Policy Positions
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Water
Water Conservation and Drought
CCOF is deeply concerned about the drought conditions in California and the impact this is having on producers in the Central Valley especially, some of whom are CCOF members. We are pleased that Governor Schwarzenegger has declared an emergency and we will continue to keep you updated on the specifics of this situation.
CCOF’s summer issue of our magazine, CERTIFIED ORGANIC, will have a feature article on water conservation in California, informing us about organic farmers who are implementing practices that help protect one of California’s most precious resources. CCOF has been working with other organizations like the California Institute for Rural Studies (CIRS) and the Polaris Institute which are both working on water issues. The recently released report, WATER STEWARDSHIP: ENSURING A SECURE FUTURE FOR CALIFORNIA AGRICLTURE, contains compelling research and information about organic farming practices that incorporate water conservation methods that you’ll find compelling. If you’d like additional information or have questions about water, please contact Claudia Reid.
Climate Change
Climate Change Action Plan
AB 32, the greenhouse gas emissions legislation that passed in 2007, requires the California Air Resources Board (ARB) to accomplish a number of tasks, including adopting regulations to require reporting and verification of statewide greenhouse gas emissions, to monitor and enforce compliance with the greenhouse gas emissions program, to adopt a statewide greenhouse gas emissions limit equivalent to the levels in 1990, to be achieved by the year 2020, and to create and implement a public process to achieve the maximum technologically feasible and cost-effective greenhouse gas emission reductions.
In compliance with AB 32, the ARB has posted its Draft Scoping Plan for your input and comment. CCOF encourages you to read this document and send in your comments. Many of the recommendations are incentive-based, thanks to many industries, including agriculture, weighing in early on in the process of creating the Draft Scoping Plan.
Because these regulations will impact EVERYONE in California, not just organic farmers, CCOF will be working behind the scenes to assure our members that the organic agriculture perspective is heard during the comment period and during the implementation of the new regulations. We will work with California Farm Bureau Federation, Community Alliance with Family Farmers and other organizations to advocate on behalf of organic systems, which by their very nature accomplish many of the goals stated in the draft scoping plan. Some of these goals include improving air and water quality and sequesting carbon. If you have great ideas about how organic agriculture can help improve our environment, contact Claudia Reid, Policy Director at CCOF.
USDA/NOP/NOSB
USDA/NOP/NOSB
USDA
National Organic Program (NOP)
National Organic Standards Board (NOSB)
CCOF’s Position on Grower Group Certification
The certification of grower groups enables a large number of producers from the same geographic region who share common agricultural practices to collectively market products as organic under one certificate. While this system may be more cost efficient for small producers and exporters, it is not necessarily in compliance with the National Organic Program (NOP) standards since some parcels in the group will not be inspected annually. NOP regulation asserts that all organic production facilities must be inspected annually by a third party certifier, but grower groups typically require only 20% of their operations to be inspected each year. Using this system, a specific organic operation could be out of compliance for up to five years before the certifier became aware of it.
In an effort to maintain organic integrity, CCOF has routinely not certified grower groups. We believe that all producers of organic products should complete the certification process, including annual inspections for all individual operations. Allowing grower group certification creates a potential for unfair competition with other organic growers and also room for possible corruption. For these reasons, CCOF supports a short-term phase out of grower groups under the NOP and urges the immediate termination of group certification to retail operations. For more information about grower group issues, follow the links below.
NOP Policy…
IFOAM Response…
Read the position statement letter submitted by CCOF…
USDA
Under the National Organic Program (NOP), 7 CFR Part 205, the United States Department of Agriculture (USDA) is the official regulatory and enforcement agency for organic agriculture, food and other products.
Consistent with CCOF’s history, CCOF remains committed to working with the NOP to ensure organic food and agriculture maintains the highest standards and consumer confidence possible. CCOF actively engages the NOP on a variety of issues ranging from standards interpretation to protection of organic consumer expectations and addressing drift issues. Please support CCOF to help continue our vital work.
National Organic Program (NOP)
On the NOP website, CCOF clients and the public can obtain a wide variety of information. Some sections of the website highly recommended to CCOF certified clients are:
>NOP Policies and News Updates
>Labeling guidelines
>Frequently Asked Questions
>Accreditation
>Appeals Process
>State Organic Program Approval Procedures
>Export Arrangements
>Contact Information
>Background and History
>Upcoming Events
Clients can also view the final rule text, and download the rule in Spanish and Japanese.
>Read the National Standards on Organic Agricultural Production and Handling
>View Final Regulations in Japanese
>View Final Regulations in Spanish
>View the Final Rule Fact Sheets in English and Spanish
>Commercial Availability Comments
The National List of Materials is also available on the NOP website, as is the petitioning process for adding materials to the list.
National Organic Standards Board (NOSB)
The National Organic Standards Board (NOSB) is comprised of 15 members who advise the US Secretary of Agriculture and USDA on implementation of the National Organic Program. They are hugely influential and are responsible for review of new materials petitions, many organic standards interpretations, and recommendations on development of new organic standards. However, recommendations by the NOSB are not official policy until they are approved by the National Organic Program.
CCOF has been very active in monitoring NOSB meetings and providing commentary reflecting the needs to organic agriculture, consumers and organic processors. Your support helps keep organic standards strong.
The NOSB website includes information on petitioning the NOSB to add a material to the National Materials List.
March 2007 NOSB OMRI Meeting Report
Meeting Report The National Organic Standards Board (NOSB) met on March 27, 28 and 29, 2007. The report prepared by OMRI has important updates on new policies, proceedures, Handling and Agricultural Ingredients as well as livestock issues.
November 2003 NOSB Updates
Amendments to the USDA National Organic Program National List 7 CFR Part 205.600-607, as of November 3, 2003
NOSB Recommendations that have not completed a final rulemaking for addition to the National List, as of November 3, 2003
Consolidated National List (7 CFR 205.600-607), December 2001 Final Rule with Amendments, compiled by the Organic Materials Review Institute, November 14, 2003
Please call us if you have any questions at (831) 423-2263, or email us at ccof@ccof.org.
Pesticides
Pesticide Drift
CCOF addresses the issue of potential pesticide drift in every certification by requiring clearly defined buffers and boundaries between organic and non-organic farms.
CCOF supports organic farmers’ rights to recoup financial losses as a result of pesticide drift. Consuming organic products is the most effective way to reduce worker and consumer exposure to harmful pesticides. Consumer support of organic agriculture helps reduce the amount of pesticides used in agriculture.
Organic agriculture uses a systems approach to pest control by using natural forces to achieve balance, such as the introduction of beneficial insects, soil building, and when absolutely necessary, the application of products approved for organic agriculture.
Invasive Species
Organic IPM Management Plan for LBAM
CCOF is pleased to provide our members with an ORGANIC IPM MANAGEMENT PLAN FOR LBAM. This document will be useful if you live in one of the delineated or quarantine areas of California that have experienced an LBAM find. This pest, and the dynamics of the eradication plan, continue to be one of CCOF’s top priorities. Please contact Claudia Reid if you have questions or need additional information.
LBAM Spraying Halted
On June 19, 2008, the California Department of Food and Agriculture and the US Department of Agriculture announced significant improvements to the eradication plan for Light Brown Apple Moth (LBAM). These include halting aerial spraying over urban areas and mounting an aggressive ground treatment program in the 11 affected California counties. The Department will also rapidly implement a Sterile Insect Technology (SIT) component to the program, with plans to roll out a pilot SIT program next spring, 2009, with the full program being implemented by spring 2010.
CCOF is a member of the Invasive Pest Coalition, which strongly supports this new strategy uses a ground-based approach and newly available control measures to eradicate this invasive pest in an effective and environmentally safe manner. The IPC is an organization comprised of a broad range of agricultural organizations including conventional and organic farming which is committed to supporting efforts to prevent the introduction of invasive pests into California. Unfortunately, with an increasingly global society, invasive pests like the light brown apple moth are introduced into the state. The IPC believes the potential damage to local farmers, California native plants and species and the overall environment necessitates eradication of the light brown apple moth.
We welcome your input to our thinking and ask you to contact Claudia Reid if you have questions or need additional information. We continue to work with CDFA to explore alternatives to aerial spraying for LBAM.
Food Safety
Food Safety
Produce Safety
Beneficial Bacteria Help Suppress E. coli O157 Scientists working for the USDA’s Agricultural Research Service have shown that beneficial bacteria can out-compete some harmful pathogens, and in the process, suppress the buildup of pathogens, including E. coli O157. This is one of the primary reasons why the promotion of microbial biodiversity on organic farms can reduce food safety risks. In some cases the pathogen-suppression caused by colonization with beneficial bacteria is linked to a competitive effect – the beneficial bacteria use up energy sources or moisture needed by the pathogen. In other cases, the beneficial bacteria produce chemicals that act like antibiotics in suppressing pathogens. In the absence of competitive bacteria or other control agents, pathogen populations can grow 100,000-fold higher in a day or two when moisture and temperature conditions are favorable.
Source: ARS News, June 2008
The Leafy Greens Marketing Agreement was formed in the spring of 2007 in response to a food borne illness outbreak in September 2006. Operating with oversight from the California Department of Food and Agriculture, the LGMA is a mechanism for verifying through mandatory government audits that farmers follow accepted food safety practices for lettuce, spinach and other leafy greens.The LGMA accepted Good Agricultural Practices (GAPs) for leafy greens, which serve as the cornerstone to the Leafy Green Handler Marketing Agreement. The strengthened GAPs have been presented to California growers and handlers, and CCOF representatives continue to participate in as many meetings, conference calls, and events on this topic to ensure our clients, especially small growers, are not left out of the discussion. Claudia Reid, Policy Director for CCOF, works with CCOF Board Chair Will Daniels, who currently sits on the Leafy Green Marketing Agreement Technical Advisory Committee, other organic farming representatives, and our partner organizations such as Organic Trade Association to keep a close eye and ear on further developments with this issue. There are STILL no organic reps on the Marketing Agreement Advisory Board at this time (despite CCOF’s recommendation), so organic producers must remain vigilant on this topic.
Constructive discussion is beginning to occur between LGMA, retailers, federal and state agencies concerned with habitat, water and air quality issues and farmers, but according to one retail representative, “it will take a long time” to build back a level of trust between retailers and farmers because of the deaths and disease resulting from the E Coli outbreak. Visit the CDFA website to read more…
HR 5904 (Costa) Food Safety Legislation
The newest in a long list of food safety legislation has been introduced by Congressman Jim Costa (D-Fresno). Entitled the Safe Food Enforcement, Assessment, Standards and Targeting Act of 2008′ otherwise known as the `Safe FEAST Act of 2008,’ this legislation, authored by Mr. Costa, along with his colleagues Congressmen Putnam (R-Fla), Cardoza (D-Merced), Nunes (R-Fresno, Tulare) and Farr (D-Monterey), would establish new procedures and requirements to improve the safety of food, whether produced and distributed domestically or imported into the United States, by providing for improved information technology to identify high-risk imports and for enhanced capacity in the United States and in foreign governments to identify and address food safety issues on a scientific basis. CCOF will be monitoring this legislation carefully to make sure it helps our members comply with all food safety requirements while continuing to produce and handle products organically. For more information, please email Claudia Reid, CCOF Policy Director.
CCOF Defends Organic Agriculture Against Attacks During E.Coli Outbreak
CCOF press release: No Evidence to Link Organic Spinach to E. coli O157:H7 Outbreak The U.S. Food and Drug Administration and the State of California announced results from the field investigation of the outbreak of E. coli O157:H7, tracing a matching genetic fingerprint in spinach that sickened 199 people (and killed three) to samples of cattle feces and wild pigs found on on a ranch in San Benito County, California. Investigators found that numerous wild pigs thrived alongside grazing cattle in the riparian habitat of a cattle operation near a spinach field.
According to the FDA, all connections between specific bags of spinach and individual victims of the outbreak were traced to Dole bagged spinach packed by Natural Selection Foods, San Juan Bautista, California. On September 15, 2006, Natural Selection Foods initiated a voluntary recall of all the spinach brands it packs (both conventional and organic). Visit the FDA website for further information.
CCOF Press Release: CCOF Defends Organic Agriculture Against Attacks “The tragic outbreak of E. coli O157:H7 in spinach that has killed one person and sickened nearly 200 others in 25 states, is being mistakenly linked to organic farming practices,” said CCOF Executive Director Peggy Miars. “Our sympathy goes out to the individuals and families affected by the outbreak. I’m concerned that misinformation is being spread about the source of the contamination and that organic is being unjustly blamed.”
2008 Farm Bill
2008 Farm Bill
CCOF Advocates for Organic’s Fair Share in The 2008 Farm Bill
The Farm Bill battle has been won but the war still wages. As we continue to work with our colleagues on implementing the 2008 Farm Bill that just passed, we still need your help. We will monitor the appropriations process in Congress to make sure they fund the programs that they authorized. We will work with USDA and other agencies to make sure that they design the programs the way we — and Congress — intended. And we will work with NRCS and other implementers here in California to make sure our farmers have access to these programs that are so important for organic farmers. Please contact Claudia Reid at CCOF, the Sustainable Agriculture Coalition, or the Organic Farming Research Foundation (OFRF) for ways to stay involved during the next crucial steps.
FARM BILL FINALLY PASSES
On May 22, 2008, the House of Representatives voted overwhelmingly to override President Bush’s veto of the 2008 Farm Bill. However, a complication arose when it became clear that the printed version prepared by the House clerk and sent to the President for his review and eventual veto, had omitted Title III of the Conference Report that had been passed by both House and Senate in identical form. Finally, on June 18, 2008, both the House (by a vote of 317-109) and the Senate (by a vote of 80-14) overrode the President’s second expected veto, to pass the 2008 Farm Bill. Last Thursday, June 12, 2008, Secretary Schafer announced that the USDA has already begun implementing the marketing assistance loan and loan deficiency payment provisions of the new bill.
Organic Wins
In addition to the increased research, education and extension funding, the 2008 Farm Bill addresses other factors that are limiting organic production in the U.S., including:
providing $5 million for collection of economic data about organic production and markets;
providing $22 million to offset part of farmers’ organic certification costs;
taking steps to eliminate bias against organic growers in crop insurance programs;
establishing financial and technical support for conversion to organic production.
For details on 2008 Farm Bill provisions related to organic agriculture, please visit the Organic Farming Research Foundation (OFRF) website.
In short, the 2008 Farm Bill is a vast improvement for organic agriculture over the 2002 Farm Bill. If President Bush vetoes the bill and Congress fails to override the veto, the 2002 bill would probably be extended into 2010 and all of these gains for organic farmers would be lost.
Get Involved! Advocate, Educate, Speak Out and Spread the Word
Contact Tracy Lerman at OFRFto sign up for updates and action alerts. For more information, email Tracy at tracy@ofrf.org.
Speak Out! Respond to Farm Bill action alerts by sending emails or calling your Member of Congress; you can communicate directly with and/or find out who your representative is at: house.gov/writerep
Write letters to the editor or op-ed pieces for your local newspaper
Educate others! Host a meeting in your community about the Farm Bill
Spread the Word! Encourage your friends and colleagues to get involved
GE & Cloning
Genetic Engineering & Cloning
CCOF is engaged in a range of activities to protect ourselves and the environment from the dangers of modifying the genes of plants and animals.
Skip to info on: Genetic Engineering | Cloning
Farmers get toll-free number to learn proximity to GE alfalfa
The U.S. Department of Agriculture (USDA) is offering alfalfa farmers a toll-free number for inquiries about the proximity of their farms or fields to genetically engineered (GE) Roundup Ready alfalfa. The number is 866-724-6408 and is operational only from 9 a.m. to 5 p.m. Eastern Time, Monday through Friday. This action is in response to a court order prohibiting the planting of Roundup Ready alfalfa after March 30, 2007.
Genetic Engineering
You Are What You Eat
Are you curious about how your food is produced? You can refer to The True Food Shopping Guide which will provide you with all kinds of information about foods that have been genetically modified. CCOF has not verified any information on this site nor can CCOF guarantee the accuracy of the list. If you’d like to purchase your food from producers that you KNOW are not using anything that’s been genetically engineered, use the CCOF Organic Directory. You can search by region, product, name of operation, location, etc.
California State GE Legislation for 2007-2008 - AB 541
AB 541 is one step closer to becoming California’s first state law protecting farmers from the hazards of genetically engineered crops. Having already passed the Assembly, it passed out of the Senate Agriculture Committee on June 5th, 2008. It has the support of California Certified Organic Farmers, Community Alliance with Family Farmers, the California Farmers Union, the California Farm Bureau, the California Cotton Ginners and Growers Associations, and many food safety and environmental organizations.
Introduced by Assembly Member Jared Huffman (6th AD) early in 2007, the bill was held over in the Agriculture Committee in April. Since then, AB 541 has been scaled back to address two provisions related to farmer protections.
AB 541 will enact protections for California farmers against frivolous lawsuits that intimidate and harass those who have not been able to prevent the inevitable – the drift of genetically engineered pollen or seed. It will level the playing field for farmers accused by agricultural biotechnology companies and other patent holders of contract violations, and discourage the practice of biotech companies sampling crops without explicit permission from farmers and prosecuting based on unverifiable testing results.
Specifically, the newly amended bill would provide for:
1. Protection from patent infringement lawsuits for farmers unknowingly contaminated by GE crops. Currently, farmers with crops that become contaminated by patented seeds or pollen have been the target of such lawsuits without clear recourse or defense.
2. The establishment of a mandatory crop sampling protocol to be used by patent holders when investigating farmers they believe may have violated patents or seed contracts. This protocol would require the farmer’s written permission for sampling, and provide for a state agriculture official to accompany the patent holder during the sampling and collectduplicate samples for independent verification if requested by either party.
The original bill included several other elements, including the establishment of the country’s first system of notification for the locations of GE crops; the confinement of experimental pharmaceutical-producing crops to greenhouses to protect the food system from contamination; and, legislative clarity that the GE crop manufacturer is liable in the event of contamination, and not farmers.
GE Pre-Emption in 2006 - SB 1056
Victory! SB 1056 Fails to Pass California Senate
SB 1056 was introduced in 2006 in response to the passage of county and city bans on genetically engineered (GE) crops. These local governments felt the need to step in due to the absence of statewide regulations to protect consumers, farmers, and the environment from the serious risks of GE crops. SB 1056’s main goal was to strip the rights of local governments who chose to impose these bans, and thus turn all authority on GE crops over to the state. Although SB 1056 did get painfully close to passage, in the end it failed to make it out of committee in the California Senate and died with the close of the legislative year on August 31, 2006. CCOF Executive Director Peggy Miars spent numerous hours strategizing with allies, writing opposition letters, recruiting farmers to speak to elected officials, and pounding the halls of the Capitol to discuss the bill with (sometimes uninformed) Senators and their staff. CCOF also sent an email Action Alert to over 5,000 subscribers in hopes of generating attention, advocacy, andopposition to this bill. We want to thank every organization and each individual who made efforts on behalf of the opposition of SB 1056. Read More…
The Dangers of Genetically Engineered Crops
GMOs and organicWhat is Genetic Engineering?
Genetic engineering (GE) is a new technology that involves the manipulation of genes. Unlike traditional hybridization techniques that have been used for centuries, genetic engineering allows researchers to break down the species boundaries set up by millions of years of evolution. Never before was it possible to transfer genes from animals to plants or from bacteria to humans. By combining the genes of unrelated species, permanently altering their genetic codes, novel organisms are created that will pass the genetic changes onto their offspring through heredity. There are many unanswered questions about the effects that genetic engineering could have on the health and ecology of our world once released into the environment.
CCOF Has a History of Working to Protect Farmers from GE Contamination.
For years CCOF has opposed the commercialization of GE crops because of the threat they pose to organic and non-organic growers. CCOF has worked hard to ensure that the regulations adhered to by growers throughout California and the rest of the country prohibit the use of genetically engineered products in organic production. The USDA’s National Organic Program Final Rule classifies genetically modified products as an “excluded method” in organic production.(i) CCOF played an instrumental role in ensuring that GMOs were excluded from the Final Rule when it was crafted and written into law.
Economic, Environmental, and Public Health Considerations for Growing Genetically Engineered Crops
* GE crops impact beneficial insects and other non-target species.
o Increased mortality rates in Monarch butterfly larvae have been shown to occur when fed genetically engineered Bt (Bacillus thuringiensis) pollen.(ii)
o Giroux et al. reported that ladybugs, which prey on the Colorado potato beetle, consumed fewer potato beetle eggs when the potatoes had high levels of Bt toxin.(iii)
o In work conducted at the Swiss Federal Research Station for Agroecology and Agriculture, Hilbeck et al. reported that lacewing larvae reared on prey that were fed Bt-producing corn took longer to develop and had a strikingly elevated mortality rate.(iv)
o Research in Ohio on genetically engineered potatoes found natural enemies reduced to such low levels that aphid outbreaks occurred.(v)
* Pests resistant to chemicals or pesticides are likely to develop with GE agriculture.
o Recently an herbicide-tolerant canola plant was discovered that cross-pollinates with a related weed.(vi) This could mean, among other results, that weeds will eventually emerge that are herbicide-resistant, requiring more toxic chemicals to get rid of them.
o A study published in 1999 raises concern that insects may develop resistance to moderate dose Bt corn, potentially undercutting the current strategy recommended to growers by the USDA to avoid pest resistance.(vii)
o The current reliance on just a few broad-spectrum herbicides makes it likely that resistance will develop even faster. Already canola weeds resistant to three herbicides have been found in a field in northern Alberta, Canada.(viii)
* Genetic pollution is already affecting organic and non-organic growers.
o USDA has admitted that genetically engineered seeds may have moved outside of field test sites due to animal dispersal.(ix) No published studies have examined the extent of the ecological consequences of this impact on natural populations.(x) Yet the potential for economic harm for farmers of genetic pollution are already real and severe.(xi)
o In September 2000, taco shells sold in supermarkets were contaminated with a variety of GE corn (StarLink) engineered with tolerance to glyphosate and to express the pest toxin Bt.(xii) The GE corn was approved for use in animal feed only, due to EPA concerns about possible human allergic reactions to the problem. Although it was grown on less than 0.5 % of all U.S. corn acres, more than 300 food products were recalled as a result of the contamination. Experts in Iowa estimated that approximately half the state’s corn (roughly 1 billion bushels) could be contaminated.(xiii)
o In September 2002, USDA discovered a Prodigene plot of pharmaceutical corn growing near fields of non-organic corn. Fearing that gene flow from the “pharm” corn (engineered to contain an experimental pig vaccine) had contaminated the food corn, the agency ordered 155 acres destroyed. Government regulators then checked its other fields and discovered that volunteer “pharm” corn from a Nebraska field trial had contaminated soybeans there, resulting in the quarantine and destruction of $3 million worth of beans.(xiv)
o In Hawaii, independent laboratory testing results issued in September 2004 found genetically modified organisms in papayas grown on organic and non-organic farms. Contamination was also found in the stock of non-genetically engineered seeds being sold commercially by the University of Hawaii.(xv)
* GE crops and their effects on human health
o A public health issue was narrowly averted when independent tests on the GE soybean revealed that people allergic to Brazil nuts also reacted to the engineered soybean.(xvi)
o Many studies have shown that DNA does not always fully break down in the digestive system.(xvii, xxviii) Gut bacteria can take up genes and fragments of DNA (xix) which could potentially lead to the spread of antibiotic resistance.
o According to Salk Institute cell biologist David Schubert, the crude and unpredictable nature of genetic engineering techniques could lead to “the biosynthesis of molecules that are toxic, allergenic or carcinogenic … GM (genetically modified) food is not a safe option, given our current lack of understanding of the consequences of recombinant technology.”(xx) Schubert and others recommend long-term animal feeding studies to test for possible toxic and reproductive effects.
o GM maize (StarLink corn) that had not been approved for human consumption by the US Food and Drug Administration was found in store-bought taco shells distributed by Kraft Foods in September 2000.(xii)
* Increased costs and liability to organic and non-organic farmers
o A survey of farmers conducted in 2003 by the Organic Farming Research Foundation showed that many organic farmers are incurring more costs to grow their crops because they are having to pay for DNA tests or undertaking more costly planting processes to ensure that they have not been contaminated by genetically engineered crops.(xxi)
Federal Agencies: Inconsistent in Their Assessment of the Safety of GE Crops
The FDA states GMO crops are the same as traditional crops for all regulatory purposes. But this policy is inconsistent with the views of many of their own scientists, as well as other Federal government researchers.(xxii) The quotes below highlight the concerns that many scientists are raising about the safety of deregulated GMO crops.
o FDA microbiologist Dr. Louis Pribyl stated: “There is a profound difference between the types of unexpected effects from traditional breeding and genetic engineering ….”(xxiii)
o Dr. E.J. Matthews of the FDA’s Toxicology Group warned that “. . . genetically modified plants could … contain unexpected high concentrations of plant toxicants…,” and cautioned that some of these toxicants could be unexpected and could “…be uniquely different chemicals that are usually expressed in unrelated plants.”(xxiv)
o Quote by Dr Suzanne Wuerthele, US Environmental Protection Agency (EPA) toxicologist: “This technology is being promoted, in the face of concerns by respectable scientists and in the face of data to the contrary, by the very agencies which are supposed to be protecting human health and the environment. The bottom line in my view is that we are confronted with the most powerful technology the world has ever known, and it is being rapidly deployed with almost no thought whatsoever to its consequences.”(xxv)
CCOF Supports a Moratorium on the Propagation of GE crops until:
1. Adequate, accurate, peer-reviewed research assessing the risks GE crops pose to wildlife, human health, and soil ecology is required to be presented as part of the approval process for any proposed commercialization.
2. Contamination of organic and non-organic crops by GE crops is the liability of the patent owners and growers of these GE crops.
3. An adequate regulatory framework is in place to protect organic and non-organic farmers from GE contamination at all stages of the farming process:
* Development of buffer zones that account for the full possibility of seed and pollen dispersal as estimated by scientific reports.
* Protections are required to prevent pollen dispersal through insect and wind vectors.
* Financial protection is guaranteed to the organic and non-organic growers who become contaminated by GE crops.
* Rigorous precautions are in place throughout the food chain, including specialized mills, processing facilities, transportation systems, and distribution networks to maintain separation of GE materials
* Labeling standards and requirements to identify GE content are in place for all the above operations but most especially on final product presented to the consumer.
An Invitation to Join Californians for Ge-Free Agriculture (CGFA)
CCOF is excited to be a founding member of a new coalition working to prevent genetically engineered (GE) crops in California. We are encouraging all of our members to get involved with this coalition and lend support to the campaign.
Right now California is virtually free of genetic engineering (GE), with the major exception of GE cotton grown in the Central Valley. In the next few years, however, the industry hopes to commercialize a new generation of GE crops in the state, including: Bayer’s herbicide-tolerant rice; Ventria Bioscience’s pharmaceutical rice (with human genes); and, Monsanto’s herbicide-tolerant strawberries, lettuce and rice. Bayer’s GE rice was recently approved by the federal government and could be grown in California soon.
We must stop GE crops in order to continue being a world leader in organic and sustainable agriculture. Californian farmers and consumers can lead the way in the rejection of this dangerous technology and demand a different kind of agriculture.
Please join the campaign today. You can find out more about Californians for GE-Free Agriculture by visiting our website www.calgefree.org and signing up for our volunteer network to receive updates and information about getting involved.
Thanks for your support and interest.
Footnotes and References
(i) USDA National Organic Program Final Rule. Section 205.105(e) (“Excluded Methods” are defined under “Terms” in Section 205.2)
(ii) John E. Losey, Linda S. Rayor, and Maureen E. Carter. “Transgenic pollen harms monarch larvae.” Nature. Vol. 399. May 20, 1999.
(iii) Giroux et al. “Bacteriological Insecticide M-ONE Effects on Predation Efficiency and Mortality of Adult Coleomegilla maculata lengi (Coleoptera: Coccinellidae).” Journal of Economic Entomology 87: 39-43. 1994.
(iv) Hilbeck A., Moar W.J., Pusztai-Carey M., Filippini A. and Bigler F., 1999. Prey-mediated effects of Cry1Ab toxin and protoxin and Cry2A protoxin on the predator Chrysoperla carnea. Entomologia Experimentalis et Applicata. 91 (2), 305-316.; Hilbeck, A., M. Baumgartner, P.M. Fried, F. Bigler. 1998a. Effects of transgenic Bacillus thuringiensis corn-fed prey on mortality and development time of immature Chrysoperla carnea (Neuroptera: Chrysopidae).
Environmental Entomology. 27: 480-487.; Hilbeck, A., W.J. Moar, M. Pusztai-Carey, A. Filippini, and F. Bigler. 1998b. Toxicity of Bacillus thuringiensis Cry1Ab toxin to the predator Chrysoperla carnea (Neuroptera: Chrysopidae). Environmental Entomology. 27: 1255-1263.
(v) Hoy, C.W., J. Feldman, F. Gould, G.G. Kennedy, G. Reed, and J.A. Wyman. 1998. Naturally occurring biological controls in genetically engineered crops. Pp. 185-205 in Conservation Biological Control, P. Barbosa, ed. New York: Academic Press.
(vi) Laura Tangley. “Of Genes, Grain, and Grocers: The Risks and Realities of Engineered Crops.” U.S. News and World Report. April 10, 2000.
(vii) F. Huang, et al. “Inheritance of resistance to Bacillus thuringiensis toxin (Dipel ES) in the European corn borer.” Science. 284: 965-7. May 7, 1999.
(viii) Mary MacArthur. Triple-resistant canola weeds found in Alta. The Western Producer. February 10, 2000.
(ix) Wrubel, R.P., Krimsky, S., and Wetzler, R.E. “Field Testing Transgenic Plants.” Bioscience. Volume 42, Issue 4. April 1992.
(x) L.L. Wolfenbarger and P.R. Phifer. “The Ecological Risks and Benefits of Genetically Engineered Plants.” Science. December 15, 2000.
(xi) Anthony Shadid. “Blown profits.” Boston Globe. 8 April 2001.
(xii) Kay, J., (October 13 2000), San Francisco Examiner.
(xiii) Neil E. Harl, et al, “The StarLink Situation,” IA State University. And “Starlink corn crisis sparks regulatory, market concerns,” Food and Chemical News, October 30, 2000.
(xiv) For instance, see: T. Hesman, “Crop experiments get more watchful look; USDA ordered destruction of soybeans after contamination,” St. Louis Post-Dispatch, Nov. 22, 2002; E. Weise, “Company is fined for ‘escaped’ corn,” USA Today, Dec. 9, 2002.
(xv) “Genetic Traits Spread to Non-Engineered Papayas in Hawaii,” Environment News Service, September 10, 2004.
(xvi) Nordlee, J.D., Taylor, S.L, Townsend, J.A., Thomas, L.A. and Bush, R.K. (1996). “Identification of a Brazil Nut Allergen in Transgenic Soybeans” New England Journal of Medicine, Vol 334 (11) p. 726
(xvii) Schubbert, R., Lettmann, C. and Doerfler, W. (1994) Ingested foreign (phage M13) DNA survives transiently in the gastrointestinal tract and enters the blood stream of mice. Molecules, Genes and Genetics 242, 495-504.
(xviii) Schubbert, R. Hohlweg, U., Renz, D. and Doerfler, W. (1998) On the fate of orally ingested foreign DNA in mice: chromosomal association and placental transmission in the fetus. Molecules, Genes and Genetics 259, 569-576
(xix) Mercer, D.K., Scott, K.P., Bruce-Johnson, W.A., Glover, L.A. and Flint, H.J. (1999) Fate of free DNA and transformation of oral bacterium Streptococcus gordonii DL1 plasmid DNA in human saliva. Applied and Environmental Microbiology 65, 6-10.
(xx) Schubert, D. (2002). “A different perspective on GM food,” Nature Biotechnology, Vol. 20, p. 969.
(xxi) Elias, P., (June 5, 2003) “Biotech Revolution Costs Organic Farmers”. The Associated Press.
(xxii) Food & Drug Administration’s (FDA) internal memoranda about the hazards of genetically engineered foods, which became available through the lawsuit (Alliance for Bio-Integrity et al., vs. Shalala, et al.)
(xxiii) Comments from Dr. Louis J. Pribyl re: the “Biotechnology Draft Document, 2/27/92.” Administrative Record (A.R.) 19179. Dated March 6, 1992.
(xxiv) Memorandum from Dr. Edwin J. Mathews to the Toxicology Section of the Biotechnology Working Group. Subject: “Analysis of the Major Plant Toxicants.” Administrative Record (A.R.) 18572. Dated October 28, 1991.
(xxv) Reprinted with permission of Dr Suzanne Wuerthele, US Environmental Protection Agency (EPA) toxicologist