Non-GMO Food Labeling: Is it truth or deception?

Recently I responded to a tweet from @BioChicaGMO who posed the question:

To which I responded:

As a result, @BioChicaGMO reached out to me and asked me to coauthor a blog for the Genetic Literacy Project. We took differing approaches toward the issue of labeling on Non-GMO foods. Last week the blog was posted:

The Non-GMO Project is a non-profit organization that provides “North America’s only third party verification and labeling for non-GMO (genetically modified organism) food and products.

You may have seen its seal on various products in supermarkets, particularly at Whole Foods.The organization works with three companies or technical administrators including SCS Global Services to evaluate if products comply with its standards. Most recently, it has expanded its labeling services to include restaurants and delis.

The Non-GMO Project claims to verify more than 20,000 products. “We currently have more than 2,200 participating brands, and are receiving an average of 70-80 new verification inquiries every week,” says Megan Westgate, Executive Director of the Non-GMO Project, was recently quoted as saying. The organization claims sales of its verified products tops $7 billion annually.

For those concerned about consuming GMOs, this voluntary label, together with products that exist under the USDA’s organic label, provides many options. For those who oppose mandatory labeling of GMOs, the label provides an example of how voluntary labeling can work without imposing costs on others.

However, a seemingly grey area exists when a product is labeled as non-GMO, yet a GMO counterpart does not exist. For example, should an avocado be labeled as non-GMO if GMO avocados don’t exist? What about salt? Crushed tomatoes? Arecent article highlighted that some brands of popcorn are advertised as not containing genetically modified corn when there is no genetically modified corn of the popcorn variety on the market. Some people might argue that such labeling practices are misleading and dishonest; others don’t have a problem with it. This article provides opinions from both perspectives.

Labeling as GMO-free is disingenuous – Jennie Schmidt

It seems to me to be disingenuous to label foods as “non-GMO” when the counterpart GMO food doesn’t exist. The “Fair Packaging and Labeling Act of 1966” directs the Food and Drug Administration and the Federal Trade Commission to regulate labeling of foods and consumer commodities to “…to prevent unfair or deceptive packaging and labeling of many household consumer commodities.” I consider “non-GMO” labeling to be deceptive when the equivalent GMO product doesn’t exist in the marketplace. It’s akin to the claim that peanut butter is cholesterol free. Since cholesterol is produced in the liver and peanuts don’t have livers, peanut butter has always been cholesterol free.  To advertise it as cholesterol free is deceptive because it wasn’t there to begin with. Read the rest of the article here.

The Costs of GMO Labeling

There has been much discussion over whether or not the labeling of "GMO" foods would add to the cost of food production or not. This was one of the supporting arguments for GMO labeling at the legislative hearing at the Maryland House of Delegates Committee on Health and Government Operations during which Doug Gurian-Sherman of the Union of Concerned Scientists and Michael Hansen of the Center for Food Safety, both insisted that labeling costs would be minor at best.

So does Mother Jones

So does The Grist

Wow, do these scientists and journalists have any understanding of the food supply chain from farm gate to grocery shelf?

Apparently not, nor does anyone else who thinks that "GMO" labeling won't increase the cost of food.

Here is my pictorial analysis of the food supply chain from my farm gate:

Seed corn is ordered and delivered to farm, then planted in the spring around May.

By summer, it looks like this.

By fall, it looks like this.

It gets harvested between September and November.

Corn is transferred from the combine to a tractor trailer truck.

The grain is hauled here to our on-farm grain bins for storage.
We have storage for about 50,000 bushels, less than 25% of our total
yields in a normal year for corn, soybeans, wheat and barley, all of which need
to be stored until they're needed by our customers. This includes the specialty seeds we grow
that require segregation from commodity grains.

When its time to sell, we reload the trucks and haul it to the local grain elevators.

The tractor trailer delivers the corn here

Or here

Or here

And that's just 3 of the local grain elevators. We have several other options depending on who is buying our grain. We and all our farming neighbors deliver to the same elevator and unload grain. This is called "commingling" where our crop is combined with everyone else who delivers to the same elevator and stored together in these large bins, regardless of what variety or trait of corn was grown.

So where's the cost you ask? Well, every farmer in the region is hauling grain usually around the same time... to the same group of elevators. Hopefully you read my blog on seed choice last year and realize that all farmers determine their own purchases for seed and we don't all grow the same thing. In fact, we grow 3-4 different varieties of corn ourselves. Why? Because we match the varieties of corn to our soil types. That's called good stewardship and good business practice.

The food supply chain in the United States relies on a system of commingling, grain delivered to the elevator by farmers throughout the region. Maryland has 2 million acres of farmland, nearly a half million of which grew corn in 2012. In a not very good growing year, Maryland farmers produce 53 million bushels of corn.

If GMO labeling were to pass, that would require a HUGE addition to both on and off farm storage. Nationally, we're talking billions of dollars in infrastructure needed to segregate grain. What none of these labeling laws is clear about either is how to achieve this segregation? Should it be segregated by trait? by variety? both? The more layers of segregation, the more infrastructure is required and the more the costs escalate. 

Segregation is costly. We know because we do it every year, year in and year out, and have for years. We do it because we get paid a premium for ensuring that the specialty grains and seeds we grow are "identity preserved", very much like the certified organic process, involving higher management, higher tracking, and systems in place to ensure that the grains and seeds are genetically consistent and true to their traits, of highest quality meaning they are uniform in size, shape, color, free of weed seed and contamination. We will have 900 acres of grains and seeds this year that will require some protocol for identity preservation. They will be tested for the presence of GMO and tested to ensure that they are genetically consistent to parent seeds. This requires us to use some of our grain tanks for segregation. It requires us to do more "housekeeping", cleaning equipment, trucks, trailers, planters, harvesters, grain bins, etc... all along the food supply chain to ensure that we have preserved the identity of that crop. It is an inherently more costly system.

So what are the costs? Here is my rudimentary analysis from the USDA Crop Production 2013 Summary. 

There is 13 billion bushels of on farm storage in the United States.

There is 10.4 Billion bushels of off farm storage in the United States.

Last year, U.S. Farmers grew the following crops ALL of which require storage:

• 13.9 billion bushels of corn
• 389 million bushels of sorghum
• 421 million bushels of rice
• 3.3 billion bushels of soybeans
• 2.1 billion bushels of wheat
• 215 million bushels of barley
• 1 million bushels of oats
• 7.6 million bushels of rye
• 18 million bushels of millet
• 3 million bushels of flax seed
• 7.8 million bushels of safflower
• 1 million bushels of canola
• 65 million bushels of sunflower
• 38 million bushels of rapeseed and mustard seed
• 301 million bushels of lentils
• 937 million bushels of dry peas
• 250 million bushels of peanuts
• 1.5 Billion bushels of other dry edible beans including:
• light red kidney
• dark red kidney
• Great Northern
• baby limas
• large limas
• pinto beans
• small white
• navy beans

So 2013 produced roughly 23.5 billion bushels of 26 different grains and seeds, including those already in some form of identity preservation protocol, and have storage capacity of 23.6 billion bushels... without the extra infrastructure to segregate "GMO" from "nonGMO". To segregate, additional infrastructure would be required along the entire food supply chain from farm gate to grain elevator to processor to manufacturer, in order to separate corn, soybeans, and canola. 

A new grain bin cost approximately $2/bushel to buy and install, so a 50,000 bushel bin will cost $100,000. If we currently have sufficient storage for commingled grains and seeds, what will be the astronomical figure to segregate them by trait? That answer is dependent on how we are going to segregate.  In order to have true traceability, GMO seeds and grains would have to be segregated by trait, so RoundUp ready traited grains would have to be segregated from Bt traited grains, and the stacked or combined traited grains would have to be segregated from those that are just Bt or just RoundUp Ready, and the combinations of traited grains would have to be segregated by the combination or stack of traits in the seeds too, because otherwise, you don't have "truth in labeling" to say which GMO is in the product. 

I mean surely, we need to label it by GMO trait right? because otherwise "we don't know". This is the premise by which the activists say is the problem right? The uncertainty of GMO? We can't commingle traited seeds and grains because then we no longer have true traceability. Absolute and utter segregation by trait or combination thereof is required to meet the demands of what is being called for in the GMO labeling legislation across the U.S.

True GMO labeling will require vast capitalization of infrastructure to segregate grains and seeds by trait. (Read $$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$).

And I've only been talking about the costs of grain storage.  I can't even begin the fathom the costs that it would take to segregate all along the entire food supply chain, keeping GMO corn, soybean or canola ingredients segregated by trait from conventional counterparts from the farm to the processor to manufacturer. We're talking billions of dollars in order to maintain the absolute traceability of a certain genetic trait in a seed from farm to final product. 

Those who say GMO labeling won't add to the consumer's grocery bill need to go back to Economics 101 and some basic high school math. 

True traceability in our food supply system will be hugely expensive.

Its likely that as a nation, we'd never capitalize all that infrastructure to achieve true traceability.

Which goes to the crux of the matter -  this isn't about labeling, as I cited in my last GMO blog, labeling is a means to an end. As noted by many activist groups, the ulterior motive behind labeling is not about a consumer's right to know, it is about banning the technology. 

Say NO to mandatory GMO labeling. Stand for science.

I Grow GMO: Not Ashamed or Embarrassed

Yesterday, I testified before the Maryland State Senate Committee on Education, Health, and Environmental Affairs Committee. I was speaking against SB778 "Genetically Engineered Foods - Labeling Requirements" 

My interview with WBOC on GMO labeling

Introduced by Senator Karen Montgomery, of Montgomery County, the bill synopsis states: 
 "Requiring specified raw foods and packaged foods that are entirely or partially produced with genetic engineering to display a specified label beginning on July 1, 2015; requiring a manufacturer to include a specified label on specified foods; requiring a supplier to include a specified label on a container used for packaging, holding, or transporting specified foods; requiring a retailer to place a specified label on a shelf or bin containing specified foods; etc."

She introduced the hearing legislation by asking why people acted "ashamed or embarrassed" about GMO. She claimed she was a supporter of biotechnology and wasn't afraid of it but that consumers have the right to know. 

But many of the groups who claim that consumers have the "right to know" are actually working toward a ban of the technology. 

Organic consumers Association: "Once GMOs foods are labeled, informed consumers will move to protect themselves and their families by not buying them. Once enough consumers shun GMO-tainted and labeled foods, stores will stop selling them and food manufacturers will stop putting GMO food ingredients in their products."

Center for Food Safety:  "Labeling #GMO food is not enough. We must keep new GE crops out of food supply to begin with take action @TrueFoodNow"

March Against Monsanto: "Many presume the March Against Monsanto is a protest about GMO. While food plays a very big role in the global protest, there are many insidious tentacles to the biotech giant. MAM seeks to destroy the root."

Truth-Out: "GMO labeling laws are the cornerstone of the anti-GMO movement. But consumers are also expanding the fight by demanding outright bans on the growing of GMO crops."

In fact, two consumers who testified at the same hearing in favor of labeling voiced the very same thing, that labeling didn't go far enough, that biotechnology needed to be banned.

The Consumers Union, Food and Water Watch, and Union of Concerned Scientists had their legal team of suits presenting. I'm not going to restate their position because if you google Michael Hansen or Doug Gurian-Sherman, you will find pages of testimony nearly word for word identical to what they told the senate hearing yesterday, including continuing to claim the validity of the retracted Seralini study.

In response to Senator Montgomery's comment: I am an unashamed and unembarrassed supporter of biotechnology. On my Maryland farm it has resulted in higher yields and lower pesticide applications, year after year, wet season, dry season, normal season. Even when Hurricane Irene knocked our corn flat, biotech held its ears better than non GMO corn by 26 bushels per acre, which in a very crappy year, makes a world of difference to our family farm's ability to stay afloat.

Our corn yield comparison data

Our soybean yield comparison data

Biotech out perform our specialty seeds: non GMO & Identity Preserved. Yes, we grow and segregate a variety of different types of grains and seeds, all of which are tested and verified as pure to the variety they are supposed to be. This year, we will have 900 acres of grains and seeds under some protocol for identity preservation. The seed must be genetically consistent and true to its traits, uniform in shape, size and color, and free from weed seed and contamination. They are tested and verified to meet those standards. So co-existence of conventional, biotech, and organic/Identity Preserved/nonGMO grains and seeds is possible. We do it every day on our family farm and have for many years now. Biotech threatens none of our niche or specialty markets. These farming systems are not and should not be considered mutually exclusive.

When you combine higher yields consistently, with less man hours on a tractor, burning less diesel fuel, and saving pesticide sprays, you have a far more sustainable family farm on the environment: less greenhouse gases, less fuel consumption, less pesticide use = protecting and preserving more resources.

But to the larger picture, biotechnology has brought us Humulin, Epogen, Herceptin and many, many other excellent lifesaving medical therapies. 

Biotechnology means we don't harvest insulin from hogs or cattle pancreas anymore.

Biotechnology means we don't harvest the enzyme chymosin from young calves to extract rennet from their stomachs which is then used to coagulate milk in the cheese making process. 

To me, this is progress. To me, these are reasons to oppose mandatory labeling of "GMO". It is both safe and efficacious in medicine and in food. 

Science and research concurs. Published last year, An overview of the last 10 years of genetically engineered crop safety research reviewed 1783 studies, 312 of which were GE food & feed consumption studies finding "no scientific evidence of toxic or allergenic effects". The researchers concluded that "that genetic engineering and GE crops should be considered important options in the efforts toward sustainable agricultural production."

1783 studies... 312 of them on consumption of GE food and feed. That's a safety track record.

Nicolia, et al, 2013. Critical Reviews in Biotechnology

The technology is valuable in both medicine and food. The technology has many benefits to mankind.No one but the activists are saying biotech was supposed to be a "silver bullet". Farmers know its one of many tools in the tool box to improve sustainability and produce more food on less land.  Efforts to undermine the technology through mandatory GMO labeling that falsely implies there are safety concerns where none exist is misleading and a disservice to consumers.

I oppose Maryland SB778

Stay Calm & Farm On!

Today started with an interesting twist. My son has had a difficult week with issues at school. This morning I told him my best advice was to "stay calm and study on." Little did I know that in a short time, this saying would come back and help me deal with attention from an article in a national newspaper. . As I drank my morning coffee, I opened my email to find an article that included me in the New York Times. It was shared on a listserv by a member of the Hunger & Environmental Nutrition Dietetic Practice Group to which I belong (remember I was an RD before I was a farmer). WHAT? Why on earth would the New York Times care about me and why would I be included in an article?  So here is the link to the article:

Food Politics Creates Rift in Panel on Labeling

The crux of the problem with this article and the way it came about was that NO ONE contacted me to inquire about my business relationships or to verify what was being written about me. This was an absolute broadside. I've never heard of Stephanie Strom, nor did she contact me to confirm the information she received from whatever source she thought was valid. Sadly, this illustrates what is wrong with today's journalists, the lack of integrity. A story is a story for the headlines and screw the accuracy because accuracy would make it a non-story.

THEN, I got my first tweet about the article! It said: 

"@FarmGirlJen Why are you in bed with #Monsanto #GMO?" 

(Oh no! What if my husband finds out?.....) 

This tweet came from a woman who calls herself a "Spiritual Teacher & Healer." Not sure she remembered her spiritualness when she tweeted me. I didn't find it very healing nor did she try to find out the facts first before she sent out that tweet. Only in her 2nd tweet did she ask what the facts were.... REALLY?

I have been speaking about agriculture, biotechnology, and farming systems for many years now.I  show yield data from our farm comparing our conventional, organic (formerly), and biotech yields and methods, talk about our farming practices and why we do what we do and how its changed over the generations. Its all about how we make decisions on our family farm and why.  When I give presentations, I  list the companies that my family farm does business with and any background about me that folks who are narrow-minded will assume makes me biased or otherwise unable to be objective, as was noted in the NY Times article. So what I did do was fully disclose all of our family farm's business associations with seed companies, chemical companies, commodity groups, and national and regional agri-businesses on the disclosure form for the Academy of Nutrition and Dietetics. I don't personally have direct dealings with all of them but I knew that if I did not list them all, that something like this would happen. Lo and behold..... it did. Did anyone else feel obligated to disclose where they purchase supplies for their business? ( By the way, I buy my paper from Staples, and this computer came from CompUSA. I buy groceries at Food Lion and shop at Tractor Supply for my clothes... I'm a farm girl not a fashionista). I also listed the prize money I won for being chosen as one of America's Farm Mom of the Year.  I did not disclose that the funds went into my kids college funds and to local non-profits including my church food pantry. Shame on me! 

For the record, I do not know if Monsanto has a "test farmer" program but if they do, I and my family farm am not part of it. We do LOTS of on-farm research which I blogged about last year: Growing Answers: On-Farm Research

So after my initial shock, I adopted my own advice that I had given my son but adapted it to suit my situation.  Today my mantra was: 

  "Stay calm and farm on."