Perspectives from Beyond Pesticides and the Cornucopia Institute
In recent weeks, following the USDA’s Under Secretary Greg Ibach’s comments on gene editing in organics, a number of advocacy organizations have addressed the question of gene editing in Organics. In this article, we bring you perspectives from Beyond Pesticides and the Cornucopia Institute. In the Organic Farmers Association’s most recent e-newsletter, Mark Rokala, the Policy Director, asks the question, “Is it time to discuss gene editing methods within organic?” His question stems from comments made by the U.S. Department of Agriculture (USDA) Under Secretary for Marketing and Regulatory Programs, Greg Ibach, before the U.S. House Agriculture Subcommittee on Biotechnology, Horticulture, and Research on July 17, 2019.
Beyond Pesticides reported that in his remarks, the Under Secretary opened the door to consideration of allowing new gene-editing technologies to be permitted under the federal National Organic Program (NOP) and its standards. He said, “As the National Organic Standards Board set the rules originally, GMOs are not eligible to be in the organic program. However, we’ve seen new technology, including gene-editing, that accomplishes things in shorter periods of time than a natural breeding process can. I think there is the opportunity to open the discussion to consider whether it is appropriate for some of these new technologies that include gene-editing to be eligible to be used to enhance organic production and to have drought and disease-resistant varieties, as well as higher-yield varieties available.”
Targeted genetic modification (TagMo) or targeted genome editing is emerging and being adopted quickly. These are very clearly genetic engineering techniques but are not regulated by the current government structure because they do not involve DNA from a "pest" under the USDA APHIS regulatory structure. Many of these techniques involve precise changes in existing DNA without using foreign DNA from a different species. These new technologies make genetic modification much more accessible and less expensive. The resulting plants may not show up as genetically engineered in the commonly used testing methods because they contain no foreign DNA, just native DNA that has been changed at the gene level by humans.
Historic Perspective
In 1997, the U.S. Department of Agriculture (USDA) published a draft rule that would have allowed GE, irradiation, and sewage sludge (the “Big Three”) in organic production, which was met by the second largest number of comments the agency had ever received—well before the days of internet advocacy—overwhelmingly opposing the inclusion of the “Big Three.” The prohibition of gene editing falls under the “excluded methods” provision of the organic regulations. The law prohibits “a variety of methods used to genetically modify organisms or influence their growth and development by means that are not possible under natural conditions or processes, and are not considered compatible with organic production.” (7 CFR 205.2) These prohibited methods include cell fusion, micro- and macro-encapsulation and recombinant DNA technology (including gene deletion, gene doubling, introducing a foreign gene and changing the positions of genes when achieved by recombinant DNA technology). The secondary effects from the use of GMOs are starting to emerge clearly in parallel with the new technologies. Issues such as reduction in diversity on farms where GMOs are grown, the demise of beneficial species both above and below the soil, the decline in soil fertility and resilience from increased use of herbicides, the evolution of weeds resistant to those herbicides, the altered nutritional profiles of the GMO crop products, and the displacement of small farmers from their land are all violations of the principals of organic agriculture.
In April 2013, the NOSB Materials/GMO Subcommittee started to grapple with the definition of "excluded methods" in the USDA organic regulations. They recognized that this 1995 definition of “excluded methods” was in need of re-examination and updating due to rapid advances in recombinant DNA biotechnology that have resulted in gray areas for the organic standards regarding interpretation and enforcement. In 2011 and 2012 the NOSB had a number of issues to consider which the 1995 definition was inadequate to clarify including genetically engineered vaccines for livestock, the use of cell fusion within plant families to create male sterility in brassica hybrids, whether or not GMOs could be used in biodegradable bioplastic mulches, and the question of whether mutated algae might therefore be genetically engineered. The question of clear definition was further required with the rise of gene editing with no insertion of foreign DNA, synthetic biology, and the genetically engineered insects that are starting to appear made a revision even more important. In November of 2016, the National Organic Standards Board (NOSB) unanimously adopted a recommendation that clarifies that new gene editing techniques are not permitted in organic https://www.ams.usda.gov/sites/default/files/media/MSExcludedMethods.pdf .
The recommendation builds on the previous definition of ‘excluded methods’ in organic to encompass new genetic technologies in this rapidly expanding field. The recommendation also recognizes that the NOSB and USDA National Organic Program will need to continually review new genetic technologies as they emerge to determine if they are prohibited.
Genetic Engineering vs. Gene Editing: What’s the difference? (Source: Beyond Pesticides website. www.beyondpesticides.org)
Genetic Engineering (GE) techniques typically have employed gene transfer — moving selected genes for some desirable trait from one plant (or bacteria) species into another. A well-known example is Monsanto’s iconic Roundup Resistant soybean: its genetically engineered resistance to the impacts of glyphosate allowed use of the company’s glyphosate-based herbicide Roundup to kill weeds without killing the soybean plant. With wide adoption of the seed, Roundup’s use spiked, as did the inevitable issue of glyphosate resistance in the soybean plant itself.
Gene editing is described as different from gene transfer GE technology. It is described by a National Geographic article as the removal of certain bits of DNA (genes) from a plant cell’s genome “in order to control traits. The cell’s genetic structure then repairs itself automatically, minus the targeted gene.” The changes to the genome made by gene editing are permanent — they are passed on to the seeds the edited plant will generate.
Beyond Pesticides’ Analysis
There are many problems with Genetic Engineering (GE), and consumers trust the organic label to provide food free of GE. USDA has long promoted GE, but has avoided pushing it in organic since the run-in with organic producers and consumers over the Big Three. Former Secretary of Agriculture Vilsack, for example, promoted a policy of “coexistence” between GE and organic producers. In this regard, organic producers are joined by others who choose not to grow GE crops because they limit export sales.
Unfortunately, even USDA’s “coexistence” policy threatens the genetic and chemical integrity of organic food. In practice, “coexistence” means that those who develop and use GE technology are not held accountable for the damage they cause. The damage includes that arising from both genetic drift—which can make organic crops unsaleable in the organic marketplace—and chemical drift arising from the increased use of chemicals in GE-chemical intensive cropping systems. Any standard of acceptable use of technology would require control over the consequences. If the technology cannot be controlled, it should not be used.
Organic systems are modeled on natural ecosystems. GE organisms belong in neither: GE is based on an out-of-date theory of “one gene—one effect” and ignores pleiotropy. Thus, a gene that makes a plant tolerant of glyphosate is assumed not to have other effects that might be important ecologically or nutritionally. Even the effect of herbicide tolerance itself may result in the presence of toxic metabolites of the herbicide in food. Traditional breeding, like evolution itself, depends on forces acting on the whole organism. Exposure over time to different environments exposes unexpected traits. GE plants are created by manipulation of DNA that may create unanticipated results—results that may not be apparent until, for example, the plant is grown under unforeseen conditions.
Risks associated with GE crops cannot be predicted. While the GE/chemical industry has created many claims to virtue for GE crops, the net effect of GE-based agriculture has been an expansion in the use of pesticides and subsequent resistance to pesticides—in other words, the pesticide treadmill.
The Cornucopia Institute’s Perspective
GMO-Friendly USDA Ogling Organic: Under Secretary’s Testimony Opens Discussion to “Enhance Organic Production” By Melody Morrell, Operations Director, Cornucopia Institute and Marie Burcham, Domestic Policy Director, Cornucopia Institute
USDA Under Secretary Greg Ibach recently made comments before the House Agriculture Subcommittee suggesting it is time to discuss the possible allowance of gene editing methods within organic production. Ibach’s words are in line with the Trump administration’s stance. Organic standards currently prohibit the use of genetic engineering (GE) and genetically modified organisms (GMOs), but USDA Secretary Perdue has been very friendly toward biotechnology companies and products. President Trump’s June executive order to streamline approval for new GMO crops was immediately followed by a USDA proposed rule that would allow biotechnology companies to regulate their own GE creations. Ibach’s testimony is not surprising in this environment.
“The allowance of any GE techniques under the organic label raises legitimate ‘slippery slope’ concerns. The USDA would be hard-pressed to find the resources to track allowed GE technologies and products in the organic sector, assuming they could summon the will,” observes Cornucopia’s director of domestic policy Marie Burcham, JD. We have already seen the playbooks of biotechnology companies. Because GMOs are an expensive investment, both in terms of time and money, only the largest biotechnology companies are positioned to research, develop, and test new crops. They benefit enormously as regulatory hurdles are removed.
The majority of genetically engineered crops currently on the market have been modified to withstand synthetic pesticides, repel pest species, and extend crop shelf-lives to benefit processors and retailers. Biotechnology companies hold patents on their seeds, which ensure they retain all rights to the engineered traits. As a result, four seed companies now own more than 60% of the global proprietary seed sales. This runs counter to the spirit of organic agriculture. As noted by our allies at the Organic Seed Growers and Trade Association (OSGATA), organic seed promotes biodiversity, democratizes collective resources, celebrates seed quality over quantity, and preserves agrarian tradition.
GMO seeds are not needed or wanted in organic agriculture. In a 2017 survey conducted by Natural Grocers, 70% of respondents said they buy organic to avoid GMOs. Although advocates of GMOs claim that these crops will help farmers respond more quickly to environmental and pest threats, it takes years of testing to ensure the crops will perform as expected. In addition, the FDA does not perform testing to ensure the safety of these plants to the environment and humanity; instead they rely almost entirely on manufacturer claims of safety and only monitor the food safety and nutrition of gene-edited foods if the manufacturer requests consultation.
The alternative to this technology is selective breeding—an important and deeply underfunded tool for organic farmers. Our ancestors used this technique to domesticate wild plants and to produce crops, including tomatoes, broccoli, and corn. Selective breeding continues to hold promise for improving drought, disease, and pest resistance in future crops. Farmers can further improve yields in challenging conditions by promoting plant and wildlife biodiversity and soil health. These practices also result in higher nutrient levels in food, better pest management, and overall superior environmental sustainability.
Since one of the hallmarks of organic agriculture is the prohibition of genetic engineering, allowing for the certification of GMO crops would further erode consumer confidence in the organic label. Indeed, the National Organic Standards Board (NOSB) voted to exclude all genetic modification and manipulation from organic production in 2016 and again in 2017.
The track record of regulators in safeguarding the organic standards is not reassuring. For years, Cornucopia has reported on the USDA’s consistent refusal to enforce organic laws. Industrial-scale, confinement livestock facilities, providing no legitimate grazing or even access to the outdoors, are currently being certified organic. And in 2017, the NOSB voted to allow hydroponic production methods in certified organic agriculture, despite the mandate to steward soil and the outcry from hundreds of venerated organic farmers and advocates. When interviewed on this subject, USDA Secretary Perdue demonstrated little understanding concerning the foundation of organic agriculture. Additionally, when the NOSB voted to remove several materials from the list of substances allowed for use in organic production, including carrageenan and non-essential conventional ingredients, Perdue’s USDA overrode its own organic advisory board.
Looking at this spotty history, there is little reason to believe the current USDA will protect the integrity of the organic label. Any allowance of GMOs in organic agriculture would also further embolden industrial organic companies and their lobbyists. The pressures on ethical, family-scale farmers would increase, further hurting their bottom lines.
While the USDA ponders the use of gene editing to help farmers, funding for organic plant breeding continues to lag far behind that of conventional plant breeding. The benefits that Ibach and others claim we would get from new gene editing technologies can be achieved through selective breeding. These authentic breeding methods should be funded fully and used to their best advantage to develop cultivars that are resistant to drought, pests, and other organic agricultural concerns.
