(Beyond Pesticides, August 5, 2019) The U.S. Department of Agriculture (USDA) appears to have forgotten the lesson learned 20 years ago when it was forced to ban genetic engineering (GE) in organic regulations. At a July 17 hearing called by the U.S. House Agriculture Subcommittee on Biotechnology, Horticulture, and Research on “Assessing the Effectiveness of the National Organic Program,” Greg Ibach, the USDA’s Under Secretary for Marketing and Regulatory Programs, stated, “There is the opportunity to open the discussion to consider whether it is appropriate for some of these new technologies, including gene editing, to be eligible to be used to enhance organic production.”

In 1997, the U.S. Department of Agriculture (USDA) published a draft rule that would have allowed GE, irradiation, and sewage sludge (the “Big Three”) in organic production, which was met by the second largest number of comments the agency had ever received—well before the days of internet advocacy—overwhelmingly opposing the inclusion of the “Big Three.” The prohibition of gene editing falls under the “excluded methods” provision of the organic regulations. The law prohibits “a variety of methods used to genetically modify organisms or influence their growth and development by means that are not possible under natural conditions or processes, and are not considered compatible with organic production.” (7 CFR 205.2) These prohibited methods include cell fusion, micro- and macro-encapsulation and recombinant DNA technology (including gene deletion, gene doubling, introducing a foreign gene and changing the positions of genes when achieved by recombinant DNA technology).

Ask Members of Congress to Remind USDA that Genetic Engineering Is NOT Acceptable in Organic!

There are many problems with GE, and consumers trust the organic label to provide food free of GE. USDA has long promoted GE, but has avoided pushing it in organic since the run-in with organic producers and consumers over the Big Three. Former Secretary of Agriculture Vilsack, for example, promoted a policy of “coexistence” between GE and organic producers. In this regard, organic producers are joined by others who choose not to grow GE crops because they limit export sales.

Unfortunately, even USDA’s “coexistence” policy threatens the genetic and chemical integrity of organic food. In practice, “coexistence” means that those who develop and use GE technology are not held accountable for the damage they cause. The damage includes that arising from both genetic drift—which can make organic crops unsaleable in the organic marketplace—and chemical drift arising from the increased use of chemicals in GE-chemical intensive cropping systems. Any standard of acceptable use of technology would require control over the consequences. If the technology cannot be controlled, it should not be used.

Organic systems are modeled on natural ecosystems. GE organisms belong in neither:

GE is based on an out-of-date theory of “one gene—one effect” and ignores pleiotropy. Thus, a gene that makes a plant tolerant of glyphosate is assumed not to have other effects that might be important ecologically or nutritionally. Even the effect of herbicide tolerance itself may result in the presence of toxic metabolites of the herbicide in food.

Traditional breeding, like evolution itself, depends on forces acting on the whole organism. Exposure over time to different environments exposes unexpected traits. GE plants are created by manipulation of DNA that may create unanticipated results—results that may not be apparent until, for example, the plant is grown under unforeseen conditions.

Risks associated with GE crops cannot be predicted.

While the GE/chemical industry has created many claims to virtue for GE crops, the net effect of GE-based agriculture has been an expansion in the use of pesticides and subsequent resistance to pesticides—in other words, the pesticide treadmill.

Nearly half of all consumers in the U.S. say they avoid buying GE foods, and the growth of the organic sector—now more than $50 billion per year in sales—offers those consumers the choice they want.

Ask Members of Congress to Remind USDA that Genetic Engineering Is NOT Acceptable in Organic!

Letter to Congress

On July 17, Greg Ibach, the USDA’s Under Secretary for Marketing and Regulatory Programs, stated, “There is the opportunity to open the discussion to consider whether it is appropriate for some of these new technologies, including gene editing, to be eligible to be used to enhance organic production.” I am writing to ask that you let Under Secretary Greg Ibach know his statement is unacceptable and challenges a foundation of organic principles and values.

Evidently, Mr. Ibach has forgotten the reaction 20 years ago, when the USDA published a draft organic rule that would have allowed genetic engineering (GE), irradiation, and sewage sludge (the “Big Three”) in organic production. The suggestion was met by the largest number of comments the agency had ever received, overwhelmingly opposing the inclusion of the “Big Three.”

That is why the final organic regulations include a provision prohibiting “excluded methods,” which are “a variety of methods used to genetically modify organisms or influence their growth and development by means that are not possible under natural conditions or processes, and are not considered compatible with organic production.” (7 CFR 205.2)

There are many problems with GE, and consumers know that they can trust the organic label to provide food free of GE. USDA has long promoted GE, but since the run-in with organic producers and consumers over the Big Three, avoided pushing GE in organic. Former Secretary of Agriculture Tom Vilsack, for example, promoted a policy of “coexistence” between GE and organic producers. In this regard, organic producers are joined by others who choose not to grow GE crops because they limit export sales.

Unfortunately, even USDA’s “coexistence” policy threatens the genetic and chemical integrity of organic food. In practice, “coexistence” means that those who develop and use GE technology are not held accountable for the damage they cause. The damage includes that arising from both genetic drift—which can make organic crops unsaleable in the organic marketplace—and chemical drift arising from the increased use of chemicals in GE-chemical intensive cropping systems. Any standard of acceptable use of technology would require control over the consequences. If the technology cannot be controlled, it should not be used.

Organic systems are modeled on natural ecosystems. GE organisms belong in neither:

GE is based on an out-of-date theory of “one gene–one effect” and ignores pleiotropy. Thus, a gene that makes a plant tolerant of glyphosate is assumed not to have other effects that might be important ecologically or nutritionally. Even the effect of herbicide tolerance itself may result in the presence of toxic metabolites of the herbicide in food.

Traditional breeding, like evolution itself, depends on forces acting on the whole organism. Exposure over time to different environments exposes unexpected traits. GE plants are created by manipulation of DNA that may create unanticipated results—results that may not be apparent until, for example, the plant is grown under unforeseen conditions.

Risks associated with GE crops cannot be predicted.

While the GE/chemical industry has created many claims to virtue for GE crops, the net effect of GE-based agriculture has been an expansion in the use of pesticides and subsequent resistance to pesticides—in other words, the pesticide treadmill.

Nearly half of all consumers in the U.S. say they avoid buying GE foods, and the growth of the organic sector—now more than $50 billion per year in sales—offers those consumers the choice they want.

USDA should abandon efforts to insert GE into organic and instead devote efforts to controlling the technology so that it does not injure organic farmers or the environment.

Thank you for your attention to this issue.