Title: Peggy G. Lemaux
1Food Fights Genetically Engineered Crops and
Foods
Peggy G. Lemaux University of California,
Berkeley http/ucbiotech.org
2What happens to all of the genetic information
from the two parents?
If you wanted to create a new wheat variety
one with better nutritional qualities what
would you do? Cross with an ancient wheat variety?
Ancient variety
Modern bread variety
3Chemical units represented by alphabetic letters
4of wheat
Random retention of information from each parent
5wheat
By reading entire genome, information can be
used for Marker-Assisted Breeding
Genomics
1700 books (or 1.7 million pages)
6Genetic Engineering Technology
equivalent to a gene
7TERMS USED
GMO Genetically Modified Organism GEO
Genetically Engineered Organism LMO
Living Modified Organism rDNA
Recombinant DNA Biotechnology
8Genetic Engineering
Classical Breeding
compared to
9SOURCE NCFAP USDA
10Global Area of Biotech Crops, 1996 to 2007 By
Crop (Million Hectares)
Source Clive James, 2008
11Global Area of Biotech Crops, 1996 to 2007 By
Trait (Million Hectares)
80
70
60
50
40
30
20
10
0
1996
1997
1998
1999
2000
2001
2002
2003
2004
2005
2006
2007
Source Clive James, 2008
12Estimated over 75 of Processed Foods in U.S.
Have GE Ingredients
13Only a few whole foods on the market are
genetically engineered
14WHATS IN THE PIPELINE?
15Arcadia Biosciences develops canola that uses 50
less nitrogen fertilizer
SOURCE http//archives.foodsafety.ksu.edu/agnet/2
007/4-2007/agnet_april_10.htmstory0
16Gene from wild rice species improves weed control
for cultivated rice
2005 IRRI Field Trail - Recovery after 17 d
submergence
SOURCE http//www.mercurynews.com/mld/mercurynews
/news/local/states/california/northern_california/
16115998.htm
17Engineered drought tolerance leads to vigorous
growth of plants after prolonged drought control
plants died
SOURCE Rivero, R.M., Kojima, M., Gepstein, A.,
Sakakibara, H., Mittler, R., Gepstein, S. and
Blumwald, E. 2007. Delayed leaf senescence
induces extreme drought tolerance in a flowering
plant. Proceedings of the National Academy of
Sciences USA 104 19631-19636.
18Salt-tolerant Tomatoes
Engineered
Control
SOURCE Zeraim Gedera L.T.D., Israel
19Plum trees genetically engineered for resistance
to plum pox
SOURCE Information Systems for Biotechnology,
June 2006. APHIS petition (http//www.aphis.usda.g
ov/brs/aphisdocs/04_26401p.pdf ) image courtesy
of http//www.forestryimages.org
20GE Grape Root Stocks Field Tested in Northern
France for Fanleaf Virus Protection
SOURCE USDA Foreign Agricultural Service. 2005.
EU-25 GMO trials on grape wine given go-ahead in
France. Report E35183
21Tear-free onion developed by turning off
tear-inducing enzyme
SOURCE Scientists create 'no tears' onions,
Herald and Weekly Times, 2/1/08 http//www.checkbi
otech.org/green_News_Genetics.aspx?Namegeneticsi
nfoId16834
22Altering transport gene in carrot results in more
bioavailable calcium for humans
SOURCE Morris, J., Hawthorne, K.M., Hotze, T.,
Abrams, S.A. and Hirschi, K.D. 2008. Nutritional
impact of elevated calcium transport activity in
carrots. PNAS 10.1073/pnas.0709005105.
23Introduction of single bacterial gene increases
folate levels in tomato to levels comparable to
spinach
SOURCE Diaz de la Garza, R.I., Jesse F. Gregory
III, J.F. and Hanson, A.D. 2007. Folate
biofortification of tomato fruit. Proceedings of
the National Academy of Sciences USA 104
4218-4222.
24Mitigating food allergies, like peanut, soy and
wheat, through engineering of plants
25Production of HIV vaccine in tomato elicits
immune response in mice
SOURCE HIV vaccine from tomatoes, a long
awaited gift for millions, Checkbiotech,
1/23/08, http//www.checkbiotech.org/green_News_Ge
netics.aspx?infoId16740 Ramírez, Y.J.,
Tasciotti, E., Gutierrez-Ortega, A., Donayre
Torres, A.J., Olivera Flores, M.T., Giacca, M.,
Gómez Lim, M.A. 2007. Fruit-Specific Expression
of the Human Immunodeficiency Virus Type 1 Tat
Gene in Tomato Plants and Its Immunogenic
Potential in Mice. Clinical and Vaccine
Immunology 14 685-692.
26Expression of lectin from Entamoeba histolytica
may lead to vaccine for amoebiasis
SOURCE Chebolu, S. and Daniell, H. 2007. Stable
expression of Gal/GalNAc lectin of Entamoeba
histolytica in transgenic chloroplasts and
immunogenicity in mice towards vaccine
development for amoebiasis. Plant Biotechnology
Journal 5 230-239.
27Oral administration of proinsulin in lettuce
protects against insulitis in diabetic mice
SOURCE Ruhlman, T., Ahangari, R., Devine, A.,
Samsam, M. and Daniell, H. 2007. Expression of
cholera toxin B-proinsulin fusion protein in
lettuce and tobacco chloroplasts - oral
administration protects against development of
insulitis in non-obese diabetic mice. Plant
Biotechnology Journal 5 495-510.
28Scientists create rice with cholera vaccine
SOURCE http//www.guardian.co.uk/science/story/0,
,2100737,00.html Nagai et al. 2007. Role of
Peyer's patches in the induction of Helicobacter
pylori-induced gastritis. Proceedings of the
National Academy of Sciences USA 104 8971-8976.
29U.S. Regulatory Agencies (based oversight on
existing regulations)
USDA
FDA
EPA
- Field testing
- Permits
- Notifications
- Determination of
- non-regulated status
- Pesticidal plants
- tolerance exemption
- registrations
- Herbicide registration
30Safety of engineered food Is it as safe as a
conventional food?
for the introduced genetic material and the
products made from it. These products have to be
tested and analyzed separately. Regulators look
at, for example, specificity and mode of action
of protein, source of protein, its stability
during digestion and processing
SOURCE Safety of Genetically Engineered Foods
Aproaches to Assessing Unintended Health Effects
2004. Natl Acad Press
31Substantial
32Substantial
33FOOD FIGHTS IN CALIFORNIA
34IN CALIFORNIA, IT ALL STARTED IN
MENDOCINO COUNTY
Mendocino County was the first principality in
the U.S. to vote on an ordinance to prohibit
growth and propagation of GE plants and animals
35March 2004 MENDOCINO MEASURE H passed March
200456 For 44 Against
- unlawful for any person, firm, or corporation
to propagate, - cultivate, raise, or grow genetically
modified organisms in - Mendocino County (excluded microorganisms)
- DNA or deoxyribonucleic acid means a complex
protein that is - present in every cell of an organism
- The ban does not pertain to properties within
city limits, or - lands managed by State, Tribal and Federal
agencies.
- At election time, no GE organisms were known to
be in production in Mendocino County. -
36CHARACTERIZATION OF MEASURE H ELECTION RELATED
MATERIALS IN MENDOCINO COUNTY
Giusti et al. (2004) Focus on Genetically
Engineered Crops and Foods - A Case Study from
Mendocino Countys Public Debate.
37ORDINANCE VOTING MOVED TO OTHER COUNTIES
and results differed
38Moratorium on GE crops June 2006 Passed 5-0 Board
of Supervisors
Ordinance makes it unlawful to cultivate
propagate, raise ro grow any GE crop and act in
violation constitutes a public nuisance.
prohibits planting and production of GE crops in
county. County Health Officer is charged with
enforcement.
39Proposed Lake County Ordinance
The proposed ordinance describes a "Genetically
modified crop" as a crop that has been created or
modified through genetic engineering. It does not
include nonliving or non-reproducing organisms or
products. "Genetic engineering" means a
process or technology employed whereby the
hereditary apparatus of a living cell is altered,
modified or changed so that the cell can produce
more or different chemicals or perform
completely unique functions.
Definition of GE taken from Monterey County
Zoning Ordinance (21.64.140) - 1992
40COUNTY ORDINANCES
Countywide Votes
Board of Supervisors Votes
41November 2004, FresnoPassed Board of
Supervisors 5 For 0 Against
- Whereas, biotechnology has the potential to
greatly improve the health, nutrition and
economic vitality of all of humanity1, and - Whereas, biotechnology can make the food we eat
safer2, more nutritious and free from allergens,
and - Whereas, the University of California and the
California State University systems are world
leaders in biotechnology research19 recognizing
that science is the driving force behind
innovation and technology advancement and has
been a key driver for Californias agricultural
success20 and - Whereas, patchwork county-by-county regulation of
biotechnology suppresses important scientific
developments, dismantles Californias leading
research and development infrastructure,
undermines the farmers choice and flexibility to
meet market and environmental demands, and is
unnecessary given the coordinated federal
framework for regulating biotechnology21, and - Therefore, be it resolved that the County of
Fresno affirms that the right for farmers and
ranchers to choose to utilize the widest range of
technologies available to produce a safe,
healthy, abundant and affordable food supply, and
that the safe, federally regulated use of
biotechnology is a promising component of
progressive agricultural production.
But several counties passed pro-GMO Resolutions
County of Fresno affirms the right for farmers
and ranchers to choose to utilize the widest
range of technologies available to produce a
safe, healthy, abundant and affordable food
supply, and that the safe, federally regulated
use of biotechnology is a promising component of
progressive agricultural production.
42Do you see a trend in what type of local laws
were passed?
As of 3/24/08
43SOURCE Capital Press, March 18, 2008
44Pre-emptive Seed Laws passed in 16 states were
enacted to stem the tide of county-based
ordinances
No countyshall adopt or continue in effect any
ordinance, rule, regulation or resolution
regulating the labeling, packaging, sale,
storage, transportation, distribution,
notification of use or use of seeds
4516 such laws were passed six did not pass
SOURCE http//www.environmentalcommons.org/gmo-tr
acker.html
46The push to control when and where GE crops could
be grown moved from cities and counties to
commodity groups, like the CA Rice Commission,
which controls most of the rice planted in the
state. They called for a ban on field testing of
GE rice in the state until safeguards are
acceptable to them (Feb 2007)
SOURCE Capital Press, February 23, 2007.
47Roundup Ready Alfalfa Planting Curtailed
United States District Court For the Northern
District of California IN THE UNITED STATES
DISTRICT COURT FOR THE NORTHERN DISTRICT OF
CALIFORNIA GEERTSON FARMS INC., et al.,
Plaintiffs, v. MIKE JOHANNS, et
al., Defendants. No. C 06-01075 CRB PRELIMINARY
INJUNCTION ORDER
and to a courtroom in San Francisco, where the
judge rescinded deregulation of RR alfalfa. U.S.
farmers can no longer plant RR alfalfa until an
environmental impact study is done to determine
the risk the GE gene might pose in
contaminating organic and conventional alfalfa
and on the development of Roundup resistant weeds
(Feb 2007)
By Memorandum and Order dated February 13, 2007,
the Court concluded that the federal defendants
violated the National Environmental Protection
Act (NEPA) by failing to prepare an
environmental impact statement (EIS) before
deregulating Roundup Ready alfalfa. The Court
granted plaintiffs motion for summary judgment
because of the potential significant
environmental impact of gene transmission
specifically, the acknowledged risk that the
genetically engineered gene will contaminate
organic and conventional alfalfa. The Court also
found that defendants had failed to adequately
consider the deregulation decisions impact on
the development of Roundup resistant weeds... In
any event, to minimize the harm to those growers
who intend to imminently plant Roundup Ready
alfalfa, the Court will preliminarily enjoin all
future planting of Roundup Ready alfalfa
beginning March 30, 2007. Those growers who
intend to plant Roundup Ready alfalfa in the next
three weeks, and have already purchased the seed,
may plant the seed. All growers intending to
plant after March 30, 2007, or who have not yet
purchased the seed, must plant non-genetically
engineered alfalfa.
48California Legislative Bill AB541 Liability for
damages caused by GE plants passed by Assembly
Jan. 2008, awaiting Senate
Bill establishes right of farmers /landowners to
compensation for economic losses due to genetic
contamination of their crops. Protects farmers
from being sued by GE manufacturer if crop is
contaminated by companys product. Prohibits
open-field cultivation of GE food crops used to
produce drugs.
49The EPA regulates GM crops with pesticide
properties, primarily under FIFRA.10 FIFRAs
express preemption provision states that a State
shall not impose any requirements for labeling or
packaging in addition to or different from those
required under FIFRA. 7 U.S.C. 136v(b).
After all of the voting, City, County and State
statues might be illegal due to the fact that
national laws and regulations might pre-empt
local laws.
In recent years, numerous courts have struck
state laws regarding food labeling on either
express or implied preemption grounds.12
Although a full preemption analysis of the many
differing proposed state statutes on GM
technology is beyond the scope of this LEGAL
BACKGROUNDER, many of these statutes, if enacted,
would likely fail on preemption grounds.
Excerpted from Lasker, E. 2005. Federal
Preemption and State Anti-GM Food Laws. Legal
Backgrounder, Vol. 20 No. 60. Washington Legal
Foundation
50What Are Some of the Issues?
51What are some food safety issues?
- No peer-reviewed food safety tests
- Creation of allergens or activation of toxins
- Pharma crops contaminate food supply
- Labeling
- Changes in nutritional content
- Gene flow from food to intestinal bacteria
increase in antibiotic resistance
52What are some food safety issues?
- No peer-reviewed food safety tests
- Creation of allergens or activation of toxins
- Pharma crops contaminate food supply
- Labeling
- Changes in nutritional content
- Gene flow from food to intestinal bacteria
increase in antibiotic resistance
53Difficulties with food safety testing
What to do and how to do it?
It is difficult if not impossible to test food
safety of whole foods and feeds with animal
tests. Despite what non-experts commonly think,
animal tests are not the gold standard.
Compositional analysis and toxicity testing of
individual components is much more sensitive than
whole foods testing.
Nutritional and Safety Testing of Foods and
Feeds Nutritionally Improved through
Biotechnology 2004. Comprehensive Reviews in
Food Science and Food Safety, ILSI
54Example of animal safety test
55Experiments comparing first generation GE crops
with isogenic counterparts
SOURCE Flachowsky, G. 2007. Feeds from
Genetically Engineered Plants - Results and
Future Challenges. ISB News Report, March 2007,
pp. 4-7.
56What are some food safety issues?
- No peer-reviewed food safety tests
- Creation of allergens or activation of toxins
- Pharma crops contaminate food supply
- Labeling
- Changes in nutritional content
- Gene flow from food to intestinal bacteria
increase in antibiotic resistance
57(No Transcript)
58Inadvertent Creation of Allergens and Toxins
Is Toxin Creation Confined to GE Foods?
No naturally occurring toxins happen due to
classical breeding efforts also, e.g., potato
(glycoalkaloids) and celery (psoralens)
59Allergy Creation Confined to GE Foods?
Classically bred foods can cause allergy problems
too Example Kiwi
Long-term Food Safety Studies Should They Be
Done, How and on What Foods?
60Fumonisin Reduction with Bt-maize
- 1989 High levels of fumonisin cause large-scale
outbreaks of lethal lung edema in pigs, brain
tumors in horses - Fumonisin contamination caused by insect
infestation - 20- to 30-fold fumonisin reduction with Bt-maize
SOURCE Hammond, B. et al., (Feb. 2004), Lower
fumonisin mycotoxin levels in the grain of
Bt-corn grown in the United States in 2000-2002,
J. Agric. Food Chem. 52 1390-1397
Modified from Drew L. Kershen University of
Oklahoma
61What are some food safety issues?
- No peer-reviewed food safety tests
- Creation of allergens or activation of toxins
- Pharma crops contaminate food supply
- Labeling
- Changes in nutritional content
- Gene flow from food to intestinal bacteria
increase in antibiotic resistance
62November 14, 2002 Biotech Firm Mishandled Corn
in Iowa By Justin Gillis
The biotechnology company that mishandled
gene-altered corn in Nebraska did the same thing
in Iowa, the government disclosed yesterday.
Fearing that pollen from corn not approved for
human consumption may have spread to nearby
fields of ordinary corn, the U.S. Department of
Agriculture ordered 155 acres of Iowa corn pulled
up in September and incinerated.
Production of pharmaceuticals in edible crops
cause concern
63- Planted soybeans in field previously used for
testing transgenic corn. - APHIS (USDA's Animal and Plant Health Inspection
Service) discovered "volunteer" corn plants
growing among soybeans. Instructed ProdiGene to
remove the corn plants. - Soybeans harvested before all the corn was
removed, mixed with 500,000 bushels of soybeans. - Soybeans destroyed. In late 2002 ProdiGene
ordered to pay 250,000 civil fines,
reimbursement for lost crops, and 1 million
higher regulatory fees.
64USDA tightens rules on Pharm/Industrial Crops
- Crop inspection 7 times 5 in growing season,
- 2 after harvest
- Field isolation distances increased
- Dedicated farm equipment required
- Permits required for industrial crops,
- like pharm crops
65What are some food safety issues?
- No peer-reviewed food safety tests
- Creation of allergens or activation of toxins
- Pharma crops contaminate food supply
- Labeling
- Changes in nutritional content
- Gene flow from food to intestinal bacteria
increase in antibiotic resistance
66Why Doesnt FDA Have a Labeling Policy for GM
Foods?
Actually it does
Foods produced through biotechnology are subject
to same labeling laws as all other foods
and food ingredients
Govt-mandated label information relates to
composition or food attributes not agricultural
or manufacturing practices
No label needed if food essentially equivalent in
safety, composition and nutrition
GM food labeled if 1. Different nutritional
characteristics, 2. Genetic material from known
allergenic source e.g., peanut, egg 3. Elevated
levels of antinutritional or toxic cmpds
67Why not just label?
Putting a label on a whole food is relatively
easy, but
68Processed foods are different. Tomato sauce can
contain 8 or more different varieties each
requires tracking to assure accurate content
information.
69But there are foods that are tracked for consumer
choice like organic and
70Kosher
Should everyone pay a premium price for GE- free
foods?
For which people pay premium prices
71Might another solution be to allow the creation
of a specialty market for GE-free foods for which
people pay a premium price and for which farmers
are paid premium prices to grow them?
72What are some environmental issues?
- Gene flow via pollen flow to generate superweeds
(herbicide tolerance to wild/weedy species) - Transfer of transgenes to non-GMO / organic
crops? - Loss of genetic diversity?
- Property rights (gene patents)?
- Spread of pharmaceutical genes into commercial
crops?
73What are some environmental issues?
- Gene flow via pollen flow to generate superweeds
(herbicide tolerance to wild/weedy species) - Transfer of transgenes to non-GMO / organic
crops? - Loss of genetic diversity?
- Property rights (gene patents)?
- Spread of pharmaceutical genes into commercial
crops?
74Pollen Drift of Corn
SOURCE Ma, B.L. 2005. Frequency of Pollen Drift
in Genetically Engineered Corn. ISB News Report,
February 2005.
75 Pollen Flow Distances for Crop Species of Interest
76Consequences of gene flow from GE crops to
weedy species in field
GM canola
non-GM canola
77Question What Are the Consequences of Gene
Flow? Consider Vitamin A Genes vs. Herbicide
Tolerance Genes from GE Rice to Weedy Red Rice
78Pollen Flow between Herbicide-Tolerant Canola
Cause of Multiple Resistant Canola Variety
crossing
"Triple-resistant canola"
(Two GE traits one mutation)
Hall et al. (2000)
79Consequences of Triple-Resistant Canola and
HT-Wild Hybrids?
- What is the actual risk?
- HT doesn't necessarily translate into
- increase in weediness
- HT gene only helps plant if you spray
- target herbicide
- Eventually cant use specific
- herbicide
- Who stands to lose?
- Herbicide manufacturer
- HT plant developer
- Farmer
canola
80What are some environmental issues?
- Gene flow via pollen flow to generate superweeds
(herbicide tolerance to wild/weedy species) - Transfer of transgenes to organic crops?
- Loss of genetic diversity?
- Property rights (gene patents)?
- Spread of pharmaceutical genes into commercial
crops?
81What Exactly Is Organic Agriculture? It is a
production system that
- Places a priority on health of crops, animals,
- farmers, environment, and consumers
- Doesnt use synthetic pesticides and fertilizers
- Focuses on improving soil fertility through use
- of organic matter and cover crops
- Supports and enhances an abundance of
- beneficial insects
- Must have 3 years with no prohibited material
- and be inspected on an annual basis by a
- USDA accredited certifier to be
certified organic
P. Ronald UC Davis
82US Organic Sales Figures
Total Foods and Organic Foods Consumer Sales and Market Penetration 1997-2005 Total Foods and Organic Foods Consumer Sales and Market Penetration 1997-2005 Total Foods and Organic Foods Consumer Sales and Market Penetration 1997-2005 Total Foods and Organic Foods Consumer Sales and Market Penetration 1997-2005 Total Foods and Organic Foods Consumer Sales and Market Penetration 1997-2005
Organic Food (mil) Organic Food Growth Total Food Sales (mil) Organic Penetration
1997 3,594 n.a. 443,790 0.81
1998 4,286 19.2 454,140 0.94
1999 5,039 17.6 474,790 1.06
2000 6,100 21.0 498,380 1.22
2001 7,360 20.7 521,830 1.41
2002 8,635 17.3 530,612 1.63
2003 10,381 20.2 535.406 1.94
2004 11,902 14.6 544,141 2.19
2005 13,831 16.2 556,791 2.48
3-fold increase in market share since 1997 at a
rate of growth of 15-20/year. This represents
13.8 billion
Source Nutrition Business Journal estimates
based on Organic Trade Associations 2006
marketing survey, annual Nutrition Business
Journal marketing surveys and other sources
(http//www.ota.com/pics/documents/short20overvie
w20MMS.pdf)
83Organic Food Sales in the U.S. by food category,
2005 (Source Organic Trade Association, 2006)
SOURCE Winter, C.K. and Davis, S.F. 2007. Are
organic foods healthier? CSA News 52 2-13.
84CA Organic Production Acreage
In 2001 organic acreage (cropland and
pastureland) was 0.3 of U.S. agricultural
acreage gt2 for some vegetables (most recent
figures ers.usda.gov/publications/aib780a.pdf)
85Organic Agriculture
Can It Coexist with GE Crops? How?
86Capital Press, September 16, 2005
Is this the first time coexistence between
conventional and organic agriculture has been an
issue?
87One of the most divisive issues regarding genetic
engineering is the suggestion that a choice must
be made between EITHER organic agriculture OR
GMOs.
As long as these issues are polarized into all
is permitted or nothing is permitted, rational
social discussion is impossible. Dualism (right
versus wrong) is the enemy of compromise.
- Co-existence
- development of best management practices used to
minimize adventitious presence of unwanted
material and effectively enable different
production systems to co-exist to ensure
sustainability and viability of all production
systems. General concept of co-existence is well
established in California with conventional,
organic and IPM systems working together.
88How might a GE crop be a co-existence issue for
an organic farmer?
89What Genetic Modification Input Methods Are
PERMITTED? ( 205.2 National Organic Program)
- they ...include the use of traditional
breeding, conjugation, fermentation,
hybridization, in vitro fertilization, or tissue
culture.
F.J. Chip Sundstrom CCIA
90And What Genetic Modification Input Methods Are
PROHIBITED? ( 205.2 National Organic Program)
- A variety of methodsare not considered
compatible with organic production. Such methods
include cell fusion, micro- and macro-
encapsulation, recombinant DNA technology
(including gene deletion, gene doubling,
introducing a foreign gene, changing the
positions of genes when achieved by recombinant
DNA technology).
F.J. Chip Sundstrom CCIA
91Are There Tolerances for GE in Organic Products?
From NOP preamble
- Organic Production is a PROCESS certification NOT
a PRODUCT certification it allows for
Adventitious Presence (AP) of certain excluded
methods. - As long as an organic operation has not used
excluded methods and takes reasonable steps to
avoid contact with the products of excluded
methods unintentional presence of products of
excluded methods should not affect status of an
organic product or operation.
F.J. Chip Sundstrom CCIA
92- Pesticides When residue testing detects
prohibited substances at levels that are greater
than 5 of the EPAs tolerance for the specific
pesticide residue detectedthe agricultural
product must not be sold or labeled, or
represented as organically produced.
- GMOs At the present time there are no
specified tolerances for GMOs in organic
products. Organic products are not guaranteed
GMO-free, although some organic farmers sign
contracts guaranteeing GMO-free
93So, will an organic farmer automatically lose his
accreditation if his/her crop is found
contaminated with a GE crop? No. As long as an
organic operation has not used excluded methods
and takes reasonable steps to avoid contact with
the products of excluded methods, as detailed in
their approved organic system plan, the
unintentional presence of the products of
excluded methods should not affect the status of
an organic product or operation.
SOURCE AMS National Organic Program QA
94An organic farmer can lose the ability to sell a
crop as organic if a contract is voluntarily
signed stating the crop is 100 GE- free and
evidence of GE contamination is found. This is
not an NOP organic rule but a private agreement.
SOURCE AMS National Organic Program QA
95Where to get more information on the issues?