Post market-monitoring may be undertaken for the purpose of:

A) Verifying conclusions about the absence or the possible occurrence, impact and significance of potential consumer health effects; and

B) Monitoring changes in nutrient intake levels, associated with the introduction of foods likely to alter nutritional status significantly, to determine their human health impact. ^[1]

It should be noted that these are issues which should be resolved in a scientific setting prior to market.

 

Yet Codex is obviously content to allow the public to act as lab rats in the real world rather than force these side effects to be addressed in an actual lab. Absolute disregard for the global population is evident here.

The Codex principles of risk analysis, particularly those for risk assessment, are primarily intended to apply to discrete chemical entities, such as food additives and pesticide residues, or a specific chemical or microbial contaminant that have identifiable hazards and risks; they are not intended to apply to whole foods as such.^[3]

Essentially, this is an admission that risk assessment methodology is absolutely incapable and inappropriate when dealing with the safety of a whole food.

 

As Codex makes clear, the principles for risk assessment were never intended to address anything other than chemicals and additives.

However, one should remember that risk assessment is indeed the method used to determine the safety of vitamins, nutrients, and minerals by Codex Alimentarius in order to label them unsafe at unreasonably low levels.

But Codex continues with even further admission that the testing methods used are not nearly as intense as one might think.

 

The document reads,

Traditionally, new varieties of food plants have not been systematically subjected to extensive chemical, toxicological or nutritional evaluation prior to marketing, with the exception of foods for specific groups, such as infants, where the food may constitute a substantial portion of the diet.

 

Thus, new varieties of corn, soybean, potatoes and other common food plants are evaluated by breeders for agronomic and phenotypic characteristics, but generally, foods derived from such new plant varieties are not subjected to the rigorous and extensive food safety testing procedures, including studies in animals, that are typical of chemicals, such as food additives or pesticide residues, that may be present in food.^[4]

Simply put, Codex is admitting, albeit cleverly, that the testing method for whole foods is inadequate, and that the testing itself is not nearly as extensive as it would be for evaluating a known toxin like a chemical, pesticide, or apparently, vitamins and minerals.

As related to Codex’s position on vitamins and minerals, Codex considers genetically modified foods that have been engineered to produce a deadly chemical or pesticide to be a whole food, but vitamin C is considered a toxin.

Yet Codex does not stop here with the prefacing of their intended deceit and the admission of flawed and manipulated science.

 

It says,

Animal studies cannot be readily applied to testing the risks associated with whole foods, which are complex mixtures of compounds, often characterized by a wide variation in composition and nutritional value.

 

Owing to their bulk and effect on satiety, they can usually only be fed to animals at low multiples of the amounts that might be present in the human diet.

 

In addition, a key factor to consider in conducting animal studies on foods is the nutritional value and balance of the diets used; this is in order to avoid the induction of adverse effects that are not related directly to the material itself.

 

Detecting any potential adverse effects and relating these conclusively to an individual characteristic of the food can, therefore, be extremely difficult. If the characterization of the food indicates that the available data are insufficient for a thorough safety assessment, properly designed animal studies could be requested on the whole foods.

 

Another consideration in deciding the need for animal studies is whether it is appropriate to subject experimental animals to such a study if it is unlikely to give rise to meaningful information.^[5]

But there are several problems with this statement.

First, let it be made clear that this writer does not support the use of animals for laboratory testing for any reason.

However, this issue is not the focus of this article and it will be repeatedly referred to in its proper context in terms of scientific debate.

That being said, what Codex has admitted to in this statement, albeit subtly, is that test subjects will actually be fed significantly less of the GM food in question than exists in the standard human diet.

 

Nowhere does Codex mention that the amount fed to the test subjects can be adjusted per capita, but simply that the amount fed to them will be,

“at low multiples of the amounts that might be present in the human diet.” ^[6]

Furthermore, Codex attempts to convince the reader that because of differences in nutritional values and diet balance in the animals being tested it is extremely difficult to determine if there are any adverse effects resulting from the material being tested or another material/condition. Hence, Codex would have the reader believe that this problem could not be solved by the addition of a control group.

In the end, the overall conclusion of Codex is that testing GM foods is largely unproductive and that, for the most part, it should only be conducted in very special circumstances. Mere post-market tracking is looked upon as the most favorable route.

 

This, however, leaves the consumer as the test subject, and corrective action can only be taken after it is too late for hundreds, thousands, or even millions of people.

Codex furthers this claim with an admission of its acceptance of “substantial equivalence” as a testing standard.

 

Because of the problems associated with using risk assessment to address dangers in whole foods (but evidently not nutrients and vitamins), Codex claims it must rely on substantial equivalence to address intended and unintended changes in the food. Hence, Codex officially accepts the concept. ^[7]

In subsequent sections, Codex claims that even weak standards like substantial equivalence may not be required.

 

The guidelines state,

“For the reasons described in Section 3, conventional toxicology studies may not be considered necessary where the substance or a closely related substance has, taking into account its function and exposure, been consumed safely in food.” ^[8]

However, there is no discussion of exactly how it will be determined that these substances have been consumed safely in food to begin with.

 

Considering the fact that toxic substances like fluoride and rBGH have been consumed “safely” in food for many years, it is certainly frightening to think that even more substances may be created and added to the food supply under the guise of a history of safe consumption.

 

Nevertheless, this process (or lack thereof) is not only unscientific, it is very dangerous.

Information about the known patterns of use and consumption of a food, and its derivatives should be used to estimate the likely intake of the food derived from the recombinant-DNA plant.

 

The expected intake of the food should be used to assess the nutritional implications of the altered nutrient profile both at customary and maximal levels of consumption.

 

Basing the estimate on the highest likely consumption provides assurance that the potential for any undesirable nutritional effects will be detected. ^[9]

While this language is carefully crafted to appear benign and concerned only with the welfare of different cultures consuming the GM food, what is actually being presented is the idea of a Global Expectable Average Daily Diet for purposes of creating an Upper Limit not on GM food, but on the nutrients existing within the food itself - all this, while, at the same time, allowing genetically engineered food to remain virtually unregulated.

As mentioned in the chapter dealing with vitamin and mineral supplements, the Global Average Daily Diet is simply taking the “average” level of consumption of a food or nutrient across the world and using that level as a base level standard for what will be considered the average intake of the product by all populations. The highest or lowest levels are usually chosen based on the needs of the scientist, particularly in situations like these where researchers have ulterior motives.

Remember, in the case of vitamin and mineral food supplements where the highest level of intake was used instead of the real average. This was because third world countries were not included properly in the average.

Like the GADD for vitamins and nutrients, the highest level of consumption will be used to examine GM food. However, using the highest level of consumption, in this case, will have an entirely different effect than it did upon vitamins and minerals.

Using the highest level of consumption estimation in concert with the concept of substantial equivalence, Codex creates an environment where it would be difficult for GM food not to be approved.

With the concept of substantial equivalence and the GADD taken in concert with one another, we could easily imagine a hypothetical scenario such as the following:

We might imagine that potatoes have a higher consumption rate in North America and Europe than in other regions of the world. So researchers would determine, based on the rate of potato consumption of Europe and North America, the Global Expectable Average Daily Diet.

 

This average consumption rate would be applied worldwide regardless of other cultures’ consumption of potatoes. Likewise, using the concept of substantial equivalence, GM potatoes would be approved with an Upper Limit of the highest rate of consumption worldwide.

However, there are even more dangers to using the “substantial equivalence/substantial similarity” model in conjunction with the “risk assessment” evaluation methodology in terms of GM food.

Indeed, there exists a very real possibility that the Codex position on GM food as well as vitamin and mineral supplements will be used to develop a food system in which GM food is the only acceptable form of food allowed in the supply, while any other food may be removed from the market.

 

In addition, it is entirely possible that once the standards are set by Codex and agreed upon by nations participating in the WTO, that foods containing high levels (or reasonable levels) of nutrition could be removed from the market simply on the basis of their high nutritional content.

For instance, the damage to the food supply does not end with the introduction of GM foods. In addition, because Codex standards are enforced by the WTO, the Maximum Permitted Levels for vitamin and minerals developed by Codex will remain in place.

So, because the risk assessment for GM food based on “substantial equivalence” will inevitably determine the GM food itself to be safe, the problem then becomes the nutritional value within the food.

The nutrition then becomes the enemy and must be removed.

While this might seem both improbable and impossible, it is, in fact, neither.

The seeming improbability of a Codex declaration of nutrients as toxins has already been realized and the genetic manipulation of the nutritional properties of food is not an impossibility at all.

While the cover story for the introduction of GM food often involves the alleged wish to bring about the end of malnutrition by increasing nutritional properties of the food genetically (a blatant contradiction if one accepts that nutrients should be treated as toxins), the ability to decrease nutrition through genetic modification is just as realistic.

We then have a situation where nutritionally deficient GM food is not only allowed, but required due to the “dangerous” amount of vitamins and minerals that exist in the natural food.

 

Codex even admits later on in the Guidelines that nutrients will be focused on rather than the dangers of the GM food.

 

It says,

To assess the safety of a food derived from a recombinant-DNA plant modified for a nutritional or health benefit, the estimated intake of the nutrient or related substance in the population(s) is compared with the nutritional or toxicological reference values, such as upper levels of intake, acceptable daily intakes (ADIs) for that nutrient or related substance.^[1]

The question then is not the safety of the GM food, but of the amount of vitamins and nutrients included in it.

Continuing through the Guidelines, such a statement is cleverly made.

 

It says,

“Rather than trying to identify every hazard associated with a particular food, the intention of a safety assessment of food derived from recombinant-DNA is the identification of new or altered hazards relative to the conventional counterpart.” ^[2]

Not only is this an extremely limiting set of standards for assessing the safety of the product, what is actually meant by “hazard”, although not explicitly stated, is nutrients.

This is made even clearer in the next paragraph which states,

“Upper levels of intake for many nutrients that have been set out by some national, regional and international bodies may be considered, as appropriate. The basis for their derivation should also be considered in order to assess the public health implications of exceeding these levels.” ^[3]

Clearly, nutrients are the focus of much of the risk assessment methods applied to GM food.

This may initially cause some GM food products to be rejected by Codex due to the higher level of nutritional properties being produced. That is, until the food is modified once again to have a lower nutritional value. When seen in this light, it becomes obvious that many of the Codex Guidelines are intertwined with one another.

 

However, none are more important than those related to vitamins, minerals, and nutrients.

Returning to the Codex Guidelines themselves, the organization leaves itself yet another loophole by claiming that, in a situation where even the unbelievably weak “substantial equivalence” method cannot allow the approval of a GM food, that the food used as a conventional counterpart may be changed in order to suit the GM product which is being evaluated.

 

It says,

When the modification results in a food product, such as vegetable oil, with a composition that is significantly different from its conventional counterpart, it may be appropriate to use additional conventional foods or food components (i.e. foods or food components whose nutritional composition is closer to that of the food derived from recombinant-DNA plant) as appropriate comparators to assess the nutritional impact of the food.^[4]

In this statement Codex is openly admitting that it will simply change the “scientific” process that we are supposed to put our faith in, in order to accommodate the GM substance being tested.

 

Essentially, Codex is saying,

“If the conventional counterpart is not substantially equivalent, change the conventional counterpart to one that is.”

Clearly, inasmuch as Codex guidelines are accepted, Codex is exercising control over the food supply and the choice that every human being has a right to make on their own.

 

Unfortunately, it is a very real possibility that if Codex Alimentarius is not stopped, we will live in a much smaller world where starvation, sickness, and hunger are rampant and where we must beg our multinational corporate masters for a bite of the toxic mass that we will have no choice but to eat.

 

 

Sources

[1] “Foods Derived From Modern Biotechnology,” 2nd edition. Codex Alimentarius. P.27
[2] Ibid. p.25
[3] Ibid.
[4] Ibid. p.17

 

 

 

 

 

 

 

Part 7

February 20, 2013

 

 

In several of my recent articles, I have discussed the problems of using “risk assessment” methodology in the evaluation of both vitamin and mineral supplements and Genetically Modified (GM) food.

 

I have also discussed at length the dangers of the Codex Alimentarius and U.S. Food and Drug Administration position on GM food which is known as “substantial equivalence” and, in its more extreme forms, “substantial similarity.”

However, another concern addressed by the Codex Guidelines has to deal with antibiotic resistance created through the process of genetic engineering. Yet, as is typical of any Codex Alimentarius presentation, the agency makes several misleading and unsettling statements in this regard as well.

 

While Codex does state that methods should be used that do not result in antibiotic resistance, it qualifies that claim in its document “Foods Derived From Modern Biotechnology,” by stating that these methods should be used,

“where such technologies are available and demonstrated to be safe.” ^[1]

This is certainly no mandate. It is merely a suggestion that will most likely be completely ignored by industry.

The Guidelines then go on to say that,

“Gene transfer from plants and their food products to gut micro-organisms or human cells is considered a rare possibility because of the many complex and unlikely events that would need to occur consecutively.” ^[2]

This statement stands in direct contradiction to established science.^[3]

 

Indeed, the series of events that would have to transpire in order for the transfer of modified genes from a plant to human DNA or cells are neither unlikely nor rare.

 

In a footnote to this statement, Codex makes the claim,

“In cases where there are high levels of naturally occurring bacteria that are resistant to the antibiotic, the likelihood of such bacteria transferring the resistance to other bacteria will be orders of magnitude higher than the likelihood of transfer between ingested foods and bacteria.” ^[4]

Yet while this may in fact be true the statement is still misleading.

 

The issue being discussed in the footnoted statement is the likelihood of DNA transfer from GM plants to humans. Furthermore, if such events were so unlikely, why would it be important not to use antibiotic resistant gene technology in the future?

Another concern presented in the section of “Foods Derived From Moderin Biotechnology” dealing with GM plants is the question of potential allergens being created within the food products as well as the introduction of entirely new allergens that have never before existed in nature.

While Codex claims that “all newly expressed proteins” as well as “a protein new to the food supply” should be tested for safety, there are legitimate questions as to whether or not Codex has the ability or the desire to test for such possibilities. ^[5]

First, while it is quite possible to know what foods occurring naturally are allergenic, it is much more difficult to come to these conclusions about new substances or proteins.

 

This is partly due to the fact that naturally occurring materials have so many millions of years of history and use which, in itself, tends to naturally weed out the allergenic foods from the non-allergenic ones in a population’s diet. GM products do not have this history.

Indeed, the idea that over time a population tends to form its own guidelines through natural process adds to the ease in which scientific inquiry may form knowledge of the food properties in relation to the population itself. Again, this is not the case with GM food.

Therefore, another problem with the Codex Guidelines is made manifest. Because Codex works on a global scale, the potential allergens are listed globally and may not take into consideration (in future labeling) the geographic concerns of individual populations.

 

When one considers the fact that allergens differ across geographic boundaries, with some foods being allergenic in one culture but not in others, he/she is confronted with the task that, in order to introduce a new substance into the food supply with new proteins, all of these populations must be tested separately.

 

The tests of course should also be conducted over a longer period of time to investigate prolonged exposure.

However, Codex makes no mention of this problem and, likewise, mentions no remedy for it.

 

Are we really supposed to believe that, hidden deep within the Guidelines, Codex plans to organize representative samples of every culture across the globe for every new protein added to the food supply? This is not likely even if one believed the organization was working truly promoting food safety.

Secondly, Codex itself admits tremendous flaws in its ability to test for new allergens.

 

It says quite plainly that,

“there is no definitive test that can be relied upon to predict allergic response in humans to a newly expressed protein.” ^[6]

Because of this lack of a standardized and easily deciphered test, it goes on to say,

“A critical issue for testing will be the availability of human sera from sufficient numbers of individuals.” ^[7]

This, however, is a major problem due to the fact that in order to test for just one allergy a minimum of eight sera is required for a major allergy, and a minimum of twenty-four sera for a minor allergy.^[8]

This is a rather large amount of material for testing purposes. It should be noted that this is the required sera for just one test subject. This test would have to be repeated hundreds and perhaps even thousands of times per geographic region or culture. It would then have to be replicated hundreds or thousands of times more on a global scale to account for these regions and cultures.

Even Codex admits, albeit in a footnote, that,

“It is recognized that these quantities of sera may not be available for testing purposes.” ^[9]

With this in mind, it is clear that testing for allergens in GM products would prove extremely difficult to organize and conduct, even if Codex were truly committed to its professed goal of food safety.

 

 

 

 

Notes

[1] “Foods Derived From Modern Biotechnology,” 2nd edition. Codex Alimentarius. P.18
[2] Ibid. p.18
[3] Ho, Mae-Wan; Ryan, Angela; Cummins, Joe; “Cauliflower Mosiac Viral Promoter- A Recipe For Disaster?” Institute of Science in Society. 
[4] Foods Derived From Modern Biotechnology,” 2nd edition. Codex Alimentarius. P.18
[5] Ibid. p. 27
[6] Ibid. P.20
[7] Ibid.
[8] Ibid.
[9] Ibid. p.22

 

 

 

 

 

 

 

Part 8

February 22, 2013

 

 

In the course of the recent article series I have written regarding Codex Alimentarius and its position on Genetically Modified (GM) food, I have criticized both the “risk assessment” method of GM food evaluation as well as the official position of Codex Alimentarius in regards to the “substantial equivalence” standards.

 

I have also written about the very real possibility of the introduction of new allergens and antibiotic resistant bacteria into the general food supply.

However, up to this point, all of the problems with the Codex Guidelines mentioned have been in relation to the section of the Codex GM position document known as “Foods Derived From Modern Biotechnology,” which focuses on GM plants.

There are, accordingly, two more sections - one dealing with GM Micro-Organisms and the other dealing with GM animals.

However, while it may seem that the majority of criticism expressed thus far focuses more attention on the first section (GM plants), the fact is that all three sections are very similar in their language and directives, with only a few changes in the wording made to apply to the new topic.

In many of these sections the language is word for word, copied and pasted to reiterate the same purpose as the first section. Therefore, I will not repeat my criticisms of the second and third sections that have appeared in my criticism of the GM Plants section.

 

Suffice to say that all of the problems existing in the GM Plant section exist in the GM Micro-Organism and GM Animal sections as well, namely those of questionable scientific practices, the ignoring of relevant data, and so on. This claim is easily verifiable by reading the Guidelines document cited in the footnotes.

With that said, some attention should be paid to the section entitled, “Guideline For The Conduct Of Food Safety Assessment Of Foods Produced Using Recombinant-DNA Micro-Organisms.”

 

This section deals mainly with bacteria, yeasts, and certain types of fungi in their uses in food production.

While making many of the same admissions present in the GM plant Guidelines, one of the most startling statements made regarding GM micro-organisms is the admission that they can in fact survive digestion.

Codex says,

“In some processed foods, they [GM micro-organisms] can survive processing and ingestion and can compete and, in some cases, be retained in the intestinal environment for significant periods of time.”^[1]

While this statement is not revolutionary, it is quite surprising to see it uttered by Codex Alimentarius, an organization that seems to go to great lengths to approve GM products.

Nevertheless, the fact that these micro-organisms can survive digestion is extremely important to the GMO safety debate. So are the questions of rDNA retention in the intestinal tract, the potential for changing the intestinal flora of those consuming the GM product, and the subsequent effects on the immune system.

These are all concerns that Codex tacitly admits the existence of, simply by acknowledging the need to test them.^[2]

 

Yet the tendency of GM micro-organisms to survive digestion and begin to change the makeup of the human intestines is mentioned later, in a footnote, where it is stated quite openly,

Permanent life-long colonization by ingested micro-organisms is rare. Some orally administered micro-organisms have been recovered in feces or in the colonic mucosa weeks after feeding ceased.

 

Whether the genetically modified micro-organism is established in the gastrointestinal tract or not, the possibility remains that it might influence the microflora or the mammalian host.^[3]

It should be noted that the idea that “life-long colonization by ingested micro-organisms is rare”^[4] is highly contested by many independent scientists.^[5]

 

Yet, even if one were to assume the truth of Codex’s statement, the fact that it is rare means that it is still possible. More importantly, the statement admits that, even without long-term residence in the intestinal tract, there is still the distinct possibility that it will still significantly affect the intestinal flora and likewise the host itself.

Still more obviously biased concerns exist in the subsection dealing with the information that should be provided on each of the DNA modifications or micro-organisms. This information is, for the most part, very basic. It contains such data as which genes are added, the number of insertion sites, etc.

 

However, two sources of information that are required to be included cause some concern.

The first is the inclusion of the,

“identification of any open reading frames within inserted DNA or created by the modifications to contiguous DNA in the chromosome or in a plasmid, including those that could result in fusion proteins.”^[6]

The second is the,

“particular reference to any sequences known to encode, or to influence the expression of, potentially harmful functions.”^[7]

Yet, both of these expressions (fusion proteins and genes that express harmful functions) are considered potentially dangerous even under the weak Codex standards.

 

These expressions refer to the ability of some proteins to fuse with other proteins of the same and other species, mutating the DNA of the species, or forcing it to produce potentially adverse effects. Neither of these characteristics should be present in food, yet Codex mandates only that they be reported, not removed, as a result of the testing.

 

This appears to be a continual thread of Codex’s Guidelines.

Thus, Codex continues by saying that additional information should be provided

to demonstrate whether the arrangement of the modified genetic material has been conserved or whether significant rearrangements have occurred after the introduction to the cell and propagation of the recombinant strain to the extent needed for its use(s) in food production, including those that may occur during its storage according to current techniques;^[8]

...as well as,

to demonstrate whether deliberate modifications made to the amino acid sequence of the expressed protein result in changes in its post-translational modification or affect sites critical for its structure or function;^[9]

While reporting information related to the instances above might seem like a good idea (and certainly few would argue that it isn’t), simple reporting is not enough.

 

Indeed, these issues, as well as the others mentioned in this section of the Guidelines, are related directly to the question of the stability of genetically modified organisms.

 

This is mentioned briefly in this section of the Guidelines, most notably in a footnote where it says,

Microbial genes are more fluid than those of higher eukaryotes; that is, the organisms grow faster, adapt to changing environments, and are more prone to change.

 

Chromosomal rearrangements are common. The general genetic plasticity of micro-organisms may affect recombinant DNA in micro-organisms and must be considered in evaluating the stability of recombinant DNA micro-organisms.^[10]

It is clear that GM organisms are often dangerously unstable.

 

Many of them carry genes that overproduce a certain characteristic, cannot be turned off, or simply begin to change even after it has been bonded to the new strain of DNA.

Yet, with all of these admissions by Codex as to the dangers that GM micro-organisms pose to those who consume them as well as the fact that GM DNA is often unpredictable, the Codex Guidelines recommendations for testing suggest that these micro-organisms should be assessed based upon tests conducted on the conventional counterpart, not the micro-organism itself.

If tests conclude that the questionable micro-organisms are removed or rendered non-toxic in their individual and natural states, then,

“viability and residence of micro-organisms in the alimentary system need no examination.”^[11]

Embodying the impracticality and unscientific methodology of substantial equivalence in this context, Codex does not take into account the various potential dangers that it mentioned just a few short paragraphs previous.

Even on the question of antibiotic resistance, Codex takes the position of ignoring sound science in terms of its allowance of antibiotic resistant genes to be used as recipient organisms.

 

It says,

In general, traditional strains of micro-organisms developed for food processing uses have not been assessed for antibiotic resistance. Many micro-organisms used in food production possess intrinsic resistance to specific antibiotics.

 

Such properties need not exclude such strains from consideration as recipients in constructing recombinant-DNA micro-organisms.^[12]

Although Codex does suggest that transmissible antibiotic resistant genetic strains should not be used, it clearly states that they should not be removed from consideration for use.

 

This does little to ease the concerns related to antibiotic resistance in general. This is because, as mentioned earlier, any gene that is inserted into another organism via genetic modification is inherently unstable. Not only that, but this process creates the potential to destabilize other genes as well. So the possibility still exists even when not using what is considered a “transmissible” gene.

 

Codex, of course, does not address this issue. It merely suggests that these antibiotic resistant genes not be removed from consideration as potential transfers and recipients.

The final mention of Codex’s treatment of GM micro-organisms revolves around some of the testing methods used to determine the potential of allergenicity – Sequence Homology and Pepsin Resistance testing.

 

With the exception of the specific serum tests mentioned earlier (the more reliable form of testing when adequately provided for), these are the only two methods mentioned for determining potential micro-organism allergens.

The problem with both of these methods is that they are insufficiently geared to the task.

 

By Codex’s own admission, Sequence Homology only assesses,

“the extent to which a newly expressed protein is similar in structure to a known allergen,” not whether the protein actually is an allergen.^[13]

But even this limited testing ability is challenged by the fact that the test can only be conducted by using sequences of allergens that are already known and available in scientific literature and public databases.^[14]

 

The document also says,

“There are also limitations in the ability of such comparisons to detect non-contiguous epitopes capable of binding themselves specifically with IgE antibodies.”^[15]

Therefore, the Pepsin Resistance test is just as problematic as Sequence Homology because, as Codex admits,

“a lack of resistance to pepsin does not exclude that the newly expressed protein can be a relevant allergen.”^[16]

Because several food allergens have demonstrated a resistance to pepsin digestion, it was conceived that this method of testing would be useful for determining potential food allergens.

 

However, this is obviously not the case as the correlation between pepsin resistance and allergenicity has not been fully investigated in its own right.^[17]

There is also the potential for Codex to use the some to ignore the many, i.e. actually using pepsin resistance testing to claim that if a substance has no pepsin resistance, then it is not a potential allergen.

In the end, the Codex position on GM Micro-Organisms and the potential safety implications of these organisms is yet more example of Codex’s complete and intentional obfuscation of the relevant scientific data. In cases where the science supports Codex’s position, the science is touted at every available opportunity.

 

When it does not, the science is ignored.

 

 

Notes

[1] "Foods Derived From Modern Biotechnology,” 2nd edition. Codex Alimentarius. P.39
[2] Ibid. p.42
[3] Ibid. p.48
[4] Ibid.
[5] Smith, Jeffrey. “Seeds Of Deception.” YES Books, 2003.
[6] “Foods Derived From Modern Biotechnology,” 2nd edition. Codex Alimentarius. P. 44.
[7] Ibid. p.45
[8] Ibid. p.45
[9] Ibid. p.45
[10] Ibid.
[11] Ibid p.49
[12] Ibid. p.49
[13] Ibid. p.53
[14] Ibid. p.54
[15] Ibid. p.54
[16] Ibid. p.54
[17] Ibid.

 

 

 

 

 

 

 

Part 9

February 26, 2013

 

 

In my last article entitled, “Codex Alimentarius and GM Food Guidelines Pt.8”, I detailed the Codex Alimentarius position regarding Genetically Modified (GM) Micro-Organisms. Similarly, in several of the articles I have written recently, I have also discussed the Codex position on GM plants and other GM organisms.

Yet, no analysis of the Codex Alimentarius positions on GM food and/or organisms would be complete without a discussion of the Codex position on GM animals.

Indeed, the “Guideline For The Conduct of Food Safety Assessment of Foods Derived From Recombinant-DNA Animals,” a subsection of the Codex document “Foods Derived From Modern Biotechnology,” is as interesting for the concerns that it does not address as for the ones that it does.

 

Largely a copied and pasted version of the two sections before it, (“Guideline for the conduct of food safety assessment of foods derived from recombinant-dna plants” and “Guideline for the Conduct of Food safety Assessment of foods produced using recombinant-dna micro-organisms”) the GM animal Guidelines does not address some very key issues such as:

1. Animal welfare

2. Ethical, moral and socio-economic aspects

3. Environmental risks related to the environmental release of recombinant-DNA animals used in food production

4. The safety of recombinant-DNA animals used as feed, or the safety of animals fed with feed derived from recombinant-DNA animals, plants and micro-organisms.^[1]

As can be easily seen, these issues are extremely important in their own right. Just the moral issues, in addition to the hazards of the potential of GM animals being released into the environment, are enough to fill volumes. However, Codex chooses not to deal with these issues in its Guidelines.

 

With that being said, because Codex treats GM animals essentially the same as GM plants, there is very little difference in the guidelines. This shows a lack of scientific zeal as animals are fundamentally different than plants.

Yet one area where Codex does address a different aspect of the GM safety question is related to veterinary drug residues. It says,

Some recombinant-DNA animals may exhibit traits that may result in the potential for altered accumulation or distribution of xenobiotics (e.g. veterinary drug residues, metals), which may affect food safety.

 

Similarly, the potential for altered colonization by and shedding of human pathogens or new symbiosis with toxin-producing organisms in the recombinant-DNA animal could have an effect on food safety.^[2]

With its implicit admission of the instability of modified genes, Codex now also admits that these genes, when changed in animals, could affect the distribution and retention of veterinary drugs and other substances which would necessarily change the content of the food product derived from that animal.

 

As Codex states, this same situation could also apply to human pathogens as well as veterinary drugs.

As a side note, it appears that 2007-2008 was a very beneficial year for GMO food producers. Not only were the pro-GM testing Guidelines approved by Codex, but many countries, such as the European Union who had been opposed to the introduction of GM food up to this point, began changing their position to one that was slightly more open to GMO.

For instance, in 2008, Codex Alimentarius approved Guidelines that would allow low levels of GM products that have not been approved by the countries’ regulatory agencies inside products that are imported into the country.

 

This would include products like grain, corn, and oats. Codex claims that this set of standards merely recognizes the fact that GM products will inadvertently mix with non-GM products during processing and transportation and that it means to provide guidance in this unavoidable situation.^[3]

However, this presupposes that GM contamination of food shipments is unavoidable when in fact just the opposite is the case. If GM products were not used to begin with, the entire issue would not need to be addressed.

Also, if countries that did not approve of GM products would simply refuse to import them if they were contaminated with one single GM organism, then the fact that the majority of people do not want GM food would be driven home.

 

This would be a great move for both the exporting and importing countries in that GM would be made economically unfeasible as well as forcing the importing country to produce their own food.

 

It may come as a surprise to many that these Guidelines were approved with the consent of the European Union, the very state that has voiced much dissent to GM products in the past. This is a clear signal that the European Union, now that is has become even more integrated than it was when the GM debate first appeared, is preparing to accept GM food on the level of the United States in the future.

While these Guidelines only apply to GM contamination of imported food, the European Union’s own guidelines have become much more relaxed in relation to GM food production within its borders. It is here that the various European countries are experiencing the tyranny of being a member of a European super-state that undermines their national sovereignty.

In March 2010, against the objections of countries such as Italy and Austria, the European Union’s European Commission approved an antibiotic resistant genetically modified potato.^[4]

These countries who, before joining the EU, would have had complete authority to block the importation and production of GM material now must defer to the EU court and commission system that are clearly undemocratic and unconcerned with the safety of the European people.

This is the same situation that occurred in 1998 when the European Union approved the MON810 strain of GM maize developed by Monsanto against the protest of several EU states.

Subsequently, several member nations banned the cultivation of the maize which now pits them against the European Commission in an ongoing battle for national sovereignty.^[5]

However, sovereignty is not likely to win out.

In 2007, the European Court of Justice overturned Austria’s ban on cultivation of GMO’s even though Austria has the broad support of its people and other nations.

The court also ruled that individual countries had no right to deny farmers the ability to grow GM crops that the EU had previously approved. This ruling has effectively removed Austria’s total cultivation ban. While many other Austrian regulations are in place that will make it a little more difficult for GMO production than in other countries, the European Commission and Courts will likely continue to chip away at them little by little.^[6]

India has also relaxed its opposition to GM foods as evidenced, also in 2007, by the fact that the Indian Ministry of Environment and Forests announced that organisms that are not living (living being defined as an organism capable of replication) will now be exempt from the existing approval processes. This effectively allowed all “non-living organisms” into India without any testing at all.

 

This applied to a wide range of products such as those containing GM corn or soy.^[7]

It should also be mentioned that as of January 2009, the FDA has announced that labeling of GM food animals is not required at the consumer level.

While GM animals are required to be labeled while alive, when the animals reach the food stage, the labeling requirements disappear. GM animals are only required to be labeled at the food stage when there appears to be a substantial difference in the food product.^[8]

However, it should be remembered that, because the FDA works on an even more relaxed version of substantial equivalence than Codex, it is already assumed that these foods will not be significantly different from a conventional counterpart.

Thus, we have unfettered access of GM animal food products to the food supply with no way for the consumer to determine whether or not the product he/she is eating has been genetically modified - a step which the FDA and Codex Alimentarius have both worked so hard to reach in the past.

 

 

Notes

[1] “Foods Derived From Modern Biotechnology,” 2nd edition. Codex Alimentarius. P. 57.
[2] Ibid. p.71
[3] “Codex Alimentarius Commission: New Standards, old concerns,” July 14, 2008.
[4] Hickman, Martin; Roberts, Genevieve. “Fury as EU approves GM potato.” The Independent. March 4, 2010.
[5] “EU food authorities say genetically modified maize is safe.” AFP. June 30, 2009. Accessed May 24, 2010.
[6] “Further ‘Rubberstamp’ GMO Approvals In The Pipeline In Europe.” Bridges Trade BioRes October 5, 2007. Vol. 7 No. 17.  Accessed May 24, 2010.
[7] “India Fast-Tracks Imports Of Non-Living GM Material.” Bridges Trade BioRes October 5, 2007. Vol. 7 No. 17.  Accessed May 24, 2010.
[8] Reinberg, Steven. “FDA Issues Final Regulations for Geneticially Engineered Animals.” US News And World Report. January 15, 2009.  Accessed May 24, 2010.

 

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