The Pros and Cons of Testing Organics for GMOs
Should organic crops and foods be tested for GMOs? There is debate both for and against testing.

Dag Falck, organic program manager at Nature’s Path, was initially concerned that the use of GMO testing would move organic from a process-based certification to one based on testing end products. But he gradually began to understand the need for testing. In contrast to the impact of pesticide residues on organic crops, which can be detected by the presence of dead or damaged plants, GMO contamination can be difficult to see. “Without testing we cannot ‘see’ the contamination, and are left guessing if our efforts to remain GMO-free are effective or not,” he says.

Mark Lipson, policy program director, Organic Farming Research Foundation, argues against mandatory GMO testing in organic production. “There is no statutory basis for a testing requirement, and the ‘excluded methods’ provision of the NOP regulation does not allow for penalizing a producer in the case of inadvertent contamination.  Producers would, however, be penalized in the marketplace, regardless of how the contamination occurred,” he says.

Kathleen Delate, associate professor-organic crop specialist at Iowa State University, says, “GMO testing is a function of private contracts and not of the National Organic Program, so it would be very difficult to have any testing mandated by the government, let alone have sufficient resources to police the testing.”
However, former National Organic Standards Board chairman Jim Riddle says a GMO threshold in organics, which would require testing, is needed to help organic farmers seek legal remedies for losses suffered due to GMO contamination.

           
           
 


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Keeping GMOs Out of Organic:
Non-GMO Project Builds Critical Mass to Address Growing Threat

By Ken Roseboro


Michael Funk, chairman of the board of United Natural Foods, recently expressed urgency about addressing the threat of genetically modified organisms (GMOs) to organic and natural foods. Speaking at the Natural Products Expo West tradeshow this past March, Funk said, “Time is of the essence. Contamination is happening at a greater rate. If we don’t act now, there won’t be GMO-free food.”

Funk spoke to encourage natural and organic food companies to participate in the Non-GMO Project, an independent, nonprofit initiative to address the GMO threat and verify the non-GMO status of organic and natural foods.

“The Non-GMO Project is the solution to protect the industry. Consumers want non-GMO choices,” said Funk, whose concern about GMOs led him to become president of the board of directors of the Project.

The Non-GMO Project aims to reach a critical mass of manufacturers and ingredient suppliers. Many organic companies are leading this effort.

The Growing Threat of GMOs in U.S. Agriculture
Today, genetically modified crops, particularly corn, soybeans and cotton, dominate agriculture in the United States. In 2008, American farmers planted more than 146 million acres of GM corn, soybeans, cotton and sugar beets. GM varieties accounted for more than 80 percent of corn, 92 percent of soybeans, and 86 percent of cotton. The U.S. produced 50 percent of the world’s GM crops in 2008.

With so much GM crop acreage, the threat of contamination from GM plants to organic and non-GMO crops through seed mixing, cross-pollination and co-mingling in grain handling is real and something that the organic industry must deal with now.

Health and Environmental Risks of Genetic Modification
How much of a threat are GMOs? Enough to lead six European Union member states—Austria, Hungary, France, Greece, Luxembourg, and Germany—to ban production of Monsanto Company’s MON 810 GM corn, the only GM crop approved for production in the rest of Europe.

Germany’s Agricultural Minister Ilse Aigner justified her country’s ban by stating that MON 810 “represents a danger for the environment.”

Recent research studies also indicate health risks from MON 810. A published study by Italy’s National Institute of Research on Food and Nutrition found significant disturbances in the immune systems of mice that had been fed MON 810.

Another study conducted by the Austrian Ministries for Agriculture and Health found that mice fed a hybrid GM corn containing MON 810, produced fewer litters, fewer total offspring and more females with no offspring than mice fed non-GM corn.

“There was a 20 percent decline in offspring (in mice fed GM corn),” said Michael Hansen, senior scientist for food safety at Consumers Union, which publishes Consumer Reports. “There is something going on to have (such negative) reproductive effects.”

More studies showing damage to health and the environment are likely to follow. Meanwhile, very few studies showing the safety of GM food have been conducted.

An Organic Farmer’s Challenge
Frank Morton faces a threat to his livelihood from GM sugar beets, the latest GM crop to be grown commercially in the United States. Morton produces seed for organic chard, table beets, and other vegetables in Oregon’s Willamette Valley, where seed for GM sugar beets is grown.

Pollen from GM beets could easily contaminate his chard and beets, destroying the organic status of the seed and ruining his business. Because of this, Morton must have his seed tested for GMOs at a laboratory.

“I have to pay an additional expense because of a technology that will destroy the value of our crop if we get positive results,” he said.

The contamination threat to Morton’s seed is growing. This past spring GM sugar beet plants were discovered in a soil mix sold to gardeners at a landscaping business just a few miles from Morton’s fields. Because of the threat to his business, Morton joined a lawsuit organized by the Center for Food Safety to sue the USDA for failing to examine the environmental and economic impacts of GM sugar beets. “USDA didn’t consider the impact on all these farms and markets where we sell seeds,” he said. “If there is any GMO contamination, my customers won’t buy the seed. Who is going to pay for that?”

GM sugar beets were planted for the first time in 2008 and accounted for 50 percent of U.S. sugar beet production. GM beets have been processed into sugar and used to sweeten cereals, baked goods, and other conventional food products. Products containing GM beet sugar are now on retail shelves in the United States—with no labels indicating the presence of GM beets.

Many other organic farmers, particularly those in the Midwest where GM corn and soybeans dominate, also face GMO contamination risks.

The National Organic Program (NOP) says farmers can’t lose organic certification due to “adventitious” GMO presence in their crops, but farmers can lose money if grain buyers reject their crops due to contamination.

Limitation of NOP in Addressing GMOs
For processors, these challenges go beyond just the raw ingredients from the field. Jessica Walden, technical specialist at Quality Assurance International, said that GMOs may be an issue with some minor ingredients allowed in the 5 percent of nonorganic materials in processed foods, including processing aids, citric acid, vitamins, flavors and enzymes. “More and more (nonorganic ingredients and processing aids) are being produced with or are derived from materials that could include GMOs,” she said.

Genetic engineering is an excluded method in the NOP, but the NOP does not prescribe ways to avoid GMO contamination in farming or processing or give guidance to organic certifiers on how to determine whether an input or ingredient is derived from GMOs.

“More clarity is needed from the NOP on how far certifiers should go in determining whether or not a material, which may have been produced at some stage in the process with GMO technology, is prohibited for use in organic,” Walden said.

The Non-GMO Project Addresses GMO Threat
The Non-GMO Project has emerged to keep GMOs out of organic and natural foods. At the heart of this nonprofit Project is a standard, developed with input from members of the organic and natural food industries, which defines what “non-GMO” is.

Natural and organic food companies are enrolling products in the Project’s non-GMO verification, a third-party program to verify that products meet the non-GMO standard. The verification program includes customized protocols, such as sampling, testing and audits to minimize and eliminate GMO risks to food products.

Nature’s Path Organic Foods chose to participate in the Non-GMO Project because current organic practices do not prescribe systems to address the GMO threat, says Dag Falck, Nature’s Path organic program manager. “We had to be involved in a more rigorous approach to address GMO contamination.”

Nature’s Path started the Project’s non-GMO verification process in the summer of 2008. The first step was to complete a product information spreadsheet about Nature’s Path products. FoodChain Global Advisors, technical advisor to the non-GMO Project, then provided an analysis of products at risk for GMO threats.

Nature’s Path uploaded data about its ingredients to FoodChain’s online database. Information uploaded included the name of each ingredient, the processing facility where the ingredient is used, and whether the ingredient is low- or high-risk for GMO contamination.

Ingredients derived from corn or soy, the two main GM crops, are considered high-risk. For Nature’s Path, corn, which is used in many of its cereals, represented the highest risk.

GMO Testing
A protocol for GMO testing of ingredients is prescribed based on the contamination risk. However, the Non-GMO Project does not specify a laboratory for testing; verified companies choose whichever lab they prefer.

GMO test methods used include lateral flow “strip” tests that detect the genetically modified protein in a sample and polymerase chain reaction (PCR) method that detects the genetically modified DNA.

Nature’s Path uses a combination of the less expensive strip tests at critical control points along with taking composite samples for laboratory PCR analysis.

Falck emphasized that testing is used to eliminate GMO contamination along the supply chain and not to determine if a final product contains GMOs.

Testing helps companies meet the standard’s “action thresholds,” which are 0.1 percent for seed, 0.5 percent for food, and 0.9 percent for feed. The thresholds are not rejection levels; instead, positive tests above the thresholds trigger action steps to enhance quality assurance.

The aim of the Project is continuous improvement. For example, if a company cannot initially meet the action thresholds, variances of 0.25 percent for seed, 0.9 percent for food, and 0.9 percent for animal feed are allowed.

“This is a doable program,” Falck said. “It is realistic, stringent, and practical in its application. “

Organic certification helps streamline the Non-GMO Project verification. Traceability is one of the core requirements of the Non-GMO Project verification. Companies such as Nature’s Path, whose products are all certified organic, have already established traceability with organic record-keeping. “We can just copy the audit trail for organic certification and use it in the non-GMO verification,” Falck said. In addition, organic inspections can be conducted at the same time as non-GMO inspections to increase efficiency and decrease cost.

“A lot of the foundation work (for non-GMO verification) is already done by organic practices,” said Michael Potter, president of Eden Foods, another Non-GMO Project participant.

Unlike organic certification, which is mandatory for companies wanting to label their products “organic,” the Non-GMO Project is a voluntary verification.

Creating a Non-GMO Supply Chain
Getting ingredient suppliers involved in the non-GMO verification is critical. “If suppliers don’t work with you, you can’t get the job done,” Potter said.
Ingredient suppliers to Nature’s Path can either enroll their own products in the non-GMO verification or supply Nature’s Path with GMO test results for their ingredients.

In the case of highly processed ingredients such as lecithin or oils where the genetically modified DNA is no longer present, Nature’s Path requires that suppliers provide GMO test results on raw materials, such as soybeans, used to make the ingredient.

Potter said that the more suppliers who participate in the Non-GMO Project, the easier it will be for everyone in the industry to verify that their products are non-GMO. For example, once a source of seed or an ingredient is verified non-GMO for one processor, other processors would be able to access the same source.

“In the long-term, we hope the Non-GMO Project becomes as popular as organic and that more farmers, suppliers and processors participate,” Falck said. “Success comes through the participation of everyone.”

Megan Thompson, executive director of the Non-GMO Project, said the Project is multi-faceted, working at all levels of food production, from helping create an independent supply of non-GMO seed to providing consumers with non-GMO products.

Nature’s Path is putting 65 products through non-GMO verification and aims to complete the process by this October. The verification lasts for one year and is renewed every year following successful completion of annual audits.
Once verified, companies can put the Non-GMO Project Verified seal on their products. Falck says Nature’s Path may be one of the first companies to use the seal.

As more companies participate, the Non-GMO Project continues to improve its processes. Another Non-GMO Project participant, tortilla chip manufacturer R.W. Garcia, developed a quality manual for its suppliers and employees that the Project is using as a template to give to other participants. “The first companies going through non-GMO verification are helping us refine our processes to make sure they are accessible to everyone,” Thompson says.

Since its inception, the Non-GMO Project has encouraged industry input and participation to make it accessible to all companies facing GMO challenges. “The GMO issue can be intimidating,” Thompson says. “We are offering resources that support companies in handling it solidly and consistently so that they are protected from the liability of contamination.”

“Critical Mass”
What’s the bottom line to participating in the Non-GMO Project? Fees are based on the number of products and processing facilities a company has and whether products and ingredients are low- or high-risk for GMOs. There is a volume discount for larger companies with many products and a reduced fee for smaller companies. “A lot has been done to make it affordable for companies to participate,” Thompson said.

The aim, she stressed, is to build “critical mass” by getting as many natural and organic food manufacturers to participate as possible.

“The sooner everyone gets on board, the easier it will be for the industry,” said Michael Funk.

To date, more than 350 products are enrolled in the non-GMO verification process. Besides Nature’s Path and Eden Foods, other participating companies include Whole Foods Market, which enrolled its “365” and other private label products; Blue Marble Brands, which includes Mediterranean Organic, Moosewood, Old Wessex, Ltd., Organic Baby, and Organic Classics; Lundberg Family Farms; R.W. Garcia; San-J International; SK Foods International and WholeSoy & Co. Thompson expects the number of participating companies to increase significantly this year.

Thompson is also working with natural food retailers to help educate consumers once the Non-GMO Project Verified seal starts appearing on products this fall.

“We are working with our retailer partners to put together supporting retailer packages, shopping guides, and other in-store educational materials to promote awareness of the GMO issue and the Project,” Thompson says.
Industry members have questioned the need for another label that could confuse consumers, a legitimate concern, says Falck. “It’s a complex issue, but if we don’t do anything, one day we could find out that we are contaminated to an unacceptable level. Consumers would be disappointed, and the damage from this would be much greater than having some confusion today.”

Potter sees the Non-GMO Project as a necessity. “Given the massive release of GMOs, it has to be done. To serve our customer base, we have to do it.”
“We want our industry to become a GMO-free region,” Funk says. “Consumers are counting on us to offer safe and healthy food.”

Ken Roseboro is editor and publisher of The Organic & Non-GMO Report, a monthly publication focusing on the GM food issue and markets for non-GMO products, and The Non-GMO Sourcebook, an annual directory of suppliers of non-GMO and organic products. He can be reached at ken@non-gmoreport.com.