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Friday, June 26, 2015

Who Controls The Food Supply?

Who has actually has the control? Maybe not who you think. Certainly not Pinky and the Brain.
(The serious part of this post originally appeared on Forbes, 6/26/15)

A common anti-GMO narrative is that large international companies seek to “control the food supply” through patents and the ownership of seed companies.  Ironically, the opponents of plant biotechnology have exercised a far more significant degree of “control”.  Very few of the possible “GMO” crop options have ever been commercialized in either the developed or developing world.  It gives me no pleasure to say this, but over the last 20 years I've watched as anti-GMO activists have successfully employed three, potent control strategies:  political over-ride of the regulatory system, manipulation through brand protectionism, and pressure exerted via importers. 

The farmers who have been granted the opportunity to grow biotech crops have adopted them enthusiastically. The traits have provided growers with logistical advantages, reductions in risk, and/or economic benefits. This has been true in both the developed and developing world.

Adoption rates of biotech varieties in various crops and geographies (data from The Context Network, USDA-APHIS, FAO-Stats)

However, very few of the world's fruit or vegetable growers have had a biotech option, nor have the farmers who grow wheat, barley, rice, potatoes or pulse crops.  This is true in spite of the fact that genetic engineering could address important and even critical needs in those crops.

Political Over-ride

The first success of the anti-GMO movement was the politically driven decision by most of Europe not to allow biotech crops to be cultivated and to require GMO labeling of foods.  The response of those food companies was to avoid GMO ingredients so they would not have the stigma of a label.  The EU subsequently funded a huge amount of safety testing, and their scientific bodies have concluded that there is no special risk associated with these foods.  But for Europepolitics still trumps science and that phenomenon has been exported through European influence on governments throughout the developing world.  Groups like Greenpeace have also aggressively opposed any efforts to allow poor farmers around the world to ever try out the technology.  The food supply for the poor is certainly being “controlled,” but by the activists, not by the seed companies.

Manipulation Through Brand Protectionism

A strategy of the anti-GMO movement for control of the rich world food supply has been to exploit brand protectionism.  The first example was with the potato industry.  An insect resistant potato was launched in 1996 at the same time as biotech traits were first commercialized in soybeans, cotton and Canola.  I interviewed many potato growers in the first few years the trait was available and they were extremely happy to have a solution to their most damaging insect pest, the Colorado Potato Beetle.

Colorado Potato Beetle Damage (photo by Jeff Hahn, UMN Extension)

Potato growers were also excited about virus resistance and improved storage traits that were in the product development pipeline.  Frito-Lay was sponsoring biotech trait development in universities for the potatoes used to make chips.  The activists recognized that in the North American potato industry, McDonald’s and Frito-Lay have enormous economic leverage as the biggest customers for frozen fries and chipping potatoes. They threatened those company’s brands with the prospect of unwanted press attention through targeted protests.  At McDonald’s, the decision was taken at the CEO level to avoid the brand risk, and so, in three phone calls to frozen fry producers, biotech potatoes were finished (I know this from three people who participated in that meeting).  A similar marketing-driven decision at Frito-Lay led to termination of their development programs.  There was nothing the potato growers, the major processors, or Monsanto could do about it because of the market power of those huge food companies – companies who effectively yielded that leverage to the control of the activists.  Meanwhile, potatoes still require extensive and costly pest control measures.

Brand Protectionism's Expanded Reach

The success of the activists in exploiting brand protectionism had a major chilling effect on other crops with high profile, consumer brands.  In the mid 1990s there was a great deal of interest in biotechnology solutions.  I was personally aware of projects that had been started or which were planned for bananas, coffee, grapes, tomatoes, lettuce, strawberries and apples.  When MacDonald’s and Frito-Lay acquiesced to the activist pressures around 1999, all the planning and work was halted in those and other brand-sensitive crops.  The ag biotech companies like Monsanto or Syngenta or DuPont essentially gave up on biotech efforts in “specialty crops” and focused only on the big row crops.  Fifteen years later that pattern of effective activist control remains largely in place.

Fusarium head blight of wheat (right) reduces
yield and leads to rejected loads because of the
DON mycotoxin (Wikimedia image)

Pressure Exerted Via Importers

At the turn of the century there were two biotech traits poised for commercialization in wheat in the US and Canada (wheat being one of the largest and most extensively traded crops in the world).  There was to be a herbicide resistance trait from Monsanto, and also a disease resistance trait from Syngenta.  Once again, I had the opportunity to interview many wheat growers to assess their interest in these options.  Most already had positive experiences growing biotech soy, corn or Canola, and they were keen to try the new wheat options.  They never got that chance.  Major wheat importers from Europe threatened to boycott all North American wheat if any commercial biotech varieties were planted in the US or Canada.  Europeans grow a great deal of wheat, but they need the high quality Hard Red Spring Wheat and Durum pasta wheat grown in the Northern Plains and Prairie provinces.  European bread and pasta makers did not want to have to label their products as containing GMOs, knowing that this would make them the subject of activist pressure.  So they used their considerable economic leverage as importing customers and made the boycott threat (not in a public way, but quite clearly).  The wheat grower organizations in the US and Canada could not resist and reluctantly asked Monsanto and Syngenta to stop their programs.  Both companies complied.  This was a clear example of food supply control – control based on the activist’s ability to create marketing issues for the sort of companies that really do have leverage.

The anti-GMO movement continues to use the threat of brand damage to get food companies and food retailers to use their market power to inhibit the introduction of new biotech traits and crop options.  These same strategies may well block second generation traits in applespotatoescitrus, and tomatoes.  The GMO labeling efforts and non-GMO projects are transparently being pursued with the goal of eliminating even the few existing biotech crops.

So who controls the food supply? Does that control entail any respect for the opinions and needs of farmers?  Do those that exercise the control contribute in any way to solutions to real world challenges and threats to the food supply?  Do those that exercise the control help to develop useful tools for the resource-poor farmers in the developing world?  Are any of the big food industry players with critical leverage willing to resist the control that is being achieved via their market power?  Are consumers happy with the reality of a food supply controlled by those who reject sound science?  Are they happy with a food supply controlled with the aid of food companies who profit from the fears that they and their allies have planted?

You are welcome to comment here and/or to email me at

Friday, June 19, 2015

One Agricultural Scientist's Concerns About The Future Of The Food Supply

(originally posted on Forbes 6/17/15)

I’m generally optimistic about the ability of the world’s farmers to continue to feed the growing population, and also to satisfy the increased food demand of the growing middle class in previously poor countries.  That hope is based on the amazing track record of innovation by farmers and their technological supporters that I have witnessed over the past four decades.  I do, however, have some significant concerns about trends and factors that may compromise the farming enterprise over the next critical decades.  My “concerns” fall into four major categories, and I will unpack each of them in subsequent posts. I will briefly describe the full set of concerns in this article because, while no single issue is insurmountable, there are potential negative synergies between them.

I. Changing physical/biological realities for farming

Farming has always been a challenging and risky endeavor.  It is becoming even more so in an age of climate change and with even more frequent introduction of invasive pests.  These combined issues are a dire threat to the livelihoods of smallholder coffee farmers facing worsening rust issues in Central America.  It’s a harsh reality for California farmers facing a lack of water because of low snowpack in the Sierras.  It’s a depressing reality for Florida citrus growers  or Italian olive growers  facing new pests killing their trees and possibly their industries.  These challenges play out differently in diverse geographies and for various crops, but these enhanced uncertainties are of major concern – particularly in light of the categories described below.
Dead olive trees in Italy, killed by a newly introduced disease with no short-term or even obvious long term cure

II. Three societal trends compromising the future of the farming enterprise:

1. The level of public investment in agricultural research continues to decline even though the pay-off of such spending has been clearly documented.  Private investment is strong, as is some from philanthropies, but it is best complimented by public activity.

2. There is also a two-fold “brain-drain” happening in key fields of expertise in agricultural sciences (e.g. agronomy, soil science, soil microbiology, plant pathology, entomology, nematology, etc). A combination of baby-boomer retirements and a lack of young people entering these disciplines is driving this shortage. We are losing a huge resource in terms of expertise and experience with those retirements (I'm talking here of far to many of my peers). Finding qualified applicants for jobs that support farming has become extremely difficult for employers. This is a precarious situation as we face the highest levels of food demand in history.

3. Increasingly, the ownership of farmland is in the hands of uninvolved, “absentee” owners (often the remote descendants of past farming families) who lack understanding of the implications of their leasing practices. Many important, sustainable farming practices pay for themselves, but only over the medium to long term. Common, annual cash rent leases don’t give farmers the appropriate rewards for running their complex, long-term operations.
A Map of Leased Land in the US

III. Uncertainties about the on-going “Social License” of agriculture

Farming, like any enterprise, depends on a certain level of societal trust and non-interference with its activities.  The term “social license” is used to characterize this relationship. This is threatened, because the farming community is a tiny minority in society, whose reputation can be driven, not by its own actions, but by outside voices.  Farming today is the subject of widespread disinformation from elements within the press, social media, the entertainment industry and certain not-for profit groups.  It is also grossly mischaracterized by a burgeoning, fear-for-profit sector in food marketing.  The phenomenon of “parallel science” also distorts and confuses even that potential voice of reason.  This climate of disinformation also leads to declining public trust in the regulatory system and to erosion of the scientific independence of those regulators.  Objective data demonstrates great progress in the health and environmental profiles of modern farming.  That is not the story that consumers are hearing in the Internet age.  Farmer-bloggers and others do their best to counter this phenomenon, but they are seriously out-gunned.

IV. Control of the Food Supply

Only a small fraction of the possible applications of plant biotechnology have ever been implemented on a commercial or humanitarian level.  I’m careful not to say that biotech, or any other singular technology, will “feed the world.”  Only farmers could ever do that. But biotechnology is one category in the “tool box” that can be particularly helpful for farmers for certain crop-specific issues.  It could also have interesting consumer benefits.  Only a tiny fraction of that potential has been realized because the “food supply” has been quite effectively “controlled” by the opponents of “GMO crops.”  In my next post I will describe how that control has been achieved. What has been largely ignored is the fact that where farmers have had the option to grow biotech crops (on about 8% of global cropland), they have found them to be extremely useful and adopt them at high rates.  This has been true in both the developed and developing world. When the “control of the food supply” works against the interests of farmers, it compromises their ability to meet the modern food supply challenges.

Why I'm Concerned

As I watch the combination of rising demand, changing climate, and new pest problems with low investment, declining expertise and technology suppression, my optimism about the food supply is tempered.  As I see the farming community being falsely represented, less fairly regulated, and ignored I worry about their incentive to forge on or stay in that critical but difficult business.  When I see rich world agendas being imposed on the world’s poor as form of green imperialism, I worry about those people at most at risk if we fail in the modern food challenge.
I would be interested to know what others think about these issues and would greatly appreciate hearing any ideas about solutions.  I’d like to combine them with other ideas that I have heard when I unpack these concerns in subsequent posts.

As always you are welcome to comment here and/or to email me at

Thursday, June 4, 2015

Organic Offshoring: As Demand Rises, Increase In Imports Poses Safety Risks

Corn infected by the fungus Aspergillus which can produce aflatoxin (Iowa State IPM)

(This post originally appeared on Forbes, 6/3/15)

There is a trend in the organic food industry with the potential to damage the entire Organic brand.  This risk was highlighted by a recent Canadian Food Inspection Authority decision to institute mandatory mycotoxin screening of corn imported from India.  This began after CFIA found dangerous levels of aflatoxin in shipments intended for organic chicken feed.
A little background on aflatoxin. It is one of the most toxic and carcinogenic chemicals known.  It is the third highest cause of cancer death world wide. Aflatoxin is a serious threat to health.  So - highly toxic feed transported half way around the world seems seriously “off-brand” for organic. It should. Many consumers willingly pay a price premium based on their belief that organic means safer/better*.   That trust is being seriously violated by the phenomenon behind the recent Canadian incidents.

Canadian farmers can certainly produce wheat, and for the last 30 years
the gains have mostly been through yield (my graph based on FAOStats data)

A logical question is, “why would Canadians import corn from India when Canadian farmers are fully capable of producing that crop.” The answer is that Canadian production of organic corn (and other organic grains) has not kept up with demand. The same is true for the U.S. This shortfall has induced some animal producers and human food manufacturers to tap distant sources.  Why the gap?  Some of this is related to the three-year transition required for a farm to qualify as organic, but much stems from the fact that farmers are not being offered a high enough price premium for organic to justify the logistical, yield and risk-based costs of growing under the organic rules. It simply does not make economic sense for them to make that commitment when they know that the way they are normally farming is perfectly reasonable.  When buyers then choose to source their organic supplies from low-cost, off-shore sources, it only serves to entrench those inadequate premiums for the local producers.  The higher prices that consumers are willing to pay for organic are not being sufficiently passed along to the farmers in their own region.

This organic off-shoring phenomenon is much broader than some corn for chickens in Canada.  Much of the recent growth in organic sales has been outside of its traditional niche of fresh fruits and vegetables.  This growth has been in meat, dairy and packaged foods, all of which involve non-perishable ingredients which, like that Indian feed corn, can be cost-effectively shipped from around the world to Canada or other rich countries.  These importable ingredients include animal feeds, but also cereal grains/flours; dried milk, fruit and vegetable products; spices, nuts; fruit juice concentrates and frozen items. There can be mycotoxin issues with many of these ingredients, but in the rich world we have systems that manage that risk quite well.  If you go to the low cost market, there is no such guarantee. Andrew Porterfield has recently described enhanced pesticide risks associated with this same import trend.

Importation as such is not the problem.  There are many completely logical and safe reasons for international food trade from reputable sources.  The problem is that some of this organic-supply-driven-sourcing exposes us to crop production in regions that don’t have the basic environmental and food safety protections that we who live in the rich world normally have the privilege to assume.  Keeping fungal toxins out of the food supply requires careful attention to pest control, careful harvesting and proper storage.  It requires monitoring and rejection protocols.  These precautions are well integrated into developed world food systems. When companies go outside of the mainstream supply to cheaply fulfill organic or non-GMO demand, these safety features are often missing.  How often does that lead to dangerous contamination as in the Indian corn incident?  No one knows because there had been no routine testing of imports until this recent Canadian decision to look at one category.  Corn is certainly not the only ingredient with the potential for mycotoxin issues.  There is nothing in the organic rules to address these risks.  In fact the organic limitations on insecticide and biotech options increase the risk of the pest damage that initiates contamination.

The aflatoxin incident and policy change in Canada attracted very little attention in the North American press.  Perhaps it would be different if/when someone finds mycotoxin contamination in an organic human food ingredient.  It is tragic that this danger is still prevalent in many parts of the world, but it is absurd to be importing it so that it becomes a “rich world problem.”  If food companies are unwilling to pay farmers for the true cost of organic or non-GMO production, they should not be profiting from a consumer illusion of safety when in fact those customers are being put at greater risk.

You are welcome to comment here and/or to email me at

*There is actually no convincing data to support the idea that organic is more nutritious.  There is also no reason for modern consumers to be afraid of pesticide residues on conventional food.  Some of the most environmentally beneficial farming options are not allowed or are impractical under the organic rules.  Consumer beliefs are also influenced by certain organic food marketers who actively misrepresent conventional farming as a way to enhance their own fear-based sales.

Friday, May 29, 2015

Why Is The USDA Getting Involved In A 15th Method Of Food Labeling?

(This post originally appeared on Forbes, 5/28/15)
A couple of weeks ago I was deeply disappointed to read that the USDA might get involved in an aspect of “non-GMO food labeling.”  The marketing of non-GMO food is an opportunistic, fear-based phenomenon – not something worthy of aid from a science-oriented agency like USDA.  Also, if the goal is to allow consumers “know more about their food,” then why not transmit knowledge with context and perspective that would diminish, rather than promote, superstition? Printing was state-of-the-art in 1435.  We can do better in the 21st century!


It may seem extreme for me to declare that the fear of GMO foods is a superstition, but consider the history of this phenomenon.  For two decades, the opponents of crop genetic engineering have promoted the idea that transgenics, a particular means of genetic modification, is something sinister and frightening.  Their arguments are typically accompanied by emotive images such as hypodermic needles full of colored liquids protruding from ripe fruits and vegetables.  Such images bear absolutely no connection to the actual process of plant genetic engineering.
Examples of what crops looked like before humans began the process of genetically modifying them
(From Genetic Literacy Project)

These websites don’t communicate the fact that virtually all crops have been “genetically modified” in many ways for centuries and that transgenics have been the most carefully introduced and independently tested of all.
Although all of the major scientific bodies around the world have affirmed the safety of “GMO crops,” the fear-based messaging has worked. This has created an up-selling opportunity in the food industry, and that kind of marketing is well served by the two word message, “non-GMO.”  The seller can tap in on all the emotive, doubt-sowing efforts to date without any potential confusion that would be created by knowing the full story.  It’s effectively a “right to not know.”

Wikipedia example of a scan code
In an era of scan codes and smart devices, a curious consumer could have all the resources they need in an interactive, multi-media form.  They could ask: “What are the ingredients in this food?”  “Where has it been sourced and why?”  “What is known about the safety of the ingredients and the food as a whole?”  “What does the nutrition labeling information on the back mean?”  “What kind of farms and farmers were involved in the production of this food?”  “Why do farmers choose to use certain agricultural technologies?”  Consumers could “know” a great deal.

A Suggested Role For USDA

The drawback with this is that as with all information available today, it is very hard for the consumer to sort out what is true.  Here is where a public agency with extensive expertise in the practice and science of agriculture could play an appropriate role.  They could be an independent “third party” that could vet the information offered via 21st century methods.  To do so would require more resources for the USDA because their workers are already engaged in other important work.  As consumers, we would be better served by a modest increase in USDA funding via our taxes than by spending billions on “GMO-free” food marketed based on superstition. If you have not heard it in a while listen to Stevie Wonder’s classic song, “Superstition” , particularly the repeated lyric:
“When you believe in things that you don’t understand, then you suffer... superstition ain’t the way.”
Now imagine the lyric,

"When you're afraid of things you don't understand, and you pay more... superstition ain't the way."
Wikipedia image of Stevie Wonder from 1973 - Lyric slightly modified

You are welcome to comment here and/or to email me at

Wednesday, May 13, 2015

Pests In Paradise

Our adventure started here after an 8-mile hike to Snowmass Lake near Aspen, Colorado
(originally posted on Forbes, 5/11/15

I learned something very important about crop pests in a most unexpected setting – a paradise-like wilderness area in the Colorado Rockies.  It was the summer of 1978 and I had gotten married the year before. This was my first chance to share a favorite place, the Snowmass/Maroon Bells Wilderness Area, with my wife.  We backpacked into Snowmass Lake and day-hiked to high passes through huge meadows filled with beautiful wildflowers.  However, on this trip, I noticed details I had never observed on earlier visits as a suburb-dwelling teen.  With “new eyes” from my first year of agricultural training, I saw that many of the plants showed signs of insect feeding damage or gall formation.  They exhibited symptoms of fungal infection – such as rusts and leafspots.  There were pests in this paradise! And they were host specific – not interlopers carried in on the boots of visitors like us.
View from Buckskin Pass
Thinking about it, I realized that this wasn’t really surprising.  Plants have the unique “super power” of turning sunlight, water and carbon dioxide into the food that directly or indirectly feeds everything else – including us.  It makes perfect sense that insects and fungi have evolved to “harvest” that energy, in even this pristine ecosystem.  I then realized that what we call “pests” are simply part of the natural order.  Thus, it is to be expected that we often have to find ways to deal with “pests” of cultivated crops.  The need for pest control isn’t an artifact of human farming. Practical farming needs may complicate pest control, but the basic phenomenon of pests is entirely “natural.”

On one hand, we might say that a “pest” is simply a human concept for cases where this natural phenomenon interferes with our agenda.  However, it seems that plants “agree” with our assessment that these damaging, dependent organisms are pesty. Plants are obvious targets, but they don’t just take it.  I once heard a presentation about the genetics of a particular alpine wildflower that grows in exactly the same kind of meadows we were visiting in 1978. This species has genetic “factions” employing two different strategies to deal with insects that want to eat it.  One is to put energy into rapid growth and seed production, so that even with bug damage, the species survives.  The other strategy is making chemicals to protect the plant from the bugs, leaving less energy for seed production.  Depending on the season, one strategy or the other is more successful.
Chemical defense is common among plants.  In some cases we have come to like the pesticidal chemicals they make. The caffeine in coffee and the capsaicin in hot peppers were “intended” by those plants to ward off “pests.”  Many vegetables we enjoy, such as tomatoes, eggplants and cauliflower, still make some of a not-so-nice “natural insecticide” called nicotine.  But don’t worry. You would have to eat an enormous amount to be hurt by the nicotine, caffeine or capsaicin.
So since pests are part of the natural order, and since plants fight back with their own “pesticides,” human use of pesticides makes sense as part of a pest management strategy for the plants we tend.  That is particularly true now that we have developed many products that are quite specific for certain pests, and very low risk for us or for the environment. Pesticides are also necessary tools for those farming under the organic rules.  Synthetic pesticide residues are present at even less consequential levels in our produce than plant-made chemicals.
A slightly modified quote from the Princess Bride (modified from

If you have the chance, I encourage you to visit those Colorado wildflower meadows.  They are beautiful, and unless you look for it, you probably won’t notice the battle between plants and pests that is going on in the background.  The wildflowers survive, even with the damage.  The season is also short, so there are not many generations of the pests. We humans require a higher standard of pest protection for our crops. To make the most responsible use of our land, water, fuel or other inputs, we cannot tolerate too much pest damage or the crop is diminished.  Besides, as even my grand daughter realizes, pests are yucky!  

You are welcome to comment here and/or to email me a

Friday, May 8, 2015

Does Science Belong On Your Dinner Plate?

(Originally published on Forbes 5/5/15

I was recently asked to give a talk in Toronto addressing this question: “Does science belong on my plate?” The quick answer is:

“No, because Science isn’t a “thing” you can serve or eat. Science is really a verb - a process, a method, a conversation.”

A longer, better answer is:

“There is a rich history of innovation and change in the human food supply extending over millennia. More recent innovation examples that have been achieved using sound science are a continuation of that tradition. They certainly belong on our plates.”

Many consumers have the impression that, until recently, food and food production was something little changed. This mistaken view is understandable considering modern society’s isolation from the production of food, and marketers’ penchant for using romanticized imagery and narratives to sell food products.

This is a great bread product, but that image has nothing to do with how the wheat for that is produced today.

The truth is that innovation and change have been central to food and farming throughout human history - both before and during the scientific era. One of my goals as a new Forbes contributor will be to tell some of the stories behind interesting and important innovations that have changed what is “on our plates” in very positive ways.

Feast or Famine

From the beginning, a fundamental challenge for humanity has been that sources of food tend to be either over-abundant or scarce. Thus, innovations around food storage and preservation have been key to our survival (e.g. drying, salting, pickling, cheese making, fermentation…). Even the ancient storage of dry grains involved innovations like using herbs to line the urns to reduce damage from insect pests.
Cold storage has been used to spread-out the supply of food beginning with caves or cellars. Later people used stored ice from the winter, and eventually came up with refrigeration. Susanne Freidberg’s excellent book, Fresh, describes just how transformative and controversial the innovation of mechanical refrigeration was as it was slowly adopted around the turn of the 20th century.


Another major theme of human food-supply innovation has been “genetic modification.” The “natural,” pre-domesticated forms of our food plants are barely recognizable vs their modern forms. Over millennia, humans consciously or unconsciously selected for more desirable specimens, and in so doing, they achieved dramatic genetic changes even with no understanding of the underlying biology. While this worked well for grains and vegetables, a few thousand years ago people realized that you cannot propagate a desirable specimen of a tree or vine by replanting its seeds, because they don’t grow up to be the same as the parent. So, people innovated various ways to “clone” these desirable cultivars – rooting, grafting, budding etc. A “transgenic” innovation of that category saved the European grape industry in the 1870s when it was on the verge of collapse due to a deadly new pest. The innovated solution was to use American grape species as the protective rootstock on which to graft venerable varieties of the traditional species, Vitis vinifera. That system still protects virtually all of the world’s grapes today.
This cool vineyard I saw in Sicily a few weeks ago survives because it is on American rootstock

In the last century, increasing scientific understanding has enabled continued innovation to enhance the food supply in terms of quality and availability. By better understanding plant physiology, innovative controlled atmosphere storage systems were developed that have greatly enhanced our access to fresh fruits throughout the year. Similar packaging and shipping innovations have reduced post-harvest waste and expanded value-added, “fresh cut” options for consumers. Science-based advances in chemistry, biology, and toxicology have enabled innovative new methods of crop pest management with far better health and environmental profiles. Rapidly advancing understanding of genetics has enabled a growing and increasingly precise “tool box” for crop innovation (cross breeding, hybridization, wide crosses, mutation breedinggenetic engineeringmarker assisted selectiongenome editing).
The long tradition of food and agricultural innovation continues, enhanced by the application of the scientific method.  So, yes – “science” in that form certainly belongs on our plates.  I'm happy to talk about this in the comments here and/or at 

Tuesday, April 28, 2015

My Comments To The USDA On Agricultural Coexistence

Today I submitted a comment on the official USDA regulatory forum on the question of coexistence in agriculture.  Here is a link for background from a workshop on this topic held in North Carolina this March.  Here is a link of you want to comment (>4500 people have so far and the comment period is open until May 11, 2015).

The point I hoped to make was that coexistence between different kinds of farming is something people have known how to do for a very long time, but it requires a certain level of reasonableness and cooperative spirit.  That is rarely a problem when you are talking about real farmers and if there are rational standards for "adventitious presence."  The issues to do with coexistence today arise from downstream players making unreasonable demands and by those which are not, by their own statements, interested in coexistence.  The USDA seems to be trying hard to make this an open dialog, but there are aspects of this debate that need to be recognized for what they are.

Text Of The Comment I Submitted 4/28/15

While the coexistence of diverse commodity and identity preserved crops is a long-standing, successful feature of American agriculture, some aspects of the current coexistence discussion warrant careful consideration.  Particularly for row crops, the definition of acceptable “adventitious presence” is critical in any identity preservation effort.  That threshold drives the costs of isolation and segregation protocols as well as the level of risk for the producer.  The threshold of adventitious presence should logically be driven by objective issues of functionality in the intended use and/or by levels that are practical in the real world.  That sort of system has long enabled coexistence in farming.

The current problems for co-existence arise in what many participants in the North Carolina workshop described as "sensitive markets."  Principally this means products intended for "non-GMO" and/or organic markets.  Unfortunately, a significant proportion of those markets have been established at the consumer end through fear-based marketing and advocacy.  For these IP segments there is no "reasonable level of adventitious presence," because the categories were never based on any reason-based functionality or safety criterion.  Perhaps "fear-based marketing" sounds like a harsh term, but if you look at examples of promotional campaigns generated by very large, for-profit, organic and non-GMO food companies, it’s hard to come up with a friendlier sounding descriptor:

1. This recent video produced by Organic Only, a consortium of organic marketers including may of the largest ones:

2. Several productions from the large, non-GMO promoting fast food chain, Chipotle:

3. This humorous, but not fair 2005 production from the Organic Trade Association: 

Coexistence requires, by definition, some level of fair play and mutual respect from the parties involved.  The corn and soybean growing neighbors who are trying to make a living in commodity and IP markets may have that sort of working relationship, but the demands coming down to them from "sensitive markets" are often driven by rather successful, fear-for-profit business models.   These downstream drivers are certainly not on the "coexistence" page at all – in fact exactly the opposite.  Some explicitly state that their goal is the elimination of biotech crops via the agency of GMO or non-GMO labeling and its effects on markets.  As is usually the case, the farmers have virtually no leverage in these exchanges.  With this enormous gulf in terms of power and intention, the prospects for rational co-existence are not encouraging.

There are certainly players in the organic and gmo-free segments that could be reasonable participants in a coexistence discussion, but their voices do not represent or apparently influence other important players.  It would be irresponsible to fail to explicitly acknowledge this “elephant in the room.”