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Title: Peggy G. Lemaux


1
Food Fights Genetically Engineered Crops and
Foods
Peggy G. Lemaux University of California,
Berkeley http/ucbiotech.org
2
What 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
3
Chemical units represented by alphabetic letters
4
of wheat
Random retention of information from each parent
5
wheat
By reading entire genome, information can be
used for Marker-Assisted Breeding
Genomics
1700 books (or 1.7 million pages)
6
Genetic Engineering Technology
equivalent to a gene
7
TERMS USED
GMO Genetically Modified Organism GEO
Genetically Engineered Organism LMO
Living Modified Organism rDNA
Recombinant DNA Biotechnology
8
Genetic Engineering
Classical Breeding
compared to
9
SOURCE NCFAP USDA
10
Global Area of Biotech Crops, 1996 to 2007 By
Crop (Million Hectares)
Source Clive James, 2008
11
Global 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
12
Estimated over 75 of Processed Foods in U.S.
Have GE Ingredients
13
Only a few whole foods on the market are
genetically engineered
14
WHATS IN THE PIPELINE?
15
Arcadia Biosciences develops canola that uses 50
less nitrogen fertilizer
SOURCE http//archives.foodsafety.ksu.edu/agnet/2
007/4-2007/agnet_april_10.htmstory0
16
Gene 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
17
Engineered 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.
18
Salt-tolerant Tomatoes
Engineered
Control
SOURCE Zeraim Gedera L.T.D., Israel
19
Plum 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
20
GE 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
21
Tear-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
22
Altering 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.
23
Introduction 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.
24
Mitigating food allergies, like peanut, soy and
wheat, through engineering of plants
25
Production 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.
26
Expression 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.
27
Oral 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.
28
Scientists 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.
29
U.S. Regulatory Agencies (based oversight on
existing regulations)
USDA
FDA
EPA
  • Field testing
  • Permits
  • Notifications
  • Determination of
  • non-regulated status
  • Food safety
  • Feed safety
  • Pesticidal plants
  • tolerance exemption
  • registrations
  • Herbicide registration

30
Safety 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
31
Substantial
32
Substantial
33
FOOD FIGHTS IN CALIFORNIA
34
IN 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
35
March 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.

36
CHARACTERIZATION 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.
37
ORDINANCE VOTING MOVED TO OTHER COUNTIES
and results differed
38
Moratorium 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.
39
Proposed 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
40
COUNTY ORDINANCES
Countywide Votes
Board of Supervisors Votes
41
November 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.
42
Do you see a trend in what type of local laws
were passed?
As of 3/24/08
43
SOURCE Capital Press, March 18, 2008
44
Pre-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
45
16 such laws were passed six did not pass
SOURCE http//www.environmentalcommons.org/gmo-tr
acker.html
46
The 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.
47
Roundup 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.
48
California 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.
49
The 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
50
What Are Some of the Issues?
51
What 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

52
What 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

53
Difficulties 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
54
Example of animal safety test
55
Experiments 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.
56
What 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)
58
Inadvertent 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)
59
Allergy 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?
60
Fumonisin 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
61
What 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

62
November 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.

64
USDA 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

65
What 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

66
Why 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
67
Why not just label?
Putting a label on a whole food is relatively
easy, but
68
Processed foods are different. Tomato sauce can
contain 8 or more different varieties each
requires tracking to assure accurate content
information.
69
But there are foods that are tracked for consumer
choice like organic and
70
Kosher
Should everyone pay a premium price for GE- free
foods?
For which people pay premium prices
71
Might 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?
72
What 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?

73
What 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?

74
Pollen 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
       
 
 
76
Consequences of gene flow from GE crops to
weedy species in field
GM canola
non-GM canola
77
Question What Are the Consequences of Gene
Flow? Consider Vitamin A Genes vs. Herbicide
Tolerance Genes from GE Rice to Weedy Red Rice
78
Pollen Flow between Herbicide-Tolerant Canola
Cause of Multiple Resistant Canola Variety
crossing
"Triple-resistant canola"
(Two GE traits one mutation)
Hall et al. (2000)
79
Consequences 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
80
What 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?

81
What 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
82
US 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)
83
Organic 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.
84
CA 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)
85
Organic Agriculture
Can It Coexist with GE Crops? How?
86
Capital Press, September 16, 2005
Is this the first time coexistence between
conventional and organic agriculture has been an
issue?
87
One 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.

88
How might a GE crop be a co-existence issue for
an organic farmer?
89
What 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
90
And 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
91
Are 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

93
So, 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
94
An 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
95
Where to get more information on the issues?
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