Talk:Genetically modified food controversies/Archive 2

Royal Society
Hi everyone. I happened to notice that the reports of the Royal Society haven't been discussed, even though they're a scientific institution just as respected as the AAAS, National Academies, etc. So I think editors might be interested: 2002, 2009, Guardian article on 2009 report, Science article on 2009 report. I'm not really sure which article I'm thinking about here (in this article I think it's mainly useful for establishing statements as factual) - this just happens to be the one that I was editing. :-) Arc de Ciel (talk) 10:48, 1 June 2013 (UTC)
 * Better to stick to Science than the guardian. The guardian is against GM as an editorial position in it's enviromental section whereas Science would be more neutral and less likely to skew things, IRWolfie- (talk) 10:43, 3 June 2013 (UTC)

I agree that the Royal Society should be considered as a source. Well the stuff from the Guardian could be used to describe those against GMOs could it not?66.93.53.90 (talk) 17:29, 5 June 2013 (UTC)
 * Better to use the science source, it has a better reputation for science reporting than any newspaper, IRWolfie- (talk) 18:41, 5 June 2013 (UTC)

Neutrality
Question the neutrality of this page. The page seems very much biased in favor of one side (proponent) rather than looking at both sides equally.

A great example we have one section starting off "One of the major environmental benefits from using GM crops is the reduction in the use of pesticides." When in fact that has not occurred, and pesticide and herbicide use has increased with the introduction some of these crops due to weed and insect resistance, and more crop varieties now being able to tolerate herbicides such as roundup.

So not only is the claim one sided, it actually has been disproven by numerous reports and studies.

I think the page needs a serious review with regards to the neutrality. — Preceding unsigned comment added by 96.31.177.52 (talk) 21:55, 27 April 2013 (UTC)

Do you have a source for those claims? I've read an article from Benbrook that made these claims, but further investigation revealed that he is heavily biased, and made up a significant portion of his data. I am not aware of any other even partially reputable studies that support this claim. If we're going to use benbrook as a source we should at least include some of the criticisms of his studies. 50.83.69.183 (talk) 20:17, 29 April 2013 (UTC)


 * I don't understand the objection, 96.31.177.52.  Pesticides are not the same as herbicides.   GMO-s that make BT (which is a pesticide) need less chemical pesticides sprayed on them.  This is documented by anti-GMO people as well as pro-GMO.   With respect to GMOs that are resistant to herbicides (like Roundup), weeds do develop resistance to the herbicide after several seasons, which leads to an increase in chemical herbicides that are used.  The article says both things.  It is neutral and accurate. Jytdog (talk) 23:08, 29 April 2013 (UTC) (edited to make it clear I was responding to 96.31.177.52 Jytdog (talk) 03:48, 30 April 2013 (UTC))


 * Yes, that is my point. I was trying to respond to the original poster of the question. I was using pesticide as a generic term because the poster used it too (it encompasses herbicides, insecticides, fungicides, etc). My response was aimed at Benbrook's study, which has been criticized, so I suggested that it should either not be included, or included with the criticism mentioned for balance. This is one of the articles that criticizes it. I was trying to point out that it's not really a good source to use (assuming the original poster was talking about Benbrook's study, which is the only major one done on this subject). 50.83.69.183 (talk) 03:15, 30 April 2013 (UTC)


 * Sorry for the misunderstanding, 50.83.69.183. I was also responding to the original poster, not to you :) Jytdog (talk) 03:48, 30 April 2013 (UTC)

I think there may be some bias in this article and I tried to correct it as well.173.69.138.229 (talk) 22:32, 26 May 2013 (UTC)
 * Your edits aren't appropriate. For example, you can't change the text from "there is broad consensus" to "some scientists" when the sources support the statement that "there is broad consensus." BlackHades (talk) 22:36, 26 May 2013 (UTC)

I understand now that the beginning section does not need references. On your other points, there is no broad consensus. That is incorrect. Only one source I found actually supports what you said. Saying there is a broad consensus violates Wikipedia's policy of neutrality.173.69.138.229 (talk) 22:45, 26 May 2013 (UTC)
 * There was more than one source that directly stated there is broad consensus. Not to mention everything else fully supports that statement. All the major science and medical organizations that published their position in GM food have stated that GM food is as safe as conventional food with not a single major science or medical organization in the world in opposition. When WP:reliable sources state there is broad consensus and there isn't any WP:reliable sources that state the contrary, it's not appropriate to remove the statement. BlackHades (talk) 22:54, 26 May 2013 (UTC)

I have looked up this myself and find the previous user to be incorrect. What 173.69.138.229 has noted is correct in part. While there may more more than one source supporting the claim, it is still not a correct one. I plan to make a section on this talk page addressing this issue, instead of letting one editor decide the fate of this article and letting it be discussed amongst others.Historyday01 (talk) 17:36, 27 May 2013 (UTC)


 * Hello Historyday. The issue has been hashed out extensively here and elsewhere.  But for starters you can search this page and its archives for "safety".   It is not just one editor.  No one denies that there are lots of sites out there that question the safety of GM food in general (real and imagined) - note that the statement is NOT that all GMOs real or imagined are safe - the statement is that the scientific consensus is that GM foods that are on the market are as safe as their conventional counterparts. The nuance is intentional and important. There is lots of WP:FRINGE on this, like there is on Global warming.  Jytdog (talk) 17:42, 27 May 2013 (UTC)

Your comments are exactly why I am posting a section to address this topic. But, your statement that GM food on the markets is safe is exactly what Monsanto and supports of GMOs would say. I assure you. I want to counter that bias in this article. I will not give up until you get rid of that silly idea that there is a scientific consensus.Historyday01 (talk) 20:32, 27 May 2013 (UTC) No the silly idea is that gm crops are dangerous its not bias if it is supported by a broad scientific consensus the only people who think gm foods are dangerious are scientifically illeterate their have been no concerns raised by any legitimate scientists, the truth is not biased and wikipedia has a policy against supporting fringe theorys 98.250.4.115 (talk) 04:28, 10 June 2013 (UTC)

Is there a broad consensus that GM foods are safe?
Two times in the article, there is the repeating of the phrase about a broad consensus. One in the introduction ("There is broad scientific consensus that food on the market derived from GM crops pose no greater risk than conventional food") and one in the section titled Health "There is broad scientific consensus that food on the market derived from GM crops is safe to eat." I have looked up this issue myself and do not believe there is a "broad consensus" as the issue of GMOs is still a hotly debated one. There is what I believe is a questionable source from agbioworld (http://www.agbioworld.org/biotech-info/articles/biotech-art/peer-reviewed-pubs.html) which seems to be not credible or even if so, it seems bias toward GMOs. I also believe this sources is NOT scientific in nature and not a source of the claim of broad consensus at all and must be removed at once: http://www.sddt.com/News/article.cfm?SourceCode=20121107cc&_t=California+voters+rebuff+labels+on+GMO+foods#.UNZXbInjlhs. Also, http://blogs.scientificamerican.com/guest-blog/2011/08/11/genetically-engineered-crops/ while scientific is not from a peer-reviewed journal and must be removed.

What I worry about is that this article, by saying GMOs are safe, that it is not neutral in its point of view and is taking a stand in the issue of GMOs, in this case for GMOs itself. Wikpedia has a policy of neutrality and including these sentences along with another part in the introduction, "no reports of ill effects have been documented in the human population from GM food" compromises such neutrality. Lets go through all of the sources that are cited. If you follow the AAAS claim, and go to their full statement on GMOs, the sources are weak, and they cite an EU study, of which the link is broken, with their statement citing only one lone study by the NIH (http://www.aaas.org/news/releases/2012/media/AAAS_GM_statement.pdf and http://www.ncbi.nlm.nih.gov/pubmed/22155268). Now, the source for the World Health Organization (WHO) is a FAQ page which has no footnotes or corroborating evidence to support their claims (see especially question 5): http://www.who.int/foodsafety/publications/biotech/20questions/en/. I looked next at the National Research Council report (http://www.nap.edu/catalog.php?record_id=10977#toc) and found these interesting comments: So, it is bit shaky to say that this source says GMOs are safe. They NEVER say that in the report, but rather say that more studying is needed and that there is possible adverse rates. Nothing is cut and dry in science. I next moved to the University of California study starting on page 2. On the next page, it concludes that GMOs are safe as regular food citing numerous sources, while interestingly noting the page before that "animals developed stomach damage from consuming this GM food." (http://anrcatalog.ucdavis.edu/pdf/8180.pdf) I conclude that none of these sources cited in the introduction do not demonstrate the "broad consensus" that is claimed as the article currently notes.
 * "Unintentional compositional changes in plants and animals are likely with all conventional and biotechnological breeding methods."- http://www.nap.edu/openbook.php?record_id=10977&page=3
 * "Despite these technological advances in analytical chemistry, our ability to interpret the consequences to human health of changes in food composition is limited...The major challenges to predicting and assessing unintended adverse health effects of genetically modified (GM) foods—including those that are genetically engineered—are underscored by the severe imbalances between highly advanced analytical technologies and limited abilities to interpret their results and predict health effects that result from the consumption of food that is genetically modified, either by traditional or more modern technologies."- http://www.nap.edu/openbook.php?record_id=10977&page=5
 * "The committee recommends that compositional changes that result from all genetic modification in food, including genetic engineering, undergo an appropriate safety assessment."- http://www.nap.edu/openbook.php?record_id=10977&page=8 (why isn't this noted in the introduction!)
 * "The knowledge base required to interpret results of profiling methods, however, is insufficiently developed to predict or directly assess potential health effects associated with unintended compositional changes of GM food, as is the necessary associative information (e.g., proteomics, metabolomics, and signaling networks)."- http://www.nap.edu/openbook.php?record_id=10977&page=10
 * "When warranted by changes such as altered levels of naturally occurring components above those found in the product’s unmodified counterpart, population-specific vulnerabilities, or unexplained clusters of adverse health effects, the committee recommends improving the tracking of potential health consequences from commercially available foods that are genetically modified..."-http://www.nap.edu/openbook.php?record_id=10977&page=12
 * "Furthermore, it is possible to add a protein with an imbalanced amino acid pattern to an otherwise adequate dietary protein intake and observe adverse effects on growth rates, as some amino acids are known to cause other types of toxicities when consumed in excessive amounts, and others to do so only when their intake is excessive relative to that of a structurally similar amino acid."- http://www.nap.edu/openbook.php?record_id=10977&page=110
 * "Foods produced through agricultural biotechnology may result in the expression of proteins new to the human diet. Some of these new proteins may induce an allergic response to sensitive members of the population."-http://www.nap.edu/openbook.php?record_id=10977&page=114
 * "the magnitude of additions or deletions of specific constituents and modifications that may result in an unintended adverse effect, such as enhanced allergenic potential...the more effective such modifications are, the likelier are unintended effects on the bioavailability of other dietary constituents, that is, changes that increase uptake of essential trace elements also may increase the bioavailability of unwanted contaminants, such as toxic heavy metals."

The second use of the claim of scientific consensus is in the section titled "Health." It cites some of the similar sources which I shall not address again. Instead, I'll go though the other sources cited for that claim and for others in the paragraph. I start with an NIH article which notes that because GMOs have GRAS (Generally Recognized as Safe) status that means they are safe, and that because the crops were tested, they are safe, saying that "there is little documented evidence that GM crops are potentially toxic." (http://www.ncbi.nlm.nih.gov/pmc/articles/PMC2408621/) Oh really. I think there is too much trust in regulatory institutions by the authors of this study which casts doubt on their conclusion. The same is the case with this source (http://www.ama-assn.org/resources/doc/csaph/a12-csaph2-bioengineeredfoods.pdf) which puts trust in the FDA, which is troubling. Anyway, the study itself still says the following: "Bioengineered foods have been consumed for close to 20 years, and during that time, no overt consequences on human health have been reported and/or substantiated in the peer-reviewed literature. However, a small potential for adverse events exists, due mainly to horizontal gene transfer, allergenicity, and toxicity." They never say outright that GMOs are safe either but say they want safety measures in place (http://www.ama-assn.org/resources/doc/csaph/a12-csaph2-bioengineeredfoods.pdf).

The last source I looked at was a report from the European Union (http://ec.europa.eu/research/biosociety/pdf/a_decade_of_eu-funded_gmo_research.pdf). First, I looked up "eu report on gmos is bias" to see what I found and sure enough I found some groups in opposition, but this included a report by Earth OpenSource and some news reports about certain orgs. accusing them of bias (http://earthopensource.org/files/pdfs/GMO_Myths_and_Truths/GMO_Myths_and_Truths_1.3b.pdf, http://www.euractiv.com/cap/food-agency-questions-reliabilit-news-515210, http://www.health.am/ab/more/eu_food_safety_agency_attacked_for_pro_gmo_bias/ and http://www.gmfreecymru.org/news/Press_Notice03May2011.htm). While this wikipedia article cannot come out and say the EU regulators were bias, there could at least be a note that some groups accuse the regulators of bias (and also looking for the EU response to these allegations) as to put the report into a broader context. I kept reading through the the report and it seemed more pro-GMO, with statements like that on page 22: "Undeniably GM technology is an important tool in the fight against global poverty and food insecurity." How can such a governmental body try to evaluate GMOs neutrally with such a comment among many others? I read through the whole report and it seems to say know it will say GMOs are safe. However, once again, there is trust put in regulators without question this time by the article itself.

Back to the introduction. One sentence says that there is "no reports of ill effects have been documented in the human population from GM food." I have already addressed these sources in the previous sentences. If you still say there is a scientific consensus, then you are wrong. It is better to say that the safety of GMOs is still disputed as no source I have read from those cited can confirm with 100% certainty that GMOs are safe to eat and have no health effects. Here are some additional studies I found as well which may be of interest and should be included for the sake of balance:
 * Hematotoxicity of Bacillus thuringiensis as Spore-crystal Strains Cry1Aa, Cry1Ab, Cry1Ac or Cry2Aa in Swiss Albino Mice


 * Identifying reliable sources (medicine) cautions against using single animal studies. This is especially problematic with new studies that contradict the current research and have not had time to be properly responded to. AIR corn (talk) 02:18, 28 May 2013 (UTC)

http://www.cspinet.org/new/pdf/fda_report__final.pdf
 * HOLES IN THE BIOTECH SAFETY NET: FDA Policy Does Not Assure the Safety of Genetically Engineered Foods
 * Written on behalf of a consumer advocacy organization by someone employed by the union of concerned scientists a known anti-GM organisation. Anyway the questioning of the FDAs methods and motivations is already provided. AIR corn  (talk) 02:18, 28 May 2013 (UTC)

http://www.ncbi.nlm.nih.gov/pubmed/21338670
 * Maternal and fetal exposure to pesticides associated to genetically modified foods in Eastern Townships of Quebec, Canada
 * Is mentioned in the article. AIR corn (talk) 02:18, 28 May 2013 (UTC)

http://www.usgs.gov/newsroom/article.asp?ID=2909
 * Technical Announcement: Widely Used Herbicide [Roundup made by Monsanto) Commonly Found in Rain and Streams in the Mississippi River Basin
 * Nothing to do with GMOs or health. AIR corn (talk) 02:18, 28 May 2013 (UTC)

Analysis: Super weeds pose growing threat to U.S. crops http://mobile.reuters.com/article/idUSTRE78I4BA20110919?irpc=932
 * Nothing to do with health. Super weed potential already mentioned, in fact I think this article is even used. AIR corn (talk) 02:18, 28 May 2013 (UTC)

http://ucsusa.org/food_and_agriculture/our-failing-food-system/genetic-engineering/failure-to-yield.html
 * Failure to Yield: Evaluating the Performance of Genetically Engineered Crops
 * published by union of concerned scientist - not reliable. AIR corn (talk) 02:18, 28 May 2013 (UTC)


 * This Scientific Study perhaps (http://www.nap.edu/openbook.php?booksearch=1&term=gmo&record_id=12832&Search+This+Book.x=0&Search+This+Book.y=0)
 * I am not reading 500 odd pages, doesn't even seem to have much to do with GMOs. AIR corn (talk)


 * Transgenes in Mexican maize: molecular evidence and methodological considerations for GMO detection in landrace populations (http://www.ncbi.nlm.nih.gov/pmc/articles/PMC3001031/)
 * Linked page not available, but pretty sure this study or a similar one is mentioned under gene flow. AIR corn (talk) 02:18, 28 May 2013 (UTC)

http://healthandwellnessmagazine.net/content/features/poor-gut-health-and-autism-linked-through-gmos-genetically-modified-organisms/
 * Poor Gut Health And Autism Linked Through GMOs (Genetically Modified Organisms)
 * Nowhere near a reliable source. Seems like everything gets blamed for causing autism nowadays. AIR corn (talk) 02:18, 28 May 2013 (UTC)

a critical assessment http://www.testbiotech.de/sites/default/files/TESTBIOTECH%20Cultivation_GE_%20plants_US.pdf
 * 30 years of genetically engineered plants - 20 years of commercial cultivation in the United States:
 * Not familiar with them, but appear to be another advocacy group. Doesn't provide any evidence of harm, just suggests there could be. AIR corn (talk) 02:18, 28 May 2013 (UTC)

http://www.fao.org/ag/save-and-grow/)
 * This part of the FAO report called "Save and Grow" perhaps (http://www.fao.org/ag/save-and-grow/en/4/index.html, original link is here:
 * Does not seem relevant to GMOs


 * HEALTH HAZARDS OF GM FOODS (https://d3n8a8pro7vhmx.cloudfront.net/prop37/pages/67/attachments/original/1348032282/Peer_reviewed_studies_on_GM_food_health_risks.pdf?1348032282)
 * Not a reliable source. AIR corn (talk) 02:18, 28 May 2013 (UTC)

http://www.enveurope.com/content/23/1/10
 * Genetically modified crops safety assessments: present limits and possible improvements
 * Séralini. His studies are covered here and at the soon to be kept Seralini affair. AIR corn (talk) 02:18, 28 May 2013 (UTC)

http://agroeco.org/wp-content/uploads/2010/09/garcia-altieri.pdf http://www.aaemonline.org/gmopost.html http://www.laleva.cc/food/gmnewcastlereport.PDF (New Study Finds GM Corn and Roundup Causes Cancer In Rats) http://www.sciencedirect.com/science/article/pii/S0278691512005637 http://www.ncbi.nlm.nih.gov/pubmed/22821326 http://www.ncbi.nlm.nih.gov/pubmed/22526921 http://www.ncbi.nlm.nih.gov/pubmed/22137360 http://www.ncbi.nlm.nih.gov/pubmed/22266476 http://www.ncbi.nlm.nih.gov/pubmed/22331240 http://www.ijbs.com/v05p0706.htm http://www.ncbi.nlm.nih.gov/pubmed/17426049 http://www.ncbi.nlm.nih.gov/pubmed/16373198 http://www.ncbi.nlm.nih.gov/pubmed/16276681 http://www.ncbi.nlm.nih.gov/pubmed/15182708 http://www.ncbi.nlm.nih.gov/pubmed/9707097 http://www.ncbi.nlm.nih.gov/pubmed/9464316 http://www.ncbi.nlm.nih.gov/pubmed/20643706 http://www.ncbi.nlm.nih.gov/pubmed/19013644 http://www.ncbi.nlm.nih.gov/pubmed/19672767 http://www.ncbi.nlm.nih.gov/pubmed/17984146 http://www.ncbi.nlm.nih.gov/pmc/articles/PMC2627714/ http://www.ncbi.nlm.nih.gov/pubmed/2370887
 * Transgenic Crops: Implications for Biodiversity and Sustainable Agriculture
 * American Academy of Environmental Medicine position paper on GMOs:
 * Technical report on the FSA project “Evaluating the risks associated with using GMOs in human foods"
 * Long term toxicity of a Roundup herbicide and a Roundup-tolerant genetically modified maize
 * Genotoxic effects of the herbicide Roundup(®) in the fish Corydoras paleatus (Jenyns 1842) after short-term, environmentally low concentration exposure
 * Differential genotoxicity of Roundup(®) formulation and its constituents in blood cells of fish (Anguilla anguilla): considerations on chemical interactions and DNA damaging mechanisms.
 * Relative toxicity of the components of the original formulation of Roundup to five North American anurans
 * DNA damage in fish (Anguilla anguilla) exposed to a glyphosate-based herbicide -- elucidation of organ-specificity and the role of oxidative stress.
 * Cytotoxic and DNA-damaging properties of glyphosate and Roundup in human-derived buccal epithelial cells.
 * A Comparison of the Effects of Three GM Corn Varieties on Mammalian Health
 * Detection of cytogenetic and DNA damage in peripheral erythrocytes of goldfish (Carassius auratus) exposed to a glyphosate formulation using the micronucleus test and the comet assay.
 * Cytogenetic effect of technical glyphosate on cultivated bovine peripheral lymphocytes.
 * [Cytotoxicity and genotoxicity of human cells exposed in vitro to glyphosate].
 * Glyphosate-based pesticides affect cell cycle regulation.
 * Cytogenetic damage and induction of pro-oxidant state in human lymphocytes exposed in vitro to gliphosate, vinclozolin, atrazine, and DPX-E9636.
 * 32P-postlabeling detection of DNA adducts in mice treated with the herbicide Roundup.
 * European eel (Anguilla anguilla) genotoxic and pro-oxidant responses following short-term exposure to Roundup--a glyphosate-based herbicide.
 * Genotoxicity of AMPA, the environmental metabolite of glyphosate, assessed by the Comet assay and cytogenetic tests.
 * Biomonitoring of genotoxic risk in agricultural workers from five colombian regions: association to occupational exposure to glyphosate.
 * Alteration of estrogen-regulated gene expression in human cells induced by the agricultural and horticultural herbicide glyphosate.
 * Food-related illness and death in the United States (talks about illness from GMOs)
 * An investigation of the cause of the eosinophilia-myalgia syndrome associated with tryptophan use. (relates to GMOs)
 * Eosinophilia-myalgia syndrome and tryptophan production: A cautionary tale (a disease in the 1989 was likely caused by modified organisms, some of the first to die from GMOs)

Also see: Monsanto, which is fighting efforts to label genetically engineered food in California, supported labeling such food in Britain http://www.mercurynews.com/elections/ci_21452920/monsanto-fighting-efforts-label -genetically-engineered-food-california

Some sources which are anti-GMO but must be considered as well: "Research not sponsored by the corporations is virtually non-existent, and there’s a very disturbing reason why. Big Agra companies invoke intellectual property law to restrict independent researcher’s use (and study) of their products."-http://www.marksdailyapple.com/gmo-monsanto/
 * http://www.liveinthenow.com/article/gmo-dangers-how-much-more-proof-do-we-need
 * http://www.foodandwaterwatch.org/factsheet/genetically-engineered-food-human-health-risks/ (some of the sources at the end of this PDF perhaps)
 * http://www.organic-center.org/science.pest.php?action=view&report_id=159
 * http://www.organicconsumers.org/articles/article_11361.cfm
 * http://www.responsibletechnology.org/health-risks#1
 * http://gmoinside.org/downsides-to-gmo-infant-formula-we-asked-a-pediatrician/
 * http://earthopensource.org/index.php/news/148-former-monsanto-employee-put-in-charge-of-gmo-papers-at-journal
 * This study is supposedly supported by Monsanto (http://www.sciencedirect.com/science/article/pii/S0273230011001516) along with many others ( http://www.greenmedinfo.com/blog/monsanto-funded-science-denies-emerging-roundup-cancer-link).
 * http://www.safe-food.org/-issue/references.html#MayenoGleich (a lot of sources on here to consider)

I'm done. Now I want a discussion of these sources, and rejection of that silly idea of scientific consensus which is completely wrong which the sources above show to be true.Historyday01 (talk) 20:37, 27 May 2013 (UTC)


 * History, this post is too rambling and cannot be responded to.  Do you want to discuss your doubt that there is a scientific consensus that GM food on the market is as safe as its conventional counterparts, or whether pesticides like glyphosate are dangerous (different question), whether Monsanto is evil, or whether IP is evil, or whether regulatory authorities are corrupt?  Please focus.  Please note that if you do want to challenge the consensus for safety of GM food that is on the market, any non-scientific source is not acceptable.  Thanks.   Jytdog (talk) 21:49, 27 May 2013 (UTC)

Well, I wanted to post my sources here. I do wish to challenge the idea of scientific consensus. I used a lot of scientific sources. Why these sources show that there is no scientific consensus. If you think so, then you are incorrect. Well, the current article cites a Yahoo! article that "proves" consensus. Should this then be eliminated?Historyday01 (talk) 20:33, 31 May 2013 (UTC)


 * no you didn't use a single scientific source they are all political or activist websites nothing legitimate98.250.4.115 (talk) 04:40, 10 June 2013 (UTC)


 * Historyday - (quick note - it would be great if you indented your responses by using one, two, or three colons as is usual, to keep threads clear) it is unfortunate that you posted all your sources here. It makes conversation really difficult. You should post them on a sandbox page on your userpage and bring in ones that are relevant to the discussion, so they can be discussed. Otherwise it is just piling on.Jytdog (talk) 22:17, 31 May 2013 (UTC)


 * History, much of this seems completely unrelated to the text in question. Some aren't even related to GM at all. Would be helpful to focus on references specifically to the one you're challenging that "There is broad scientific consensus that food on the market derived from GM crops pose no greater risk than conventional food" and "no reports of ill effects have been documented in the human population from GM food". Based on your list of references, it's unclear what exactly you're challenging. BlackHades (talk) 22:05, 27 May 2013 (UTC)

I tried to relate it as much to GMOs as possible. All of them are related to GMOs in some way or form. I did focus on the references that were in the article itself and challenged them.Historyday01 (talk) 20:33, 31 May 2013 (UTC)


 * This is not atomic war where "close" is good enough. The question you say you are challenging is "There is broad scientific consensus that food on the market derived from GM crops pose no greater risk than conventional food".  Issues and sources related to intellectual property are irrelevent to this statement of the consensus about health effects. Issues and sources about glyphosate in streams or effects on ag workers are irrelevant to this consensus statement about health effects. Arguments over labeling are irrelevant to this consensus statement about health effects. As I initially asked you - what exactly is the question you are asking? Jytdog (talk) 22:17, 31 May 2013 (UTC)

Well,we should say that in the article then. It confuses the reader to not have this section. I'll add this and a number of the sources found here as well.Historyday01 (talk) 20:34, 31 May 2013 (UTC)
 * Scientific consensus is not a case of every scientist agreeing with each other. So just because some scientists have come out and said GMOs are not safe to eat does not mean there is no longer consensus. It is also something that can be hard to present, our article explains it how quite well. There is scientific consensus that GM food is as safe as non-GM food because the majority of studies that have tested this have found no significant difference between the two. The few that have, have either had serious shortcomings or the results have not been replicated (part of the scientific process). AIR corn (talk) 01:26, 28 May 2013 (UTC)
 * I went through maybe a third of the sources provided and many are already in the article. You might want to have another read through there. AIR corn (talk) 06:24, 28 May 2013 (UTC)

Well thanks for that. I'll also add your words about scientific consensus into the article.Historyday01 (talk) 20:34, 31 May 2013 (UTC)

I agree with HistoryDay; I don't see a broad scientific consensus on the safety of GM food, at all. I think the list of citations currently provided in support of this claim is more about quantity than quality. Of course, it mostly cites sources that favor GM food. Here's a report from a group with safety concerns about GM food that contains links to 100+ scientific articles questioning its safety. Are you saying all of these studies have "serious shortcomings"? Aircorn says "the majority of studies that have tested this have found no significant difference between the two". But surely a "majority" is not "consenus"? Nor does a "majority of studies" provide evidence about the class as a whole. If y'all are hinging this claim on the idea that genetic modification itself does not inherently pose a safety risk, then this is the claim that should be stated in the lede. groupuscule (talk) 04:21, 30 May 2013 (UTC)

Thanks for that.Historyday01 (talk) 20:34, 31 May 2013 (UTC)


 * Your link doesn't qualify as WP:RS. All the WP:RS provided so far on this topic seem very consistent regarding safety of GM food. If you have any WP:RS that states otherwise, you're more than welcome to bring it up for discussion. But a paper with no author name from a site called nongmoproject is not an WP:RS. As there are several WP:RS already that repeatedly affirms there is broad scientific consensus on the safety of GM food, if someone wants to challenge this, they have to bring up an WP:RS that states otherwise which no one has yet to do. BlackHades (talk) 05:14, 30 May 2013 (UTC)
 * BlackHades, I didn't introduce that link because I want to use it in the article; I introduced it because its many citations represent obvious counterexamples to the "broad consensus" claim. Your reaction to my comment, seeking to discredit "my link", is upsetting to me. You did not respond to any of my comment except to clarify that "my link" should be excluded! And could you please show me the best source making the "broad consensus" claim? groupuscule (talk) 05:39, 30 May 2013 (UTC)

Exactly. I think the sources for "broad consensus" are weak.Historyday01 (talk) 20:34, 31 May 2013 (UTC)


 * What is your definition of consensus? As to feeding studies that show significant differences between GMOs when compared to the non-GMO parents I only know of two (the one done by Pusztai and the one by Seralina). There are also two others, both conducted by the industry (one involved peas and the other nuts), but these are foods that illicit allergic reactions naturally in some. They also seem to be glossed over as the provide evidence that the industry is regulating itself seeing as research on both were stopped. Note that all four of these are mentioned in the article. We are talking about scientific consensus so all that really matters are published peer reviewed papers. I don't know where you get the other 96 studies from, I assume you are just counting the references without looking at their relevance. The Seralina is a roundly panned study, even by people not interested in GMO (if you say something causes cancer you are going to get oncologists commenting on it). Pusztai is better, but still has attracted a lot of criticism. You also have to take into account that significance is generally judged at the 5% threshold. This means you would expect 1 in 20 studies to show a significant difference even when there is not a true difference. On top of that there are issues with using animal studies to infer human consequences (see WP:MEDRS for explanation). Also no one is saying GMOs are safe, just that the evidence so far is that they are no less safe than the food they are derived from. AIR corn  (talk) 05:24, 30 May 2013 (UTC)
 * '"Also no one is saying GMOs are safe, just that the evidence so far is that they are no less safe than the food they are derived from." ??? groupuscule (talk) 05:39, 30 May 2013 (UTC)
 * Food is not always safe to everyone, peanuts can be deadly. A genetically modified peanut(unless it takes away the allergen) will still be dangerous to those people. I should clarify too that these are the currently commercialised GMOs. Theoretically a food could be purposely modified with a toxin that is harmful to humans. AIR corn (talk) 06:11, 30 May 2013 (UTC)


 * I want to add that:
 * A pro-GM bias seems to exist here and across dozens of other pages on the topic.
 * Names of the same editors seem to pop up again and again on all these pages.
 * The cartoon representation of genetic modification, shown on many of these pages, represents genetic modification as achieving end results identical to the end results of conventional breeding. This representation is simplistic, misleading, and biased.
 * The Wikipedia user base may have a systemic bias toward being credulous of technology and technological methods.
 * The number of public relations professionals and scientists paid to advocate for GM far exceeds the number of people paid to advocate against it.
 * What are we going to do about it? groupuscule (talk) 05:21, 30 May 2013 (UTC)


 * Can't speak for anyone else, but I have a pro-science bias, not a pro-GM one. I would argue for evolution and AGW as much as this, but I just happen to know more about this issue than those and they seem pretty well covered at the moment.
 * The same happens on all wikipedia pages. People have interests and tend to edit what interests them.
 * What are your suggestions for improving it?
 * Not sure what you mean by this?
 * Citation needed. And even if true what are you implying, that we are being paid to edit here. I wish.
 * You have the option of an WP:RFC on the issue if you think there is a problem with bias on these pages. AIR corn (talk) 05:33, 30 May 2013 (UTC)

I completely agree with Aircorn and that's what I was trying to counter. I have a feeling BlackHades may like GMOs (maybe). I have an inkling. I'll do a request for comment.Historyday01 (talk) 20:34, 31 May 2013 (UTC)


 * Historyday, I just want to point something out. You added a statement from the http://www.greenfacts.org/ site, which I was not aware of, and which seems darn good. They  have a section on GMOs, and for this section they rely on a document that they describe as "the leading scientific consensus report produced in 2004 by the Food & Agriculture Organization (FAO): "The State of Food and Agriculture 2003-2004"" (in the green box on this page: http://www.greenfacts.org/en/gmo/index.htm)  In that section, they summarize the FAO report as saying the following: "Currently available transgenic crops and foods derived from them have been judged safe to eat and the methods used to test their safety have been deemed appropriate. These conclusions represent the consensus of the scientific evidence surveyed by the ICSU (2003) and they are consistent with the views of the World Health Organization (WHO, 2002)" (http://www.greenfacts.org/en/gmo/3-genetically-engineered-food/4-food-safety-labelling.htm#0p0)  They link to the actual FAO report, which is here: http://www.fao.org/docrep/006/Y5160E/y5160e10.htm    So... Jytdog (talk) 21:46, 31 May 2013 (UTC)

Does part of or all of this page have a bias toward GMOs?
There is a continuing insistance by some users who edit this page that there is a "broad consensus" declaring GMOs are safe. However, after further investigation, I found this to not be the case and a number of the sources to be faulty. I wish to have a request for comment on this issue and to wonder if this page has a bias toward GMOs, which if so would violate the WP policy that all articles must be neutral.Historyday01 (talk) 20:39, 31 May 2013 (UTC)
 * An RFC should not be started without prior discussion. There is nothing wrong with the sources in use, IRWolfie- (talk) 20:52, 31 May 2013 (UTC)

I understand your concern but there has been a discussion.If you want to comment above, go ahead. Whoh. There is something wrong with the sources in use. The AP article would be fine if talking about Prop 37, but using it as a source of scientific consensus is utterly absurd.Historyday01 (talk) 20:53, 31 May 2013 (UTC)
 * Yes we don't really need to rely on it. IRWolfie- (talk) 21:04, 31 May 2013 (UTC)


 * Can you please familiarise yourself with basis about original research, IRWolfie- (talk) 21:04, 31 May 2013 (UTC)


 * The premise is untrue. Nobody here is saying that "there is a "broad consensus" declaring GMOs are safe." Nobody. And so if that is what you actually investigated, it is no wonder that you could not find corroboration. Jytdog (talk) 21:53, 31 May 2013 (UTC)
 * Actually that's not correct. In the previous thread User:BlackHades quoted a journal entitled Genetics with this statement -- "There is broad scientific consensus that genetically engineered crops currently on the market are safe to eat." -- which happened to be very close to the wording in the article's health section (in wikipedia's voice) until you recently changed it. Should this article really consider Geneticists to be experts on the health effects? El duderino (abides) 05:20, 3 June 2013 (UTC)
 * As above. Also, please stop capitalizing "geneticists" - it's the name of a profession. ;-) Arc de Ciel (talk) 09:46, 3 June 2013 (UTC)
 * And as I replied above, those aren't representative. I capitalized it earlier in referring to the journal, just didnt bother italicizing but I can see how that might seem disconcerting. El duderino (abides) 11:55, 3 June 2013 (UTC)


 * El duderino. You wrote that people here are saying that "there is a "broad consensus" declaring GMOs are safe."  I said that nobody is saying that.  You responded by quoting  "There is broad scientific consensus that genetically engineered crops currently on the market are safe to eat."  Do you see that these two quoted statements are very different?  The second is very limited; the first is very very broad.  They are not saying the same thing.  This conversation is already difficult;  if you do not deal with what is actually being said, it becomes impossible.  Do you see what I mean?  Thanks. Jytdog (talk) 18:06, 3 June 2013 (UTC)
 * Not really. I know you said Nobody is saying that GMOs are safe. But others are saying that, to varying degrees. Look at BlackHades first quote in blue up above. If you're making the distinction about "currently on the market" then no, I don't think that's enough of a difference here. Certainly not "very" -- because there is so much PR spin in these articles it's ridiculous, and a disservice to wikipedia and its readers. El duderino (abides) 06:21, 5 June 2013 (UTC)
 * El duderino, I am the biggest contributor, or one of the biggest contributors, on each of the GM articles, and have worked very hard to provide accurate, non-spin information to wikipedia's readers. There are a lot of controversies around GMOs and this article is very long in order to provide an accurate, nuanced discussion of all the issues.   The real world is messy, not black and white, and nuance does matter.  Really, no one is saying that "GMOs are safe" - nobody sane would make such a broad statement, because it is so easy to think of GMOs that would be dangerous for some purpose.  None of the quotes in blue say that either - btw the first quote in blue says "There is broad scientific consensus that genetically engineered crops currently on the market are safe to eat." which is what I am saying, so I don't understand why you are citing it here again...Jytdog (talk) 12:51, 5 June 2013 (UTC)
 * Sure, nuance matters. I've said as much elsewhere about the mainstream/fringe debate, arguing for more careful distinctions. But how has that been received? Apparently nuance only matters to some here when it serves the POV of pro-GMO. By the way, when we're in disagreement about something, please don't insult my intelligence with plattitudes like 'The real world is messy, not black and white' because those are the kind of remarks that come off as patronizing. Judging from your other comments I don't think you mean it that way. But I do think you know that conflict heightens these differences. El duderino (abides) 15:21, 5 June 2013 (UTC)


 * No intent to insult you. Glad you agree that nuance matters.  Let's keep moving - it is not clear to me if there are objections you have to any other specific content in the article.  If there are, I suggest you open a new section for each specific thing as this is all cluttered. Jytdog (talk) 15:35, 5 June 2013 (UTC)


 * I suggested that an RFC was the way to go. They can be a lot of work to organise and if not done correctly can become quickly derailed. You would probably want to discuss the question here first. Nothing ruins an RFC quicker than one that is considered non-neutral or one that is vague. You will also want to discuss who should be notified and what projects. If you notify people, even in good faith, without doing this then you open yourself up to claims of canvassing !votes. If you have not done one before you might want to look at some past RFCs or ask someone more experienced to help. Saying all that, there is nothing stopping you just starting one now with whatever question you want. I am not sure if you have done so yet, but if you look through the archives this statement has already been discussed. From memory it foccused more on the "broad regulatory consensus" that was proposed, but you might find some useful information there. AIR corn (talk) 22:06, 31 May 2013 (UTC)
 * So do we want an RFC or not? This seems to be a sticking point at a few articles and I for one would welcome a chance to get some sort of Wikipedia wide consensus on this issue. Should we work on a suitable question to present? AIR corn (talk) 13:33, 5 June 2013 (UTC)

I love your elan on this! How about this. "The article Genetically modified food controversies states the following, which has been contested.  Is the following an acceptable statement under Wikipedia's policies and guidelines? There is broad scientific consensus that food on the market derived from GM crops poses no greater risk than conventional food.(ref name="AAAS")American Association for the Advancement of Science (AAAS), Board of Directors (2012). Legally Mandating GM Food Labels Could Mislead and Falsely Alarm Consumers(/ref)(ref name="WHO")World Health Organization. Food safety: 20 questions on genetically modified foods. Accessed December 22, 2012.(/ref)(ref name=NRC2004)United States Institute of Medicine and National Research Council (2004). Safety of Genetically Engineered Foods: Approaches to Assessing Unintended Health Effects. National Academies Press. Free full-text. National Academies Press. See pp11ff on need for better standards and tools to evaluate GM food.(/ref)(ref name="decade_of_EU-funded_GMO_research"/)(ref)Other sources:
 * Winter CK and Gallegos LK (2006). Safety of Genetically Engineered Food. University of California Agriculture and Natural Resources Communications, Publication 8180.
 * Dr. Christopher Preston, AgBioWorld 2011. Peer Reviewed Publications on the Safety of GM Foods.(/ref)"
 * Dr. Christopher Preston, AgBioWorld 2011. Peer Reviewed Publications on the Safety of GM Foods.(/ref)"
 * Dr. Christopher Preston, AgBioWorld 2011. Peer Reviewed Publications on the Safety of GM Foods.(/ref)"
 * Dr. Christopher Preston, AgBioWorld 2011. Peer Reviewed Publications on the Safety of GM Foods.(/ref)"
 * Dr. Christopher Preston, AgBioWorld 2011. Peer Reviewed Publications on the Safety of GM Foods.(/ref)"

I agree, that should be contested, no doubt. That is the question that was being asked earlier by Historyday01 or at least trying to have a discussion about this topic.66.93.53.90 (talk) 17:27, 5 June 2013 (UTC)

I add to this that I moved the claim of broad consensus to the subsection titled Health instead of the intro where some user and I'm roughly paraphrasing, said before "didn't need to be cited."-66.93.53.90 (talk) 17:51, 5 June 2013 (UTC)
 * The lead should summarize the article, and it is an important point, IRWolfie- (talk) 18:43, 5 June 2013 (UTC)

btw I am not sure we need to go to an RfC; the only person still objecting or even actively talking in opposition to the description of the consensus "that food on the market derived from GM crops poses no greater risk than conventional food" is the duderino and that is not even very focused. We have no sustained dispute here which is the usual reason for an RfC.Jytdog (talk) 22:36, 5 June 2013 (UTC)
 * once again you're misrepresenting your opposition -- a common tactic here, apparently. i am not the only one who questions the spin in this article and others. i suggest you stop it and try harder to collaborate and reach compromise. El duderino (abides) 03:06, 9 June 2013 (UTC)
 * Glad to see you back, duderino. How am I misrepresenting anything here, and more importantly, what have I misrepresented in the past?   Again, this will go much better if you deal with content rather than focusing on personal attacks. Jytdog (talk) 03:30, 9 June 2013 (UTC)
 * What personal attack? Saying that you are misrepresenting is not an attack, no matter how personally you take it. I already said that i am not the only one here who is challenging your push for a pro-GMO POV -- you said i am the only one active, whatever that means. also, there is no timetable, so stop pretending that we must be here everyday. El duderino (abides) 07:17, 10 June 2013 (UTC)
 * Please see below. Arc de Ciel (talk) 07:48, 10 June 2013 (UTC)
 * You are "misrepresenting the opposition" with your claim that only one user "is still objecting" to the pro-GMO slant on this article and others. There is no "broad scientific consensus" on the issue; nor is there a Wikipedian consensus as you claim. Your answer is, as usual, deliberately misleading. groupuscule (talk) 03:52, 9 June 2013 (UTC)


 * Hi groupuscule.  Glad to see you back -your last edit here was May 30 - I thought you had left.  Please stop with the personal attacks.  There is no need and it is not helpful.  Thank you. Jytdog (talk) 13:14, 9 June 2013 (UTC)
 * There you go again. He didnt make any personal attack. You need to review wp:npa specifically,the "what is not an attack" part.. El duderino (abides) 07:17, 10 June 2013 (UTC)
 * If you imply that the messages were written with an intent to deceive, that can reasonably be construed as a personal attack. Groupuscle's statement that Jytdog is being "as usual, deliberately misleading" (my emphasis) falls into this category. In your own comments, "tactic" implies intent, as does "pretending," or at the least both of these have common interpretations which imply intent. (These are also WP:AGF violations, by the way.) The ideal is to avoid referring to an editor's intent at all, except if you're trying to give advice on their user talk page or if you escalate to an appropriate forum for requesting intervention. Arc de Ciel (talk) 07:48, 10 June 2013 (UTC)
 * You're reading too much into the disagreements, but regardless -- discussion of intent is not necessarily an attack, and the guideline of AGF does not require continued assumption in face of evidence to the contrary. El duderino (abides) 12:03, 12 June 2013 (UTC)
 * Request for WP:reliable sources to refute the "broad scientific consensus" in question have repeatedly been asked for and none yet have been provided. We can only write what WP:reliable sources state and when several WP:reliable sources affirm the "broad scientific consensus" statement, that is what we write. Note that this same discussion has already been had and settled repeatedly throughout the years. Please browse archives. The page Talk:Global warming had the same problem of dealing with new editors time and time again trying to dispute the "scientific consensus" text so they added an FAQ to their talk page. We should add a FAQ on this talk page just like Talk:Global warming so we don't have to have this same argument on scientific consensus over and over again. BlackHades (talk) 07:21, 9 June 2013 (UTC)
 * That's a good point. I think that a few other articles would benefit from the same header. bobrayner (talk) 12:34, 9 June 2013 (UTC)
 * I have written a draft FAQ - please see the new section below. :-) Arc de Ciel (talk) 09:30, 10 June 2013 (UTC)

FAQ
Per the above comments, I have written a draft FAQ. (I notified FTN and Wikiproject Genetics.) Please feel free to edit, add more questions, etc. Much of the language comes directly from other FAQs, so I can't take too much credit. :-)

A couple of things: I think there should be a question about environmental effects (or a general question about non-health-related effects) but I'm not the best person to write it so I've left it for someone else. I assume we should also discuss what articles this will be used on, since that will probably affect the language. I was thinking mainly of this page and the main GM food page when I was writing. Arc de Ciel (talk) 09:30, 10 June 2013 (UTC)


 * Thank you! My only quibble is that instead of "pose no more risk than conventional foods" I think "pose no more risk than their conventional counterparts" would be more accurate.  But it works as it stands.  Thanks again. Jytdog (talk) 11:32, 10 June 2013 (UTC)
 * ✅ - no problem. :-) Arc de Ciel (talk) 06:16, 11 June 2013 (UTC)


 * Nicely done. a13ean (talk) 13:55, 10 June 2013 (UTC)


 * I think the following section could be changed:


 * Q5: Aren't a lot of people concerned about GM foods? Didn't (insert country) ban GM foods?
 * A5: This is not directly relevant to the article, except to the extent that we should impartially describe the numbers of people concerned and the countries involved. The scientific evaluation itself is based on the views of the experts in the relevant fields. (Many people deny global warming and evolution, but this does not affect the scientific conclusions about these facts.) Bans on GM foods are political decisions and not scientific ones.


 * It's not wrong, I just don't think there's a need for the extra commentary, if that makes sense. Stalwart 111  14:39, 10 June 2013 (UTC)
 * ✅, sounds good. Further suggestions welcome. :-) Arc de Ciel (talk) 06:16, 11 June 2013 (UTC)


 * I'm not a fan of the FAQ, although I'll admit it hits the more common questions. I wonder why it is necessary given that there's 6 references cited to the lead. I would prefer that the article stand on its own without having an extra thing to update and tweak. In addition, the FAQ's wording, careful as it is, doesn't really reflect the nuances involved (maybe the article doesn't either) and could come off as dismissive of the potential risk. Yes, currently, none of the products on the market cause health problems as these mostly involve minor modifications such as tweaked EPSPS or Bt; however, the 2004 NRC report which looked at this closely noted that "it is unlikely that all methods of either genetic engineering, genetic modification, or conventional breeding will have equal probability of resulting in unintended changes" and provided a summary of which ones were more likely to have unintended effects (see page 4), which of course placed the more exotic modification methods as having higher potential for unintended effects. In addition, much of the controversy centers around the destruction of a long-term common good (relatively benign pesticides such as Bt and glyphosate, which are becoming useless) for a short-term boost (see e.g. Impacts of genetically engineered crops on pesticide use in the U.S. -- the first sixteen years or a 2011 Reuters report). An additional concern is the extreme political influence of the ag-biotech industry. It's not clearly policy-compliant to publish an FAQ which selectively asks only questions which can be responded to portray the controversy as basically ignorance run amok. Somehow, even though I can't place any specific wording as bad, the FAQ seems to set a strong tone that concerns about GMOs are unnecessary, which is inappropriate. II  | (t - c) 02:36, 11 June 2013 (UTC)


 * It was proposed (by BlackHades and seconded by bobrayner, above) because people are challenging the sources. :-) It's definitely not my intent to imply concerns are unnecessary, and I think it's a big problem if that's how I sounded. On reflection, I agree with your comment, and I have a few ideas which I'll think about. I think the selection of questions might be one of the more important issues - I think the question that I mentioned above on other potential risks would help with that (as I mentioned above, I deliberately left it out for the beginning but I'd like to see it included), but I couldn't think of any others. Most of the repeating concerns on these talk pages do indeed come from one "direction" - do you have any suggestions? I'm never particularly attached to any of my specific editorial decisions (and in this case much of the wording isn't mine anyways.) Arc de Ciel (talk) 06:16, 11 June 2013 (UTC)


 * (New comment) I read through again and made a few changes - they're minor so I probably didn't address everything. I was trying to make it a bit more clear that valid concerns do exist. I also added the "other concerns" question as Q5, but I'm not sure how good my answer is. Please let me know what you think. Arc de Ciel (talk) 07:10, 11 June 2013 (UTC)


 * To be clear, this FAQ is for the talk page, not the article itself, right? It's designed to defuse heated conversations before they start, answer previously addressed questions to save time and give new editors an introduction to how the article has been built so that they have a better appreciation for some of the considerations to date. It's more a matter of working notes for editors rather than commentary for readers. Stalwart 111  10:01, 11 June 2013 (UTC)
 * Yes it would be for the talk page not the article. Similar to the one at Talk:Global warming. It's so we don't have to rehash the same discussions over and over. BlackHades (talk) 10:49, 11 June 2013 (UTC)
 * Thanks, that does significantly mollify my concerns. II  | (t - c) 08:11, 12 June 2013 (UTC)
 * Yes, of course - it wasn't intended in any other way. :-)
 * By the way, with respect to your recent change - my intent there was to avoid implying that all non-health related concerns are necessarily valid (there are some fringe claims associated with environmental effects, for example). Is there a way you think that might be accommodated? I have been thinking of including a statement like, "For these concerns, there may be a scientific consensus that they are valid, there may not be a consensus yet, or there may be a consensus that they are invalid." I saw similar language in other FAQs; it seemed awkward, but it occurs to me now that the wording may have been chosen to remove any possibility of implied NPOV violations. Arc de Ciel (talk) 08:01, 13 June 2013 (UTC)
 * The point of removing "and many of these are important" is to leave the importance unstated, per WP:ATTRIBUTEPOV, Wikipedia policy. Leaving aside the word many, which kinda weird as there's not really that many, concerns might be important or unimportant depending on who you talk to. If you simply say that yes, there are other concerns, it doesn't imply that they are important. It's possible that all are unimportant and we shouldn't get into the weeds like that in a FAQ. In the case of pesticide resistance, certainly it seems that scientists have been generally silent historically on pesticide resistance, certainly suggesting to those with strong faith in science that it is unimportant. And although that's changed a bit over the years, it still seems like strong proponents mostly avoid discussing the topic. Nature mentioned it in 2013 in its news section, noting that Monsanto denied the problem. More recently, there is at least one detailed argument explaining that this is not a problem (Kniss blog post 2013) II  | (t - c) 05:42, 14 June 2013 (UTC)


 * This FAQ is condescending and disrespectful of the many Wikipedia editors (not to mention scientists) who don't agree that there is a "broad scientific consensus" on GMOs. Numerous scientific articles suggesting the contrary have been disregarded. Here is an excellent paper that directly addresses the fake consensus being promoted by the biotech industry. Here is some helpful secondary literature on that paper. groupuscule (talk) 04:10, 11 June 2013 (UTC)
 * Hi Groupuscule - thanks for the links! I see that your understanding of Wikipedia sourcing is improving. (No sarcasm - I consider that a good thing.) It appears to me that your first source is from a peer-reviewed journal, which is a good sign. However, it is a sociology journal, which is the wrong scientific field. (It's common for fringe authors to publish in journals whose reviewers lack the expertise for proper peer-review, but of course that's not necessarily what's happening here.) I'm not familiar with the author or the quality of the journal itself, so I'll avoid making other comments on it, but if everything checks out, then it might be RS for some article content, since controversy includes sociological aspects. (Note that RS status can change depending on what statement is being supported.) If so, we can definitely discuss additions to the article based on this source (preferably in a different section, so we don't interrupt this discussion).


 * However, even if this source is acceptable (even if it were in a biological journal, actually), it wouldn't be sufficient to overturn the "scientific consensus" statement. To challenge this statement, you would need to present sources of equivalent reliability to those in the lead, which include direct statements from major medical and scientific organizations. Also, remember that the scientific consensus described in the lead only refers to specific health claims and is not a "consensus on GMOs" - in fact, the topic is so broad that I don't think it's clear what that would mean. Other GMO issues may or may not have scientific consensus depending on what the issue is. Arc de Ciel (talk) 06:16, 11 June 2013 (UTC)
 * Good job drafting the FAQ. It seems to address the most common discussions brought up in Talk. BlackHades (talk) 06:32, 11 June 2013 (UTC)


 * Oppose, per groupuscle. We have still not resolved the issue of so-called 'broad scientific consensus' regarding the safety of GMOs. And afaict User:Arc de Ciel is not objective enough to write any FAQ inna neutral way. El duderino (abides) 11:57, 12 June 2013 (UTC)
 * I do not claim responsibility for the FAQ; I wrote the initial version, which includes lots of non-original content (as I made clear) and which has already been further modified through the suggestions of other editors. I expect (and hope) that it is modified further; Wikipedia is collaborative, and the responsibility is ultimately with editorial consensus. My own role was just to put something together that I considered approximately acceptable and then to ask for comment. Beyond that I have the right to continue as part of the discussion but only as one editor among many. It is also entirely possible that my opinion will change. Please believe me when I say that if you follow the recommendations (on reliable sourcing and other topics) that I'm trying to present to you and others, you are more likely to change my mind, not less.


 * And of course: please feel free to propose changes to the FAQ. Similarly, please feel free to bring policy-based discussion on specific article content (thank you for engaging on the scientific consensus statement; see the responses by other editors below). Arc de Ciel (talk) 08:01, 13 June 2013 (UTC)


 * Oppose, per ImperfectlyInformed. Also, on the matter of "bias" it states: "Some views about GM foods are not supported by the relevant field (biology)." So biology is now the overarching relevant field here? On the matter of profit, it states: "While people often associate GM foods with large corporations, they are also studied and produced by academic researchers." It then gives an example of research stemming from the Swiss Federal Institute of Technology that was funded by a corporation (Syngenta). The fact is, that overwhelmingly, it is corporations who have spent the most time and money developing this technology, that is why they are associated with it, and that is why profiteering is a major concern. Semitransgenic  talk. 15:07, 12 June 2013 (UTC)
 * I have no problem with clarifying this - of course if we start discussing an economic problem then the highest-quality sources will be in economics, and so forth. All the prominent fringe claims that I've encountered are related to biology. For example, we could write "Some views about the nature and characteristics of GM foods" which excludes concerns about profits, funding, etc. Arc de Ciel (talk) 08:01, 13 June 2013 (UTC)


 * Unclear why folks are voting. But semi I wanted to ask you a question - do you have data to support your claim that "The fact is, that overwhelmingly, it is corporations who have spent the most time and money developing this technology,"?  Am very curious about that.  Also if by "develop" you mean take a specific product through the regulatory process I would find the claim to be common sense credible, but if by "develop the technology" you mean working out the underlying science behind the technology, the technology itself (e.g. the gene gun was invented in academia) as well as creating and testing specific GM plants (1000s of which have been created and field tested although only tens have been formally developed and approved), I would be surprised if the claim is true - this is where I am interested if you data to back that up. Thanks!Jytdog (talk) 15:15, 12 June 2013 (UTC)
 * you are being pedantic, development in this context means R&D with a view to taking product to market, it requires huge amounts of capital investment, involves in-house research, and can involve corporate funded academic efforts. Are there any independent research facilities that have put more time and money into this than Monsanto, Syngenta, DuPont, and BASF combined? Semitransgenic  talk. 15:41, 12 June 2013 (UTC)
 * semi it was a real question. thanks for telling me what you meant. Jytdog (talk) 16:04, 12 June 2013 (UTC)
 * It is a little ironic, but one of the major reasons that large multinationals are responsible for most of the GMOs is because the cost of regulation is prohibative for smaller independant facilities. Many GMO plants have been created outside of these companies, but have not been taken any further. This is why currently only cash crops like cotton and maize are commercialised. Still corporate involvement in GMOs is a geniune concern. AIR corn (talk) 08:39, 14 June 2013 (UTC)


 * I think it is too soon to have a FAQ. There have only been two debates over this statement and this one is still ongoing. AIR corn (talk) 08:14, 14 June 2013 (UTC)

Genetics: A Thought Experiment
If I may return to this thread with two quotations and some questions:

Is an spiritual journal dedicated to studying astrology reliable for statements about astrology because it has astrology in the title? Or, to reduce the binary thinking: on what types of statements found in astrology journals can we rely, and on what statements ought we not rely? To get a little "realer" with this question: would it have been epistemologically reasonable in 1870 to challenge the authority of Polygenism and Craniometry despite the apparently expert consensus of polygenists and craniometers? groupuscule (talk) 19:46, 16 June 2013 (UTC)
 * Please see WP:NOTAFORUM. If you truly doubt what is clearly a WP:MEDRS, please take it to WP:RS/N.  If you have any specific suggestions related to the article, make them here, but otherwise this sort of thing seems eminently unproductive.  a13ean (talk) 20:11, 16 June 2013 (UTC)


 * Comparing a scientific journal to a pseudoscientific one is a non-argument. If you wish to know how an encyclopedia would portray Craniometry and Polygenism, pick up an 1870's encyclopedia. We are not hear to right great wrongs. You are falling into the standard arguments that fringe proponents have always used on wikipedia to justify fringe opinions being inserted. IRWolfie- (talk) 22:32, 16 June 2013 (UTC)

regulatory nuances
some aspects that need to fleshed out in the lead, which are currently missing from the article entirely, but which might help with clarifying this matter, include the precautionary principle, the Cartagena Protocol and the Codex Alimentarius. We should note that European regulation is markedly different from the US - where the industry is essentially self-regulating and has done most of the safety testing itself. Europe has traditionally erred on the side of caution and upholds a case-by-case approach. With regard to the American situation the SAGE A-Z on Green Culture offers a succinct overview:
 * "In 1992, the FDA adopted a policy whereby GE foods were presumed 'generally recognized as safe'. Similarly, the FAO and the WHO subscribed to the concept of substantial equivalence, which regards GE food products to be as safe as their conventional counterparts. Safety resting through the FDA has been documented by the nonprofit Center for Science in the Public Interest(CSPI) and others to he inadequate. Studies noted that biotechnology companies frequently have not released the requested information, there were undetected errors in technical data, and the FDA had a lack of necessary authority in the review and regulation of GE research and crops. Since 2003, official standards for food safety assessment have improved with the global consensus forwarded by the Codex Alimentarius Commission of FAO/WHO. These principles dictate a pre-market assessment, performed on a case-by-case basis, which includes an evaluation of both direct and unintended effects. However, peer-reviewed studies found that despite these guidelines, risk assessment of GE foods has still not followed a defined prototype."

The matter of the original 1992 FDA ruling (which Monsanto was involved in) is the root of much of the suspicion and skepticism (especially in Europe) surrounding the food safety issue, and this is not helped by claims (attributed to James Maryanski) that the decision to avoid applying a GMO specific regulatory regime was motivated by politics rather than science. US economic interest, big business, and political careerism has muddied this debate from the very beginning, made worse by the fact that the bio-tech sector in the US was regulating itself and carrying out most of the testing for well over a decade after the introduction of GMO food crops. Semitransgenic talk. 17:12, 14 June 2013 (UTC)


 * I think you are right, that a discussion of precautionary principle vs other approaches would be very helpful! Thanks for that.  However, some of what you write is not accurate.  There is no "assumption of substantial equivalence."  That is a misunderstanding that I find is pretty widespread.  Rather from regulation article:, "Substantial equivalence embodies the concept that if a new food or food component is found to be substantially equivalent to an existing food or food component, it can be treated in the same manner with respect to safety (i.e., the food or food component can be concluded to be as safe as the conventional food or food component."  So it is not an assumption you start with -- rather, it is the first test that a new GMO has to pass.  Also, if you are interested in the overall policy framework -- there is a great history of the US regulatory policy here: http://lawdigitalcommons.bc.edu/cgi/viewcontent.cgi?article=2236&context=bclr  The three main tenets of the overall US policy framework for regulating biotechnology as a whole (which includes foods from GMOs) that were generated in 1986 were: (1) U.S. policy would focus on the product of GM techniques, not the process itself, (2) only regulation grounded in verifiable scientific risks would be tolerated, and (3) GM products are on a continuum with existing products and, therefore, existing statutes are sufficient to review the products.  You can see that policy yourself, here: http://web.archive.org/web/20130214064202/http://usbiotechreg.epa.gov/usbiotechreg/  (In the course of looking that up I discovered that the site has been taken down and is only available through the internet archive. It was live just a few months ago.  Crazy.)  Jytdog (talk) 19:52, 16 June 2013 (UTC)
 * In the USA: I can form a biotech company, splice fish genes into an apple, and sell the resulting organism unlabeled and unregulated because my product is "substantially equivalent" to an apple. Optionally I may choose to run tests and share some of the results with the FDA. groupuscule (talk) 19:59, 16 June 2013 (UTC)


 * Semi, groupuscule that is just wrong. It is as wrong as saying the earth is flat.  Look at what is happening with the GM salmon case, for example.  And Monsanto's latest dual-trait products.  It is dead wrong. Jytdog (talk) 20:40, 16 June 2013 (UTC) (edited my comment, what a boner!!  my apologies to semi and groupuscule!!!! and groupuscule thank you for handling my mistake so graciously and with wit! Jytdog (talk) 14:39, 17 June 2013 (UTC))
 * Semi, based on how quickly you responded I don't reckon that you looked at the two sources I cited there... they provide a really good grounding for reality based discussions of US regulatory policy. :)  I do hope you look at them! Jytdog (talk) 20:48, 16 June 2013 (UTC) (talk) 20:40, 16 June 2013 (UTC) (this comment not relevant.  my apologies again. Jytdog (talk) 14:39, 17 June 2013 (UTC))


 * Jytdog, I don't resent your confusing me with Semitransgenic, as I suspect we genomically qualify as “substantially equivalent”. I also admit that I only skimmed your source before replying. At your urging, I took a closer look at this "great history of the US regulatory policy" to see if I had missed some critical example of a federal agency regulating genetically modified crops. Instead, I found one argument after another supporting these claims:


 * That all three relevant federal agencies have left genetically modified organisms substantially unregulated;
 * That these agencies have followed policy instructions to disregard the possible unique effects of genetic engineering; &
 * That the deregulation of genetically modified crops in the US has been conducted over the protests of advocacy groups, concerned members of the public, and even scientists working for the deregulating agencies.


 * What follows is a summary, full of excerpts, which I think clearly presents information from the article: “Risk and Regulation: U .S . Regulatory Policy on Genetically Modified Food and Agriculture”, published in 2003 by attorney Emily Marden as part of “a project on International GMO Regulatory Conflicts”. groupuscule (talk) 14:12, 17 June 2013 (UTC)


 * Sigh, you are again doing OR here. What is the point of this outpouring of text? How will this help us generate content? Jytdog (talk) 14:42, 17 June 2013 (UTC)
 * I removed it, pasting a 40k byte piece of original research is utterly excessive. If this continues I will take it to arbitration enforcement over violations of the fringe science remedies, IRWolfie- (talk) 23:11, 17 June 2013 (UTC)

Marden, 2003
Marden's primary argument in this article, as made clear by the introduction, is that US agencies have adopted a sort of 'don't ask, don't tell' policy with respect to GMO risks. Although “the United States has maintained that existing regulatory oversight is adequate to safeguard the public“, Marden writes, “the nature of the scientific risks that could demonstrate risk or harm are not defined. Instead, the U.S. policy tends, to minimize the existence of any risks associated with GM products, and directs the agencies to refrain from hypothesizing about or affirmatively searching for safety or environmental concerns” (735).

She contrasts the neglect of safety concerns in the US with the embrace of the “precautionary principle” in Europe. In keeping with this principle, “The Europeans focus on the fact that the GM process itself is new and therefore may have unintended hazardous consequences” (735). To demonstrate the lack of precaution exercised in the US, Marden begins a detailed history of how business and political interests have blocked effective regulation.

We join the story in the 1980s, as the Reagan Administration simultaneously promotes the US as a biotechnology leader abroad while pursuing deregulation of biotechnology at home. During this time, “the White House […] thwarted legislative interference” with biotechnology in order to protect the US position ad an industry leader (737). The Administration maintained control over the development of policy, and appointed a regulations working group under the White House Office of Science and Technology Policy. In 1984, this group published a “Coordinated Framework for Regulation of Biotechnology”, which took the position that products should face no special regulations because of the process used to produce them. They released another draft in 1986 (738).

A “Biotechnology Science Coordinating Committee” was created to establish regulatory responsibilities among agencies (739). This group did not reach consensus on regulations, and during the Bush Administration its materials were forwarded to the “President's Council on Competitiveness”, led by Vice President Dan Quayle. Quayle's group released a document titled “Exercise of Federal Oversight Within Scope of Statutory Authority: Planned Introductions of Biotechnology Products into the Environment" (740). The Administration produced several more reports, all of which underscored the need to avoid special regulations on biotechnology (740–741). In 1992, the Administration published a “Final Statement of Scope”, which directed: “oversight will be exercised only where the risk posed by the introduction is unreasonable” (741).

"The scientific principles outlined in the Final Statement of Scope are the clearest statement of the Administration's tenets on GM foods.

The five policy principles listed are:


 * 1) The same physical and biological laws govern the response of organisms modified by modern molecular and cellular methods and those produced by classical methods;
 * 2) Information about the process used to produce a GM organism is not a useful criterion for determining whether the product requires less or more oversight;
 * 3) No conceptual distinction exists between genetic modification of plants and microorganisms by classical methods or by molecular techniques... ;
 * 4) Crops modified by molecular and cellular methods should pose risks no different from those modified by classical methods for similar traits ... ; and
 * 5) In many respects, molecular methods resemble the classical methods for modifying particular strains of microorganism, but [are even more useful than the classical methods.]

Neither the Final Statement on Scope nor the other documents out- lines how to determine when measurable risks are present ("the scope principles do not dictate precisely how information on risk should be evaluated").

It was left to the agencies to implement these policy principles and to determine the degree of uncertainty acceptable under the Administration directives. Although Administration policy statements have no formal authority over regulatory actions, they are important as guiding principles for agencies. During the Reagan and Bush Administrations, the three agencies involved were sympathetic to a pro-GM technology perspective. For example, Henry Miller, Commissioner of FDA during the Reagan Administration, was openly supportive of GM technologies and averse to imposing any unjustified government burden. USDA was also eager to embrace the Administration's GM policies as part of its mission to promote U.S. agriculture, including GM crops. EPA was amenable as well, as its directive was simply to apply existing pesticide law to GM products.

The fundamental adherence to this policy continued under the Clinton Administration. By that time, the United States had established itself as the world leader in the GM arena, and government officials were eager to promote the U.S. position. (pp. 742– 743)"

The list of “five policy principles” seems to include little more than five restatements of the “substantial equivalence” policy. Each of these items is deregulatory in nature, emphasizing the absence of risks rather than identifying possible risky areas to explore. And it was this policy which met with “fundamental adherence” from federal regulatory agencies during the Clinton Administration. Marden will prove this point in great detail.

Food and Drug Administration (FDA)
The Food and Drug Administration (FDA) is "the most central of the three agencies involved in oversight of GM products and is charged with ensuring the safety of human food and animal feeds."
 * "The general food safety provisions of the FFDCA state that a food is adulterated if it "bears or contains any poisonous or deleterious substance which may render it injurious to.health." There are no pre-market reviews of approvals required of foods. Instead, manufacturers or distributors bear the burden of ensuring that any finished food placed on the market meets the safety levels implicit in the definition of adulterated foods" (746).
 * "The 1992 FDA Policy had two purposes. First, it outlined the agency's view that most GM products were presumed or likely to be GRAS, and therefore not subject to food additive review. In addition, it established a voluntary pre-market consultation process to reassure companies and the public that the food supply was being safeguarded" ( 747).
 * "An undated document titled 'FDA Regulation of Food Products Derived from Genetically-Altered Plants: Point to Consider' similarly refers to the Final Statement on Scope in stating that "FDA's objectives in regulating the food products of biotechnology should be to assure safety and provide assurance to the public ... while avoiding 'unnecessary' regulatory processes i.e., ones that do not justify the resource burdens they place on FDA and industry'. The document goes on to balance the options for industry oversight between 'satisfy[ing] the public that it is being protected" and "avoid[ing] the appearance of complete industry self-regulation.' (747–748)
 * "The essence of the 1992 FDA Policy was its presumption that genetic material inserted into existing plants was GRAS, and its expectation that most expression products would also be GRAS" (748)
 * "On its face, this presumption was logical." In explicitly stating. its GRAS presumption, however, the approach was different than FDA's approach to conventional food ingredients. There, the burden is always on the manufacturer, in the first instance, to establish that. any altered ingredients remain GRAS (or are approved as food additives), and that the food as a whole meets the statutory safety standard. In this sense, prior to the introduction of GM foods, FDA had generally taken a conservative approach, and repeatedly made clear that. companies should not presume that an ingredient is GRAS simply because it is present in the food supply in other countries or in different formats." (749)
 * "Even a component of food, such as phytosterols derived directly from vegetable oil, are not presumed to be GRAS. Instead, the manufacturer must. demonstrate that the substance is GRAS at the levels and in the form provided. Though most new hybrids of standard fruits and vegetables will be determined to be GRAS by their producers, FDA has never issued a blanket presumption in this regard. Also, in making its general safety presumption, FDA did not address the issue of the complexity of the genome or the issue of unintended effects in modified foods." (749)

Summary of the above.
 * The FDA (along perhaps with the Congress responsible for the FFDCA) expects manufacturers to monitor their own products for poison or adulterants.
 * Secretly, the FDA's primary objectives on GMOs are:
 * (a) to appear to be regulating GMOs in order to placate the public, and
 * (b) to avoid regulating GMOs at all costs.


 * The FDA assumes that genetically modified foods are safe unless proven otherwise. In doing so it lowered standards for this new type of food, to below its historical standards even for well known substances like vegetable oil derivatives.
 * The FDA assumes that genetic modification has no unintentional genomic effects.

The next section, which discusses the reaction of FDA scientists to these above policies, is a must read:

Starting at the bottom of p. 749:

“The voluntary consultation program established by the 1992 FDA Policy was designed as a safeguard against erroneous GRAS presumpdons.” However, Marden writes: “The policy, however, was not mandatory, nor did it establish mandatory disclosure of information regarding GM foods. The only part of the process that would be transparent to the public was the letter that the agency sent "not objecting" to the voluntary consultation” (751).

In 1997, the FDA released a 9-point list of information it would seek during the consultations. However: “Though the scope of information requested was broad, FDA's ability to obtain data it wanted may have been less than satisfactory. In January 2003, the Center for Science in the Public Interest ("CSPI") released a report based on its review of fourteen FDA GM product consultations obtained through a Freedom of Information Act request to the agency. According to CSPI, in six of the consultations, FDA requested additional information, and in three of those cases, the companies refused FDA's request.” (753)

In the next section of the review, Marden describes the public outrage which mounted as Americans realized that genetically modified organisms were not being regulated.

"The Union of Concerned Scientists ('UCS'), an alliance of 60,000 citizens and scientists, has been another prominent voice on the issue. UCS relies on its scientific expertise and publicly questions the basis for FDA's regulatory process. UCS has urged FDA to require safety testing—on the level of food additive petitions—prior to allowing GM foods on the market and has also consistently urged the agency to require labeling of its products. As the pace of GM products entering the market increased in the 1990s, UCS became a vocal critic of what it saw as the agency's collusion with industry and failure fully to take account of allergenicity and other safety issues."

(BlackHades, take note: does the position taken by the Union of Concerned Scientists win your support in the “broad scientific consensus debate”?)

Marden then describes a lawsuit (Alliance for Bio-Integrity v. Shalala, 1998), in which the Alliance demanded that the FDA conduct the same tests for genetically modified foods as it would for food additives. “The plaintiffs identified a range of secondary changes that could occur in products as a result of genetic modification, including unwanted, unpredictable new toxins and/or carcinogens or degradation of nutritional quality” (755).

The District Court of the District of Columbia agreed to the government's request for summary judgment and deferred to the FDA, upholding the 1992 regulations on the grounds of the FDA's superior scientific expertise. (I guess no one told them about the FDA's... you know... scientists.)

After 9 years of offering no formal barrier whatsoever to genetically modified foods, the FDA announced a new regulation:

"a new rule that would requite manufacturers of 'plant-derived, bioengineered foods and animal feeds' (GM foods) to notify FDA at least 120 days before the products are marketed in a 'Premarket Biotechnology Notice' ('PBN'). 112In essence, FDA's proposed rule would make the 1992 voluntary consultation process mandatory.' 3FDA was careful to state that its proposal did not reflect any new safety concerns about the products.' 4The agency characterized the proposed rule as simply a proactive measure to ensure that FDA stayed current with developing technology as GM products became more widespread and complex. FDA restated its belief that GM products are safe. (757–758)"

The FDA said that the new regulation would provide "the opportunity to discuss safety and other regulatory issues ... before new hioengineered foods go on the market" (758; emphasis Marden's). However, the policy (which had not been introduced at Marden's time of writing) did not impose any additional requirements to test or regulategenetically engineered products.

Department of Agriculture (USDA)
Marden gives the USDA more credit than the FDA (and EPA), saying that the FDA did in fact regulate products that could be construed as “plant pests”. It regulated genetically modified “plant pests” more heavily than their conventional counterparts.

"In a sharp divergence from FDA, USDA initially chose to take a precautionary approach under this existing statutory regime. Instead of presuming that existing regulations were adequate to apply also to GM products, USDA proposed and promulgated regulations specific to GM products. These regulations made clear that not all GM products would be subject to the FPPA, but went on to state that those GM products that could be considered 'plant pests' under the existing definition would be subject to a mandatory pre-release permitting process. 157As of 1999, USDA had completed more than 6,700 permits for more than 20,000 locations under this system."

So the USDA actually bucked the “substantial equivalence” policy! They did treat genetically modified crops as an inherent risk:

"It appears, therefore, that the regulation applies to GM plants simply because they have been produced via the process of genetic engineering. In this sense, USDA's approach is a deviation from the OSTP policy that regulation should be product-based, and not process-based. USDA attempts to deny its divergence in both the preamble to the proposed rules and the final rules. Its reasoning, however, is unconvincing. USDA states that the rule is consistent with the Coordinated Framework because it applies to 'only genetically engineered organisms or products which are plant pests or for which there is reason to believe are plant pests, and not to ... an organism or product merely because of the process by which it was produced.'' Nevertheless, the language of the regulation makes clear that the trigger is the GM process, as well as meeting the plant-pesticide definition."

The USDA did lower its standards in 1992, so that if you said your product met six criteria, all you had to do was notify the USDA that you were doing tests.

"In 1992, the agency proposed a notification process by which certain organisms would not be subject to the pre-introduction permitting process. 162 This process allowed plants that met certain criteria to avoid the detailed informational requirements established in the permit rule. Notification also streamlined the process, permitting applicants to introduce their plant. varieties without waiting for a lengthy agency review. The six criteria used to determine eligibility for the less detailed petition process were:

(1) whether the plant is corn, cotton, potato, soybean, tobacco or tomato;

(2) whether the genetic material is integrated in a stable manner;

(3) whether the function of the introduced genetic material is known and does not result in a plant disease;

(4) whether the genetic material does not encode infectious, toxic or pharmaceutical substances;

(5) whether the genetic material does not pose the risk of a new plant virus; and

(6) whether the plant does not include genetic material from a known animal or human pathogen.' 63

Under the notification requirement, the manufacturer or importer has the responsibility of certifying to the agency that the plant meets the six requirements. 16" In addition, the notifying party must inform USDA of its intention to conduct field tests thirty days in advance of such tests, and to provide information about the plant, time and place of the test.' (769–770)"

The USDA also expanded the scope of a “petition process” by which companies could “petition” to have their products “nonregulated”. (771–772)

Guess who liked this change and who didn't:

In 1997, the USDA restored their testing requirements to the pre-1992 regime. Just kidding, they reduced the requirements again. This time they expanded the pre-approved plant varities from 'six' to 'all' and announced that they expected 'ninety' or perhaps 'ninety-nine' percent of all crops to go through with no testing.

"USDA amended its regulations again in 1997 to open the notification process to any plant species—not just the six listed—meeting the six requirements, as long as those species had similar 'low risk' characteristics. 171In its preamble to this proposed rule, USDA revealed its enthusiasm for the technology by predicting that eventually eighty to ninety percent of all GM plants would be introduced under the simplified procedure. 172Eventually, the agency stated that it expects that as many as ninety nine percent of all crops could be introduced by notification.173 (p. 771)"

The USDA also expanded the scope of a “petition process” by which companies could “petition” to have their products become “nonregulated”.

"USDA's 1997 modifications to its regulations also expanded the class of potentially nonregulated organisms. USDA stated that nonregulated status would be extended to GM plants that were 'closely related' to a GM plant that had been granted nonregulated status under a petition. 176Thus, once a GM plant had been granted nonregulated status tinder a petition, all 'closely related' plants would also be exempt.' 7A party simply had to certify to USDA that an article was 'closely related.''"

Next: a subjectively written dramatization of the above process. Optional; not USDA-approved.

Monsanto: Hey USDA, we invented a type of corn that has never existed before. It will “resist droughts”. USDA: Awesome! But: Is it safe? Monsanto: Oh totally, totally... it's totally safe. Here, look at this data proving it's safe! USDA: We hereby declare that Monsanto's new corn is Safe! We have made a list of all the bad things that might happen.... and said they won't happen! The Wonder Corn and All Its Children Will Live With Us Forever in Harmony! Public: Wait, what's this about nonregulated Wonder Corn? USDA: Didn't you see our notice in the Federal Register? Public Actually, we did. We sent you tens of thousands of letters and comments. It seems as though the vast majority of us asked you not to “nonregulate” this new corn. We provided a number of different arguments concerning the risks and unknown factors surrounding this new organism. Why would you... USDA: Look, we have addressed the issues raised during the comment period. We addressed them! They're addressed! Quit whining and drink your corn. Monsanto: $$$

Fin

Marden: “USDA offered no clear definition of what level of similarity would demonstrate "closely related" status or how the agency would assess whether specific gene insertions create unreasonable levels of risk.” (772)

In response to critics who argued that the 1997 changes opened a “huge loophole”,

"USDA responded that safety was ensured whether the GM organism was under a permit or a notification, or was nonregulated. USDA pointed out that any company introducing a GM product has obligations to certify that the plant or organism meets regulatory safety standards and these obligations ensure that companies will remain in compliance.'' USDA further noted that it conducts inspections at various intervals of time, again ensuring compliance."

How could we expect less than thorough investigations and careful scrutiny of new products? Whose interests would the USDA promote, if not those of the hard-working American farmer?

"In fact, USDA's actions on GM products have been the subject of extensive criticism. Many have pointed out that the agency has an internal conflict of interest on the regulation of GM products, as it does for all newly introduced plants. Indeed, USDA's APHIS unit is responsible for issuing regulations and reviewing releases of GM organisms in the environment. At the same time, the Agricultural Research Service ('ARS') and Agricultural Marketing Service ('AMS') of USDA are geared toward developing and promoting agricultural biotechnology in the United States and internationally. ARS, for example, is partially responsible for developing and promoting the controversial 'Terminator' technology. A division of the Food Safety Inspection Service ('FSIS') advocates the U.S. position on regulation of GM products in international fora such as Codex Alimentaritts. The U.S. Codex Commission, housed in FSIS, has consistently taken a strong position that. GM products pose no novel risks and should not be the subject of extensive process-based regulations." "An example of this internal conflict was on display in a speech given by Secretary of Agriculture Ann M. Veneman at the United Nations Food and Agriculture Organization's ('FAO') 31st Conference.m Secretary Veneman touted the benefits of GM crops and went so far as to promote American products: '[B]iotechnology .. will reinvigorate productivity growth in food and agriculture production and .. make agriculture more environmentally sustainable. Agricultural biotechnology ... also promises much more, such as drought. resistant crop varieties for Africa: 1 g' To critics, such statements prove that USDA has no interest in upholding stringent regulations on the GM industry."

Happy ending?: "At the end of the Clinton Administration, then-USDA Secretary Dan Glickman acknowledged the institutional conflict of interest, and announced measures to combat its effects in decision making. 192 Among the measures proposed were independent scientific reviews of USDA's biotechnology approval process, a reinforced line between agency regulatory functions and promotions of trade, and the convening of a panel of representatives from industry, farm, consumer and environmental groups to advice on issues related to GM foods.''"

No: “With the change in Administrations, however, this proposal does not appear to have gone forward. As a result, it is not clear whether the proposal would have placated critics.”

The National Academy of Sciences (author of one of the Big Thirteen sources currently cited as evidence of a “broad scientific consensus” on the comparative safety of genetically engineered products) called the USDA's guidelines “generally superficial”. The NAS

"identified an instance in which a variety of corn producing a protein with insecticidal properties was grown commercially, following a notification, without any thorough consideration by the manufacturer or the agency of the impacts of the insecticide on the environment. In addition, NAS found fault with the fact that once USDA accepts a petition for nonregulated status, it does not conduct post-commercialization monitoring for environmental effects. (775)"

The Natural Resources Defense Council said that the USDA assigned “nonregulated” status based on “qualitative rationalizations and incomplete field studies” even though the plants it approves “could have irreversible harmful effects on genetic diversity and on the plants' traditional counterparts.” (776)

Environmental Protection Agency (EPA)
The EPA didn't need to lower its standards because they started low.

“EPA, in contrast, has remained largely consistent in its approach. EPA made clear that the relevant statutory framework was written broadly enough to include GM products, and that its existing product based approach would apply. In recent years, this perspective has been subject to criticism in response to growing concerns that EPA has not fully considered environmental risks and lacks the capacity to monitor them.” (767)

The EPA's policy: “Following the Coordinated Framework, EPA took the position that its existing statutory and regulatory framework under the Federal Insecticide, Fungicide, and Rodenticide Act ('FIFRA') would be adequate for GM products.” (776) What did this mean, exactly?

"EPA did not issue any further outline detailing its approach to GM products. After receiving numerous inquiries as to the data required under F1FRA for registration of GM plants, however, EPA issued a proposed policy statement in 1994. […] In the proposed policy, EPA coined the term "plant-pesticide" to refer to GM products under EPA authority. By definition, a "plantpesticide" was a "pesticidal substance that is produced in a living plant and the genetic material necessary for the product of the pesticidal substance, where the pesticidal substance is intended for use in the living plan t." 216EPA also made clear that it considered its existing review and risk assessment. procedures adequate for GM products. Like FDA, EPA stated that its approach would be product-based: "EPA indicates that it proposes to focus its regulatory attention on the plantpesticide and not on the plant per se."

To focus the agency's resources where there was greater risk, EPA's 1994 proposed policy identified a number of products that would be exempt because the risks were deemed negligible. 218Exemptions included plants that already contained some level of the incorporated pesticide, plants that were sexually compatible with another plant containing some level of the incorporated pesticide, and those modifications that only affected the plant itself. 219The agency's rationale was that "[ijf a plant normally produces a pesticidal substance, organisms that normally come in contact with the plant have likely been exposed to that substance in the past." 220In a further justification, the agency acknowledged that genetic modification designed to increase the levels of previously existing pesticidal proteins in plants posed the greatest risk to non-target species. Even so, the agency reflected that any such increases were not likely to result in overall significantly different exposures of the non-target organisms to the public and thus did not need to be targeted by regulation. 221In addition, EPA reasoned that transfers between closely related species would not likely result in levels of toxic proteins that greatly exceeded the normal range, and that there are limits to which toxic protein can be increased without unwanted effects on other desirable characteristics of the plant. 222Thus, EPA concluded that most plants with altered levels of plant-pesticides would not require registration.

Traditional pesticides subject to FIFRA must undergo an extensive pre-market testing regime laid out in regulations. 225These tests are designed to establish environmental and ecological impacts of pesticides, and predate GM technology. As written, the rules do not require testing on GM plant-specific issues such as the potential travel of the genotype into other plants or wider potential ecological effects on the food chain. Despite EPA's acknowledgement of these issues in the agency's 1994 proposed policy, the agency has never formally addressed what kind of testing would be appropriate for plant-pesticides.

In 2001, EPA published a rule finalizing elements of the 1994 publication. Inter alia, the final rule changed the name of the regulated element from "plant-pesticide" to "plant incorporated protectant." 227The nomenclature change clarified that a regulated GM plant was one intended to have pesticidal properties: "Plant incorporated protectant means a pesticidal substance that is intended to be produced and used in a living plant, or in the produce thereof, and the genetic material necessary for production of such a pesticidal substance." 228Thus, the definition excludes plants with chance pesticidal modifications. The 2001 rule also affirmed the exemptions contained in the 1994 proposal and reiterated EPA's focus on the pesticidal aspects of the plant and not on the plant itself, remaining consistent with White House policy. (pp. 777 – 780)"

Summary: The EPA didn't explain its policy at first. In 1994 it clarified that it would not test plants genetically modified to produce pesticides—even though it tests new pesticides on their own. Over several rounds of policy clarifications, the EPA has maintained the Bush/Reagan hard line: insisting that genetic modification does not produce unpredictable products which might require testing.

So far the EPA has registered 12 genetically modified pesticide plants. Now, one regulatory function it might helpfully perform would be limiting the amount of pesticide ingested by humans. This is part of the EPA's job, based on the Federal Food and Drug Consumption Act and the Food Quality Protection Act:

"EPA has additional authority under the FFDCA, as amended by the 1996 Food Quality Protection Act, to set 'tolerances'—or permissible levels—of pesticide residues on food.'' EPA is directed by statute to set a tolerance such dial there is 'reasonably certainty that no harm will result' from aggregate exposure to the pesticide over a lifetime. 212 The FFDCA states that a food is adulterated if it contains a pesticide residue, unless the amount of residue is within an established tolerance."

What permissible levels of pesticide residue has the EPA established for genetically modified pesticide crops? Trick question:

"“Because these registrations were not open to the public, the range of data reviewed by EPA is not known. As of 1999, EPA had exempted all plant-pesticides registered for food from the FFDCA tolerance requirement. The agency's justification in each case was that the pesticidal proteins originated from sources not known to be food allergens, and that the plant-pesticides were therefore not expected to be food allergens.”"

The EPA did not see fit to regulate the amount of pesticide Americans swallow every time they (unwittingly) eat genetically modified food. They did this not because they tested the pesticides and found they weren't harmful. They exempted 12 plants, which hyper-manufacture protein pesticides, because the proteins they were told the plants would be making were not known food allergens.

Conclusion
"Consistent with domestic policies, the United States has thus far taken a strong position in opposition to any efforts to regulate GM technology based on the development process, or on grounds of potential health or environmental risks. In discussions of the Codex Alimentarius Commission ('Codex'), a joint venture of the World Health Organization and the Food and Agriculture Organization of the UN, the United States has consistently sparred with Europeans over the incorporation of the Precautionary Principle into regulation of GM technology. 252In addition, the United States and its allies in the so-called 'Miami Group' stood firm against efforts by the European Commission and others negotiating the CBD to permit nonscientifically base measures to justify exclusion of GM products from entry into a country."

In short, Jytdog's article provides excellent support for the concerns raised by Semitransgenic, and I hope this breakdown proves useful for incorporating evidence into the article. groupuscule (talk) 14:12, 17 June 2013 (UTC)


 * The last sentence is so... out of touch with reality.  1) You cannot field test a GM crop without USDA and maybe EPA permission (not voluntary).  2) You cannot release a GM crop (e.g. start selling seeds to actually grow crops that you can harvest and turn into food) without USDA and maybe EPA permission (not voluntary).  3) While starting to sell a new food from a GM crop needs only a "voluntary" submission to the FDA, a) no company has ever started selling a food from a GMO without making a submission to the FDA and getting sign-off; b) if you did do that, it is very likely that all hell would break loose on you and you would be forced to withdraw the food, which would mean that all the money you spent developing the product would be wasted, and you would be an utter moron.   The FDA submission is about as "voluntary" as responding to a cop on the street when he asks you a question.  So no, groupuscule, you can NOT form a biotech company, splice fish genes into an apple, and sell the resulting organism unlabeled and unregulated because your product is "substantially equivalent" to an apple.   Outside of this howler of a finale,  the essay is just a critique of the US regulatory system, which is WP:SOAPBOX and does not belong here, or anywhere else in Wikipedia.  Groupuscule, while it was surely fun to write and post this, please remove it, and please stick to commenting on content. Thanks. Jytdog (talk) 03:52, 19 June 2013 (UTC)
 * I do agree that this is veering into using Wikipedia as a forum, and 40k on a talk page is excessive. Editors need to stay focused on changing the article. Does someone have an edit in mind? This article doesn't really summarize the regulatory article much at all, except to discuss labeling. If no edits are in mind, probably better to take this debate somewhere else. II  | (t - c) 05:26, 19 June 2013 (UTC)
 * this began with the suggestion that there is no mention of the precautionary principle, the Cartagena Protocol or the Codex Alimentarius anywhere in this article. There should really be some context provided, in terms of the history of GMO bio-safety testing and the matter of arriving at the stated scientific consensus ("food on the market derived from GM crops pose no greater risk than conventional food"): which is derived squarely from the concept of substantial equivalence. It would clearly be useful to highlight that testing regimes can vary, regionally, that they are subject to interpretation, subject to improvement, and that new testing methods will be needed to deal with advances in GE food produce. For example the WHO report that is offered as one of the consensus citations addresses some of these issues, the following caveat is also offered: "Different GM organisms include different genes inserted in different ways. This means that individual GM foods and their safety should be assessed on a case-by-case basis and that it is not possible to make general statements on the safety of all GM foods. Semitransgenic  talk. 18:22, 19 June 2013 (UTC)

Hi semi, as I mentioned above I agree that it would be great to discuss those matters. Really! I hope to work on that over the weekend. And I agree 100% that one cannot speak a priori about the safety of all GM foods - that is part of the consensus and why it is limited to "currently marketed." That is a perfect quote to pull out! In any case, what was off target was groupuscule's essay on his objections to the US approach. This is not a soapbox. Jytdog (talk) 18:43, 19 June 2013 (UTC)


 * it might also worth highlighting, and especially in the context of regional differences, that America refused to be party to the Convention on Biological Diversity and is therefore not subject to the provisions set out in the Cartagena       Protocol; meaning is has been able to ignore the issues associated with the precautionary principle - unlike the 166 countries that have signed up. Considering this point we see that the American position differs somewhat from that taken in the EU, in particular see note No.2 below the linked list.  Semitransgenic  talk. 18:54, 20 June 2013 (UTC)