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Written Testimony to the Record

United States Department of Agriculture,

Agricultural Marketing Services   August 25, 2017
National Bioengineered Food Disclosure Standard

Proposed Rule Questions Under Consideration

Brian Clement, Ph.D., L.N. and Rudhi Leonardi
Hippocrates Health Institute On behalf of   The POP Campaign


The Agricultural Marketing Services (AMS) has been charged to develop a national mandatory system of rules to ensure open and transparent labeling of GMO foods. On July 29, 2016, Congress passed the National GMO Bill 764. This bill requires disclosure if food products contain bioengineered (GMO or GE) materials. The bill stated included three different options of disclosure: digital disclosure such as QR codes, URLs, and 800 numbers, words/text of the package, or symbol on the package. Congress gave the USDA two years to implement the law.


In response to this mandate, the Hippocrates Health Institute (HHI) and the POP Campaign (POP) are submitting this document on behalf of its constituents and clients. More than 50 years ago, the Hippocrates Health Institute was founded by Ann Wigmore, a humanitarian and health visionary. She advanced a simple concept first voiced by the father of modern medicine – Hippocrates – who nearly 2,500 years ago taught: “Let food be thy medicine and medicine be thy food.”


As someone who from personal and professional experience has seen the difference eating a healthy plant based diet can make in health and vitality, I am very concerned that the United States continues falling behind in health status, in part because of lifestyle decisions, in particular around food choices. A study recently published by the Commonwealth Fund reiterated what has been previously reported, that the United States spends more than any other high-income country on health care, 2-3 times the GDP (over $9,000 per person) but has poorer health outcomes and shorter life expectancy than our international counterparts. ([1] ) The study also found that 68 percent of American seniors are living with two or more chronic health conditions. (2)


The health, vitality and freedom for all of us to make informed food choices is at the root promoting improved health status in our country as a majority of chronic health conditions are related to diet and lifestyle. The regulations regarding any disclosure on food standards must be clear, comprehensive, and transparent to support the citizenry of this wonderful country. Especially, these must be in complete support of the consumer’s best interest and at the core of safe families and children for our future health. This is an obligation on the part of parents for their families and an equal obligation on the Department of Agriculture and Congress to support transparency in labeling.


We still presume and stand by past comments made to the Senate where it was stated that the research on the safety of GMOs still is far from settled and that hundreds of scientists from around the world agree that there is a risk to consumers. Therefore, it is our primary position that clear transparent labels are absolutely necessary and that every provider of food in this country provide consumers truth and clarity on the quality of that food and what is in it – the driving principle of the POP Campaign being “Quality Food is a Human Right.” Certainly Genetically Engineered foods and ingredients do not fit into this equation. As it is recommended below that small businesses and institutions also comply, adequate governmental support is needed and would be required and provided to cover all certification costs. Please see the responses below to the 30 questions proposed.
  1. What terms should AMS consider interchangeable with ‘bioengineering’? (Sec. 291(1)) Context:  The disclosure standard would be a mechanism to inform consumers about their food.  AMS is considering the advantages and disadvantages of allowing the use of other terms to provide for disclosure.
The market continues to be very creative in its ability to scoot around any definition that is placed on a label. Honest refinements of definitions are constantly challenged and often get stalled in the court system to refine points of law and regulations. We continue to seek clarity and simplicity in labeling to prevent such quagmires and advocate transparency at all levels.


We propose a radical yet simple approach for true labeling. As a rule, it is recommended that any “terms” used now and in the future that are different from the purest definitions of food used 50 years ago that described crops and food, be the guidepost. This “50 year” marker would ensure transparency and a simple and clear policy directive.


In essence, any term would be labeled that is different from describing food of that era before the chemistry revolution took hold and exploded with such mantras DuPont used: “Better Living Through Chemistry”, which changed in 1999 to “The Miracles of Science”. Within this context, any reference or technology within “modern biotechnology” or “genetic modification” or “bioengineering” or CRISPR/Cas9 et cetera would be subject to clear labeling.


Any current or future refined definitions would state that Bioengineering is interchangeable with any in vitro or mediated gene or clustering of genes in any bacteria or DNA fragments that might be within the scope of any modification including the CRISPR/Cas9 mediated system. This includes any edited gene out of a plant or living species or any insertion of synthetic fragments or gene of any other type. Any new name or current name under which and where any future scientific advances purport to improve plant and/or growing strategies exist, would be included in the transparent labeling process. Any targeted modification editing or in-frame deletions or insertions to a species that are presumed to affect pathways of the bio-species would have to be considered “bioengineered” and therefore labeled.


Also included are any “next generation” biosynthetic or bio-compatible expressions or “advancements” that will emerge that we today are not aware of which in some way mediate the current “organic” strains of the plants and animals we have now. Such a policy would include cloning of any type orchestrated through mediated recombining of genes. There also should be included any strategies that seek to alter the DNA of any food source through the manipulation of its gene reorganization or reconstruction.


Crucial to this labeling requirement, also, is the growing process. Of special concern, for example, is a process wherein the beginning is a fermentation base starter wherein a new growth begins with one type of a modified organism, and then, it is modified or mitigated by a second generation of a plant or animal species not modified, usually growing on top of it or using it as a starter. A clear label is still a must. An example is where current algae is GE modified and grown as a base (like soil or a mold) which serves in essence as a host to another organism or seed of a plant or animal. In essence, the line of this life cycle is not complementary to the purity of the plant or animal species. Therefore, clearly it is recommended that any foods involved in such a process be subject to GMO labeling. Again, a 1950s marker would draw lines clearly.


Recombining of any fragments or sequencing of DNA of a plant or animal in any gradient form to ensure enhanced strength, gene resistance, or complementary compatibility with any environmental factor still would be considered a form of re-sequencing and under a blueprint of another species than what nature intended. Therefore, it would require labeling. The backbone of this label is the exposure of truth and the trust of the consumer.


Although we are a plant-based community, all of these comments apply to animal or species bioengineering when used at any level for human consumption. This would pertain to next generation species, such as GE salmon, that have evolved and/or interbreed with “natural” salmon.


Lastly, any new or interchangeable terms to describe new recombinant of food gene creation or recombinant generation advancements through engineered or manufacturing principles are to be clearly labeled GMO. Beyond conventional breeding, this would include use of artificial tissues or organs where animal genes have been modified or used to replace an original gene or used in food production and the use of 3-D printing of genes or seeds or any replication of the natural process of a food product. Included would be any bioengineered “bio-sack” or “protective” shield to encapsulate an animal organ or meat section while in the animal to make it “super enhanced” or more compatible with our human digestion or consumption. It is key to note that animals fed with any such products would also be subject to the GMO labeling process.
  1. Which breeding techniques should AMS consider conventional breeding? (Sec. 291(1)(B))     Context: AMS is considering what would be defined as modifications that could otherwise be obtained through conventional breeding because these modifications would be exempt from mandatory disclosure.
It is acknowledged that there is a modern day chess game of definitions that are played out by various boards and protocols around the globe. The slicing and dicing of definitions explode into a salad mix of classification refinement driven by industry needs and consumer demand. There are conflicting regulations to ensure trade, the Cartagena Protocol, Codex Alimentarius, FDA, USDA, NOSB, NOP, etc.


Therefore, to simplify this for consumers, again, it is safest to revert back to a “date in time” where techniques used in farming and crop growth occurred prior to the 1950s in the United States and worldwide. There is no major “roll-over” definition here triggered by pesticides that were used at that time and no “loop hole” for wiggle room around labeling.


Notwithstanding any “mutagenesis” or “buzz word” description (3) pertaining to gene alteration through nature where selective breeding techniques were intentionally and naturally used or a particular “loci” in nature happened, this time period had limited evidence of mutations and purposeful manipulation of crops. Although there clearly may have been experiments, it appears that it wasn’t until the 1960’s where “experiments showed that there were growth expressions although no colony formations, subsequently, although DNA synthesis transfers occurred, the continuation was not significant with often cell divisions ceasing and pronounced fulmination observed….there was very little and basic progress made at that time, which, although was useful did not translate into any significant gains and impact on the food supply.
 3. Mutagenic DNA repair in Escherichia coli – https://link.springer.com/article/10.1007%2FBF00277304?LI=true )
Using this measure precludes the politics and refining of definitions that have emerged since. Applying this 1950’s point in time bypasses using “harmonization” arguments and precedes setting plant breeding and gene altering protocols. Labeling becomes clear and not subject to the influence of industry and biotech at the expense of consumer free choice and health.
  1. Which modifications should AMS consider to be found in nature? (Sec. 291(1)(B)) Context:  AMS is considering what would be defined as modifications that could otherwise be found in nature because these modifications would be exempt from mandatory disclosure.
There is an excellent and complex response to this question, most clearly presented in the Consumers Union statement below, which we agree with.


In reference to the above standard, “found in nature” can be defined and interpreted in so many ways, in particular considering any “scientific method” and subsequent dialectic. Therefore, again, a simpler focus might be considered as a defining marker – for example, a date in time of 11/16/1950. Any technological advances pertaining to food development beyond this date shall be considered “not” found in nature. Policy must maintain a sensible base where changes with the times are woven clearly into it but not surreptitiously replaced.


Noting the comments in #2 above, any food source with gene manipulation or sequencing involving any genetic reconstruction, silencing or rehabilitation not found in nature in 1950 would be labeled. This includes genetic construction such as GE salmon, gene silencing in CRISPR, such as apples, mushrooms and potatoes and gene resequencing as found in gene editing, TALENs mega nucleases, zinc finger nuclease manipulations, RNAI pesticides, etc.


Provided there is no interest in such a radically simple approach as stated above, there is an excellent and complex response to this question, most clearly presented in the Consumers Union statement below.


“In trying to determine which “modifications” AMS should consider to be “found in nature,” AMS should not define these terms broadly.  If the term “found in nature” is taken literally, that could mean that only synthetic traits that do not occur anywhere in nature would make a food “bioengineered.”  Such a definition would exclude virtually all-present GMO crops.  At present, the overwhelming majority of the acreage in GE crops in the US (over 99%) contains the trait(s) for herbicide tolerance and/or pest resistance.  The main herbicide tolerance trait is for tolerance to glyphosate (although some crops are engineered to be resistant to glufosinate, 2,4-D or dicamba), while the main insect resistant trait is to produce one or more delta-endotoxins, called Cry proteins, from the soil bacterium Bacillus thuringiensis, often referred to as Bt crops.  Virtually all the glyphosate tolerant crops (e.g., corn, soy, canola, sugar beets, cotton, alfalfa) contain a glyphosate tolerance gene derived from Agrobacterium sp. strain CP4 which is found in nature.  The bulk of the Bt crops use a Bt gene, e.g., such as Cry1Ab, Cry1Ac, Cry3Bb, Cry1F, etc. which is also found in nature.  Thus, one could argue that virtually all the herbicide tolerant and insect resistant traits are “found in nature,” just not found in the plant species to which they have been inserted, and so could end up not being included in the disclosure requirements.  In addition, virtually all the genetic material that has been inserted into GE plants as part of the genetic engineering process, such as the CaMv 35s promoter (from the cauliflower mosaic virus), the Ti plasmid (from Agrobacterium tumefaciens), as well as all the various antibiotic resistant marker genes, can be “found in nature,” just not in the plant species that have been engineered.  Even the one GE animal approved by the FDA, the GE Atlantic salmon (aka AquAdvantage salmon [AAS]), would not be considered as “bioengineered,” using the broad definition of “modifications … found in nature.”  The AAS contains a growth hormone gene from Chinook salmon, while the promoter gene came from the Ocean pout.  Both these genes are “found in nature;” just not in Atlantic salmon.


So, to define “modifications … found in nature” in a broad fashion would be misleading and would clearly contrary to the intent of Congress since it would mean that the overwhelming majority of GE crops on the market would be considered to have “modifications … found in nature,” and none of the products derived from them would be required to be disclosed.


In implementing this law, AMS should therefore define “modifications … found in nature” in a narrow fashion.   Organisms that are produced through human intervention in a laboratory via “bioengineering” (i.e. “modern biotechnology) should not be considered to be “modifications … found in nature,” and should not be exempt from being disclosed under P.L. 114-216.


“Modification” should be the exact genetic construct; exact constructs are not found in nature.Rather than taking a broad approach, we urge AMS to interpret “modification” more narrowly to mean the exact genetic construct (e.g., the same nucleotide base sequence for the full construct) that has been inserted into the organism (plant, animal or microorganism).  Defining “modification” in this specific fashion ensures that all products of organisms produced using “bioengineering” (aka “modern biotechnology”) would fall under the disclosure requirements—consistent with the intent of the law.


We note that the vast majority of the traits/genes engineered into GE plants come from bacterial or viral sources (e.g., the glyphosate, glufosinate, 2,4-D and dicamba tolerance genes from various bacterial species, the CaMV 35S promoter from cauliflower mosaic virus, use of the Ti plasmid from Agrobacterium tumafasciens, the numerous antibiotic resistance genes from various bacteria) have to be “codon-optimized” so that they work in a plant genome.  What this means is that rather than inserting the exact glyphosate tolerance gene as found in Agrobacterium sp. strain CP4 into a plant, one modifies the nucleotide base sequence of the gene from Agrobacterium sp. strain CP4 so that it will “work” more efficiently when put into a plant, e.g., the enzyme produced by the gene will be produced in enough quantity in the plant to have the desired effect (resistance to glyphosate).  Usually, this entails changing roughly 20% of the nucleotide bases in a gene from a bacterial source to get it to be efficiently produced in a plant background.  In a sense, a plant can tell when foreign genetic material—say from an invading bacteria or virus—comes in because it does not have the same characteristics at the nucleotide base level as plant genetic material.  So, the fact that genes from bacteria or viral sources have to be changed at the nucleotide base level, even though the amino acid sequence of the gene product may be the same whether the gene is expressed in a bacteria or a plant, means that the “modification,” e.g., the exact genetic construct does not occur in nature.


The phenomenon of codon optimization also occurs with gene-editingtechniques.  The CRISPR/Cas9 system is considered to be the best system for gene editing.  The CRISPR/Cas system is based on a prokaryotic immune system, whereby bacteria can detect and destroy “foreign” genetic elements.  The CRISPR/Cas system has two basic elements—a molecular scissors (a protein that cuts genetic material, e.g., DNA, RNA), and guide element (a short piece of RNA) to tell the molecular scissors where to cut.  The molecular scissors is the Cas (CRISPR associated system) element, while the guide RNA (gRNA) is the CRISPR (clustered regularly interspaced short palindromic repeats) element.  The Cas element and the gRNA combine to form a complex (aka Cas nuclease complex) which will then lead to DNA being cut at a specific location (as determined by the gRNA).  When plants are transformed using CRISPR/Cas, the gene to produce the Cas element (usually Cas9) and the gene(s) to produce the gRNA(s) are inserted into a plant, often along with a marker gene, such as antibiotic resistance gene, to help in the detection of the plant cells that have been transformed (e.g., taken up the Cas9 gene and gRNA genes and expressed).  In this example, both the Cas gene and the antibiotic resistance marker gene come from bacteria so those genes must be codon optimized.  As a recent review noted, “To improve Cas9 expression in plants, most modified Cas9 genes for plant genome editing have also been optimized with plant-usage bias codons.”  These codon optimized genes are not found in nature, so plants developed using such CRISPR/Cas9 systems would not be eligible to be exempted from the labeling requirements of P.L. 114-216.


In cases where the genetic material comes from the same type of organism, although the genes do not have to be condon-optimized, the full genetic construct itself (i.e. the “modification”) would not be found in nature, even though separate parts of the construct may be.  Take the AquAdvantage salmon (AAS), for example, where the genetic construct consists of a promoter (e.g., a genetic regulatory element) gene from the ocean pout attached to a growth hormone gene from Chinook salmon that is inserted into the genome of an Atlantic salmon.  While both the promoter gene from ocean pout and the growth hormone gene from Chinook salmon do exist in nature with the same genetic sequence, the specific genetic construct (ocean pout promoter gene+ Chinook salmon growth hormone gene) does not.


Gene silencing (including RNAi and RNA-dependent DNA methylation), which has been used to create a non-browning apple, usually involves inserting short genetic sequences into plants that result in the production of very short sequences of RNA (called microRNA [miRNA] and small interfering RNA [siRNA]) that shut down/prevent expression of specific genes that contain that same short genetic sequence.  The very short sequences of RNA that are produced in the plants “bioengineered” to silence genes (such as the Arctic Apple which is engineered so that the gene [polyphenyl oxidase] that normally causes a cut apple to turn brown is turned off resulting in apples that don’t brown when cut) are not “found in nature.”


In sum, AMS should not regard gene sequences that are created in a laboratory through techniques of modern biotechnology to be “modifications…found in nature.”   Both the older types of “bioengineering” along with the newer technologies such as those of gene editing (including sequence-specific nucleases, meganucleases, zinc finger nuclease, CRISPR-Cas system, TALENs, and oligonucleotide directed mutagenesis) or gene silencing (including RNAi, RNAi pesticides, and RNA-dependent DNA methylation) involve unique genetic constructs that are not found in nature.  Products of these constructs should therefore be subject to the law’s disclosure requirement.”
  1. Will AMS require disclosure for food that contains highly refined products, such as oils or sugars derived from bioengineered crops? (Sec. 291(1)(A)) Context:  Many processed foods may contain ingredients derived from bioengineered crops, such as highly refined oils or sugars that contain undetectable levels of bioengineered genetic material such that they are indistinguishable from their non-engineered counterparts.  AMS is considering whether to require disclosure for foods containing those derived ingredients that may be undetectable as bioengineered.
Absolute clear labeling and disclosure is a must with a caveat of clarification that disclosure applies across the board in full transparency, including all aspects of bioengineering. Clear labeling is necessary for unrefined, low refined, medium refined and highly refined products that go through any process or modern combining of products. The ingredients are the drivers and any present for future manufacturing and/or future process of combining gene, plants, sugars, oils, et cetera through chemistry, bioengineering, or creative growing processes. Scientific knowledge exists to determine whether or not any inert chemicals, salts, or any other ingredient surfaces that is detrimental to human beings, especially our babies. (See Article entitled “Genetically Engineered Food Linked to Iodine Deficiency and Congenital Birth Defects: ,http://hippocratesinst.org/wp-content/uploads/2015/08/33-4.pdf )
  1. Although the Law states that the definition of bioengineering shall not affect any other definition, program, rule, or regulation of the Federal government, could there be potential areas of confusion between the definition of bioengineering as used in the Law and others [sic] similar terms used by the Federal government? If so, what are the potential remedies that could be added to this regulation to alleviate any confusion between this definition and others by the Federal government? (Sec. 292(b))
 Context:  AMS recognizes that other Federal agencies have different terms to describe organisms created through recombinant DNA techniques.  AMS is considering areas of potential overlap or confusion over terms, as well as potential language to add to this regulation to ensure the term bioengineering does not affect any other definition, program, rule, or regulation. 


Policy can lead, simply “instruct” or become part of a background. We are at the point where a definition of bioengineering should become the marker for other rules and technically take the lead pertaining to all regulations and laws pertaining to food groups.


Too many times we see that policy definitions are compromised domestically for other agendas where laws were made for other purposes. As we know Congress passes an average of 758 bills each year – with approximately 7,600 every ten years. As part of the business of legislating, contradictions emerge often.


Therefore, it is suggested that the USDA take the lead and lay down a definition to which other pieces of legislation must incorporate. Otherwise, there exists too much bioengineering industry wiggle room with no checks and balances for organic. Further, the clarity should be driven by a “Domestic” provision where all GMOs used on American soil or within its territories clearly be labeled. This bill could become the driver for future and past legislation with the definition of GMO and the standard bearer for future concerns.


Bioengineering advancements are exploding and future definitions and provisions are coming “down the pike” and must accommodate these existing food rules. Subsequently, if the above bold recommendation is accepted using a 1950s marker, a “bioengineering” definition can stand on its own in this case but will have absolutely no impact.


The intention and Spirit of the law is to be clear with the American citizenry. These are moms and dads consumers on both sides of the aisle who want the freedom to purchase quality food with clear labels for their children. If there is a need to go back to the US Senate for clarification and debate, an opportunistic window exists in the 2010 the Food Modernization Act passed wherein a provision exists where a reporting was due back to the Senate. To date, it appears that this has never happened. This may be one avenue of reporting to refine any definitions legislatively.
  1. Meat, poultry, and egg products are only subject to a bioengineered disclosure of the most predominant ingredient, or the second most predominant ingredient ….(B) if the first is broth, stock, water, or similar solution, is subject to the labeling requirements under the Federal Food, Drug, and Cosmetic Act.  How will AMS determine the predominance of ingredients?  (Sec. 292(c))   Context:  AMS is considering how to evaluate predominance to determine how the Law will apply to multi-ingredient food products.
Technical note: The regulations above continue with another subsection noting the second-most predominant ingredient as stated: “…the second-most predominant ingredient of the food would independently be subject to the labeling requirements under the Federal Food, Drug, and Cosmetic Act.”


 As a general rule of thumb, all animal products must be labeled GMO unless their animal food source markers are clearly labeled otherwise. This appears to be a complex issue to monitor and legislate with such an effective mandate. The selection of the “two most predominant ingredients” appears too risky and easy to orchestrate an end run on. Much more clear instructions are needed.


For example, a farmer may get a corn, barley, oats and molasses mix for chickens. Obviously, the ingredients that may be questionable as GMO are the corn and molasses. Yet, as the legislation reads, a farmer could choose barley and oats as the reportable items under this provision. The outlet where the items were bought may or may not have clear labels because so often this “pickup point” is a cooperative. When the many farmers bring in their crops, these often are mixed together without sorting out GMO and organic, unless there is a clear market advantage to do so. This does not always exist in “farm country”.


These practices seem nearly impossible to regulate and monitor as the clarity that is needed appears to be a daily meal recording of what is fed animals or poultry and how much when. This would be too much of an added burden on farmers with costs being rolled over to consumers. Therefore, the recommendation is to label any and all ingredients used in feeding crops and the “organic standard” fall in line accordingly.
  1. How should AMS craft language in the regulations acknowledging that the Law prohibits animal products from being considered bioengineered solely because the animal consumed feed products from, containing, or consisting of a bioengineered substance? (Sec. 293(b)(2)(A))    Context:  AMS is considering regulatory language similar to the wording in the Law and if the Agency should provide clarity that food derived from any animal, including invertebrates such as crickets or bee products, would not require disclosure as a bioengineered food solely because their nutrition came from food with bioengineered ingredients.
 There is clear disagreement on this provision because the stance is that ALL ingredients given to animals must be part of the equation when consumed. If crickets and bees are about to become genetically altered, as any other insect or animal that is used in animal production, there certainly is a need to clearly label the product. A huge concern that might emerge, for instance, is where GMO salmon is ground up and used for feedstock for other animals, fish, etc. Then these are shipped off to be processed for the consumer.
  1. What is the amount of a bioengineered substance present in a food that should make it be considered bioengineered? (Sec. 293(b)(2)(B))    Context:  The Law authorizes the Secretary to determine the amount of a bioengineered substance present in food in order for the food to be disclosed as a bioengineered food.  The amounts of a bioengineered substance that may be present in food in order for the food to be a bioengineered food might be determined in a variety of ways: if a bioengineered substance is near the top of the list of ingredients, by determining the percentage of bioengineered ingredients in a food product, or by listing any ingredient that was produced through bioengineering, among others.  AMS is considering how to determine the amount of bioengineered food or ingredient needed for a product to require a bioengineered disclosure, as well as the advantages and disadvantages of various methods.
The time is now to establish in our food a 100% GMO and bioengineered free label option where the label of 100% means truly 100%. Under such a label, any and all GMO ingredients and markers of bioengineering would be subject to complete disclosure. Following the standard thresholds as found today in the European Union and the “non GMO” labeling project would no longer apply.


The current “organic” and “100% organic” labels currently have non-organic (and GMO) thresholds of 5% and 0.9% respectively. A new gold standard would be in order with a 0.0 threshold where products, manufacturers, institutes and farmers clearly offer 100% pure GMO free food products. As growing advancements and sourcing options keep pace with technology, companies that truly purport healthy products for consumers easily would move their products in a direction of high transparency. This is what consumers want, with no “smoke screens and hidden allowances”.


Advantages would simply be to the consumers with the burden of transparency on the shoulders of industry.
9.. Should AMS consider more than one disclosure category? (Sec. 293(b)(2)(D))   Context:  AMS is considering if it should develop various categories for disclosure and if it should differentiate between those products that a) are bioengineered, b) contain ingredients that are bioengineered, or c) contain ingredients derived from bioengineered crops or animals.  Additionally, AMS is considering the creation of a set of disclosures for a category of bioengineered foods for those products that, due to changes in sourcing, include bioengineered ingredients for part of the year, and non-bioengineered ingredients for other parts of the year.  AMS is considering the advantages and disadvantages, based on cost, clarity, and other factors, of using a single disclosure category or multiple disclosure categories.
Underneath these questions is a new approach to policymaking where the policy is formed to accommodate technological innovations in favor of business. A multiple category approach is clearly an advantage to allow industry the flexibility to promote its “different types” of advancements with as little constraint as possible. Subsequently, “high tech policy framing” captures the advancements of technological innovation at the expense of clear disclosure for consumers.


If AMS or the USDA considers that there is a need to remain in step with technological advances, then a “different type” of category may be needed but not at the expense of full disclosure of GMO.


For example, such a policy would take into account the rapid development of CRISPR technology where the technological advances may be “very close to” the existing product but is missing certain genes. We do not know what will happen to organic potato crops down the road, for example, if generations of varying potatoes become cross tubers on purpose.
  1. What other factors or conditions should AMS consider under which a food is considered a bioengineered food?  (Sec. 293(b)(2)(C))      Context:  AMS must develop a process to help stakeholders determine whether a food is subject to bioengineered disclosure.  AMS anticipates the process would include considering factors such as: whether a food contains a substance that has been modified using recombinant in vitro DNA techniques (Sec. 291(1)(A)), whether the modification could not be obtained through conventional breeding or found in nature (Sec. 291(1)(B); Question 2 and 3), , and whether a food requires disclosure based on the predominance of ingredients (Sec. 292(c); Question 6), among others.  The outcomes of these determination requests might be publically posted on a Web site.  The process to implement Sec. 293(b)(2)(C) is not intended to be an investigation or enforcement process (see Questions 26-29); instead, the implementation would likely be framed for manufacturers or developers of bioengineered food or ingredients who have a question on whether their food is subject to disclosure.  AMS is considering the factors to be considered, the way to inform the public about the outcome of the requests, and ideas regarding the process to be used to make the determination.
 It appears that the intention of this section is going in the right direction to clarify for industry certain factors that may require labeling.


One very important major consideration that is not paid attention to is “inert” combinations of GMO or bioengineered foods where intake may trigger inert genes or hidden deficiencies to occur that may result in detrimental combinations of chemistry. Such a deficiency may be linked to serious detrimental health issues. For example, it is purported in an Article published a few years ago where toxic halogens called salts were hidden in GMO foods that causes birth defects. See Article entitled “Genetically Engineered Food Linked to Iodine Deficiency and Congenital Birth Defects: ,http://hippocratesinst.org/wp-content/uploads/2015/08/33-4.pdf


Such hidden actors in our foods and chemistry are not natural and should be considered a byproduct of the GMO/bioengineering process and therefore clearly labeled. Such a major policy consideration is a policy stance of precaution to avoid any damage, changes, or mutations of genes of current generations or the following generations. An 1950s marker again may be the safest. Such a cautionary approach is of particular interest to Moms and Dads with little children.
  1. Could AMS consider whether a type of food is considered a bioengineered food under the determination process?  (Sec. 293(b)(2)(C))    Context: AMS is considering if it could exclude certain food types such as medical food and dietary supplements, among others from requiring disclosure as bioengineered.
There appears to be a need for clarification in this section, as there appears to be a mixing of apples and carrots in this equation.


A key provision in the Bill’s regulations (C) states “…other factors and considerations under which a food is considered a bioengineered food”.   This question and inclusion of “dietary supplements” really does not appear in the legislation. Any “tampering” with supplements is very tricky because doing so appears to be an attempt to open the door to issues in DSHEA, the Dietary Supplement Health and Education Act of 1994.


It has been long held that there are many distinctions between food and supplements where lines must not be merged. Below is the definition section of dietary supplements used in DSHEA:


Within this DSHEA provision and definition, “food” is not to be compromised by any precedent setting provision from another act. It is independent and sacrosanct in these instructions, intention and recommendations.


As consumers greatly favor the protection they enjoy under DSHEA, then certainly a “regulatory instruction” from the FDA would be appropriate as long as there was no jeopardizing of the Act itself and no precedent set. If the USDA has the regulatory flexibility to allow or disallow any ingredient in DSHEA without jeopardizing the boundaries of the Act and its intent and spirit, then, certainly the narrow applications of GMO / bioengineered appropriately applies.


Clearly this is not a statement in favor of GMO derived supplements as any vitamins and dietary supplements derived from GE sources ought to be clearly labeled. The major concern is opening the door for industries’ footprint and manipulation of the consumer protection elements of DSHEA which have been a gold standard.
  1. A manufacturer chooses to use text to disclose a bioengineered food, what text should AMS require for a text disclosure? (Sec. 293(b)(2)(D))    Context:  Currently, some food manufacturers use language compliant with the Consumer Protection Rule 121 from the State of Vermont to identify their food products as bioengineered (“Produced with Genetic Engineering,” “Partially Produced with Genetic Engineering,” or “May be Produced with Genetic Engineering”).  AMS is considering whether to allow manufacturers to continue using these disclosures under the new national bioengineered disclosure standard and if their language is appropriate.  Further, AMS is considering what phrases could be used as a text disclosure for bioengineered food that consumers would find informative, truthful, and not misleading.
AMS is also considering whether there should be one standard text disclosure language, or whether manufacturers should be allowed flexibility to choose from more than one acceptable phrase and where the bioengineered food disclosure should be placed on food packages. 


This new labeling opportunity invites everyone involved to “get it right” and to be more transparent and clear, aiming to benefit consumers over industry. Therefore, it is recommended that there be one clear provision – either labels are “bioengineered” or possibly “GE” or “BE”.


In hindsight, the working of the Vermont GMO language was an attempt to refine words for purposes of forming coalitions and getting votes for passage, especially since it was one of the first States to orchestrate such a passage. As we know, the compromises that can occur within such a lengthy, precedent setting process can be significant and orchestrated as a voting strategy.


The preference here is 100% clarity. This would mean that, if a product were labeled “100% GMO free”, there would be NO doubt to a consumer that the ingredients would be 100% lacking of GMO ingredients. Any margin of error, as seen today, such as the 0.9 % margin under the “organic” seal ought to be eliminated for the 100% GMO label. The argument for the .9% was that industry would be hamstrung by costs in formulating its products and that binders were required for the proper product mix, binders often being GMPO. If there is no significant change, a GE or BE label would have to be inserted as part of the .9% variance, as presented below where Moms Across America have made a good attempt with their warning label.


Warning label: Warning: This product contains genetically modified organisms which have been shown to produce toxins and stimulate tumor growth in animals. Many GMOs are engineered to withstand pesticides which do not dry, wash, or cook off. Therefore, this product may contain carcinogenicneurotoxicantibiotic,  and endocrine disrupting chemicals which cause liver disease.
  1. If a manufacturer chooses to use a symbol to disclose a bioengineered food, what symbol should AMS require for disclosure? (Sec. 293(b)(2)(D))     Context:  AMS needs to ensure that the symbol designed for the bioengineered disclosure is not disparaging toward bioengineering.  As with the text disclosure, AMS must develop criteria for placement of the symbol to ensure consumers can readily locate the symbol, the symbol is scalable for different sized packages, and the symbol is a meaningful representation of bioengineered foods.  AMS is considering what the symbol should look like and guidance on its use.
 The most important point in any labeling is to ensure that there is full disclosure of GMO and bio-engineered elements in food, and that consumers are clearly aware and notified. A symbol on a package is clearly a trade-off of full, clear disclosure and is not acceptable. Consumers must have full access to ingredients and a complete education process must be in place to ensure easy and truthful selections.


As a symbol obviously will come into the market place at some point, s simple stylized strand of DNA would do the trick, meaning that the DNA would appear on any package where any GMO related technologies exist. This would also apply to CRISPR and subsequent technologies where there may be an extraction of one or more genes. Here are a few examples of a type of label that would indicate to consumers a manipulation of food gene is in the ingredients.
  1. If a manufacturer chooses to use an electronic or digital link to disclose a bioengineered food, what requirements should AMS implement for an electronic or digital link disclosure? (Sec. 293(b)(2)(D))   Context:  D) in accordance with subsection (d), require that the form of a food disclosure under this section be a text, symbol, or electronic or digital link, but excluding Internet website Uniform Resource Locators not embedded in the link, with the disclosure option to be selected by the food manufacturer;
The proposed electronic route at the tradeoff of shelf full disclosure is “bigger than necessary” for this bill at this time. We are against implementing electronic approaches and disclosures in favor of “keeping the truth on the shelves”.


One of the POP Campaign principals drafted and presented a digital communications bill for the California legislature years ago on telecommunications rights because of the notable economic discrimination that technology instilled in relationship to income disparity. Simply, economic discrimination triggered by technology was a real issue then and is a real issue now. If this “electronic or digital” portion actually goes through without any provision for clear labels, these accessibility issues may surface under the ADA, especially for seniors, and would than likely result in formal challenges.


Further, for busy Moms and Dads there is “No Time” during a quick shopping runs between work and school and dinner, etc, to access electronic in-depth information on products. This is a nice idea but unrealistic at this time,, especially because of the lack of infrastructure.


To implement this would be a completely new layer of product requirements that would set precedent for the future around ALL food products. The obvious next steps would be full and complete disclosure on ALL ingredients of every food product in the US. A new industry would be established with a possible “Seal of Good GE Keeping” with disclosure and transparency in every state and every industry.


However, if the compass is leaning to a “must implement”, then the following ought to be considered in the favor of consumers. The requirement would be that full disclosure be presented in a manner that is consumer friendly. Possibly a few schools around the country could be enrolled to edit the “ingredient context” and ensure that clarity that would be achieve full and complete understanding, even at their levels. Truth in labeling is absolutely crucial for consumers.


However, if the compass is leaning to a “must implement”, then the following ought to be considered in the favor of consumers. The requirement would be that full disclosure be presented in a manner that is consumer friendly. Possibly a few schools around the country could be enrolled to edit the “ingredient context” and ensure that clarity that would be achieve full and complete understanding, even at their levels. Truth in labeling is absolutely crucial for consumers.
For example, on line, one example of a transparency sequence may be as follows:
For example, on line, one example of a transparency sequence may be as follows:
Intro: short description of the reason this site exists – 2 sentences.
Section 1: A simple, clear, graph with descriptions of the product ingredients would be up front, visible and transparent.
Section 2: Statements of “why here” and concern about certain GMO products that are listed in this product with a little more back ground….both industry and consumer paragraphs on the same page next to each other……somewhat like an election voter ballot explanation.
Section 3: More in depth statement from the manufacturer or/and product source about the ingredients in question as to the in depth studies presented, reports, etc. The same allowance would be gi ven to groups protecting consumers.
  1. Should AMS specify in the regulations the type of electronic or digital disclosure manufacturers, e.g. QR code, can use to disclose bioengineered food?  What steps should AMS take if an electronic or digital disclosure method becomes obsolete? (Sec. 293(b)(2)(D)) Context:  AMS recognizes that disclosure technologies may quickly surpass regulations.  AMS is considering what terms will ensure the regulations keep pace with technological changes and how AMS can notify stakeholders about changes in technology as they occur.  AMS is also considering what the most appropriate electronic or digital disclosure technologies are currently and how to deal with obsolete technologies. 
The most favorable position for consumers is to “follow the package” disclosure. The responses above to question 15 are appropriate here.
  1. What kind of text, symbol, or electronic or digital disclosure should AMS require for bioengineered food that is not purchased from a grocery store shelf, such as food for sale in bulk (such as fresh produce in a bin or fresh seafood at a fish counter), in a vending machine, or online? (Sec. 293(b)(2)(D))
Context:  In some situations, disclosures may not be easily located when such products are on display for sale.  AMS is considering disclosure practices for these and other non-conventional purchasing or packaging scenarios.


 Anything in a market place or store seems to have a place where prices are displayed. Any vendor of any product that does NOT contain GMOs will somehow find a way to disclose it because of the market advantage. Such an advertizing would be placed on the product, shelf, or anywhere the customer looks to drive the customer to buy that product. Even the smallest store owners or booths have the ability to display a sign that works…… no matter how small the store. Therefore, the recommendation is that there be NO wiggle room on this point, including on conventional packaging.
  1. The Law offers special provisions for disclosure on very small or small packages.  How should AMS define very small or small packages? (Sec. 293(b)(2)(E))
  2. Context:  AMS is considering if it should mirror FDA’s treatment of very small and small packages for nutrition labeling.In 21 CFR 101.9(j)(13)(i)(B), FDA defines small packages as those with less than 12 square inches in total surface area available to bear labeling. 
Context:  AMS is considering if it should mirror FDA’s treatment of very small and small packages for nutrition labeling.
In 21 CFR 101.9(j)(13)(i)(B), FDA defines small packages as those with less than 12 square inches in total surface area available to bear labeling. FDA also has allowances for packages that have less than 40 square inches of total surface are available to bear labeling.  
A symbol stating GMO ought to have no compromise because of size of the package. A 12 square inch space is plenty for wording or a label. A small entrepreneur or provider always seems to find a way if desired. Therefore, all products ought to be labeled and displayed, as this is the modern way. Where a small provider needs help, the USDA ought to provide free assistance.
  1. What are the reasonable disclosure options AMS should provide for food contained in very small or small packages?  (Sec. 293 (b)(2)(E)) Context:  AMS is considering the disclosure standards for very small or small packages.  FDA regulates nutrition labeling on very small or small packages differently.  For example:
  1. Could disclosure requirements for very small packages be met by providing an address or phone number where consumers could obtain the information?
  2. Could disclosure requirements for small packages be met by providing abbreviated text disclosure or a Web site address where consumers could obtain disclosure information?
The labeling mandate should be maintained and required without compromise. The space that would have the address and phone number could be the same space whereby the content could be placed. Granted, there may be some hampering of esthetics in packaging; however, most products get around this by having part of the packaging paper over lapping, like some candy bars, where the information is on the outside and inside of the flap.
  1. 1 How should AMS define small food manufacturers? (Sec. 293(b)(2)(F)) Context:  AMS is considering using regulatory language similar to that of other Federal government agencies that already define small businesses.  For example:
    FSIS considers small businesses to be those with 500 or fewer employees and that produces 100,000 pounds or less of annual production of a single product, including single forms of meat such as sausage, bulk, patties, links, consumer product, etc., when determining exemptions from nutrition facts labeling (9 CFR 317.400 (a)(1)(ii)).
    FDA has several small business definitions with respect to food labeling rules, such as:  i) retailers with total annual gross sales of $500,000 or less, 21 CFR 101.9(j)(1) and (18); ii) food and dietary retailers with annual gross sales of foods or dietary supplement products of $50,000 or less, 21 CFR 101.9(j)(1) and 101.36(h)(1); and iii) businesses that employ fewer than 100 full-time workers that produce a product that sells fewer than 100,000 units throughout the United States in a 12-month period, 21 CFR 101.9(j)(18) and 101.36(h)(2). 
AMS is considering the advantages or disadvantages of these definitions of small food manufacturers for the bioengineered food disclosure regulations.
Full transparency on all products for even small companies is the recommended compass. There should be no exceptions with small companies being required to be in compliance. Every company has the ability to place a price on their product and name it and say what it is. An added disclosure of GMOs for clarity in actuality is simple and not cost prohibitive. If there are cost issues, the USDA ought to assist the business.
At times, a lengthy third party verification process may come into play although it may be expensive for smaller manufacturers. It is recommended that Federal and State subsidies be made available for transparent labeling and that a “piggy-backing” system be established to mitigate these costs. This unique added cost effective approach may include a product ingredient that has been determined GMO prior through a process of labeling by a third party company. A company may be able to “piggy-backed” on the certification of another company provided there are no changes.
  1. For disclosures by small food manufacturers, what is the appropriate language indicating that a phone number provides access to additional information? (Sec. 293(b)(2)(F)(ii)(I)) Context:  AMS is considering using language in Sec. 293(d)(1)(B) of the Law.
No. A phone number is a step away from on the shelf disclosure, as mentioned above, and most inconvenient for the busy families and consumers of today. We can’t imagine that a busy consumer or a modern mom during a shopping rush hour shop would make a phone call to get clear labeling information.


There are ways smaller manufactures have figured it out; labeling is NOT rocket science and very doable, especially if someone really wants it done. For those who need a little help, possibly there could be an allocation for a template on line and some assistance for them, as mentioned in #19. If consumer access on a phone is in order, there certainly would have to be a “common approved” script with full technical disclosure and a conformity across the board….which is another head ache.
  1. The Law excludes restaurants and similar retail food establishments from disclosure requirements.  How should AMS define similar retail food establishment to exclude these establishments from the requirements of the regulation? (Sec. 293(b)(2)(G)(i))
Context:  AMS is considering how to treat establishments that sell food ready for human consumption, such as institutional food service, delicatessens, or catering businesses.  In its regulations for Nutrition Labeling of Standard Menu Items in Restaurants and Similar Retail Food Establishments (21 CFR 101.11), FDA defines restaurant or similar retail food establishment and restaurant-type food
For FSIS, the Federal Meat Inspection Act (FMIA) provides for the mandatory inspection of commercial meat and meat products.  The FMIA and implementing regulations do, however, provide exemptions from the continuous inspection provisions for retail operations and restaurants (9 CFR 303.1(d)(2)). NOP also defines retail food establishment in its regulations (7 CFR 205.2).AMS is using this information as it considers definitions for restaurants and similar retail establishments, with the understanding that these definitions will be used to determine what types of retail establishments are excluded from the requirements of the Law.
The preference is that any person or entity that provides food to consumers, in particular families, children, and the elderly, must have GMO labeling disclosures, including restaurants and small providers


If the law is not strong mandating an allowance on this issue, there could be a provision where a consumer friendly restaurant would be acknowledged formally or placed on a list or receive some type of Federal insignia if it is willing to volunteer for GMO labeling. Because consumers want everything labeled GMO at every level, this could be an incentive for a restaurant. Any USDA guidelines might be set up through a special program and include incentives for participation.
  1. 22. How should AMS define very small food manufacturers to exclude these manufacturers from the requirements of the regulation? (Sec. 293(b)(2)(G)(ii)) Context:  See Question 19.  AMS could use definitions similar to how other Federal agencies define very small businesses, and is considering definitions to distinguish small food manufacturers (Question 19) and very small food manufacturers, with understanding that very small food manufacturers would be excluded from the requirements of the Law. 
ALL food manufacturers should be subject to GMO/GE labeling with no exception. Manufacturers need to be respected for the know-how that got them to this point in the production space. They know what is going on within the confines of their production or manufacturing or canning or bottling plants and operations. They also know exactly where and how to label.


Further, production with technology makes everything more efficient than ever, which is where the mystery is eliminated. Labeling is NOT a mystery…at least not for the mixers, machine operators, slicers and dicers on the floors where products are processed. The frontline workers usually know how things really work and pride themselves in finding answers and facing challenges. This is their profession. The truth may more be that the owners simply “don’t want labeling” because there is too much “disclosure” and “distraction” from profits and the bottom line. To strongly support consumers, “being real” under this circumstance would mean that the USDA would step in with assistance.


There is a strong need for transparency because no mom on the street or busy dad really believes that the American way really thrives with such a roadblock. So, on behalf of every Mom and Dad and consumer, all products should be labeled.
  1. Is there other equivalenton-package language that AMS should consider to accompany an electronic or digital disclosure besides “Scan here for more food information”? (Sec. 293(d)(1)(A))Context:  The word ‘scan’ may or may not be relevant for each type of electronic or digital disclosure in the present or in the future.  AMS is considering if it should issue guidance to identify equivalent language as technology changes and what that equivalent language would be. 
Direct and transparent disclosure on any product is the most preferable and bottom line at this time. The word “mark” as in bio-markers which is more common in the industry is a word that might be used. 
  1. How should AMS ensure that bioengineered food information is located in a consistent and conspicuous manner when consumers use an electronic or digital disclosure? (Sec. 293(d)(2)) Context:  AMS is considering requiring the same information associated with the text disclosure as the requirement language for an electronic or digital disclosure (See Question 12).  Further, AMS is trying to determine how various disclosure options affect the amount and type of information available to consumers.  AMS is also determining if there should be requirements or guidance on what size text would ensure the information is conspicuous to ensure the food information is located in a consistent and conspicuous manner when electronic or digital disclosure is accessed.
Clear transparency on the package itself is the preference. A 12 point lettering is preferable in bold, especially so that Seniors and those who are sight challenged can easily read what is in the packages. Lettering should always be in black print as the easiest to read for everyone. Other colors and light colors camouflage easy and clear access.


Consistent with transparency principles, in any electronic implementation, all primary and secondary information ought to be presented on the landing page for clear consumer disclosure.
  1. How should AMS ensure that an electronic or digital disclosure can be easily and effectively scanned or read by a device? (Sec. 293(d)(5)) Context:  AMS is aware that electronic or digital disclosures need to be effective, that requirements will vary for each specific type of electronic or digital disclosure, and that the technology for electronic or digital disclosure may change faster than AMS will be able to update its regulations.  AMS is determining how to address these issues given the variety of electronic or digital disclosures currently available in the marketplace, along with the specifications for these disclosures to be used effectively in a retail setting. 
Again, the preference is for consumers to receive all of the information on a product in full disclosure at point of purchase and sale of a food product. An electronic approach that trumps easy access for every consumer is more of a barrier than a free transparent access channel. Such an action does not give the consumer the edge but more favors companies.


Also, in any digital approach, issues of accessibility per the ADA, Americans Disability Act, come into play. In this case, a complete digital scanner that may meet all of these terms may be years in the future.
  1. What types of records should AMS require to be maintained to establish compliance with the regulations? (Sec. 293(g)(2))Context:  Each person or entity subject to the mandatory disclosure requirement would be required to maintain and make available to the Secretary records that establish compliance with the Law.  Typically, record keeping requirements include those for the records required to be kept, the place of maintenance of such records, the record retention period, and what it means for AMS to have adequate access to and inspection of such records. 
Under current FSIS regulations, records must be maintained at a place where business is conducted, except that if business is conducted at multiple places of business, then records may be maintained at a headquarters office.  When the business is not in operation, records should be kept in accordance with good commercial practices.  For FSIS, records are required to be maintained for a 2-year period.  The maintenance time for FDA records vary from 6 months through up to 2 years.
AMS is considering what recordkeeping requirements for persons subject to the Law would be most appropriate.
Simplification and less paperwork makes the most sense so that a “business can do business” which is a norm most consumers seek and support. However, the minimal requirements should reflect the commitment of any business to consumer transparency and to the labeling process. A two-year record maintenance record period may not be long enough to complete everything in the process because of dependency on third party clearances. Possibly a 4 year record-keeping measure would make more sense. A key variable is a reporting requirement if a product formula is changed after reporting periods.
  1. How should AMS obtain information related to potential non-compliance with these regulations?  Is there information USDA should request prior to conducting an examination of non-compliance? (Sec. 293(g) 
Context:  AMS is considering what tools could be used to identify potential non-compliance and enforce compliance with the regulations.  AMS is considering the types of information needed to verify compliance with the Law and the most optimal way to obtain such information.
Since there is such a huge move towards the integration of digital technology from the USDA, an easy access phone number for consumer reporting should be in order. Any compliance procedure must include consumer updates and information on a company’s progress. A sufficient compliance rule obviously ought to be in place whereby a company is given “reasonable time” to comply with the rules. Reports that are binding ought to be submitted pertaining to progress of a violation with the appropriate enforcement actions forthcoming. If the companies are large and do not comply, significant fines should be included, such as $2,000 a day. All proceeds would go to consumer education and access to ensure “on the pulse” updated information for quality food choices.


A consumer could proceed forward with a complaint without an attorney with correctable proof of compliance that may include photos as a simple verifiable remedy.
  1. What are the rules of practice for a hearing? (Sec. 293(g)(3)(B))Context:  AMS is considering the appropriate procedures for audits and other compliance actions, including opportunities for hearing.  AMS is considering this aspect for the rules of practice and other options regarding a prospective hearing and internal adjudication process.
 The most important issue in a hearing is to ensure that the hearing officers in truth clearly have the consumers’ interests as a priority. Too often, this is sacrificed and/or cleverly cloaked. Also, it is key to eliminate the influence of industry in any hearing where the outcome is biased. Regular monitoring procedures ought to be kept at a minimum in respect for the overload of paper and requirements most businesses face; yet, without compromise of the consumer’s best interest.
  1. How should AMS make public the summary of any examination, audit, or similar activity? (Sec. 293(g)(3)(C)) Context:  AMS is considering if the results and findings of any examination, audit, or similar activity should be posted after the notice and opportunity for a hearing described under Sec. 293(g)(3)(B).  AMS is also considering how it should make summaries of the examination, audit, or similar activity public. 
Transparency is the preference at all levels. Audits, findings, minutes and recommendations, as well as violations and missed requirements of a company, ought to be made public in the same manner that public and non-profit entities and organizations are required. Since GMO and bioengineering are public issues, disclose and enforcement requirements ought to be made public at all levels.
  1. What should the requirements for imports into the United States of products covered by the Law/regulation be? (Sec. 294(a)) Context:  AMS is considering how the disclosure requirements should be applied to imported products.
Full disclosure of GMO on all products entering America is the ideal. Spot check monitoring of the production processes of International companies is a way to add another layer of warning and monitoring. There ought to be a strengthening of both the Cartagena Protocol monitoring and compliance as well as any Codex and trade requirements to meet the US full disclosure efforts.
(1) http://www.ensser.org/increasing-public-information/no-scientific-consensus-on-gmo-safety/
(22 http://www.commonwealthfund.org/publications/issue-briefs/2015/oct/us-health-care-from-a-global-perspective

GMO Labeling Historic Vote

Thursday, September 8, 2016 @ 11:09 AM
posted by Rudi

The POP Campaign continues it’s efforts to protect consumers and maintains a presence in Washington, DC…..please donate to keep our Voices Alive where it counts. Thank you.






STAY TUNED FOR WHAT’S NEXT TO PROTECT OUR FAMILIES It is a rare bill that is opposed by Senators, Boxer, Sanders, Paul and the Heritage Foundation, but this GMO Labeling bill is one. Conservatives do not typically like federal mandates (why Senator Paul opposes) or pre-emption of states’ rights. It is also unusual for conservative republicans to ignore the Heritage Foundation’s opinion especially since one of their own, former SC Senator Jim DeMint now heads the organization. That is exactly what happened with this bill because Monsanto and the Grocery Manufacturers Association and other major corporate players hammered home that message and warned that the cost of groceries would increase dramatically to comply with a ‘patchwork’ of laws across the country.

The Senate determined to clear the GMO Labeling bill off their plate before they left Washington this week, held their vote after 10:20 pm. From 9:30 am until the vote was called at 10:20 pm, the Senate floor fluctuated between times of silence and impassioned and informative speeches by Senator Merkley, Senator Murkowski, Senator Durbin and others. Sen. Merkley did a great job of pointing out how the Monsanto corn, soy, and sugar beets when developed into high fructose corn syrup, soy bean oil, and sugar would be exempted from the mandatory labeling provision, something that undermines what Americans are expecting in any labeling requirement. He also pointed out that this is the first labeling law that has no penalty associated. Meaning that there is no reason any company should comply because there are no monetary or other typical penalties included.

Senator Tester, the only Senator to run an organic farm testified on Thursday that he had real concerns that the organic provision was not as good as people have portrayed it and that GMOs might make their way into organics. Senator Durbin pointed out the concerns about Monsanto’s herbicide and the health concerns discussed in the New England Journal of Medicine.

One of the other discussions that came out of the debate today was discussion of how our being a signatory with the World Trade Organization cost American consumers (and farmers) the ability to have country of origin included on the labeling of foods. In essence, we lost our sovereignty to an international court. The discussion went on to raise concerns about the affect the Trans Pacific Partnership Agreement might have on these issues as well.

About 7 pm and then again at 9 pm there was an attempt to bring the debate to a close and hold the vote – to move on to debate the DOD-Zika appropriations bill. Both failed. There were a number of amendments submitted, including numerous ones by Senator Sanders of Vermont. However, the Majority Leader, Senator Mitch McConnell has blocked debate and votes on any of the amendments either Republican or Democratic.

Members want to finish up their votes so they can leave Washington. They have one week left in session in July then it is off to the conventions and campaign trail. Unless there is a national emergency that warrants their return, they will be out of session until September.

Just after 9:30 Senator Stabenow, the democratic champion of the compromise bill, dressed all in red, and speaking in very motherly tones, took to the floor to give her views, raising concerns about the costs of groceries would go if with 50 different labeling laws from 50 different states; expressing her view that the science supported the safety of GMOs and provided her perspective of the history of the GMO labeling legislation and need to act. When discussing the “Vermont Meat Loophole” that the compromise bill closes, she opted not to tell the public that states could not mandate labeling on meats, eggs and dairy because of an existing federal pre-emption. According to Senator Stabenow, USDA Organic symbol will also equal Non-GMO.

As an aside, according to Open Secrets, Sen. Stabenow in this same time frame became the top recipient for Farm Bureau donors and in the 2015-2016 cycle has received $1.3 million dollars from the agriculture business donors.

At 10 pm both the Majority Leader (Senator McConnell of Kentucky) and Minority Leader (Senator Reid of Nevada) took turns in what can best be described as political posturing on matters largely unrelated to GMO Labeling. At 10:15, Senator Merkley of Oregon came back to the floor to offer to attempt to have the offered amendments debated and voted on. The vote to move his suggestion forward was called at 10:20 and was defeated with Senator Tim Scott, who replaced Senator DeMint in South Carolina casting the 51st vote no.

At 10:45 the final vote was called on passage, requiring only a simple majority. Sadly, this bill passed by a wide margin 63-30. And at 11:01 the Senate moved on to the next bill.

There were some last minutes switches such as Senator Mikulski of Maryland switching to support Senator Stabenow and Senator Flake following the Heritage recommendation.

The House must pass the bill again, and is expected to do so immediately under a Uniform Consent or Suspension Calendar procedure (meaning there will be no actual debate). Then it will be off to the President for signing into law. He is traveling at present, so they will either sign by automated pen, or wait for his return.

The POP Campaign will continue working to preserve organic standards and insure that the regulations put forward by USDA related to this bill do no harm to the existing standards.


Senate Votes to Close Debate on GMO Compromise Bill & Keep You in the DARK

Wednesday, July 6, 2016 @ 02:07 PM
posted by Rudi

– Vote on Passage As Soon as Tomorrow

July 6, 2016 5:00 pm

After three months of closed door negotiations, Senators Pat Roberts (R) and Debbie Stabenow (D) the Chair and Ranking Minority Member of the Agriculture Committee made public their solution to the GMO Labeling legislation that had failed in March. Sen. Stabenow has repeatedly stated she feels GMOs are safe, but wants Americans to truthful information on the label as requested. She insisted that any bill would have to mandate labeling. Senator Roberts promoted that Congress MUST act to pre-empt state’s rights to develop their own laws (something that is typically contradictory to Republican philosophy) to prevent a ‘patchwork’ of labeling laws across the country that would make it hard for food manufacturers to comply.

It is truly a strange time in Washington when the ultra-conservative Heritage Foundation opposes a bill that liberal Senators Bernie Sanders and Barbara Boxer also oppose, but this GMO Labeling bill is just one occasion; albeit for differing reasons.

The POP Campaign has worked aggressively to get our message out that truth in labeling matters; that the bill as presented is a boon to industry and a bust to consumers. We joined for 9 out of 10 Americans and asked for simple, back of label, all ingredients included, GMO labeling. We gave the detailed analysis and plain language talking points to many legislative staffers for their Senators and got a lot of appreciation.

Minority leader, Senator Harry Reid asked his democrats and republicans to join him in voting no – he urged that the debate on this bill needed to continue, that it should have gone through Committee and that amendments should be allowed.

Senator Stabenow lobbying a handful of her democratic colleagues to side with her, and was successful in getting the 60 votes needed for cloture (suspension of debate). Democratic Senators Feinstein, McCaskill, Manchin, Kaine, Baldwin, Casey, Franken, Heitkamp, Peters, Shaheen and Warner voted with Senator Stabenow while Sen. Sherrod Brown abstained.

Republican Senators Paul, Collins, Sasse, and Independent Senator King joined with Senator Sanders to vote no on cloture.

Senator Merkley took to the Senate floor after the vote to explain problems with the bill – the first of which he explained that the definition of ‘bioengineered food’ will exempt 3 major GMO products in US produced by Monsanto– corn when it becomes high fructose corn syrup, soy beans when it becomes soy bean oil, and sugar beets when it becomes sugar. He also pointed out that there are no enforcement provisions in the Bill and concerns about health and environmental concerns of the ‘weed-killer’ glyphosate that are used at higher levels in GMO crops.

The Cloture Vote began and was interrupted with private citizens protesting in the galley throwing dollars onto the Senate floor in protest to all the money that Monsanto and other agribusiness interests have spread around Washington to achieve their goals and keep consumers in the DARK.

What Is Next: The next step will be a floor vote, as soon as tomorrow night. We need everyone to call their senators and urge a NO vote on passage. Take to social media as well! Sometimes those who vote yes cloture will vote NO on passage. We need to make sure that happens and that this bill does not become law.

Roll Call Vote on Cloture: 65-32.

EAs —65
Alexander (R-TN)
Ayotte (R-NH)
Baldwin (D-WI)
Barrasso (R-WY)
Bennet (D-CO)
Blunt (R-MO)
Boozman (R-AR)
Burr (R-NC)
Capito (R-WV)
Carper (D-DE)
Casey (D-PA)
Cassidy (R-LA)
Coats (R-IN)
Cochran (R-MS)
Coons (D-DE)
Corker (R-TN)
Cornyn (R-TX)
Cotton (R-AR)
Crapo (R-ID)
Cruz (R-TX)
Daines (R-MT)
Donnelly (D-IN)
Enzi (R-WY)
Ernst (R-IA)
Feinstein (D-CA)
Fischer (R-NE)
Flake (R-AZ)
Franken (D-MN)
Gardner (R-CO)
Grassley (R-IA)
Hatch (R-UT)
Heitkamp (D-ND)
Heller (R-NV)
Hoeven (R-ND)
Inhofe (R-OK)
Isakson (R-GA)
Johnson (R-WI)
Kaine (D-VA)
Kirk (R-IL)
Klobuchar (D-MN)
Lankford (R-OK)
Manchin (D-WV)
McCain (R-AZ)
McCaskill (D-MO)
McConnell (R-KY)
Menendez (D-NJ)
Moran (R-KS)
Perdue (R-GA)
Peters (D-MI)
Portman (R-OH)
Risch (R-ID)
Roberts (R-KS)
Rounds (R-SD)
Rubio (R-FL)
Scott (R-SC)
Sessions (R-AL)
Shaheen (D-NH)
Shelby (R-AL)
Stabenow (D-MI)
Thune (R-SD)
Tillis (R-NC)
Toomey (R-PA)
Vitter (R-LA)
Warner (D-VA)
Wicker (R-MS)


NAYs —32
Blumenthal (D-CT)
Booker (D-NJ)
Boxer (D-CA)
Cantwell (D-WA)
Cardin (D-MD)
Collins (R-ME)
Durbin (D-IL)
Gillibrand (D-NY)
Heinrich (D-NM)
Hirono (D-HI)
King (I-ME)
Leahy (D-VT)
Markey (D-MA)
Merkley (D-OR)
Mikulski (D-MD)
Murkowski (R-AK)
Murphy (D-CT)
Murray (D-WA)
Nelson (D-FL)
Paul (R-KY)
Reed (D-RI)
Reid (D-NV)
Sanders (I-VT)
Sasse (R-NE)
Schatz (D-HI)
Schumer (D-NY)
Sullivan (R-AK)
Tester (D-MT)
Udall (D-NM)
Warren (D-MA)
Whitehouse (D-RI)
Wyden (D-OR)


Not Voting – 3
Brown (D-OH) Graham (R-SC) Lee (R-UT)

Call your Senator 202-224-3121 to say NO! to S 764. We want 100% transparent labeling on ALL food products.  (See Senator’s positions at the end)

ONE VOTE will be taken on July 6th with 51 AYES needed to pass the bill. Sorting out the tricky late maneuvering by the Senate leadership was…… well, manipulative and frustrating.  WE CAN  STOP THIS. This appears to be a “railroad” job and an up or down vote. Apparently, the majority of Senators want no discussion.
We say NO! NO! NO! to S 764. YES YES YES…we want ALL food clearly labeled GMO or NON-GMO.  (see Senators and more below)    WE CAN WIN THIS … …  please support us with your tax write off donations – hit the Paypal on the side.  Thank you for showing up….and making your calls                 

This bill stops the Vermont labeling law from going into effect….although there already has been an extension for a year to give industry a chance to get their products GMO labels…it can be done!
The amended provision in S 764 appears to violate the ADA both for disabled persons and the elderly by creating label options that consumers do not have easy access to – NO! The bill will allowing using bar codes as an option and give consumers a number to call – NO!.  The requirement for push button phones to get through to a labeling information system discriminates against low-income folks and many seniors who cannot afford push button phones – this bill discriminates – NO! Further, what about access for multiple languages…like LA schools have 82 languages …GMO food recordings will not provide easy clear access for every nationality and every family in America – NO!. This is a railroad job and a sham in favor of industry and the Monsanto Express at the expense of consumers….taking two to three years to just get the regulations out….NO!  Simply, we are appearing to get  a victory for organic but there is more to the label picture – including full transparency for many and for your children.
Also, during this 2-year time frame, the Secretary of Agriculture, yup, a Monsanto employee once, will establish the guidelines and implement rules for transparency and the protection of consumers. (Is there a fox in that hen-house…anyone?)
Call 202-224-3121 to participate in the SHOWDOWN. These Senators are on the fence and need to be educated as to what is best for your families.
Story: Let’s make this a little more real and “family crazy-making”:
 Mom shopping looking at a bar code seeing a number to call: Looking for her phone –   “OMG – sure, hold on kids,” (here at aisle #3) while I call this number to find out if our food product contains GMO ingredients……ring…ok….ring… (recording).please hold for 10 minutes? “ What! My kids won’t stay still that long and its too crowded in this store and I have a schedule to make!  I am on hold, really?”
Reality says this is ridiculous, absurd and won’t work and serves only as a “smoke screen” to protect products, not consumer Moms and Dads. Here are some Senators we are paying particular attention – speak with family members and friends to call – tell them to vote “NO” on the Bill.
Who do you know in which State?  Please call them.
Senators to educate who switched votes to yes on the procedure – they need to vote no : Tammy Baldwin (WI), Michael F Bennet (CO); Robert P. Casey (PA); Susan M. Collins (ME);Christopher A Coons (DE); Richard J Durbin )IL); Diane Feinstein (CA); Al Franken (MN); Dean Heller (NV);  Amy Klobuchar (MN); Mike Lee )UT); Joe Matchin (WV); Edward Markey (MA); Claire McCaskill )MO); Bill Nelson (FL); Gary Peters (MI); Jeanne Shahen (NH); Debbie Stabenow (MI); and Mark Warner (VA)
Senators to educate who voted yes and need to change their votes: Shelley Moore Capito (WV); Johnny Isakson (GA); Angus S King Jr (ME); Mike Rounds )SD); and Tim Scott (SC)
AGAIN……WE CAN WIN THIS IF YOU CALL … ….  Thank you for showing up and supporting our families and efforts. 
Summer temperatures soar around the country as the GMO labeling debate in Washington heats up again.  The winds of the Vermont GMO labeling bill taking effect July 1 has increased pressure to change directions. Simmering for three months with secret negotiations between Agriculture Committee Chairman Roberts and Ranking Member Stabenow over the GMO labeling of food and salmon,  a compromise labeling bill has emerged. Out of the smoldering defeat of the Dark Act, the new version was published on July 23rd.  It has no number at this time and we don’t know how and when attempts will be made to insert it in agendas. (The POP Campaign experts have reviewed the bill and posted an analysis on FB and at popcampaign.org )
Anti-Labeling Senators were adamant that there needed to be a QR scan code option and a two-year outGMO  label if they were going to compromise for mandatory labeling. (This options still cloaks the content of a product from the busy shopper.) . Senator Stabenow, who has always said she believes GMOs are safe and has received over $1 million from Monsanto Industry donors, nevertheless stood firm on the mandatory labeling component for her constituents – and has helped orchestrate a compromised version.  We don’t agree with this compromise, although kudos to her for standing up as best as she can…we need more. 
Adding to the bias, the finer points of the labeling requirements will be left to the USDA Secretary to hammer out…..who was at one time a Monsanto employee. (Who said anything about a fox in the hen house?)

WE CAN DO THIS…we almost have this victory….we need hard push-back calls to your Senators (House Reps too if you have time). It is better to leave the patchwork of state laws in place rather than put through a bill that has weaknesses and is not fair to all moms and dads across this country.

The message to your Senator is simple: We want clear consumer friendly access labeling of GMO food – now.

If you want to go further, maybe something like this:

“All food and food products available to consumers in the United States shall be labeled clearly whether or not it contains any genetically engineered ingredients, disclosing 100% of any ingredient directly or indirectly derived from a GMO source or genetically altered gene.“

GMO Invasion side copy-1

Attempts are being made for a “midnight slip-in” vote, folding a provision into a larger bill or measure at the last minute. The POP Campaign remains vigilant for you…(we hate sneaky maneuvers)….check FB and our site for updates.

This would be a major victory footprint for your children and generations to come. Please see the list below of members who voted the correct way last time stopping the Monsanto maneuvering …these are your friends on this issue…let’s encourage them to hold firm. (Senator Stabenow appears to be switching her vote based on her compromise language, we do not know for certain). There is no compromise at this time…..we demand transparency in our food and food choices…this is our Right.


GMO Bill Analysis by POP Campaign:

The POP Campaign is positioned as a voice for healthy lifestyles and food choices in any public policy platform. The POP Campaign appreciates the support of our community as we stand strong for food integrity and healthy choices for our families. Please support our efforts at www.popcampaign.org

On June 23rd, following a major National push-back victory preventing a rushed side-track labeling attempt in the Senate, Senator Roberts, Republican Chair of the Senate Agriculture Committee, and Senator Stabenow, Ranking Democratic, negotiated what they are calling “a compromise bill” on GMO labeling. This bill would pre-empt the Vermont labeling law and those of any other State. The POP Campaign’s appreciates the Committee’s efforts.

However, in spite of election year posturing and a lack of tolerance in Washington, our victory of a mandatory labeling provision included in this bill is a bit hollow for reasons that are explained below.  The POP Campaign and its supporters choose to stand strong in demanding a “straight-up” no-nonsense labeling food bill with no “cloaking” options or advantages offered to Industry over consumer “right to know”. The POP Campaign, positioned as a voice for healthy lifestyles and quality food choices, simply seeks clear direct language guideline such as:

“All food available to consumers in the United States shall be labeled clearly whether or not it contains any Genetically Engineered ingredients, disclosing 100% of any ingredient directly or indirectly derived from a GE source or Genetically altered gene. “

Please see below a detailed analysis and breakdown of the Senate’s bill language that is proposed. It makes sense that there be a report back to the Senate on final product and a public hearing process implemented to ensure all side are heard.

Pertaining to the proposed Bill, the key thing to know is that the states laws are preempted immediately. Rather than spelling out the labeling requirements and offering an immediate implementation requirement, this Bill will take 2 years to implement and leaves most of the key decisions to the USDA Secretary, a one-time Monsanto employee favoring industry.  Furthermore, it does not simply require back of label inclusion of all ingredients as requested, but prioritizes which ones would be transparently labeled and creates multiple labeling options including a scan QR code or toll free number to call to get the label information. This is unacceptable as no other food ingredient has such a complex system as a GMO derived.

It is important to note, for example, that the Genetically Engineered salmon issue appears to have been pushed under the rug and is not clearly addressed in the new Senate Bill.

This bill is on a fast track and could be voted on by both Houses between now and the July 15th summer break. The Senate could vote on this bill any day now, and the word is that the House will simple move it through on a suspension calendar procedure.

Bill Text Page 1

Purpose of the Bill: To Amend the Agricultural Marketing Act of 1946 to require the Secretary of Agriculture to establish a National Disclosure Standard for Bio-engineered Foods and for other purposes.

A major overall concern is that this Bill completely passes ALL control over to the Secretary of Agriculture who was once a Monsanto employee and is considered Industry biased. As he is responsible for writing the regulations on how to inform the public about GMOs and ensure enforcement, clearly there is a “fox in the hen house” scenario and full transparency for “the good for the people” compromised every step of the way.

It is recommendation that other Federal Departments be involved in the guideline process to ensure a balanced and favorable outcome for consumers.

Bill Text Page 2 :

Line 6 to 15: ‘‘(1) BIOENGINEERING.—The term ‘bio- engineering’, and any similar term, as determined by the Secretary, with respect to a food, refers to a food—

‘‘(A) that contains genetic material that has been modified through in vitro recombinant deoxyribonucleic acid (DNA) techniques; and

‘‘(B) for which the modification could not otherwise be obtained through conventional breeding or found in nature.

These lines put forth the defining guidelines of bioengineering and lays out A & B sections what the Bill covers. It falls short. We suggest that the definitions are too narrow and should include any food in any manner or method connected to, grown on, or combined with any Genetically Engineered molecule in any manner. For instance, we know that certain bioengineered bases such as algae can be used as starters for growing certain products. The way the Bill is written, this may slip under the radar.

Bill Text Page 3

Line 1 – 6: ‘‘(b) APPLICATION OF DEFINITION.—The definition of the term ‘bioengineering’ under section 291 shall not affect any other definition, program, rule, or regulation of the Federal Government. ‘‘(c) APPLICATION TO FOODS.—This subtitle shall apply only to a food subject to—

We know that Government regulations are tricky, inconsistent, and massively complex and in this case, a food mine field. Wiggle room appears in Industry’s favor instead of a new standard with teeth for the consumer. It is proposed that the definition of “bioengineered” is limited to this bill and will not affect any other Bill. We the People would like wording where the language SHALL be the baseline of definition, program, rule, and regulation pertaining to food across ALL Departments and ALL regulations, including International trade CODEX related bleed through.

Lines 5 – 25: ‘‘(c) APPLICATION TO FOODS.—This subtitle shall apply only to a food subject to—‘‘(1) the labeling requirements under the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 301 et seq.); or‘‘(2) the labeling requirements under the Federal Meat Inspection Act (21 U.S.C. 601 et seq.), the Poultry Products Inspection Act (21 U.S.C. 451 et seq.), or the Egg Products Inspection Act (21 U.S.C. 1031 et seq.) only if—‘‘(A) the most predominant ingredient of the food would independently be subject to the labeling requirements under the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 301 et seq.); or‘‘(B)(i) the most predominant ingredient of the food is broth, stock, water, or a similar solution; and‘‘(ii) the second-most predominant ingredient of the food would independently be subject to the labeling requirements under the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 301 et seq.).

This section appears extremely tricky as apparently only the top “two” primary ingredients” are required to be labeled. This means that if 2 ingredients make up 30% and 28% of a product, these require labeling. If the next ingredient is 19%, there is no need for a transparent label. The question surfaces about regulations of items included in food that may be GE but not counted as the top two. For example, food additives, food coloring, dyes, the results of emerging technologies, etc. would not have to be labeled as genetically engineered is they are less that the percentage of the top 2 products.

This troubling language allows existing language to “cloak ingredients” which in turn will remain hidden from consumers. This language falls in line with Industry’s position and does not offer “traffic control” measures against special manipulations of language and provisions as presented by Monsanto controlled or influenced organizations using CODEX guidelines. In essence, this provision guts the intent of any efforts to seek full transparency.

The preference would be something like was presented in the European labeling provisions: For example, where when a product contains more than 2 major ingredients or compounds, the label must be accompanied by “a list, in brackets, of its ingredients in descending order of proportion (m/m)“. As consumers, we want full transparency with no exceptions, such as chocolate as one example, where certain provisions are made so as not to fully disclose all harmful ingredients to humans.

Bill Text Page 4

Line 5: ‘‘(a) ESTABLISHMENT OF MANDATORY STANDARD.— Not later than 2 years after the date of enactment of this subtitle, the Secretary shall—

The two-year implementation may be acceptable in general; however, only with provisions that clearly protect the consumer and not industry. Any progress made in any State, such as Vermont, at the vote of consumers ought to remain in place as an additional driver to ensure that industry will step in line with transparency.

Line 8 to 19: ‘‘(1) establish a national mandatory bioengineered food disclosure standard with respect to any bioengineered food and any food that may be bio- engineered; and‘‘(2) establish such requirements and procedures as the Secretary determines necessary to carry out the standard. ‘‘(b) REGULATIONS.—‘‘(1) IN GENERAL.—A food may bear a disclosure that the food is bioengineered only in accordance with regulations promulgated by the Secretary in accordance with this subtitle.

There appears to be too much room for the Secretary of Agriculture to establish guidelines that have a “ceiling” to disclosure, especially being a past employee of Monsanto. This makes no sense and is not transparent. The wording is very tricky.

It puts into place a “ceiling” allowed and too much counter control over manufacturers who wish to be completely transparent for consumers. For example, if a food product manufacturer wishes to disclose more information on it’s product label, it would not be able to do so….in fact it would be prohibited from doing so  If, for example, GE corn is used in a burger as a filler, the consumer would not be allowed to know in complete transparency.

It is suggested that further instructions are needed to instruct the Secretary to include a balance of testimony, feedback, and resulting guidelines that include input and representation from the consumers side of the issue and not just stacked in favor of the food industry.

It is further suggested that after line #11, there be an add in that “any and all ingredients or elements of a food that involved GE at a molecular level, in the process of formulation, any stage of growth, or combinations, mixing, etc.” require labeling as Genetically Engineered or Bioengineered.

Line 23 to Page 5 line 2: ‘‘(A) prohibit a food derived from an animal to be considered a bioengineered food solely because the animal consumed feed produced from, containing, or consisting of a bioengineered substance;

This flies into the face of transparency for the consumer. It prohibits a food derived from an animal to be considered bioengineered, even if that animal only ate GE food all of its life. The language ignores the fact that the animal was force fed 100% GMO seeds, crops, grains, etc. and makes it “OK” not to inform consumers. Simply, this is not right, nor transparent for Moms and Dads.

Bill Text Page 5

Line 3 to 6: ‘‘(B) determine the amounts of a bioengineered substance that may be present in food, as appropriate, in order for the food to be a bioengineered food;

Save taxpayers money and the government bureaucrats’ time, please use the word “ALL” and end any waste of government spending and time here. Again, this means that the USDA could determine that a product that contains 28% GMO corn is not required to be labeled because it contains 40% organic grain; and 32% organic rice syrup … it may not be called organic but also not GMO…there simply is too much wiggle room here. The sliding scale is skewed towards industry. Clear and true Congressional guidance on this matter would be surprisingly wonderful and instructive.

Line 11 to 17: ‘‘(D) in accordance with subsection (d), re- quire that the form of a food disclosure under this section be a text, symbol, or electronic or digital link, but excluding Internet website Uniform Resource Locators not embedded in the link, with the disclosure option to be selected by the food manufacturer;

Simply: NO! NO! NO! Clearly, the GE product information should be on the product itself – labeled and transparent and easy to be seen by the consumer. Stop the cloak dance. This is a minimum requirement for transparency; if a link for more information is offered, terrific, but not at the cost of fully transparency..

Further, I would purport that, any technical access still would be a barrier of technology for the average consumer and therefore an infraction of the accessibility principles set forth in the ADA (American Disabilities Act). We do seek NO economic discrimination of any kind that sets the stage for discrimination and barred access to information.

Line 18 to 20: (E) provide alternative reasonable disclosure options for food contained in small or very small packages;

The small consumer is always favored and supported to ensure economic freedom and to encourage development of terrific products. However, in these cases, the disclosure of GE ingredients is a requirement 100% for consumer protection, and the larger suppliers of the products can be leveraged a fee that supports the labeling process by small manufacturers who cannot afford the costs invovled.

Bill Text Page 6

Line 15 to 18:(G) exclude—  ‘‘(i) food served in a restaurant or similar retail food establishment; and (ii) very small food manufacturers.

On the contrary to excluding restaurants and small retailers, we believe that consumers should be informed of their rights at all levels. Once set up, a restaurant can easily provide consumers GE information.

The exclusion for small food manufacturers can still be challenging for consumers, although the market may be limited. This particularly comes to mind in relationship to “ very small” food provider of baby food, which may contain 100% GE corn and be allowed to be distributed under the radar with the new provisions.  This is unacceptable.

Line 21 to page 7 line 2: 2), a bioengineered food that has successfully completed the pre-market Federal regulatory review process shall not be treated as safer than, or not as safe as, a non-bioengineered counterpart of the food solely because the food is bioengineered or produced or developed with the use of bioengineering.

This paragraph is HUGELY revealing as it protects the position of Industry, seeking assurance that their GE food is not viewed as “bad or less than” normal, regular, God given food products. Government has no business providing research for industry and taking a protective stance at the expense of consumers. It needs to support equally balanced research. This is “government by and for the People.”

For the government to back the “safety” of GE food would be a bias against organic and conventional food. Clearly, this is a provision to support those who fund politics…possibly, in this case Monsanto and the industry’s drivers.

Bottom line, there is an unequivocal need to equally protect consumers.

Bill Text Page 7


The response is simple – until 100% of Americans are technologically literate and have free access to the tools necessary to be properly informed of their food choices, complete product transparency should be on the food product itself. This is not rocket science.

At this time, any money spent by government on moving towards technological advancement and guidelines for electronic labeling is a waste of time and money. Notwithstanding this author’s position and most of our desires to support advancement, this is for another time. Possibly engaging high tech companies to fund such a study and effort would be more economically viable and more favorable to consumers across the board.

Line 8 to 16: ‘‘(4) ADDITIONAL DISCLOSURE OPTIONS.—If the Secretary determines in the study conducted under paragraph (1) that consumers, while shopping, would not have sufficient access to the bioengineering disclosure through electronic or digital disclosure methods, the Secretary, after consultation with food retailers and manufacturers, shall provide additional and comparable options to access the bio- engineering disclosure.

The food manufacturers are passing the buck here from full disclosure on the shelf. It is industry’s responsibility, not a store’s, to inform consumers what is in a product. This section passes the responsibility for electronic labeling and access to this information to the local store itself. This is a burden on small businesses and local businesses and creates a situation where there is no assurances that transparency can be offered at a local level.

Regarding line 11, this especially creates a “digital divide” among consumers and targets low income individuals, families, neighborhoods and seniors who are technologically challenged, disabled, or cannot afford readily accessible technology or phones. There may be a required cost involved to ensure proper access to all citizens if this tact is taken; and, Industry and Government should ensure complete access for all Americans prior to any implementation of this technological approach.

On line 16 – 17: paragraph (1) shall consider whether consumer access to the bioengineering disclosure through ……..

The word should not be “shall” but must. This entire electronic access issue is a cop out…just label food products and make it clear at the point of purchase   This alternative disclosure not only restricts busy moms and dads and children, but also creates barriers in language, culture, economic affordability, etc. which has not properly been addressed.

Bill Text Page 8

This page simple continues the line of thinking around technology access to food. Again, this is a smoke screen issue that is underfunded and discriminatory as mentioned above.

Possibly funding might be provided by and for Tech companies to provide guidelines and resources to address all aspects of this issue fairly without economic or technological discrimination.

Bill Text Page 9

 Line 3 to 13: ‘‘(B) any telephone number disclosure, indicating that the telephone number will provide access to additional information by stating only ‘Call for more food information.;‘‘(2) the electronic or digital link will provide access to the bioengineering disclosure located, in a consistent and conspicuous manner, on the first product information page that appears for the product on a mobile device, Internet website, or other landing page, which shall exclude marketing and promotional information;

Easy access to complete information is the goal at the point of purchase of a product. Any additional information about a food product where there is a tradeoff to complete transparency at point of purchase is simply a barrier and a violation of the intention and purpose of this legislation.

Further, access to food information would be like calling the IRS for information where there is no actual interpretation of a regulations because of liability….and a lengthy wait. Does industry really want the liability or take the risk of giving out such detailed information over the phone? Further, I cannot imagine a busy mother on the phone for ½ hour waiting to get information on her can of soup.

Make this easy; don’t over complicate this simple issue of a clear label for consumers.

Bill Text Page 10

line 4 to 13: (e) STATE FOOD LABELING STANDARDS.—Notwithstanding section 295, no State or political subdivision of a State may directly or indirectly establish under any authority or continue in effect as to any food in interstate commerce any requirement relating to the labeling or disclosure of whether a food is bioengineered or was developed or produced using bioengineering for a food that is the subject of the national bioengineered food disclosure standard under this section that is not identical to the mandatory disclosure requirement under that standard.

Obviously, this language pre-empts Vermont and other State’s efforts to provide its constituent access to safe food. This also takes away any State’s ability to monitor it’s food supply closer than is allowed by the Feds or require “more disclosure” on certain food products for its residents

Bill Text Page 11

This section addresses record keeping and monitoring.

A major concern is that there is no clear “sanction or recall” reference or provision if a company is out of GE labeling compliance. What specifically are the warning and sanction steps offered?  The Department can look away easily on this one if compliance is not spelled out or does not occur in a “self regulated” manner by a large multi-national corporation. We seek no exceptions.

Bill Text Page 12

Lines 3 to 6: ‘‘SEC. 294. SAVINGS PROVISIONS.‘‘(a) TRADE.—This subtitle shall be applied in a manner consistent with United States obligations under international agreements.

For much food that is mixed or combined with products grown internationally, this provision “requiring no labeling” as written elsewhere, appears to undercut consumer transparency and leans in favor, again, for industry over moms and dads and families.

There are too many questions here: does CODEX override US laws and regulations? What about products receive by the US through international trade? Will these require labeling of GMO? Does this mean that Monsanto grown corn from South America does not have to be labeled in a US product?

Line 13 to 16: ‘‘(2) affects the authority of the Secretary of the Treasury or creates any rights or obligations for any person under the Federal Alcohol Administra- tion Act (27 U.S.C. 201 et seq.).

This means that alcohol is out and not regulated, although we just read in the press recently how GE ingredients are found in massive quantities in wine and not disclosed to the consumer. We demand full disclosure here also, before we drink, as well as eat.

Line 17 – 21: ‘‘(c) OTHER.—A food may not be considered to be‘not bioengineered’, ‘non-GMO’, or any other similar claim describing the absence of bioengineering in the food solely because the food is not required to bear a disclosure that the food is bioengineered under this subtitle.

Legislation gibberish – what the heck does this mean? Double negatives and the appearance of double speak creates non-clarity and possible hidden meanings. Simply, consumers seek complete transparency.

Bill Text Page 13

Lines 8 to 19:  ‘‘(b) FEDERAL PREEMPTION.—No State or a political subdivision of a State may directly or indirectly establish under any authority or continue in effect as to any food or seed in interstate commerce any requirement relating to the labeling of whether a food (including food served in a restaurant or similar establishment) or seed is genetically engineered (which shall include such other similar terms as determined by the Secretary of Agriculture) or was developed or produced using genetic engineering, including any requirement for claims that a food or seed is or contains an ingredient that was developed or produced using genetic engineering.

This section clearly protects industry from any local or “supportive” business being completely transparent to its consumers about the GE ingredients in a food product. Simply, here is where the Monsnato Groups insert a protection clause of its GMO crops by prohibiting consumers from revealing the truth or labeling “out of line”. If the labeling of a product is transparent and unsafe, this tapes our mouths…clearly a step backwards.

Bill Text Page 14


In the case of a food certified under the national organic program established under the Organic Foods Production Act of 1990 (7 U.S.C. 6501 et seq.), the certification shall be considered sufficient to make a claim regarding the absence of bioengineering in the food, such as ‘‘not bioengineered’’, ‘‘non-GMO’’, or another similar claim.

Here is a huge success for Organic Labels. However, monitoring is always required to ensure that there is 100% disclosure and no “hidden” ingredients allowed. Ractopamine, an animal additive, for example, can be used in meat and not labeled for consumer transparency…this labeling is a tricky business and a dance that demands constant surveillance.



Tuesday, June 21, 2016 @ 03:06 PM
posted by Rudi

HEADS UP……let’s be ready for a sudden push back if a Senate compromise stops the Vermont GMO labeling trigger on July 1. See this recent summary from DC.

Ginger 11

By Helena Bottemiller Evich

With help from Catherine Boudreau, Ian Kullgren, Jason Huffman and Kathryn Wolfe

STABENOW: GMO LABELING DEAL ‘CLOSE’: Sen. Debbie Stabenow (D-Mich.) said late Monday that she and Sen. Pat Roberts (R-Kan.) are “narrowing the issues” surrounding GMO labeling legislation and are “close” to reaching a deal — but have not shared a draft in the Senate.


She said they have been meeting constantly. But questions remain over one of the most fundamental issues: whether on-pack labels should be part of a mandatory disclosure system. Come July 1 on-pack labeling will become the de facto national standard, as food and beverage manufacturers will be forced to comply with Vermont’s law or potentially face a $1,000 fine per day, per product.

Hope for a voluntary labeling standard faded in March when legislation offered by Roberts failed to secure the 60 votes needed to move forward. Shortly thereafter, companies like Mars and General Mills announced they would start labeling products containing GMOs, while PepsiCo appeared to quietly make the move in April. The pro-labeling camp is keeping track. Just Label It, a coalition of consumer advocacy, environmental and organic industry groups, has created a Facebook page featuring photos of products featuring disclosures about genetically engineered ingredients. The Grocery Manufacturers Association and biotech and agricultural industry groups worry that these products will be unfairly stigmatized by anti-GMO activists and companies will reformulate away from biotech ingredients.

Tick tock: There are 10 calendar days left before Vermont’s law takes effect, but Stabenow and Roberts really only have four legislative days left, considering the House won’t be in session all next week, the Coalition for Safe Affordable Food warned. This all feels a bit like the movie “Groundhog Day,” right?


Pretzel Politics – Ag Giants and GMA twist the GMO Game into Knots

Monday, March 14, 2016 @ 07:03 PM
posted by Beth Clay

Senator McConnell and Senator Roberts Contort Senate Procedures Like a Pretzel
to Keep Monsanto, Agriculture Giants and Grocery Manufacturer’s Association Happy!

March 14, 2016: Media Pundits Remind Us Daily that Americans Are ANGRY at Washington. The latest legislative machinations of senators determined to protect the interests of corporate giants over the wishes of the American people regarding mandatory labeling of bioengineered (GMO) foods underscore exactly what is wrong in Washington.



American consumers have overwhelmingly sought to have genetically modified foods labeled for two decades. Vermont is the first state to pass legislation that will be enacted in 2016. While Republicans typically defend the rights of States, and push to leave authorities with the States, they have complied with industry request to establish a national labeling standard. The catch, is they are not meeting or exceeding the state mandatory labeling provision, but lowering the standard to voluntary, in essence the standard that already exists because the US Food and Drug Administration (FDA) got it wrong from day one of regulating GMOs.

A House bill, H.R.1599 – Safe and Accurate Food Labeling Act of 2015 originally drafted by the Grocery Manufacturers Association, passed in July 2015. The Senate Agriculture Committee took up the issue, with Chairman Roberts posting a draft bill, which was voted out of Committee on March 1, 2016. He then introduced that bill as S. 2609. The two bills do not match.

Tonight, Senator McConnell on behalf of Senator Roberts last night posted Amendment No. 3450 as a Substitute Amendment to replace S. 764 as a mechanism to pass a new version of his voluntary biotech food labeling bill (different than what came out of Committee. The original S. 764 introduced by Mr. Wicker (for himself, Mr. Schatz, Mr. Sullivan, and Ms. Cantwell) was about to “reauthorize and amend the National Sea Grant College Program Act” and passed the Senate in July 2015 under Unanimous Consent.

In Mid-September the House, using the nature of a full substitute mechanism, struck all of the language after the enacting clause and insert a defunding planned parenthood bill in its place. The bill that was engrossed and sent back to the Senate as S. 764 “Resolved, That the bill from the Senate (S. 764) entitled “An Act to reauthorize and amend the National Sea Grant College Program Act, and for other purposes.”, do pass with the following AMENDMENT: Strike out all after the enacting clause and insert: SECTION 1. Short title. This Act may be cited as the “Defund Planned Parenthood Act of 2015”.” Not a single word regarding National Sea Grant College Program remained.

Now, S. 764 is to have come up for cloture vote maybe as soon as Wednesday, shorting cutting all of the standard legislative procedures and open discussion with a new version of Sen Robert’s S. 2609 voluntary labeling of biotech (GMO) foods bill which seeks to permanently preserve biotech food labeling as voluntary.

Setting aside the issue of GMO labeling, how is no Senator objecting to this sleight of hand on bills? How does a bill regarding the National Sea Grant College Program leave the Senate and come back a bill on Defunding Planned Parenthood and then get switched a second time to a Biotech (GMO) food labeling bill? Why is no Senator opposing this manipulation of the process?

What is in the new bill? In comparing the Amendment to the text of S. 2609 (which was voted out of the Agriculture Committee), there are several pages inserted into the middle of the Bill. A section references bar code voluntary labeling was inserted; the language on State Food Labeling Standard is different and includes an additional provision on instructing the Secretary of Agriculture to establish consistency between this provision and Organic food provisions. An apparently new provision was introduced as well – Section 294 which provides instruction on rulemaking regarding food labeling related to bioengineered foods and define the term ‘most frequently consumed labeled foods’. Also new is Section 294a which calls for the Secretary to establish a mandatory labeling standard if certain very complex (and potentially impossible to meet) provisions are met during rulemaking. It also includes language similar to the House version related to not implying risk of harm from bioengineered foods.

At the end of the day, the new S. 764 seeks to placate the very generous political donors such as Monsanto, GMA (who were just found guilty of skirting disclosure laws in the Washington State battle two years ago) and all of their member companies and ignores the wishes of the American people.

Can this bill be stopped? Yes, if the Senators do not get 60 colleagues to vote for Cloture. The cloture process, suspends the debate (which is not even taking place apparently); and Senator McConnell and Senator Roberts can move to vote on passage. It can also be stopped is even one Senator objects and puts a hold on the Bill. There are PLENTY Of reasons to put a hold on this bill. Senator Wicker, Schatz, Sullivan, and Cantwell could object to the hijacking of their original bill.

What Can I Do? Time is Short for Action but We Can and Should Act.

1. We all need to get involved immediately and call our own Senators and ask to vote no on Cloture on S. 764; vote not on passage of S. 764.
The Senate Switchboard is 202-224-3121
2. Consider going on the internet to http://www.senate.gov and go to the page for your two Senators – they will each have an online email – send a short message identifying yourself as a Constituent, and asking the Senator to vote no on S. 764 the Biotech (GMO) voluntary labeling bill. Ask for a follow up contact from the Senate office in the email.
3. If you use Facebook and Twitter and send messages to your Senators opposing passage of S. 764.

The POP Campaign agrees with American consumers – we do not want to be kept in the DARK, we want mandatory labeling of GMO foods. (http://popcampaign.org)


GMO Labeling Update

Saturday, March 12, 2016 @ 04:03 PM
posted by Rudi

3/12 UPDATE ON OUR NEXT CHESS MOVE – our best information we have is that  heavy duty negotiations are still in play among the Senate leadership on both sides of the GMOP labeling issue.  We will keep you informed….please continue calling   your Senators: YES on bill S 2621 and NO on S 2609 – Capitol switchboard @ 202-224-3121 – small steps but important steps.


UPDATE 3/4:  ““It was the best of Bills, it was the worst of Bills.” Charles Dickens if he were looking at Washington GMO Labeling Bil Today

(You’ll always call your Senators and voice your support: 202-224-3121) Senators Merkley, Leahy, Tester, Feinstein introduce a GMO labeling bill – S 2621. This legislation ensures that consumers can find GMO labeling on food packaging while ensuring that food producers are not subject to confusing or conflicting labeling requirements throughout the Country. Introduced in the Senate HELP Committee.  We do not know when a hearing is scheduled.

Senator Roberts railroaded through the Agriculture Committee Bill 2609 – yes – the meeting took about an hour and he asked for a vote (11 to 6) before he even heard comments from all of the Senators.  This bill amends the Agricultural Marketing Act of 1946 to require the Secretary of Agriculture to establish a national VOLUNTARY labeling standard for bioengineered foods, and for other purposes.

Really funny in the hearing is that, Senator Chuck Grassley of Iowa, himself a corn and soybean farmer, spoke and seemed to establish a new standard for safety in science – that he as a farmer goes out into the field to check if the crop is ready for harvest by popping corn kernels or soy in his mouth and that he is perfectly healthy!

Oh my…….. move over Donald.

Other Senators who were opposed, realizing the futility of the situation, simply spoke of their opposition but saved their push back for another time….possibly even a Senate floor fight.



29 February 2016

The Honorable Debbie Stabenow

United States Senate

Washington, D.C. 20510-2204

Dear Senator Stabenow:

The POP Campaign is a non-profit organization focused on protecting the organic standards of our food supply, educating the public and policy makers about the importance of high quality foods and the role these foods and their nutrients, enzymes, vitamins and minerals have on our overall well-being and the health and well-being of our children and future generations. We believe an informed consumer is an empowered consumer; that informed and supported moms and pops will ensure healthy generations of children.

We believe that a mandatory labeling provision suggested during the Agriculture Committee’s October 2015 hearing is needed.

We strongly are requesting that a mandatory labeling provision be suggested that all baby food for babies under the age of three years old be labeled GMO within three (3) years.

Protect me, I am important

We agree with the vast majority of Americans and global citizens who are concerned about the dramatic reliance in our agriculture community of genetically modified crops and the associated pesticides used with them.  Sadly, in the United States, soy, corn and wheat farms are almost all GMO crops. We are losing heritage crops and diversity in seed strains.

While the companies that produce genetically modified seeds and associated pesticides want legislators and the public to believe there is scientific consensus on the safety and benefit of their products; this assertion is false.  Hundreds of scientists world-wide have expressed concern that GMO crops have not been proven safe for animal or human consumption and that regulators have failed to validate the safety by relaxing the safety standards in order to accommodate powerful corporate organizations with deep friendships across the political landscape.

We appreciate the stance you took in 2015 to stop the speedy advance of legislation that would entrench in law a voluntary standard for GMO food labeling, while superseding the more stringent state laws already passed. We know you will make history with a provision to minimally protect babies for generations to come.

The ‘Chairman’s Mark’ draft bill that has been posted on the Senate Agriculture Committee website is a ‘dream bill’ for industry and blatantly ignores the desires of the public. It is not fair to consumers. Consumers in the United States should be afforded the same level of information on their food labels as the 64 countries that have already mandated GMO ingredient labeling, without causing major food producers any discernible burden, or driving food prices up.

In speaking with your staff, we know you are working hard to develop a strategy for mandatory labeling, and know that a party line vote may over rule your actions on the committee.  In looking for a fallback position, and because there is no scientific evidence that provides any measure of comfort to American parents on the safety of GMO food ingredients for a developing infant and toddler, we would like to suggest/request that you put forth an amendment to mandate that all infant formulas and baby/toddler foods have mandatory labeling of biotech (GMO) food ingredients.

While we want all foods to have mandatory labeling; infant formula and baby/toddler foods may be the only source of nourishment for infants and toddlers.  Moms and Pops need the ability to find out if their baby’s formula, cereals and other foods were made with GMO ingredients so they can make an informed decision for their child.

Let’s give American children a chance at quality health.

Thank you for this consideration.


Rudhi Leonardi

The POP Campaign




cc  Senator Diane Feinstein

Senator Barbara Boxer


TIME TO ACT QUICKLY – Committee Hearing March 1

Tuesday, February 23, 2016 @ 10:02 AM
posted by Rudi

UPDATE: The Senate Ag Committee DELAY meeting to MARCH 1 to mark up a bill to preempt states’ rights and to prevent Vermont’s GMO labeling law to go into effect on July 1, 2016. We know there are Senators who will vote to label and will introduce measures….. we all need to come together to make a difference here for generations to come.


CONGRATS – Our Community Stepped Up…and you have a Victory

Wednesday, December 16, 2015 @ 04:12 PM
posted by Rudi

Congratulations Everyone….YOU DID IT. We stopped the GMO language from being in the Budget–not an easy feat. Your voice counts and was heard. Together, we made a huge statement and helped move a mountain. The next phase will occur in January – in the mean time, happy holidays….and please keep us in mind for any year-end donations. We celebrate you and seek to protect our lifestyle and your children and theirs. SEE THE PRESS RELEASE BELOW:

For Immediate Release Contact: Rudi Leonardi at 1-415-999-9414
December 16, 2015 Email: Rudi@popcampaign.org

The POP Campaign Congratulates Congress for Standing Firm with Americans and Not Inserting GMO Rider into Omnibus Spending Bill

The POP Campaign (Preserve Organic Power) is pleased that Congress stood firmly with all of you and the American public and did not insert the GMO Rider into the Omnibus Spending Bill.

“Congratulations to our community on this huge big step. There is NO scientific consensus that GE foods are safe for human consumption. Published evidence validating safety for human consumption remains insufficient. We will remain vigilant in 2016 and do whatever we can to ensure quality food and choices for you and our children“ Brian Clement, Director of the Hippocrates Health Institute stated.

For 20 years, the American people have overwhelming desired to have the Food and Drug Administration (FDA) to require mandatory labeling of genetically engineered (GE or GMO) foods. A misguided FDA has taken their cues from industry and refused. A recent survey found that 9 of 10 consumers wanted this transparency in their food labeling. Now they are beginning to listen to the challenges by you as concerned parents and conscious consumers. We will keep up our voice that “Quality Food is a Human Right”.

The POP Campaign particularly wants to thank Senators Debbie Stabenow and Jon Tester for taking a strong and public stand against using the must pass Omnibus Bill as a vehicle to pre-empt the laws of state and local jurisdictions. This leaves GMO labeling voluntary at the federal level until it is taken up in 2016. We also thank the Senate as a whole for not agreeing with Industry’s supported Pompeo Bill HR 1599.

We also want to thank all of the other legislators involved in this battle for consumers and children including Senators Boxer, Feinstein, Leahy, Merkley, and Mikulski as well as Representatives Defazio, Polis and Young. We want to thank Speaker Ryan, Minority Leader Pelosi, Majority Leader McConnell and Minority Leader Reid for working with these legislators on behalf of American families.

While this is a major victory for the American people, we realize the issue is not entirely resolved. In 2016, Congress likely will address genetically engineered food labeling issues. The POP Campaign stands with all of you is standing firm that all foods from apples and alfalfa, corn, soy, and wheat to salmon that are genetically engineered should be labeled clearly.’ You, as consumers in the United States who care about this issue, like consumers in more than 60 countries around the world, have a right to make informed purchasing decisions at your grocery store. The POP Campaign and the Hippocrates Health Institute and our networks will do everything to support this right.

A mandatory labeling system is an easy, can-do solution for the federal government. If Congress does not want to mandate this, then leave the issue to the states.

A very special thanks to our on the ground voice in DC, Beth Clay, for her diligent efforts in keeping our presence live during these tipping points.

For more information about the POP Campaign, including its initiatives to ensure that baby food is labeled, please visit our FB page, website, and make a donation – you count and we voice your concernshttp://popcampaign.orgGinger 11


Short Extension: Call NOW as Budget Deadline is Postponed until approx Dec 15th-16th

Thursday, December 10, 2015 @ 03:12 PM
posted by Rudi

Heads Up: An extension was put through so Congress will work on the budget over the weekend and publish it on Monday and vote shortly after that – at least their goal.  Presumably Speaker Ryan said there would be a 3-day rule for review by the public so it appears there will be a vote next Wed or Thursday.   The Monsanto, Grocery Manufacturers and other BIG monied corporations and associations are pulling out all of the stops to get their protections in this year. Keep the calls coming and stand up for your health  and that of your children.

Save Our Children and theirs…..Speak out for your family history….label their food, they need to know! 
Call Today with a Clear Message:  I join with the POP Campaign in asking that no GMO food labeling language be included in the Omnibus Appropriations Bill due, or any other legislation this year. (We support GMO labeling but this leaves GMO labeling voluntary at this time.) Call your legislators today…the Switchboard number is:  (202) 224-3121. (NOTE: The operator will connect you to Congressional offices.  Also, use social media, (Facebook, Twitter) to reach out to your legislators online and send the same message.) You CAN make a difference – Act Now!

Ginger 11

December is a time when lots of shenanigans can take place in legislation and the legislative process. This year, Congress has a deadline of December 11 to pass an Omnibus Appropriations Bill to avoid a government shutdown. Republicans who have control of both the House and Senate know that shutting the government down, especially weeks before Christmas, can have devastating political consequences in the next election cycle and they do not want to see that happen. So timing is now!
The industry written legislation introduced by Congressman Pompeo  (HR 1599 Safe and Accurate Food Labeling Act of 2015) passed the House a few months ago. It does not yet have a Senate companion bill and is not likely to see passage by year’s end. Monsanto and its industry partners are pushing legislators to insert the core provisions of HR1599 – the state laws pre-emption and the voluntary labeling sections –  into the must pass Omnibus bill.  
Senator Stabenow, a ranking member on the Agriculture Committee, so far has not agreed to this insertion, but she needs more legislators in both the House and Senate to oppose the industry’s aggressive actions. These attempts are to use the Omnibus bill as their vehicle to shut down the state and local GMO labeling laws and to keep consumers in the dark about what is in our foods. Let’s stand up now and Save Our Children and theirs…..make this part of your family history….label their food, they need to know! 
Let’s make history together – please donate $20 to POP Campaign – http://popcampaign.org
            Call your legislators today @ (202) 224-3121 



Dear Friends and Colleagues…… before the Senate Votes in December! 

LET’S SPEAK OUT….DONATE…..SAVE OUR CHILDREN…@  http://popcampaign.org 
                  & GO MAD – GO Motivate GO Advocate & GO Donate…..  
To SAVE OUR CHILDREN.  food labels are necessary so we can easily make healthy choices.As parents supporting the POP CAMPAIGN, Preserve Organic Power, it is up to us to act to protect our children’s health and their children’s health and to protect our rights for truth in labeling. YES we are all busy and yet, this issue is too important to leave to someone else to do for us.

THREE – yes 3 easy things to do today to SAVE OUR CHILDREN!   We then will know that we did what we could for generations to come….

 1.  M = MOTIVATE – As Moms and Dads, We Motivate

Working Together we mobilize. How?  Act ourselves. Then, forward this to 3 other Moms or Dads (or groups) who have children and please MOTIVATE them

 to step up now             •  to speak out now                • to care now

about their children’s future…….let’s get the word out in a big way to  SAVE OUR CHILDREN.

Call your Senators at 202- 224-3121 to vote & support mandatory GMO labeling…. validate our message that parents nationwide demand mandatory labeling….for all food…Don’t keep us in the Dark …. especially for baby food for children under the age of 3 years.

Mention the POP Campaign – Preserve Organic Power – POP has Beth Clay, a mom of 4, in DC engaging directly with the Senate and  White House…keeping our message alive.

2. A = ADVOCATE – As Moms and Dads, We Advocate

TODAY WE CAN take the time to have our voices heard when it really counts – NOW!

TODAY WE CAN  connect as “the People” with other parents for a BIG  – YES for GMO LABLES

TODAY WE CAN post on Senators’ Social media outlets to label GMOs and to help us

                                          “SAVE OUR CHILDREN”

 3. DONATE – As Moms and Dads, We Donate

The POP Campaign and MOMs4POP Need Your Help to continue our presence in DC and continued raising your voice on these issues.  We are asking everyone to donate at least $20 to our non-profit campaign.  (Large donations of course are welcomed – thank you).

PLEASE DONATE here @   http://popcampaign.org   Make a difference for you & your Children




               PUSH TO MANDATE GMO LABELING…….NOW Label our food last-1


GMO Salmon Approved for Consumption

Thursday, November 19, 2015 @ 03:11 PM
posted by admin

Federal regulators on Thursday, November 19,2015,  approved a genetically engineered salmon as fit for consumption, clearing the last major obstacle for the first genetically altered animal to reach American supermarkets and dinner tables.20salmon-web1-master675

The approval by the Food and Drug Administration caps a long struggle for AquaBounty Technologies, the small company that first applied for approval in the 1990s. The agency made its initial determination that the fish would be safe to eat and for the environment more than five years ago.

The approval of the salmon has been fiercely opposed by some consumer and environmental groups, which have argued that the safety studies were inadequate and that wild salmon populations might be affected if the genetically engineered fish were to escape into the oceans and rivers.

Within hours of the agency’s decision, one consumer advocacy group, the Center for Food Safety, said it and other organizations would file a lawsuit to try to rescind the approval.

“This unfortunate, historic decision disregards the vast majority of consumers, many independent scientists, numerous members of Congress and salmon growers around the world, who have voiced strong opposition,” Wenonah Hauter, executive director of the group Food and Water Watch, said in a statement Thursday.

The AquAdvantage salmon, as it is known, is an Atlantic salmon that has been genetically modified so that it grows to market size faster than a conventionally farmed salmon.

“The F.D.A. has thoroughly analyzed and evaluated the data and information submitted by AquaBounty regarding the AquAdvantage salmon and determined that they have met the regulatory requirements for approval, including that food from the fish is safe to eat,” Bernadette Dunham, director of the agency’s Center for Veterinary Medicine, said in a statement.

F.D.A. officials said Thursday that the process took so long because it was the first approval of its kind. People involved in the application suspect the Obama administration delayed approval because it was wary of a political backlash.

The officials said the fish would not have to be labeled as being genetically engineered, a policy consistent with its stance on foods made from genetically engineered crops. However, it issued draft guidance as to wording that companies could use to voluntarily label the salmon as genetically engineered or to label other salmon as not genetically engineered.

Ronald Stotish, the chief executive of AquaBounty, which is majority owned by Intrexon Corporation, said he was delighted and somewhat surprised by the approval after all this time.

“We have been in this process for a very long time, working constructively and patiently wait for approval,’’ he said in an interview. “Now, we are ready to get on with our business.’’

However, Mr. Stotish declined to say what the plans were for bringing the fish to market, other than that the salmon would not be in stores immediately because it would take about two years for even these fast-growing salmon to reach market size. It is also not likely there will be much of the salmon on the market because the approved production facilities, which are in Panama, has the capacity to produce only about 100 tons of fish a year, a tiny amount compared with the roughly 300,000 tons of Atlantic salmon the United States imports each year, he said.00

Mr. Stotish said he did not know if approval was still needed from Panama to export the fish. “I have not asked that question, but I will, now that I have U.S. approval,’’ he said.

It is not clear how well the salmon will sell. Some leading supermarkets have already said, in response to environmentalists, that they have no plans to sell the salmon.

The F.D.A. does not require labels for genetically engineered foods. If genetic engineering results in a material change in a food — such as altering its nutrient content — the altered nutrition would be mentioned on the label, but not the fact that genetic engineering was used. In the case of the salmon, agency officials said, there were no meaningful differences between the engineered salmon and its conventional counterpart.

Certain consumer groups and organic food companies have been seeking in Washington and in state legislatures to require labeling of genetically engineered foods, and the approval of the salmon could galvanize their efforts. In addition to its draft guidance for voluntarily labeling salmon, the F.D.A. on Thursday released final guidance, years in the making, for how to voluntarily label food as to whether it was made from genetically engineered crops.

The fish are supposed to be raised inland, in contained tanks, to lessen the chances that they will escape into the wild. AquaBounty says this will also be less stressful on the environment than using pens in the ocean. And it could eventually allow the fish to be raised in the United States, rather than being imported, as most farmed Atlantic salmon is. Mr. Stotish has said in the past that organizations in the United States were interested in doing so.

For now, however, the fish are being raised in Panama, from eggs produced in Prince Edward Island, Canada. Approval to breed or raise the salmon elsewhere, for marketing to Americans, would require separate approvals.

Mr. Stotish said AquaBounty had applied for approval to market the salmon in Canada and Panama and would consider trying to sell it in other countries as well.

The approval could help other efforts to develop genetically modified animals. Scientists and biotechnology industry executives have complained that the long, unexplained delay in approving the salmon was a deterrent to the field. Several other attempts to develop genetically engineered animals for consumption, like a pig whose manure would be less polluting, have fallen by the wayside.

Now, however, there has been a surge of interest in developing new genetically altered farm animals and pets because new techniques, including one known as Crispr-Cas9, allow scientists to edit animal genomes rather than add genes from other species. That has made it far easier to create altered animals.

Scientists in China, for instance, recently created goats with more muscle and longer hair. Researchers in Scotland used gene editing to create pigs resistant to African swine fever. It is not clear yet whether animals created this way would even fall under F.D.A. regulation.

The AquAdvantage salmon contains a growth hormone gene from the chinook salmon and a genetic switch from the ocean pout, an eel-like creature, that keeps the transplanted gene continuously active, whereas the salmon’s own growth hormone gene is active only parts of the year. The company has said the fish can grow to market weight in as little as half the time of a conventionally farmed salmon.

Opponents of the fish say that if the bigger fish were to escape, they could outcompete wild salmon for food or mates. Other scientists have dismissed these concerns. The F.D.A. said on Thursday that there were multiple physical barriers in the Canada and Panama facilities to prevent this. The salmon are also made sterile to prevent reproduction in the event they do escape, although the sterilization technique is not foolproof.

AquaBounty first applied for approval of the salmon in the 1990s, but it took years to determine what data would be needed and how the salmon would be regulated. In 2010, the F.D.A. tentatively concluded the fish would be safe for people and the environment. In September of that year, an advisory committee found some fault with the F.D.A.’s analysis but did not in general challenge the overall conclusions. Then in December 2012, the F.D.A. released a draft environmental assessment that also concluded that salmon would pose little risk to the environment.

The F.D.A. regulates genetically engineered animals as veterinary drugs, using the argument that the gene inserted into the animal meets the definition of a drug. Critics have branded this an inadequate solution intended to squeeze a new technology into an old regulatory framework. They say the F.D.A. is not as qualified as other government agencies to do environmental assessments. The White House is now reviewing the entire framework for regulating genetically engineered products.

The F.D.A. said that to approve the salmon, it determined that the fish was safe to eat, that the inserted genetic elements did not harm the fish itself, and that the company had adequately proved that the salmon grew faster.

AquaBounty, which is based in Maynard, Mass., has long struggled to raise enough money to stay in business. It is now majority owned by Intrexon, a company started by the biotechnology entrepreneur Randal J. Kirk to pursue synthetic biology, a term for sophisticated genetic engineering.

Intrexon has also acquired the company that developed a recently approved genetically modified apple resistant to browning and a British company working on genetically modified insects, such as mosquitoes that might be tested in the Florida Keys as a way to prevent dengue fever. Shares of Intexon were up 7 percent early Thursday afternoon.


BACON, HAM & SAUSAGES “as big a cancer threat as smoking” WHO to warn

Monday, October 26, 2015 @ 09:10 AM
posted by Rudi

The WHO is expected to publish a report listing processed meat as a cancer-causing substance with the highest of five possible rankings

Bacon being grilled

When meat is preserved by smoking, curing or salting, or by adding preservatives, cancer-causing substances (carcinogens) can be formed Photo: Alamy
 By Agency

10:51AM BST 23 Oct 2015

Comments1818 Comments

Global health experts are to warn that bacon, ham and sausages are as big a cancer threat as cigarettes, it has been reported.

“The WCRF advises that people can reduce their bowel cancer risk by eating no more than 500g (cooked weight) per week of red meat, such as beef, pork and lamb”

The World Health Organisation(WHO) will publish a report on Monday on the dangers of eating processed meats.

It is expected to list processed meat as a cancer-causing substance, while fresh red meat is also expected to be regarded as bad for health, the Daily Mail said.

The classifications, by the WHO’s International Agency for Research on Cancer, are believed to regard processed meat as “carcinogenic to humans”, the highest of five possible rankings, shared with alcohol, asbestos, arsenic and cigarettes.

The World Cancer Research Fund (WCRF) has warned for several years that there is “strong evidence” that consuming a lot of red meat can cause bowel cancer.

• Gene increases cancer risk posed by processed meat

It also says there is “strong evidence” that processed meats – even in smaller quantities – increase cancer risk.

One possible reason is that the compound that gives red meat its colour, haem, may damage the lining of the bowel.

In addition, when meat is preserved by smoking, curing or salting, or by adding preservatives, cancer-causing substances (carcinogens) can be formed.

Studies also show that people who eat a lot of red meat tend to eat fewer plant-based foods that protect against cancer.

The WCRF advises that people can reduce their bowel cancer risk by eating no more than 500g (cooked weight) per week of red meat, such as beef, pork and lamb.

It also says people should eat processed meats such as ham, bacon and salami as little as possible.

Burger King's bacon double cheeseburger, coming soon to a home near youHamburgers count as red meat  Photo: burgerking.co.uk

Foods like hamburgers, minced beef, pork chops and roast lamb are also regarded as red meat.

As a rough guide, the WCRF says 500g of cooked red meat is the same as 700g of raw red meat.

• Processed meat blamed for one in 30 early deaths

Processed meat is meat which has been preserved by smoking, curing or salting, or by the addition of preservatives.

Examples include ham, bacon, pastrami and salami, as well as hot dogs and some sausages.

How much red meat do we eat?

The average person in the UK has 2.5oz (70g) meat a day 3oz (88g) among men, 2oz (52g) among women) but 33 per cent have more than 3.5oz (100g) a day.


Summary of the Senate Subcommittee Hearing on GMOs and Biotech 10/21/2015

Wednesday, October 21, 2015 @ 05:10 PM
posted by Beth Clay

A quick report on the Senate “Biotech” Food Regulations Subcommittee Hearing held today. (The POP Campaign submitted testimony to be posted soon)

Almost all of the members made at least a short appearance (except Mitch McConnell, maybe Thad Cochrane and maybe on David Perdue)

Rather than an ‘oversight’ activity, it seemed more like a lovefest of biotech food industry.  No partisanship on display.  The toughest question of the day was the patent question – i.e. how can it be materially different for US Patent Office but not for FDA?  Tepid response was not challenged.

Video and written testimony available at:  http://www.ag.senate.gov/hearings/agriculture-biotechnology-a-look-at-federal-regulation-and-stakeholder-perspectives

There was a long line of people to get in, but the hearing room was very large and accommodated the 200+ people in attendance.  About 50 of those likely were from the 3 federal agencies as they seemed to clear out after their panel finished.

It was obvious that this was a ‘pro forma’ hearing to lay the ground work for the legislation. Sen. Stabenow indicated she thought they would pass a bill by year’s end.  Sen. Hoeven indicated he is working on one.  Discussion in the line was that no democrat had yet agreed to cosponsor.

The talking points for the members took a different tone this time.  The prevailing themes:

  1. We have to feed the growing population world-wide – it is a national security issue.
  2. For democrats – Climate change was also mentioned.
  3. Numerous members asked government witnesses how everyone (including committee) can do a better job explaining biotech so that the public trusts that they are safe?
  4. Minor mention of increased food costs with labeling.

All 3 federal agencies say they have sufficient authority to regulate GMOs.  FDA witness did say that if the nutritional content was different, they would mandate labeling.

The government panel went on for 2 hours.

The public panel started with Mrs. Joanna Lidback, the female Vermont farmer – who it turns out only grows grass – not GMOs.  She is apparently is the industry darling because she has testified multiple times. At one time she admitted that she only plants grasses.

Daryl Thomas, SVP at snack food company Herr Foods ( a family owned business) turns out is married to the bosses daughter which meant he REALLY had to deliver the message to keep labeling voluntary.  His own senator (Sen. Casey) was not able to stay to hear him testify, but did stay long enough to introduce him and lend his support to the cause.

The only ‘opposing’ witness was Mr. Gary Hirshberg of Stonyfield Farm, Inc. who was there on behalf of Just Label It.  It covered all the important points- calling for a national mandatory labeling, factual , value neutral (like the EU – two word insertion in ingredients list).  He also mentioned how the voluntary guidance document issued in 2001 has just left industry to run amuck.  He underscored that companies change labels all the time and doing is not a big deal; he said the 64 countries that have mandated labeling are not seeing problems, and that the stigma concern is not valid.  The cost concern is not valid.

Mr. Jaffee from Center for Science in the Public Interest was also given a platform to testify (again) – testimony pretty much the same as the House version.  He wants more regulations, and he was the voluntary premarket review at FDA to be mandatory

The latest industry shill was Dr. Ronald E. Kleinman  Physician in Chief Mass General Hospital for Children Boston , MA  – not discussed at the hearing was that he has conflicts of interest.  His bio at Mass General states “He consults for the Grain Food Foundation, Sesame Street Foundation, Beech Nut, the Burger King External Advisory Board, and General Mills.”  This was not disclosed or discussed at the hearing.  He thinks that parents just need to be talked to and told that GMOS are safe…that our food supply is safe.

One of other issues brought up was pesticides.  The EPA talked about their role in regulating PIP crops – these are bioengineered to release a protein that kills one or more types of bugs/pests.  He says they are safe for humans, and have led to less pesticide use.

One of the Republican senators asked if Glyco was linked to cancer, and the EPA witness stated they did a review last year of the epidemiology research and did not find a link.  None of them brought up the other health risks, or the increased use of herbicides with GMOs. (except Hishberg).

Sadly, none of the Senators asked any tough questions.  It was like they knew they had to do this hearing since they had not covered the topic in 10 years, so they can check this off, let Hoeven introduce the bill, then move it through the Mark up hearing, and Check this off their to do list.




Tuesday, October 20, 2015 @ 03:10 PM
posted by Rudi

If you want to listen to the hearing at 7:00 Am Eastern Time, go to:  http://www.ag.senate.gov/hearings/agriculture-biotechnology-a-look-at-federal-regulation-and-stakeholder-perspectives

POP NOTICE -Senate Sub_n


URGENT – PLEASE MAKE YOUR CALL – A BIG CHALLENGE but”never, never, never give up.”

On a fast track for a yes vote, the House of Representatives is poised to pass this so called “Orwellian Bill” on Thursday – called the “Safe and Accurate Food Labeling Act” (H.R. 1599). It makes it illegal for states to pass common sense GMO labeling and, unamended, also prohibits states or counties from banning or regulating GMOs in any way. (YES, a version will be presented to the Senate also – not available yet.)


Please contact your representative directly (get the number here: from the House Members website www.house.gov ) or call the switch board to get connected to your Representative and express your opinion – 202-224-3121

Example Script: “Hi, I am _________. I strongly feel as a parent and consumer that I have a right to know what is in the food I buy and feed my family. I support mandatory labeling of genetically engineered foods. I strongly urge you to oppose House Bill 1599 – “the Safe and Accurate Food Labeling Act” -also known as the “Dark Act”. Thank you.”


There is a Summary of Amendments that will be proposed on Thursday from the floor – see these below (#1 Below) : Note -the we as the POP Campaign continue to push for labeling of Baby Food – we will see if this amendment in any form goes through. (#2 Below- see our version)

See the Bill as it stands now:

During the past 3 years, more than 30 states have introduced bills or ballot initiatives to require GMO labeling. The Hawaiian vote on Maui is still being challenged – and mandatory GMO labeling laws have passed in Connecticut, Maine and Vermont. Our representatives want this off of the table for the Presidential election and other members running.

The POP Campaign and MOMS4POP personally support this particular exclusion form the bill seeking labeling on all baby food of”r children under the age of 5 ears and for pregnant moms -stay tuned for more on this later. Representative Lowery: Exempts baby food and infant formula that is labeled, marketed, or advertised for consumption by children under the age of two from the provisions of this bill.”

Thank You for your efforts and for your children – “….never, never, never give up.” from Winston Churchill.




Sunday, February 15, 2015 @ 09:02 PM
posted by Rudi

rudi-new-1 rudi-new-2


WORLD RENOWN Hippocrates Health Institute’s Brian Clement  -a rare special electrifying evening – up close and personal presentation & live music, & an optional  raw foods pot-luck feast – bring a dish. Discover the latest and hottest on cutting-edge health information. PURCHASE  TICKETS HERE (http://tinyurl.com/kou9887) Invigorate your lifestyle with vibrant health tips. Busy Moms & Dads will learn quick tips & how to maintain live food as a cornerstone for family health…and so much more as presented below – an evening with Dr. Brian is a game-changer, a genuine tune-up.

Hacking the Truth about Health & Cracking the Code – really break through those beliefs holding you back
. Thrive with Vibrant, Living Food and expect Miracles & Longevity – imagine really living  the life you seek
New paradigms of the Nature of Disease – a new holistic shift in thinking – an exciting key for a hopeful future
Health Tips for a busy Mom & Dad Lifestyle – leaving a legacy for children – make your imprint stick
Updates on some of the cutting edge protocols from around the world – be inspired what others are doing
* For a few moments: in the Spirit and Respect for our beloved Robin Williams – clarifying comments about depression and chemicals and how to balance out our homeostasis

Live Music Afterwards – A talent music jam with Dr. Clement on the drums, local talent led by the Cole Tate Band and special singing new comer our own Mikaele Holzer –

and a fun questions & answers.

Exciting Booths:

– Grateful Greens – Optimal live sprouts delivered to your door – http://www.gratefulgreens.com

– Divine Organics – Gourmet Super- Foods – yummy – https://www.google.com/search?client=safari&rls=en&q=divine+organics&ie=UTF-8&oe=UTF-8

– Easy Living Foods – live products prepared with love – http://easylivingfoods.com

– Green Your SPIRIT – Green Your Spirit offers 5 day juice cleanses, one-on-on nutrition & DIY cleanse coaching, an array of healthy living classes as well as interactive group coaching via phone and Skype!   Hippocrates Health Institute certified. Learn more at www.greensyourspirit.com

– POP Campaign – Preserve Organic Power – Food Justice Campaign – http://popcampaign.org and Moms4POP -Moms Pledging and leveraging their pocketbooks –  http://moms4pop.org

– Hippocrates Books and magazines and brochures …. and more including some special practitioners

Hacking the Truth about Health & Cracking the Code
Mill Valley Community Center – 180 Camino Alto
4:30 to 6:00 – Optional Raw Pot Luck & Registration
6:00 to 8:00 – Presentation & Q & A
8:00 to 9:00 – Live Music and raw desert tasting

join in  – celebrate -eat – interact with awesome folks – and learn something new.

Cost: $20 early-bird /$25 at door + bring a raw food dish

Purchase tickets here:    http://tinyurl.com/kou9887

MORE: Brian - Hacking COLORFUL - RECENT-1


We still need to be mindful of our food -even organic meat

Monday, August 25, 2014 @ 10:08 AM
posted by Rudi

Bacteria Eating Virus Used as Food Additive on Organic Food

Written by  |
bacteria eating virus food additive organic

One of my favorite bloggers, Heather Dessinger of Mommypotamus, contributed the following guest post to rile you guys up! Thanks, Heather, for the scoop.

Michael Pollan once gave readers this advice, “Avoid food products that contain ingredients that a third-grader cannot pronounce.” Love him or hate him, Michal Pollan’s food rule #7 is spot on. And it seems simple enough, right? No disodium guanylate, pyrophosphate, sodium stearoyl lactylate, or crazy glow-in-the-dark food additives. Just real food.

Unfortunately, when it comes to bacteria-eating viruses sprayed on your lunch, labels don’t help – and “organic” is no exception. Clever labeling laws have made detecting the presence of this “food additive” – sold under the brand name Listex – virtually impossible.

Why exactly would anyone want to spray meat, cheese, fruit vegetables and other foods with viruses? It’s simple, really. Listex is a cocktail of 6 bacteria-eating viruses (bacteriophages) that have been “trained” in a lab to target and kill Listeria monocytogene,a bacteria which sickens about 1,600 people a year. Rather than work on raising healthier animals and improving handling processes, this “band aid” approach to dealing with pathogens has been creatively classified as a “clean label processing aid.” In other words, it’s been going on for years but no knows because companies aren’t required to tell you.

Clever, huh? As consumers get more savvy about reading labels, manufacturers become more coy about how they print them. They “scrub” labels of undesirable ingredients by coming up with new names for them or leaving them off altogether, often with the approval of regulatory agencies such as the FDA. Listex is a perfect example. “Consumers won’t be aware that meat and poultry products [and now cheese, fruits, vegetables and other products, including organic] have been treated with the spray,” FDA representative Andrew Zajac told the press when Listex was approved.

Now, I’m not phobic about viruses (to say the least), but I find it disturbing that such a radical approach to food safety was FDA-approved without even one human safety study. Instead it was given “GRAS” (generally recognized as safe) status because a few previous human studies on other products indicated safety, though one was as old as 1967. ¹ Hmmm . . . weren’t GMO’s approved as “GRAS”? Forgive me if I’m a little skeptical.

Trained Assassins

So basically – according to the manufacturer – the way this is supposed to work is these 6 “trained” viruses are sprayed on various foods as a safety precaution. If Listeria is present, it will mistake the viruses for food and eat them. The viruses will then begin a massive replication process that will eventually cause the bacteria to burst wide open, spilling the viruses onto the food. Yummy!

Now, normally the listeria would try to fight off the attack by producing endotoxins (substances which have been shown to provoke allergies, asthmaautoimmune problems,elevate cholesterol, cause inflammation in the digestive tract, and have been noted as a catalyst for colon cancer), but that is not the case here. Intralytix, Listex’s maker, has altered or “purified” the viruses in such a way that endotoxin levels were undetectable in the samples presented to the FDA. While that’s a good thing, we know that viruses are highly adaptable and slight changes can occur from batch to batch, so it is unclear whether this level of “purity” has continued over the years.

Another concern reported by ABC News is that “The bacteriophages might also get into battle with the friendly bacteria in the digestive system, making it harder for the body to digest food.” This a problem because not only would such a “battle” severely damage our immune systems first line of defense (the gut), it leads us right back to the concern above. How do we know that the good bacteria in our bodies won’t produce allergy/asthma/auto-immune disease/ high-cholesterol promoting endotoxins to protect themselves from Listex.We don’t.


What else don’t we know? I’d say the biggie is how another biotech darling, GMO’s, interacts with mass quantities of bacteriophages. Genetically-modified foods contain viral promoter genes that help the foreign DNA infect the host DNA, and scientists have longexpressed concerns that the viral fragments in promoter genes could recombine to create more aggressive viruses. What happens when we dump tons of live viruses on GMO-laden foods is anybody’s guess, but rather than continue on down this path and find out I have a suggestion:

Let’s Wash Our Hands!

And eat sustainably raised meats, because unlike their industrially-raised counterparts they are very unlikely to contain harmful amounts of listeria, e. coli, or campylobacter bacteria.³Let’s buy our milk and cheese from farmers who graze their cows out in open air and sunshine, and our produce from those who don’t fertilize with CAFO manure. Better yet, let’s send our little ones to do it for us.



The thing about letting my four-year old, Katie, carry a fist full of dollars through the farmers market, weigh the zucchini from the back of a rusty blue pickup, debate the merits of sausage over bacon, and inevitably hand our rancher way too much money, is this:

He SEES her. The way she smells the melons like they’re dew from heaven. The way she lights up when he says he has peaches this week. It’s not complicated. It’s about us seeing their faces, and them seeing the faces of the precious little lives that are worth more than profit margins and cutting corners.

Teaching our kids to ask for “ham and cheese with a side of virus, please” – now that’s complicated.

Listeria affects about 1,600 U.S. citizens a year, most of whom are immuno-compromised adults, pregnant women and infants. By all means let’s protect these populations with good sanitation and by educating them on how to avoid foods likely to contain listeria. But let’s not leave the “solutions” to the guys that gave us wood pulp in our cheesesecret ingredients in our orange juice, glue in our meat and ammonia-laden pink slimeAgreed?


About Mommypotamus: Heather Dessinger, aka The Mommypotamus, is a wife, blogger, and mom to two amazing kiddos, both waterborn at home. She loves all things fermenty,talks to sock puppets, and dreams of owning a backyard flock of chickens.

Her e-cookbook, Nourished Baby, is a simple guide to first foods that explains why the birth experience affects cravings for life, how to decode nursing cravings, what the latest research says about introducing peanuts, eggs and other “allergenic” foods, and more.



Hearing Entitled, “To Consider the Societal Benefits of Biotechnology”

Wednesday, July 23, 2014 @ 07:07 AM
posted by Beth Clay

A Status Report on House Agricultural Committee’s

Subcommittee on Horticulture, Research, Biotechnology, and Foreign Agriculture 

Hearing Entitled, “To Consider the Societal Benefits of Biotechnology” 

July 9, 2014

Subcommittee Members

Republican Members

Chairman:  Austin Scott, (GA-8)

Rep. Vicky Hartzler (MO-4)

Rep. Jeff Denham (CA-10)

Rep. Stephen Lee Fincher (TN-8)

Rep. Doug LaMalfa (CA-1)

Rep. Rodney Davis (IL-13)

Rep. Chris Collins (NY-27)

Rep. Ted S. Yoho (FL-3)

Democratic Members

Ranking Member: Kurt Schrader, (OR-5)

Rep. Suzan K. DelBene (WA-1)

Rep. Jim Costa (CA-16)

Rep. Marcia L. Fudge (OH-11)

Rep. Ann M. Kuster (NH-2)

Rep. Juan Vargas (CA-51)

Rep. Sean Patrick Maloney (NY-18)

Witness List:  (Testimony is hyperlinked to their name)

Mr. David Just, Professor, Co-Director, Cornell Center for Behavioral Economics in Child Nutrition Programs, Charles H. Dyson School of Applied Economics and Management, Cornell University, Ithaca, NY

Dr. Calestous Juma, Professor, Practice of International Development, and Director, Science, Technology, and Globalization Project, Belfer Center for Science and International Affairs, John F. Kennedy School of Government, Cambridge, MA

Dr. Olga Bolden-Tiller, Assistant Professor, Tuskegee University, Tuskegee, AL

Mrs. Joanna Lidback, Owner, The Farm at Wheeler Mountain, Westmore, VT

The goal of this hearing was to address the benefits of biotechnology ahead of a hearing slated to take place in the Energy and Commerce Committee in a few weeks.  While there was an opportunity for a ‘minority’ witness, both sides of the aisle agreed on the four witnesses, and thus there was no ‘opposition’ witness requested.  It was confirmed with staff that conflict of interest statements were required, and that no industry affiliation was listed on any witness.

There were about five members of the Committee present.  Rodney Davis of Illinois served as Chair for this hearing as Chairman Scott had a cold and could not talk.  Rep. Davis spoke at length about the need to improve food production to feed the planet and the lectures of Paul Erlich from 25 years ago.   Ranking Democrat and veterinarian, Kurt Schrader of Oregon, who happened to completed his undergraduate degree at Cornell, Doug LaMalfa of California whose family grows conventional seed rice in California, Suzan DelBene of Washington State whose has a background of biotechnology work in the life sciences, and Ted Yoho another veterinarian from Alachua, Florida, home to a large agricultural biotech center.  Representative LaMalfa is a cosponsors of the industry written, HR 4432.

This hearing is a one-sided presentation to the Subcommittee on the benefits of biotech foods (GMO). The witness list has been carefully constructed to bring a variety of promotional issues.   The overall thrust of the hearing is that the public has been misled and misinformed by GMO myths, and that onerous regulations on farms and innovative companies.  The focus is on the need to improve and increase crop production to feed the planet.

Dr. Just;s testimony focused on his research analyzing how consumers “tend to lump food that is labeled as having been genetically engineered together with categories of foods such as those that contain chemical preservatives or other ingredients with long names that sound overly technical, or foods that are highly processed and factory produced.”  It is his opinion that when consumers are informed of how specific crops are developed to address specific needs, that consumers loose fear and are more willing to buy.  In questions, he provided that he feels that if there was mandatory labeling on the front of the packaging, it would be viewed as a warning, and if included in the ingredients list on the back, that most consumers would not know it was there.  He also indicated that the disdain for GMO foods may lead some companies to be less innovative in GMO development, and is having a chilling effect in academic research environments, driving the research back to industry.

Dr. Juma is a plant from the Gates Foundation.  Not included in his testimony, but posted on his Harvard website is his bio, which includes: Calestous Juma is Professor of the Practice of International Development and Director of the Science, Technology, and Globalization Project. He directs the Agricultural Innovation in Africa Project funded by the Bill and Melinda Gates Foundation and serves as Faculty Chair of Innovation for Economic Development executive program. Juma is a former Executive Secretary of the UN Convention on Biological Diversity and Founding Director of the African Centre for Technology Studies in Nairobi. He is co-chair of the African Union’s High-Level Panel on Science, Technology and Innovation and a jury member of the Queen Elizabeth Prize for Engineering. He was Chancellor of the University of Guyana and has been elected to several scientific academies including the Royal Society of London, the US National Academy of Sciences, the World Academy of Sciences, the UK Royal Academy of Engineering and the African Academy of Sciences. He has won several international awards for his work on sustainable development. He holds a doctorate in science and technology policy studies and has written widely on science, technology, and environment. Juma serves on the boards ofseveral international bodies andis editor of the International Journal of Technology and Globalisation and theInternational Journal of Biotechnology. His latest book, The New Harvest: Agricultural Innovation in Africa, was published by Oxford University Press in 2011.

Dr. Juma focused his testimony on how biotech foods save lives in Africa, that the UK is now revisting its laws on GMOs because industry in the UK is adversely affected by the laws.  He feels that he concerns initially put forward when GMO were first being developed have continued although the fears have not been substantiated.  Towards the end he compared the GMO discussion to the margarine-butter debate.  He also promoted adverse information about the opposition.  He feels that those who oppose GMO crops should disclose their source of funding the same as scientists do.  He also talked about how the Philippines and Uganda have not moved forward with allowing golden rice and golden bananas because their legislators have been blocked by activists from within and outside the country.  (Rep. Davis and Schrader both talked ‘weak governments’, and not having the political will. Rep. Davis also mentioned political turmoil.)

In addition to GMO crops, he is also thinks we should be promoted GM animals.  He stated that 28 countries, most developing, are planting GMO crops and that the US risks falling behind technologically because of the misperceptions of the risks.

Dr. Bolden-Tiller  from Tuskegee focused her comments on focused on the history of crop modification (George Washington Carver is a heavy influence at Tuskegee). Her testimony included these comments:  And the facts are these: 1) the incorporation of GMO crops into operations in developing countries result in increased farm incomes and reduced

labor associated with agricultural practices, allowing for more time for education and other avenues of income; 2)it is predicted that food production must double within the next 30 years to meet the demand of the projected population; 3) biotechnology provides scientists with answers that can result in the production of more affordable foods while sustaining the environment. This is not to say that technology should be haphazardly implored, as care must be taken and questions must be asked. Carver suggested that “man is simply nature’s agent…to assist her in her work, hence the more careful and scientific the man, the more valuable he is as an aid to nature in carrying out her plans methodically….” Irrespective of one’s positions, it is sure that society must be educated about current biotechnology and forthcoming tools to come for the future.”   She concurred with the theme that the consumer has been misled.

Mrs. Lidback, the Vermont mother, farmer and full time employee of the Farm Credit Bureau. She was there as a representative of the Agri-Mark Dairy Cooperative and the National Council of Farmer Cooperatives.  She and her husband rent their 200 acre farm from relatives.  She was the perfect industry witness, she stated that she never busy organic foods as they have additional nutritional benefit, that the price of organic feed for her cattle would cost the farm an additional $75,000 a year, which they could not afford.  Towards the end of her testimony she even almost cried (as if on cue) in talking about the worry of her sons going in to farming.  Towards the end of the hearing she piped in a comment about the need to have only voluntary labeling.

It is important to be aware of the early strategies and positioning of those who want voluntary labeling of GMOs and how one sided is the education and research being shared.  There is a renewed need to get experts and researchers to share their knowledge before the committee.


The Truth About Health Conference – NYC 1/10- 1/12

Saturday, January 11, 2014 @ 06:01 PM
posted by Rudi

This conference is one of the finest in a long time, Sponsored by the Hippocrates Health Institute and Steve Shore – absolutely fantastic perspective on food and health.



Dr Gabriel Cousens & Brian Clement – GE Food linked to Birth Defects

Monday, October 28, 2013 @ 05:10 PM
posted by admin

see  http://moms4pop.org Dr Gabriel Cousens and  Brian Clement – Geneticall Engineered Food Linked with Iodine Deficiency and Congenital Birth Defects: Toxic Halogens called “salts” hidden behind the GE non-disclosure veil.     by Rabbi Gabriel Cousens, MD, MD(H), Brian Clement, Nonnie Crystal and Rudhi Lenardi (POP Campaign)

As pioneers of the vibrant, alive blueprint for health at the Tree of Life Center U.S. and Hippocrates Health Institute, The POP Campaign strives to protect the healthy lifestyle threshold against the tsunami of genetically modified organisms (GMO) for the article see: http://moms4pop.org






UNVEILED – GMO Skeleton Donors

Tuesday, October 22, 2013 @ 03:10 PM
posted by Rudi

Contact: Mark Kastel, 608-625-2042

Unveiled: GMO Labeling Opponents
Come Out of the Shadows

Natural/Organic Brands No Longer Hiding
Behind Lobbying Organization

CORNUCOPIA, WI: Proposition I-522, a citizen’s initiative on the November 5 ballot in Washington state that would mandate clear labeling of genetically engineered (GE) ingredients on food packages, has become the most expensive initiative campaign in the state’s history. The high-priced battleground is pitting consumer and farmer advocates against multi-billion-dollar agribusiness corporations.

A number of new opponents to the GMO food labeling proposal were recently revealed following the release of their names by the Grocery Manufacturers Association(GMA), a national business lobbying organization. The GMA had been, apparently in violation of state election law, hiding the identity of its donors who had provided more than $7.2 million to fight the consumer’s right to know what is in their food. The disclosure came shortly after Washington’s Attorney General Bob Ferguson filed a lawsuit demanding the GMA reveal the identity of its secret donors.

With the outing of the GMA’s donors, The Cornucopia Institute has released an updated infographic detailing the financial expenditures of corporate and organizational supporters and opponents of I-522.

“Consumers might be surprised to find out that some of their favorite organic and natural brands, hiding behind their lobbyist, the Grocery Manufacturers Association, are contributing bushel baskets of cash towards thwarting their right to make informed choices in the supermarket,” says Mark Kastel, Cornucopia’s Codirector.

A similar GMO labeling measure, Prop 37, was narrowly defeated in California last year, with GMA, Monsanto and their allies pouring more than $46 million into their campaign and outspending labeling supporters by five to one. Many prominent organic and natural brands were also exposed in California by Cornucopia for their opposition to GMO food labeling.

“We think the bad press and consumer outrage that many of the GMA member companies received in California, like Kellogs (Kashi), General Mills (Cascadian Farms/Muir Glen) and Smucker’s (Santa Cruz and Knudsen), led to the decision to try to clandestinely hide under the GMA’s cloak with its secret donor approach,” noted Kastel.

The Cornucopia infographic also outlines dozens of organic brands that have heavily contributed to the YES on I-522 campaign, including Dr Bronner’s, Nature’s Path, Annie’s, Stonyfield Farm and Nutiva. It is thought that after the dust settled in California, these groups gained respect and market share after some of the prominent, agribusiness-owned brands lost favor with politically savvy consumers.

A number of prominent organizations have also substantially contributed in support of consumer rights, including the Organic Consumers Association, Center for Food Safety, Mercola.com, Presence Marketing, PCC Natural Markets and Food Democracy Now!.

Earlier this year, the GMA publicly scrubbed its website of its members, a move thought by many to be an effort to mask which corporations/brands were helping underwrite corporate donations against I-522. They weren’t, however, able to remove this web archive detailing their membership.

“In addition to the many companies supporting a YES vote on I-522, there are thousands of individuals making small donations to fund the pro-labeling campaign,” said Goldie Caughlan, a retired nutrition educator for PCC Natural Markets in Seattle and former member of the National Organic Standards Board. “Out-of-state interests, like Monsanto and the many identified GMA members, are flooding our airwaves with misleading ads telling Washington residents how to vote,” Caughlan added.

Mandatory labeling of genetically engineered food at the state level is viewed as a watershed event by many industry observers, given the inaction on the popular proposal at the federal level – with polls showing as high as a 90% in support. Lobbyists for Monsanto, its biotech allies, and GMA in particular, have been credited with bottlenecking a federal labeling law.

After the industry advertising blitz, the most recent polling of Washington state voters indicates a tightening race on the I-522 initiative, with a narrow majority supporting labeling of GMO food ingredients. Opponents of the measure have raised in excess of $17.1 million. The GMA’s share of the NO vote dollar alone, at $7.2 million, is greater than all of the money raised by I-522 supporters, who have collected nearly $6.9 million in favor of a YES vote.

“Consumers and food citizens are increasingly interested in ‘voting with their forks,’ and many want to support companies that share their values,” observes Jason Cole, a researcher for Cornucopia who compiled the data for the infographic. “We think these conscious eaters will appreciate the infographic created by Cornucopia to help them make their purchasing decisions.”


A GENERATION RAPED – The PROMISCUITY of Genetically Engineered Crops

Sunday, September 29, 2013 @ 11:09 AM
posted by Rudi

SMART VIDEO that supports the POP Campaign’s efforts to end the promiscuity tendencies of Genetic Engineered Crops raping our minerals and nutrients from our organic plants. Save our children, jail glyphosate as the perpetrator – Dr. Huber is a solid scientist – stay tuned 🙂  Dr. Huber has the depth of 50 years as a researcher – he underscores the huge economic monopoly and money making values behind GE food at the expense of us humans as experiments. http://www.youtube.com/watch?v=nrq_1ovWlVE


FINAL LET’S GET FOLKS THERE: The POP Campaign is co-hosting Dr. Brian Clement with the yummy THRIVE Restaurant in Seattle. Dr. Brian, Director of the Hippocrates Health Institute, will be speaking about the healthy, vibrant lifestyle of living foods and updates on GMO Labeling and the Proposition 522 Labeling Efforts int he State of Washington. An amazing opportunity to learn cutting edge health information and elevate your game. USE PROMO CODE FOR A DISCOUNT : THRIVE20 – BASTYR UNIVERSITY AUDITORIUM – sign up: @http://www.generationthrive.com/events Dr. Brian Clement flyerScreen Shot 2013-07-19 at 8.45.09 PM


We are powerful as a group and must continue to educate people to stand up for their rights to label Genetically Engineered Foods – the GMO industry has been nervous and met in Washington to discuss ways to fight back, throw more money to counter efforts and to strategize for a national labeling bill – we wait and ask for support for our efforts. See the article in the Hill:

Key summit set in genetically modified food label fight – By Ben Goad –

Major players in the food industry have scheduled a crucial meeting for next week that could become a turning point in the regulatory battle over genetically modified foods.
Challenges to the use of biotechnology have created an “unprecedented period of turmoil” for food producers, the Grocery Manufacturers Association (GMA) said in a letter circulated among trade groups that was obtained by The Hill.
“We have reached a pivotal point in this effort and believe now is the time to bring together a broad coalition to confront these challenges,” the GMA wrote in the letter, which invited CEOs and top industry officials to a Wednesday summit in Washington.
Just how the food industry might move forward appears up for debate. Though organizers of the GMA summit were tight-lipped, advocates and industry officials said the options could ultimately range from a coordinated attack against labels to acceptance of a national standard.
The GMA’s membership list includes more than 300 companies, including food giants Kraft Foods, Coca Cola and General Mills. The group declined to discuss the meeting or whether it would propose a particular strategy.
“As the policy debate surrounding this issue moves forward, GMA will continue to work with its supply chain partners to inform lawmakers and consumers about the significant negative impacts such labeling requirements will have on both businesses and consumers,” the group said in a written statement to The Hill.
Opponents of mandatory labeling argue that foods made with genetically modified organisms (GMOs) are perfectly healthy and indistinguishable from “natural” products. Labels could create a false perception that the foods are somehow inferior, they say, and create a stigma that causes prices to rise.
For years, farmers have planted herbicide resistant or “roundup ready” corn, cotton and soybeans that can be easily sprayed for weeds. The genetically modified crops are used in a variety of popular processed foods, including soft drinks, margarine and breakfast cereal.
Food safety and public interest groups question claims that GMOs are safe, arguing the science is inconclusive. They have pressed for all GMO foods to be labeled so that consumers are aware of what that they’re eating.
The fight over labels is increasingly being waged at the state level — and at substantial cost to foodstuff manufacturers.
Last year, major chemical and food companies spent more than $40 million in California to defeat a ballot measure that called for mandatory labels of all scientifically engineered foods sold in the state.
Similar labeling proposals have popped up in more than two-dozen states and in Congress, and the industry group says it cannot afford to fight them all.
“Today consumers have a high degree of confidence in the safety of the U.S. food supply,” the GMA wrote in the letter. But that confidence could be eroded, the GMA warned, by 25 proposals pending in state legislatures, a ballot initiative on deck in Washington State, and the federal push for mandatory labels.
Thus far, two state legislatures — Maine and Connecticut — have approved legislation requiring labels on genetically modified foods. Governors in both states are expected to sign the bills, according to Colin O’Neil, director of government affairs at the Center for Food Safety.
O’Neil’s group has pressed the Food and Drug Administration to act unilaterally on regulations for GMO labels since a legislative mandate is unlikely to pass Congress. The FDA has not responded to the request.
Interests on both sides of the debate are watching the Washington initiative closely. Adoption of state labeling laws could subject food companies to a patchwork of regulations that would be far more costly than a federal standard, O’Neil said.
“These companies would like to see any language that would preempt state law,” he said. “A federal standard would likely do that.”
O’Neil said industry concerns over state level action, therefore, have long begged the question: “When does the labeling fight come to D.C.?”
Some industry sources said they viewed Wednesday’s meeting as a significant event, but declined to be named because of the sensitivity of the issues at hand.
Officials from the Produce Marketing Association were among those invited, though they would not be able to attend, spokeswoman Meg Miller said.
As for the group’s expectations of what the result might be: “We don’t have any at this point,” she said.



Monday, March 18, 2013 @ 08:03 AM
posted by Rudi

PLEASE Call Senators Mikulski, Shelby, and Reid and your own two senators.

Message to Senators Mikulski, Reid, and Shelby: I do not support Given the Secretary of Agriculture the Power to Ignore the Courts on GMO Seed Planting – Please Allow a Vote on Senator Tester’s Amendment 74 (Or simple strike Section 735 from the bill.)

Message to Your Two Senators: I do not support Given the Secretary of Agriculture the Power to Ignore the Courts on GMO Seed Planting – Please Vote to Support Senator Tester’s Amendment 74 to Strike Section 735.

Time is crucial on this. Senator Reid wants to vote on Monday – so we need to get calls in today and Monday morning – and the survey by the end of the weekend.

Telephone Numbers:
Senator Mikulski (202) 224-4654
Senator Shelby (202) 224-5744
Senator Reid (202) 224-3542

All other numbers at: http://www.senate.gov/”
The Issue: Section 735 of the Senate Version of HR 933 (The Appropriations Bill That Will Keep the Government Funded Through September 30.) This provision is intended to give the Secretary of Agriculture the authority to ignore court rulings barring the planting of GMO seeds. Monsanto, Bayer, and others (with the Gate Foundation an major stockholder of Monsanto doing a lot of lobbying) want to get their seeds planted without proving safety

The Solution: Senate Amendment 74 introduced by Senator Jon Tester with Senators Leahy, Gillibrand,Boxer, Begich, and Blumenthal would strike Section 735

Another Action Item – but time is running out:

Everyone Should Take the One Question Survey Posted at: https://www.surveymonkey.com/s/GMOProvisioninBudgetBill

You can also insert it on your facebook or webpage by using: Click here to take survey



Friday, January 4, 2013 @ 01:01 PM
posted by Rudi

I am outraged and laughing at the manipulations and fear tactics of the FDA. It just posted a Friday Food Safety notice to be wary of raw sprouts because of the risk of food borne illness such as salmonella and E. coli. They claim that there have been 30 reported outbreaks within the past 16 years and that the problem is with the seed itself. They caution even home grown sprouts including alfalfa, clover, radish, and mung beans.) They also caution people with challenged immune systems, children and pregnant women to not eat sprouts raw or lightly cooked.

Such BS. The problems come with the chicken, bat, and cow manure in the sol used or leaking downstream into water sources used. This comment is based on 30 reports over 16 years – what about the 100 million plus instances where people have eaten sprouts and not only boosted their immune systems and helped challenge certain diseases but also went away healthy with smiles. I wonder if the FDA has ever posted reports from years ago that a rumored 240 deaths a day are traced to meat consumption –opps, gotta be careful of the meat industry.

The POP Campaign is conducting more research to address the details in case this mushrooms into a huge strategy of control or regulation – or setting the stage for massive GE planting of sprouts.