an extraordinarily high level of GMOs. The contamination was so high that the lab said there must be almost a truckload of GM soybeans in the railcar, says Chris…
Before the contamination problem, Chris says he had a great relationship with the supplier. He had previously purchased organic soybeans from China, but was happy to use a domestic supplier. That’s all changed. Now Chris is planning to buy Chinese organic soybeans again.
It is a sad day indeed when America’s crops are so thoroughly contaminated with GMOs that our organic food processors are forced to obtain non-GMO products from other countries.
© 2011 Barbara H. Peterson
Additional research by Nicole Johnson
Additional References:
http://www.nongmoproject.org/retailers/understanding-our-seal/
http://www.truth-out.org/why-monsanto-always-wins67976
http://www.choicesmagazine.org/magazine/article.php?article=131
http://newhope360.com/food/minimal-gmo-contamination-found-organic-products