Loading...
HomeMy WebLinkAboutCOM 0480.049 2010-2012 Page 1 of 1 Murashige, Laura ru1 PICouwcn. ItECEiWir From: Jennifer Warren [jen.warren8 @gmail.com] " elms B/o a .2111°Tuesday, December 06, 2011 10:34 AM To: counciltestimony @co.hawaii.hi.us County Council Cc: cohmayor @co.hawaii.hi.us; dyagong @co.hawaii.hi.us; dikeda @co.hawaii.hi.us; jyoshimoto @co.hawaii.hi.us; donishi @co.hawaii.hi.us; fblas @co.hawaii.hi.us; bsmart@co.hawaii.hi.us; bford @co.hawaii.hi.us; apilago @co.hawaii.hi.us; phoffman@co.hawaii.hi.us Subject: Written Testimony for Adoption of 2012 HSAC, item: GMO labeling Attachments: Written Testimony for Big Island, Adoption of 2012 HSAC, item--GMO labeling.pdf Dear Council Members, This written testimony is regarding: Meeting Date: December 7 2011 Item: Adoption of 2012 HSAC legislative package, item: labeling of GMOs. My name is Jennifer Warren, and I am a concerned resident of Maui County. The biotech industry and regulatory agencies tend to complicate what is simple to cloud the real issue at hand with GMO's: • The regulatory loop hole used to approve GMO's is not based in science • Compelling early warning signs suggest we have a very sincere reason to believe GMO's are a threat to our health, especially infants, children, the elderly and sick • We have a right to know what's in our food I have attached for your review common industry arguments followed by some research documenting my concerns and my reasons for appealing this matter before you. Thank you for your time and attention to this matter. Sincerely, Jennifer Warren 415.519.0789 jen.warren8 @gmail.com Comm. N `ljr.filev.Y Ref.To: Ref. Date flri 0 7 ?R� 12/6/2011 Dear Councilmember, The biotech industry and regulatory agencies tend to complicate what is simple to cloud the real issue at hand with GMO's: • The regulatory loop hole used to approve GMO's in not based in science • Frightening early warning signs suggest we have a very sincere reason to believe GMO's are a threat to our health, especially infants, children, the elderly and sick. • We have a right to know what's in our food Below I offer to you common industry arguments followed by some research documenting my concerns and my reasons for appealing this matter before you. Kind Regards, Jennifer Warren 415.519.0789 Jen.warren8 @gmail.com Rebuttals to GMO Industry Arguments Argument 1: GMO mutations are "natural" • Have been going on since "time began", i.e. crossing different varieties in the same plant families Rebuttal 1.1: There is nothing natural about it. • Forcing gene families to cross when they never would in nature is not "natural" in the sense of naturally occurring Rebuttal 1.2:Even if GMO mutations were a natural process, "natural"does not make something safe • Hepatitis B is natural, would you like to die from that? • Water is natural, would you like to drown? • Safety or non-safety is not intrinsic to being natural Argument 2: GMOS's are safe for human consumption • They claim GMO's are safe because: "We have seen nothing after over a trillion meals" & "We saw nothing compared to a control group" Rebuttal 2: There has not been enough time or proper control groups to adequately claim this • There are 3 categories of time for effects to be revealed: o Acute, within 2 weeks o Subacute, within 6 months o long term, 6 months plus • It took 20 years to prove that 2nd hand smoke is hazardous to health • To track long term effects requires long term testing which is dependent on having control groups • No long term studies have been created in the lab, and with no labeling, no long term studies can be done in the populace • It is inaccurate to say there has been no effect because there has been no way to track the increase of incidents o Chronic health conditions like diabetes, obesity, and heart disese are on the rise according to the CDS which reports that one in two Americans now have such conditions, and that seven of every 10 deaths in the US can be attributed to them. o According to a 2010 study in the Journal of the American Medical Association (summarized here), the rate of chronic conditions among US children jumped from 12.8 percent in 1994 to 26.6 percent in 2006, with asthma, obesity, and behavior/learning disorders leading the way. (http://motherjones.com/tom- philpott/2011/09/gmos-safe-eat • Also, claiming "we have seen nothing"suggesting perfect health is misleading and inaccurate, because even within a control group no one has perfect health. Argument 3:The method of GMO production is safe • "We haven't seen a problem so far, so there must not be a problem with the genetic modification process." Rebuttal 3:Genetic Modification is the method. Genetic modification as a method produces a wide range of inconsistent results even within the same crop type, and each mutation is its own unique life form. • Each genetically modification within a single crop type is a unique mutation and therefore must be tested on a case by case basis • Suggesting that because problems have not been tracked in one GM crop type, i.e. corn, that it will not be found in another type of GM crop, i.e. alfalfa, is misleading • Every genetic modification even within a single crop type is a unique creation with a unique set of unknown potential hazards Argument 4: GMO's are safe because "we have done animal studies." Rebuttal 4.1: Published industry short term animal studies(90 days or less)suggest safety, but independent studies do not Rebuttal 4.2: Testing for safety is not even possible because the product is not consistent enough to be tested. (see rebuttal 3) Argument 5: "Customers have the freedom of choice to not plant GMO's" Rebuttal 5: Your rights end when they infringe upon my rights. The freedom of choice is not the freedom to contaminate Argument 6: "Co-existence is possible between GMO and non-GMO crops" Rebuttal 6: These crops cannot grow side by side and not have crossover, it is the nature of the system to cross pollinate • In April 2011, a jury in the US has awarded Riceland Foods Inc. US$ 136.8 million after court action over the 2006 contamination of long grain rice stocks in the USA with Bayer's unapproved experimental GM rice LL601, GM Freeze reports. This award follows several others in courts in the USA where the German—based ag-biotech company has repeatedly been found negligent for allowing a GM long grain rice strain, which had not received any safety approvals anywhere,to contaminate supplies,forcing recalls and halting exports for several years.The GM rice had only been grown on experimental plots in the USA between 1998 and 2001,yet its presence was detected in imported rice in at least 24 countries. http://www.organic- market.info/web/News in brief/Genetic Engineering/USA/176/188/0/9897.html • Co-existence is not possible Argument 7: "Regulatory agencies say GMO products are OK" Rebuttal 7.1:Regulatory agencies are in fact saying that there are harmful aspects of GMO's: • Horizontal gene transfer(previously denied) • Development of need for increased use of herbicide known to cause birth defects o The agency's vast environmental impact statement for GMO alfalfa (PDF)—was blunt on two points: 1) "gene flow" between GM and non-GM alfalfa is "probable," and threatens organic dairy producers and other users of non-GMO alfala; and 2) there is strong potential for the creation of Roundup-resistant "superweeds" that require ever-higher doses of Roundup and application of ever-more toxic herbicides.The report noted that 2 million acres of US farmland already harbor Roundup-resistant weeds caused by other Roundup Ready crops. (http://motheriones.com/tom-philpott/2011/07/welcome-age-gmo-industry- self-regulation) o Horizontal gene transfer is the transfer of DNA between two organisms; for example, eating GMO corn and the resistant engineered genes transferring to humans through saliva and the gut o By transferring this DNA,there is a high probability that the engineered aspects of resistance will be transferred to the host, resulting in unintended consequences, such as resistance to antibiotics Argument 8: "We've been doing GMO's for 16 years,and there haven't been any new health developments." Rebuttal 8: There are large trends of increasing disease incidents. • See argument 3 for health statistics Argument 9: "We already have been chemically altering our food with radiation, and there hasn't been a problem." Rebuttal 9.1: Irradiating foods was approved by the FDA based on 7 studies which were subsequently discredited. Additionally: • A compilation of 12 studies carried out in 1984 for the US government examined feeding irradiated chicken to several different animal species.The studies indicated the possibility of chromosome damage, immunotoxicity, greater incidence of kidney disease, and heart attacks. • Studies of rats fed irradiated food also indicate possible kidney and testicular tumors • One landmark study in India found 4 out of 5 children fed irradiated wheat developed polyploidy, a chromosomal abnormality that is a good indication of future cancer development (source: http://www.sustainable-city.org/articles/irradiat.htm) Rebuttal 9.2: Irradiation is a different technology to genetic modification with different potential unintended consequences. • Radiating the food mutates the genome through deleting chromosomal information, whereas GMO's insert genes and markers from completely different species • Examples of why food is radiated include stopping fruit from ripening, food from sprouting such as potatoes, and killing microorganisms • To compare irradiating food to creating a new life form through combining genes from two different species is misleading Argument 10: "GMO's are saving industry through technology." Rebuttal 10: GMO's may save a crop from one particular threat in the short term, but it is highly likely to not work in the long term and makes it very vulnerable to other threats • The beauty and functionality of the immune system is its flexibility. It will turn on a functionality when it is needed, and turn it off if not. • When GMO's are modified to produce a certain response against a specific pathogen, this response is permanently turned on. "Always on" means that the immune system is going in one direction, which makes it difficult if not unable to respond to what needs to happen when other pathogens attack • Pathogens adapt—today's fix may not work tomorrow. Argument 11: "The precautionary principle unnecessarily undermines industry's ability to be competitive." Rebuttal 11: This principle allows policy makers to make discretionary decisions in situations where there is the possibility of harm from taking a particular course or making a certain decision when extensive scientific knowledge on the matter is lacking. The principle implies that there is a social responsibility to protect the public from exposure to harm, when scientific investigation has found a plausible risk. These protections can be relaxed only if further scientific findings emerge that provide sound evidence that no harm will result. • GMO's have been put on the market with little to no testing, with no long term tests of over 90 days and significant reason to believe there are hazards to health, environment, and industry • Putting economic interests over the health of the country is irresponsible both to individual consumers and the economy as a whole • GMO are a classic example of when the precautionary principle should have been used and was not. But we don't have to continue to make the same mistake with further GM varieties. Argument 12: "The FDA has found GMO foods to be substantially equivalent to regular foods. We don't need to label GMO foods because they are no different." Rebuttal 12.1: "Substantial equivalence"was a principle used to streamline the regulatory process. • The concept of substantial equivalence has not been defined by science or agreed on by legislators. How altered a substance must be before it is considered different remains vague, making the concept useful to streamlining approval. But is not a substitute for science. • At the time of their introduction in the early 1990's, government statues did not cover GMO's, nor provide the authority to regulate them. • If the FDA had not chosen "substantial equivalence" as the regulatory principle by which to approve GM Foods, industry would have to have proven their safety. • Alternatively, the FDA could have treated GM foods in the same way as novel chemical compounds, such as pharmaceuticals, pesticides and food additives, which would have required companies to conduct a range of toxicological tests, the evidence from which could be used to set 'acceptable daily intakes' (ADIs). • Conducting toxicological experiments would delay access to the marketplace by at least five years and would have added approximately$25 million per product to R&D costs. Additionally, using ADIs would have restricted the use of GM foods to a marginal role in the diet. If laboratory animals showed no adverse effects on a diet consisting exclusively of a test material, human intake would still be restricted to 1%of the human diet. (Millstone, E. Brunner, E. and Mayer, S. (1999) Beyond 'substantial equivalence'. Nature 401: 525-26) Rebuttal 12.2:Since GMO's are not substantially equivalent to regular foods, labeling should be required as it is required with any processed food or food additive • Even orange juice must be labeled if it is from concentrate • Labeling constitutes informed consent for people to choose if they want to consume GMO's • Internationally, the US claims that regulating GMO foods violates free trade agreements, while the EU's counter-position is that free trade is not truly free without informed consent Evidence to support labeling of GMO's 1. Can't trust the federal government to protect Hawaiians from the health or environmental threats of GMO • Wikileaks revealed that the US is pushing GMO's on other countries—why? Because the revolving door between industry and government has created a situation where the very people who are supposed to be regulating the industries are from the industries themselves. i. Case in point: Michael Taylor,a former Monsanto executive and chief lobbyist, was appointed in 2009 to the FDA as Senior Advisor to the Commissioner. His duties include identifying capacity needs and regulatory priorities and planning implementation of new food safety legislation • The burden of proof for the safety rests with the GMO industry,which is an inherent conflict of interest. i. These two statements from industry are in direct conflict on this topic: "Monsanto should not have to vouchsafe the safety of biotech food. Our interest in selling as much of it as possible.Assuring its safety is the FDA's job."—Phil Angell, Monsanto's former Director of Corporate Communications.; and "Ultimately, it is the food producer who is responsible for assuring safety."—FDA Federal Register,Statement of Policy • Even if the FDA were taking responsibility,they could not perform adequately per their own internal report.The FDA evaluating its scientific mission in 2007,stated that: "the FDA cannot fulfill its mission because its scientific base has eroded and its scientific organizational structure is weak."The FDA has consequently relied on biotech to prove its own safety. • The FDA has declared that GMO foods are essentially the same through the doctrine of substantial equivalence, in which two foods are declared enough alike that they are essentially the same.As a result,they do not require food safety testing.Anyone who claims that the FDA has already tested GMO foods for safety is not aware that GMO foods actually have not been tested by the FDA and not adequately tested by the industry. Meanwhile,GMOs are approved for market. 2. GMO industry science is faulty • The norm for research in the GMO industry is short term, on animals,and with a tendency towards skewing and manipulating data. • For example, in Monsanto's insecticide producing GMO corn, MON863,the company withheld evidence for more than a year from European regulators,finally turning the evidence over a year later on order of a German court.The full study revealed rats fed MON863 had lower kidney weights and elevated white blood cell counts compared to rats fed conventional corn. 3. Unexpected Health Effects of GMO consumption • With the nature of GMO science being so inexact and untested in the long term, unexpected health effects should be considered the norm, not the exception. • In multiple studies involving GMO ingestion,the inability to reproduce--aka sterility--is exhibited, as is a sharp increase in infant mortality. Genes from the GMO product RoundUp Ready Soy have also been known to transfer to bacteria in the mouth and gut of humans. • This is called horizontal gene transfer, and shows the potential for bacteria to take up antibiotic resistant genes. Essentially,we are transferring to ourselves resistance to antibiotics. Bacteria would then become resistant to the antibiotics we use to combat disease and fail to be cured by antibiotics.Other health effects include problems with blood cell, kidney,and liver formation, as exhibited by rats fed Monsanto MON863 corn. 4. Precautionary Principle supports labeling • Definition of: "when an activity raises threats of harm to human health or the environment, precautionary measures should be taken even if some cause-and-effect relationships are not fully established scientifically." • "Today's regulatory system essentially allows anything to be released into nature unless it is proven unsafe by scientific data,which is defined to mean measurable harm. In practice,this means that preventive action is not taken until damage has already been done."—Trust Us! We're experts, p. 125 • Industry will claim it wants to"assess risks with sound science"while the environmentalist will talk about"acting to mitigate potential risks before they appear." • To industry, sound science is their science,the science that supports their point of view 5. Labeling has proven to be the Achilles Heel of the GMO industry By giving the consumer choice,they become aware of GMO's which frequently disrupts biotech sales. • Labeling effectively facilitates consumers having the choice to vote with a highly effective tool—their wallet. • In the EU,consumers demanded labeling of GMO products.As a result, over 16 multinational food corporations, including Pepsi Cola,Coca Cola, Heinz, Mars, Kelloggs, Campbell Foods, Cadbury Schweppes and Kraft/Jacobs/Suchar already make GMO and non-GMO versions of the same products for sale in the EU to meet market demand for their non-GMO products. • Consumers have a right to know what they are consuming, and the GMO industry fights this because when given the choice consumers don't choose their products (see below for stats). • We must support our right to know and choose, protect our health, and not give in to biotech's agenda for our food. Anti-labeling proponents claim it is too expensive to label, but the solution could be a simple as a sticker: • Hawaii could have an import rule for manufacturers to state whether their product is intended to be GMO or GMO free,and whether it has been tested. • Even the smallest producers would not be hindered with use of an additive sticker method,so there is no economic stumbling block for even the smallest mom and pop operation to sell products in Hawaii. • Not only is there a simple solution to labeling, even if there weren't,the potential threat to our health should not be determined based on inconvenience or cost–there is too much at stake. 6. Consumer Choice is a resounding NO! • In polls, an overwhelming majority—over 90%--have held that GM foods should be labeled as genetically modified.As ABC News stated, "Such near-unanimity in public opinion is rare." i. 93% believe GE foods should be labeled (10/10,Thomson Reuters PULSETM Healthcare Survey,"National Survey of Healthcare Consumers: Genetically Engineered Food") ii. 96% believe genetically modified foods should be labeled (6/11, MSNBC) iii. 95%of consumers believe GE foods should be labeled (11/08, Consumers Union, "Food-Labeling Poll: 2008," p. 13) iv. 94% believe genetically modified food should be labeled (9/10,Washington Post) v. 93%of the American public wants the federal government to require mandatory labeling of genetically engineered foods(6/11,ABC News) 7. Stumbling blocks to labeling: • The plantation mentality of Hawaii has sought a solution to failing plantations: i. Exchanging one set of producers—sugar and pineapple—for another, biotech agriculture is not a solution ii. Companies that are testing in Hawaii behave as if it is in Hawaii's best interest to support biotech because biotech creates jobs, but in reality biotech has also lost jobs by contaminating our non-GMO crops which were once highly sought after. iii. The bottom line is that the new plantations, Monsanto et al, do not want products labeled not because it is prohibitively expensive, but because consumers don't choose to risk their health on GM foods;the real economic problem is lack of desire for their product. • "The hope of the industry is that over time the market is so flooded [with GMO's]that there's nothing you can do about it.You just sort of surrender."—Don Westfall, Industry Consultant,Washington DC-based Promar International (link here). i. Accidental contamination of Papaya as a case in point • The main sources of papaya contamination come from two sources. First, there's the cross-pollination of the trees from the wind that carries the seeds. The fruit that's produced by the tree is still non-GMO, but the seeds produced within that fruit are GM contaminated.Second, because people eat papaya and just throw the seeds away,or throw them out into the fields,they can grow in the wild.So people inadvertently spread the seeds of the genetically engineered varieties. • No labeling only benefits the producers, both in terms of profit and plausible deniability. If we do not label it,we cannot track it; if we cannot track it,we cannot prove or disprove it was responsible for food allergies or illnesses.To choose to obstruct the ability of not only individuals but entire societies to evaluate the impact of GMO's on their health is disingenuous at best and life threatening at worst.The people of Hawaii deserve the opportunity to make an informed choice when selecting what foods to eat for their health and safety. 8. Not labeling GMO's harms Hawaiian agriculture i. According to a 2010 article in the Honolulu Star, exports of Hawai'i-grown papaya hit at least a 13-year low in 2009,with exports falling to$5.8 million,an 18%decline from 2008,according to data from Foreign Trade Zone No. 9,which is the hub for Hawai'i's international trade. ii. Sales to Japan,once Hawai'i's largest export market,fell 43 percent to$1.2 million in 2009 from$2.1 million in 2008.That's down from$15.1 million in papaya exports to Japan in 1996,which was two years before genetically modified Rainbow papaya was introduced. iii. While Japan has agreed to begin import of GMO papaya's as early as December of this year,there still remains the hurtle of public acceptance for buying a GM papaya over a non-GMO papaya at a similar price.Japan requires that the GMO papayas be labeled as a genetically modified food. Previously,the Hawaii papaya growers have not had to notify their consumers about the GMO status of their papayas.Why should Japan know if their papaya is GMO and Hawaiians not have access to this information?We are only hurting ourselves,and the long term viability of valuable agricultural crops. 9. Labeling required to trace GMO products in the food chain for creation of new food allergies and aggravation of existing ones • Without labeling,there is no traceability of products in the food chain to track food illnesses or allergies.As new genetic mutations are introduced into the food chain--aka GMO's--it is imperative to have the data to track responses to ensure food safety, especially for those with allergies. • In a 2005 independent lab study, mice fed GM peas showed an immune response,with inflammation of the lungs and increased serum antibody levels.The protein from the natural version of the same gene in beans does not cause these responses. Essentially, an allergy and adverse immune response was created. • Also, an allergen from a food known to be allergenic can be transferred into another food by genetic engineering. For example, a gene from the Brazil nut inserted into soybeans made the soy allergenic to those who normally react to Brazil nuts. • Without labeling,those with known allergies to foods would not have the opportunity to identify the"new" GMO food with the same protein as the food they are allergic to. • One case in point is the link between peanut and soy allergies. GMO soy has been shown to contain a protein 41% identical to peanuts,a known relative to soy. Someone eating GMO soy with a peanut allergy would be risking illness and even death from anaphylaxis reactions without knowing it. Labeling is imperative for their health and safety. i. Emily Yonder Meulen,a 13-year old with a severe peanut allergy—but no known soy allergy—died in 2006 of anaphylactic shock probably triggered by a tiny amount of"hidden"soy in a peanut-free Subway sandwich • Food allergies are on the rise in children,according to the largest study of its kind published this summer. Without labeling, it is impossible to say whether they are allergic to just those foods or to the GMO version of the foods with their demonstrated potential to create allergic reactions outside of the response to the the same non-GMO product. i. "The large, population-based nature of this study shows that pediatric food allergy is a significant and growing problem in our society,"said Ruchi Gupta, MD, MPH,Assistant Professor of Pediatrics at Northwestern University Feinberg School of Medicine and a pediatrician at Children's Memorial Hospital,. "Based on our data, about 1 in every 13 children has a food allergy.What's more, nearly 2 out of every 5 affected children suffer from a severe food-allergy. For these children,accidental ingestion of an allergenic food may lead to difficulty breathing, a sharp drop in blood pressure, and even death. Now that we understand just how far-reaching the problem of food allergy truly is,we can begin taking the necessary steps to keep these children safe." 10. BT toxin is not broken down in the digestive track • A landmark new study out of Canada from the Department of Obstetrics and Gynecology at the University of Sherbrooke Hospital Centre in Quebec,Can. has proven that Bt toxin,which is used in GM corn and other crops, definitively makes its way into the blood supply, contrary to what Big Bio claims--and this toxin was found in the bloodstreams of 93 percent of pregnant women tested. • Published in the journal Reproductive Toxicology,the study explains that Bt toxin enters the body not only through direct consumption of GMOs, but also from consumption of meat, milk and eggs from animals whose feed contains GMOs.Among all women tested, 80 percent of the pregnant group tested positive for Bt toxin in their babies' umbilical cords,and 69 percent of non-pregnant women tested positive for Bt toxin. • The only reason many countries approved GM crops in the first place was because they were told that GM crops were no different than conventional crops.The biotechnology industry has purported for years that the alterations and chemicals used in GM crop cultivation pose no risk whatsoever to human health,and that any GM substances that remain in food are broken down in the digestive system.