Labeling, GMOs, GMEs, and COOL
Off and on, over the past few months, I have seen and participated in several discussions relating to labeling and specifically, labels relating to GMO’s. Twitter is not the best place to have this discussion, in my opinion, so I have put together my thoughts on the subject here.
GMO vs GEO
I catch myself using these two terms interchangeably and I should not be. There is a major difference between genetically modified organisms (GMO’s) and genetically engineered organisms (GEO’s).
Modify: to limit; to make minor changes in; to make basic or fundamental changes in often to give a new orientation to or to serve a new end.
Engineer: the creative application of scientific principles to design or develop structures; to construct or operate the same with full cognizance of their design; to forecast their behavior under specific operating conditions.
All biological organisms, plants, animals, bacteria, etc., have been modified, or changed, since the beginning of time. In some cases it has been through natural processes, outside of the direct influence of man. In other instances, man has directly modified through selection. For example, keeping wheat that had more grains per head, grass that could tolerate drought, cattle that gain weight quicker or more efficiently are all manners in which man has modified organisms.
GEO’s, on the other hand, have been engineered my man to exhibit specific traits. Plants have been engineered to withstand drought, repel insects, disease and the infamous herbicide Roundup. Arizona State provides a fairly clear dissertation on Plant Genetic Engineering.
It should come as no surprise that I am not a fan of regulations, especially when they only serve to generate revenue for an agency and place more economic hardship on businesses that lead to higher costs for consumers.
When it comes to labels, the Food and Drug Administration (FDA) makes the determinations as to what is required on labels and also how it is to be displayed.
Labels should be based on science and facts. If a product, ingredient or additive poses a health risk, it is the responsibility of the FDA to let the public know.
I feel it is first important to understand the difference between the act of volunteering and the act of regulating.
Volunteer: an action not founded on any legal obligation to act.
Regulate: to control or direct by a rule, principle, method, etc.
I fully support entities that want to voluntarily label their product as being “GEO Free.” As with any USDA/FDA approved label, it should also be verifiable by traceability and/or a third-party audit. There is a demand by some consumers that want to be able to buy products that are “GEO Free.” I believe there is great potential for producers and some companies to add value to certain products by pursuing this endeavor and that the value can also be realized by the producers.
I would also fully support entities that want to voluntarily label their product as “Contains GEOs.” According to USDA on Genetically Engineered Crops, with 94% of all soybeans being a GEO variety, if a product contains soybeans, the product likely contains a GEO. Additionally, if a product contains corn, of which 65% of the varieties are GEO, it is also likely that the product contains at least some GEO.
I do not support the USDA/FDA regulating producers/companies to add to label “Contains GEO” for two reasons. The FDA could and should require labeling if GEO’s posed a health risk. However, science has not shown that GEO’s do and so they are unable to require the labeling for this reason (See FDA Labeling Guidance and Regulatory Information).
Second, if the FDA were to require labeling, for the sole reason of it being a specific plant variety, it would open the gate to require all varieties of all plants to be listed. I do not think this is necessary and it would only serve to increase the number government employees to needed to inspect, audit and verify, costing the consumer through taxes and price of final product.
The Additive Argument
Some make the statement that GEO’s should be considered an additive, but they are not, they are a variety.
Additive: a substance added in small amounts to something else to improve, strengthen, or otherwise alter it.
Variety: a taxonomic category consisting of members of a species that differ from others of the same species in minor but heritable characteristics
The “Consistency” Argument
Some question how I can be a supporter of Country of Origin Labeling (COOL) and not a supporter of a “Contains GEO” label. While the two may seem to be similar, they are very different. COOL would require a label to state the country or countries, from which the meat came from, not the breed or breeds, in the case of it being from a cross-bred.
However, for the same reason I support a “GEO Free” label, I also am very supportive of the Certified Angus Beef, Certified Hereford Beef, Harris Ranch Natural Angus and others. These are voluntary endeavors, which have verification measures in place and also yield a noticeable added value to the product that the producers also realize.
In conclusion, I fully support voluntary labeling, especially when it adds value to a product, value that is also passed on to the producer. I am also strongly opposed to the FDA regulating a label requirement that is unnecessary, that would lead to more government employees, more wasted tax payer dollars and higher costs for consumers.
Added on November 23, 2011:
Here’s a link that just appeared on food labels from UC Berkeley and Good magazine. An interesting contest resulting in an approach to change labels to make them more informative. Hope you enjoy.