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Response to “The Non-GMO Project: Resisting GE or Constructing Defeat?” (Discussion Paper from The Organic Agriculture Protection Fund of the Saskatchewan Organic Directorate)
January 28, 2011
By Megan Westgate, Non-GMO Project Executive Director
It is inspiring to see the growing passion being focused on the problem of GMO contamination; it is a massive challenge, and widespread collaboration is a prerequisite for positive progress. The recent discussion paper put forth by The Organic Agriculture Protection Fund (OAPF) raises important questions and creates a valuable opportunity for dialogue. By way of preface, I would like to emphasize that the Non-GMO Project wholeheartedly shares the Saskatchewan Organic Directorate’s concerns about GMO contamination. Although the Project is obviously committed to providing consumers with informed choices, another primary objective (as evidenced by our mission statement, below), is to control contamination and make sure that non-GMO crops, ingredients and food are available into the future. Our strategy is to leverage the power of the marketplace toward that end.
The Non-GMO Project is a non-profit multi-stakeholder collaboration committed to preserving and building sources of non-GMO products, educating consumers, and providing verified non-GMO choices.
From the beginning, the Project has been committed to eliminating GMOs. As the discussion paper accurately notes, absence of GMOs remains a stated target for the Project. In fact, the Non-GMO Project Standard explicitly states that “Absence of all GMOs is the target for all Non-GMO Project Standard compliant products” (section 2.6). Where the discussion paper is misguided is in suggesting that the Non-GMO Project’s current thresholds represent a “radical shift.” The unavoidable scientific fact, unfortunate though it may be, is that as long as there are GMOs grown in open fields, contamination is inevitable. Because GMOs were commercially cultivated for over a decade before the Non-GMO Project was created to control them, and because of their growing prevalence, the risk of contamination to both conventional and organic crops is consistent and serious. From the beginning, it was the intention of the Project to address this contamination risk in a pragmatic and rigorous way, using appropriate thresholds.
It is critical to understand that the ONLY way to identify (and control) GMO contamination is through testing. The organic standards do not require testing; the Non-GMO Project Standard does.
It is worth noting that over half of the companies participating in the Non-GMO Project produce certified organic products. These companies have chosen Non-GMO Project Verification in addition to their organic certification because they are committed to keeping their products non-GMO, and are concerned that organic certification is not adequate. Many organic companies joined the Project after their internal GMO testing indicated a growing risk of contamination.
While the Non-GMO Project sets a goal of zero GMO presence, it also requires that continuous improvement practices toward achieving this goal be part of the Participant’s quality management systems. This is where the thresholds come in. The thresholds, like all aspects of the Non-GMO Project Standard, were arrived at through the Project’s ongoing twice-yearly public comment periods. The transparent, consensus-based nature of the Project Standard’s development process is fundamental to the organization’s approach, which values participation from all stakeholders. Accusations that the thresholds are a result of “pressure from industry” are unfounded.
The thresholds were agreed upon through a transparent, public process after considering all available data on current contamination levels in the “non-GMO” (conventional and organic) food supply in North America.
The thresholds were also designed to allow some consistency with the European Union, where products containing more than 0.9% GMO must be labeled as GMO (and by extension, products below 0.9% GMO are considered non-GMO).
The criticism of the Project’s thresholds expressed in the discussion paper belies a lack of information about the current contamination risks faced by the organic sector. It assumes that the lack of thresholds in organic standards is a “zero tolerance” policy, while in fact the opposite could also be said: without thresholds, there is no limit to contamination. By setting thresholds and requiring testing, the Non-GMO Project establishes much greater rigor with regard to GMO control than do the organic standards. It is critical to understand that even for certified organic companies, the Non-GMO Project’s current thresholds are rigorous and challenging because of the GMO contamination levels commonly seen in North America at this time.
LOW-RISK VERSUS NO-RISK
The discussion paper takes the position that “low risk products are essentially ‘no-risk,’” but unfortunately this is not the case. As the Non-GMO Project Standard states, “biotechnologists are engaged in laboratory experimentation with most species” (section 2.4.2.). For this reason, the only truly non-risk materials are ones that are not derived from biological organisms. A perfect example of this fact is the recent flax contamination. Genetically modified flax has never been in commercial production, and therefore by the discussion paper’s rationale would be a “no-risk” crop. Yet widespread contamination did occur just last year, and when it did the Project was able to immediately identify enrolled products using flax and implement testing to verify their non-GMO status. A similar incident occurred with rice in 2003, and it would be naïve to think that more such contamination events will not occur in the future.
There are two other reasons why verification of low-risk products is essential. First of all, as the discussion paper notes, consumer misinformation about GMOs is “staggering.” It is emphatically not the case, though, that consumers will be “more confused” by labeling low-risk products. An example to prove this point:
Consider a shopper standing in the cereal aisle comparing a box of corn flakes with a box of raisin bran and trying to decide between the two. Imagine that the box of corn flakes has the Non-GMO Project Verified logo on it, but that the raisin bran, because it does not have high-risk ingredients, does not. The shopper assumes the raisin bran, bearing no non-GMO assurance, must be GMO, and puts it back on the shelf.
This scenario presents substantially more confusion that one in which the shopper can see the verification mark on both products, trusts them both, and can then go online to the URL displayed on the seal (nongmoproject.org) and easily see which ingredients are at risk, what the seal means, and much more about the GMO issue. The bottom line is that consumers (and oftentimes manufacturers, for that matter) have no idea of which products are at risk of being genetically modified. The Project maintains that the best way to educate the public is by putting information in front of them in as many places as possible; having the Project URL right on the food they’re buying is a powerful strategy for raising awareness, and should not be limited.
The other key reason for labeling low-risk products is that it is easier to stop GMO contamination before it happens than to clean up after it. By building a widespread and comprehensive alliance of producers committed to non-GMO, the Project is creating preemptive resistance to the spread of GMOs in two ways: 1) Companies aligned with the Non-GMO Project will be better informed and more incentivized to do everything in their power to stop new GMO crops as they are introduced, 2) If new GMO crops are introduced, an established network of Non-GMO Project producers using ingredients derived from those crops will be demanding testing and contamination controls from the beginning, helping to ensure that non-GMO sources are maintained.
A final note on this subject: wheat is looming large, threatening to be the next GMO crop, and the vast majority of consumers and companies the Project communicates with have the confused perception that wheat is already GMO. In that context, the value of labeling low-risk products (including those with wheat ingredients), and of organizing low-risk companies (including those that use wheat) is clear. The Project’s commitment to maintaining the continued availability of non-GMO crops, ingredients and products dictates that we cannot wait until things are contaminated to take action. We must be preemptive by working now with producers of both high-risk and low-risk products.
It is absolutely true that the Project values Participants’ confidentiality, and does not share verification data except in aggregate form. No reasonable company would participate in the program without this very basic privacy protection. If OAPF believes that organic certifiers need to see GMO test results for the companies they certify, the obvious solution is for the organic standards to require testing.
The Project’s symbol, the monarch butterfly on a blade of grass, evokes the story that first brought the GMO issue to mainstream consciousness: In 1999, genetically modified corn pollen was implicated in massive monarch die-off. The check mark also echoes a “V” for “verified.” While the discussion paper criticizes the implied environmental-friendliness of the logo’s imagery, it seems a stretch to suggest that certified organic is the only organization with rights to use images from nature in its branding.
IMPACT ON CERTIFIED ORGANIC
Though the discussion paper takes issue with the Project’s “decision to accept trace contamination,” the fact is that by the time the Project was founded in 2007, trace contamination was a persistent fact in North American corn, soy and cotton supplies.
Because no certification system set thresholds or required testing during the first 10 years of GMO proliferation, by the time the Non-GMO Project was started, trace contamination was a reality to be dealt with rather than a decision to make.
This is actually the very reason the Project was created; it was becoming obvious that the contamination problem, even for certified organic products, was getting steadily worse, and that without a new system we would lose our ability to produce certain non-GMO crops in North America. As the discussion paper states, it is true that the Project reflects a “lack of confidence in the organic protocol.” That lack of confidence is felt by the dozens of organic companies who are both certified organic and enrolled in the Non-GMO Project.
THE NON-GMO PROJECT LABEL AS AN EFFECTIVE CONSUMER PROTECTION STRATEGY
The discussion paper concludes with that statement that “upon close examination, the Non-GMO Project label seems to fail as a consumer protection strategy.” I would like to conclude this response by saying that upon even closer examination, in light of the significant corrections and clarifications offered herein, the Non-GMO Project label not only succeeds as an effective consumer protection strategy, but is the single most pragmatic and effective tool in North America for stopping the unchecked flow of GMOs into natural and, yes, organic, products.