Comment from Organic Consumers Association

23,066 Members of the Organic Consumers Association have signed the following petition (list of signers attached): Please halt the effort to “modernize” the regulatory process for genetically modified organisms by allowing biotech corporations to “self-regulate.” As new genetic engineering techniques are developed, the public should expect the USDA to exercise even greater caution and oversight over these technologies, not less. It is naive and irresponsible to assume that corporations will put public safety concerns ahead of corporate profits. The biotech industry wants complete deregulation a category of genetically modified organisms the it calls “plant-incorporated protectants.” These are crops that are genetically engineered to produce their own pesticides. These pesticides aren’t on your food, they are your food! Pesticide-producing GMOs include Bt crops, which are responsible for the engineered Cry1Ab toxin showing up in the blood of 8 out of 10 newborns. They also include the scary new gene-silencing GMOs in crops like Bayer-Monsanto’s SmartStax corn. This corn isn’t just genetically modified, it’s engineered to genetically modify the insects that feed on it. When rootworms feed on SmartStax corn, every bite they take delivers a payload of double-stranded RNA that triggers a lethal change in the pests’ gene expression. Who knows what it’s doing to us! Interfering RNA can trigger immune responses and could actually change human gene expression. Scientists are just beginning to explore how the naturally occurring interfering RNA we get from vegetables and grains regulates our gene expression. For instance, they only recently noticed that double-stranded RNA from rice regulates a liver gene that controls cholesterol metabolism. Virtually nothing is known about the untold numbers of other interfering RNAs that we consume through foods like rice, corn, barley, tomatoes, soybeans, wheat, cabbage, grapes, and carrots. It would have been nice for humanity to get a chance to figure out how what we eat determines which genes are expressed before genetic engineers went messing around with all of this! With 20 to 30 percent of the 86 million acres of GMO corn now carrying RNAi traits our health is already being impacted. It's unconscionable that the health risks weren't studied before RNAi entered the food supply. Especially since research on the use of interfering RNAs as a medical intervention shows that RNAi causes immune reactions in the body, triggering dangerous inflammatory responses. The EPA assumed (probably incorrectly) that the human gastrointestinal tract provides barriers to absorption that would prevent double-stranded RNA from reaching the bloodstream, but newborn infants don’t have these gut barriers and gastrointestinal problems can also cause gut permeability in adults. The EPA didn’t require Monsanto to consider these populations. In addition to dietary exposure, the EPA should have considered the inhalation of double-stranded RNA expressed in corn pollen, which can be carried by the wind up to a half-mile away. As a safety-conscious food consumer, and a public citizen whose concerns about the environment range from species extinction, soil degradation and air and water pollution, I expect taxpayer-funded agencies like the USDA to protect human and environmental health, not corporate profits. I also expect the USDA to protect organic farmers, whose crops are threatened by cross-pollination of unregulated, untested GMOs. The USDA should strengthen, not weaken, GMO regulation.