Transcript Identity Preservation and Traceability in Commodity Crops

Current Status of Food
Traceability and Labeling
in USA*
Alan McHughen, D.Phil.,
University of California
Riverside, Ca USA
[email protected]
*- and some EU info from Willy DeGreef
Grounds for EU GM food traceability
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European traceability rules are intended for food
safety management AND for consumer choice.
This dual purpose has created an unwieldy
regulation which has proven difficult to apply
and unsatisfactory for some consumers
(W. DeGreef)
Starting point
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Farmer buys certified seed, highest purity
obtainable for commodity crop
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Purity is guaranteed to 95%
Farmer may instead use saved, common or
“brown bag” common seed
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Purity level is unknown.
Sources of impurity: Farm
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From Farm to Port
Seed transport and storage on farm
 Seeding equipment
 Volunteers and weeds in field
 Pollen and seed flow from other fields
 Harvesting equipment
 Storage and Transport.
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Sources of impurity: Delivery
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Admixtures of grain at local elevator
Throughout the grain handling system
 Barges, rail cars, port storage, Panamax vessels
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Delivery port
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Unloading and local delivery.
Traceability
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Traceability demands i.p., segregation and a
paper trail with verification at every step.
Historically used only for high value specialty
products
Due to high cost
 No need for segregation of bulk commodities.
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Commodity vs discrete products
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Corn seeds vs papayas or pumelos
Corn seeds are bulked, treated as population
 Papayas are discrete, can be treated as units
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Cost of i.p. increases with degree of purity
demanded
Feasibility based on number of units, and
 Number of contact/branch/transfer points
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Traceability of commodity grain
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Is not feasible except at a cost greater than the
value of the commodity (affidavits, testing, etc. at
each step)
Cannot achieve purity higher than best starting
point (5%) without great cost
Adds nothing to public confidence in food safety
Or in regulatory system
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(30% of non-GM food imports to Korea were
actually GM: KFDA)
Why does USA not have mandatory
GM food labeling?
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Labeling in US is based on product, not process
Labels are required with changes to product
composition
If new allergens or toxicants are present
 If changes to nutrient content
 Regardless of method of breeding.
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Practical problems
Labelling of foods which do not contain any
GM genes or expression products
 No labelling of animal products
 Tracing agricultural commodities through
international trade
 Testing and identification
 The possibility of fraud
(DeGreef)
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The possibility of fraud
The tracing and labelling requirements for products in
which no GM can be detected is an invitation for fraud,
if there is a price difference
 The absence of large differences between GM and
non-GM commodities suggests that much food export
to the EU does not comply with the regulations
(De Greef)
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What are the motivations for mandatory
process based labels?
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Public “right to know”
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Informed choice
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Possible health or environment effects
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Distrust in Government regulators.
Conceptual problems with processbased GM labels
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GM Corn, soybean or canola oil sold to
consumers is identical to non-GM oil.
The label is misleading
 Cannot be independently verified by analysis
 Ripe for abuse
 Leads to consumer distrust in labels in general
 And distrust in the regulatory system in general!
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Which processes get labeled?
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Agrobacterium ?
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Biolistic ?
Irradiation mutagenesis ?
Somaclonal variation ?
Embryo rescue ?
Wide crossing genes from distant relatives ?
Genes from same species?
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What about ‘derived from’ products?
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Soybean GM with soybean gene
Soybean with bacterial gene
Tofu from Soybean with bacterial gene
Oil from Soybean with bacterial gene
Lecithin from Soybean with bacterial gene
Label problems: Special cases
Soybean from wild-type segregant
 Fruit from branch grafted onto rDNA roots
 Bread from wheat with rye genes
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Common wheat with Rye DNA
Friebe et al., Crop Science 39:1692-1696 (1999)
Economic: Who pays?
In capitalist society, those making marketplace
demands pay to have those demands fulfilled.
 But with GM labels, demand is from those
wishing to avoid purchase; the consumer is
forced to pay to fulfill demands of others.
 How do we charge the ‘demanders’ to pay for
GM food labels?
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Mandatory process based labels
satisfy few and cost everyone
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Exceptions, tolerances and allowances frustrate
those philosophically opposed to biotech
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‘reverse-onus’ of label liability raises costs to all,
especially small farmers and poor people
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Alternatives exist. Based on concern:
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If a health safety issue, fix regulatory credibility
(real hazards are in the product, not process)
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If concern is philosophical, voluntary labels work well.
Solution to problems
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Traceability of commodity grains adds
unnecessary burden to farmers and unnecessary
cost to consumers.
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Traceability should be used only for high value,
specialty and hazardous materials
Labels should be based on food composition,
not the breeding process.
Conclusion
Traceability and Labeling are feasible only
for physical products, not the process by
which they were made.
 Laws and policies requiring traceability and
labeling for process are impracticable
 Leading to loss of public trust in
politicians and regulators.
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