Myths and Truths About Genetically Modified Foods
by Jeffrey M. Smith
SeedsThe following testimony was given on October 2, 2003 before the Vermont State Agriculture Committee by Jeffrey M. Smith, author of the exposé, Seeds of Deception: Exposing Industry and Government Lies about the Safety of the Genetically Engineered Foods You're Eating.
My name is Jeffrey Smith, I have been involved with the issue of genetically-engineered foods since the mid 1990s, working for nonprofit and political groups, and lecturing on the health and environmental dangers. I worked as vice-president of marketing for a GMO-detection laboratory, which also certifies foods and crops as non-GMO (short for genetically modified organisms). I recently wrote a book entitled, Seeds of Deception: Exposing Industry and Government Lies About the Safety of the Genetically Engineered Foods You're Eating. It documents many potential and actual health dangers of genetically modified foods, and the attempts by proponents of biotechnology to cover them up.
The book includes information never before in the public domain. I encourage you to look it over before finalizing any policy on genetically modified (GM) foods. Many people have been shocked at what has been going on behind the scenes. I will be conducting a tour of the state, presenting some of the evidence to your constituents.
My conclusions are as follows:
Genetically modified foods are inherently unsafe. They can lead to dozens of unpredicted side effects.
Many of the assumptions used by biotechnology companies as the basis for their safety claims have been proven wrong or remain untested.
There have been dangerously few safety tests on genetically modified foods.
Industry safety tests are typically rigged to avoid finding problems.
The most in-depth independent studies show serious damage to laboratory animals.
One genetically modified food supplement killed about 100 Americans and caused another 5-10,000 to fall sick. Evidence implicating genetic engineering as the cause was suppressed.
Many scientists both in government and in the private sector who discovered dangers, or even expressed concern, have been attacked and silenced. How could the government approve dangerous foods? A close examination reveals that industry manipulation and political collusion - not sound science - allowed these on the market. I have discovered that:
Government employees who complained were harassed, stripped of responsibilities, or fired.1,2
Scientists were threatened. Evidence was stolen. Data was omitted or distorted. Some regulators even claimed they were offered bribes to approve a genetically modified product.3,4,5
Let's explore some of the popular myths about genetically modified foods:
The FDA has thoroughly evaluated genetically modified foods and found them safe.
This is untrue.
Internal FDA documents made public from a lawsuit reveal that agency scientists warned that genetically modified foods might create toxins, allergies, nutritional problems, and new diseases that might be difficult to identify.6 Although they urged their superiors to require long-term tests on each genetically modified variety prior to approval, the political appointees at the agency, including a former attorney for Monsanto, ignored the scientists. Official policy claims that the foods are no different and do not require safety testing.7 A manufacturer can introduce a genetically modified food without even informing the government or consumers.8
A January 2001 report from an expert panel of the Royal Society of Canada said it was "scientifically unjustifiable"9 to presume that genetically modified foods are safe. Likewise, a 2002 report by the UK's Royal Society said that genetic modification "could lead to unpredicted harmful changes in the nutritional state of foods," and recommended that potential health effects of genetically modified foods be rigorously researched before being fed to pregnant or breast-feeding women, elderly people, those suffering from chronic disease, and babies.10
In unpublished studies on the FlavrSavr tomato, laboratory rats fed the genetically modified crop developed stomach lesions and seven of the forty died within two weeks. The tomato was approved.
These foods have been extensively tested for safety.
This is untrue.
In the mid-1990s, a major grant was awarded by the British government to develop the first independent safety-testing program on genetically modified food. It was to become the model for the UK, and later for all of Europe. As part of the research, scientists fed rats a genetically modified potato engineered to create an insecticide, known to be harmless to rats. Upon examination, it was found that the rats developed damage to the immune system, smaller brains, livers and testicles, partial atrophy of the liver and potentially pre-cancerous cell growth in the intestines and stomach.11 When the lead scientist tried to alert the public about these alarming discoveries, he lost his job, he was silenced with threats of a lawsuit, and the safety testing program was scrapped.
The research was eventually published in the prestigious journal The Lancet, and remains the most in-depth animal feeding study on genetically modified foods ever conducted. Two other studies also showed preliminary evidence of a potentially pre-cancerous condition reported in The Lancet. All other published animal feeding studies on genetically modified foods were not designed to identify health effects.12, 13 That's all the other seven studies. Unbelievably, there are only ten published animal feeding studies on the health effects of genetically modified foods. In unpublished studies on the FlavrSavr tomato, laboratory rats fed the genetically modified crop developed stomach lesions and seven of the forty died within two weeks. The tomato was approved.
Approval was based on sound science.
This is untrue.
I asked Dr. Arpad Pusztai, an eminent scientist fired and silenced after discovering damaged health in rats, what was the most shocking moment he encountered. It was not discovering the damaged health in the rats or being fired after 35 years.
It came months earlier when he read the confidential submissions made by the biotechnology companies to the UK government, requesting that their foods be approved. He was given the 600+ pages by the director of his institute, who sat on the twelve-member committee that approved requests. Arpad knew that the director and most of the committee members would never actually read the studies, as they were committee-men, not working scientists. Arpad, on the other hand, had been in charge of a twenty-member team for two years, designing safety protocols. He was among the most qualified persons in the world to evaluate the submissions.
Reading them, however, was the most shocking moment. He said the studies were examples of extremely poor science. It was obvious that the companies were doing as little as possible in order to get their foods onto the market quickly. Reading these superficial studies was a turning point in this pro-biotech scientist's life. Later, when he discovered the damage to the rats after consuming genetically modified potatoes for the equivalent of ten human years, he realized that if the soy and corn on the market were creating the same effect in humans, it would never have been picked up by their flimsy tests, and it would not be obvious in the population for years.
In fact, many industry studies appear to be rigged to find no problems. In the case of a genetically engineered bovine growth hormone (rbGH), for example, researchers injected cows with only a fraction of the normal dosage before reporting hormone residues in milk.14 They heated the milk 120 times longer than standard, in an apparent attempt to report that pasteurization destroys the hormone.15 It didn't, so they added powdered hormone, 146 times the naturally occurring amount, heated that 120 times longer than normal, and only then reported that pasteurization destroys 90% of the hormone. That was what the FDA reported as well. Furthermore, researchers apparently used cows that were pregnant before treatment to claim that rbGH didn't impede fertility.16 Cows that fell sick were allegedly dropped from studies altogether.
With soybeans, serious nutritional differences between genetically modified and natural soy were omitted from a published paper.17 Feeding studies masked any problems by using mature animals instead of developing ones and by diluting their genetically modified soy 10 to 1 with non-GM protein.18
No Adequate Tests for Allergic Reactions
There are no adequate tests to verify that genetically modified food will not create dangerous allergic reactions. While the World Health Organization developed testing standards to minimize the possibility of allowing allergenic genetically modified varieties on the market, genetically modified corn currently sold in the U.S. has not been subjected to those tests and would most certainly fail them. One company's test, for example, used a far stronger acid concentration and more than 1,250 times the amount of a digestive enzyme later recommended by the WHO, to make the claim that their protein degrades too quickly to cause an allergic reaction.19
The only human feeding trial ever conducted confirmed that genetically engineered genes from soy burgers and a soy milkshake transferred to the bacteria inside the digestive tract after only one meal.20 The biotech industry had previously said that such a transfer was impossible.
Super Diseases and Cancer
The World Health Organization and the American Medical Associations, and several other groups have expressed concern that if the "antibiotic resistant marker genes" used in genetically modified foods got transferred to bacteria, it could create super-diseases that are immune to antibiotics.21 This was one reason cited why the British Medical Association called for a complete moratorium on genetically modified foods.
More worrisome is that the "promoter" used inside genetically modified foods might get transferred to bacteria or internal organs. Promoters permanently turn on genes that might otherwise be switched off. Scientists believe that this might create unpredictable health effects, including the potentially pre-cancerous cell growth found in the animal feeding studies mentioned earlier.
Only those who consumed genetically modified L-Tryptophan became ill… Once discovered, industry and government covered up facts and diverted the blame.
The biotech industry says that millions have been eating genetically modified foods without ill effect.
This is misleading.
About 100 people died and 5-10,000 to fell seriously ill when they consumed the food supplement L-Tryptophan.22 Only those who consumed genetically modified L-Tryptophan became ill. That brand had minute but deadly contaminants that would easily pass through current regulations today. The disease it created was rare, acute, and came on quickly. If all three of these characteristics had not been present, the genetically modified supplement might never have been traced as the cause. Once discovered, however, industry and government covered up facts and diverted the blame. Some tried to pin the blame on a change in the company's filter. We know now that hundreds had contracted the disease from genetically modified versions of the supplement during the four years prior to the change in the filter. The FDA testimony before Congress blamed health fraud schemes, and never told congressmen that the supplement was genetically modified.
Milk from rbGH-treated cows contains an increased amount of the hormone IGF-1. We know that IGF-1 naturally occurs in milk. We also know that drinking milk can increase the free circulating IGF-1 in humans. Premenopausal women with high IGF-1 levels are seven times more likely to develop breast cancer. Besides family history, that makes IGF-1 the highest known risk factor for breast cancer.23 Men with high levels are four times more likely to develop prostate cancer.24 IGF-1 is also implicated in colon and lung cancer.
Soy allergies skyrocketed by 50% in the UK, coinciding with the introduction of genetically modified soy imports from the U.S.25
According to a March 2001 report, the Centers for Disease Control says that food is responsible for twice the number of illnesses in the U.S. compared to estimates just seven years earlier. This increase roughly corresponds to the period when large amounts of genetically modified foods have been introduced into the American diet. Could genetic engineering be contributing to the 5,000 deaths, 325,000 hospitalizations, and 76 million illnesses related to food each year? Might it play a role in our national epidemic of obesity or the rise in diabetes or lymphatic cancers? We have no way of knowing if there is a connection because no one has looked for one.
Actually, the Food Standards Agency of the UK developed a plan to monitor potential health problems. They approached the UK supermarkets, asking to use the purchasing records of the 30 million consumers who used "loyalty cards." They were going to see if those people who ate genetically modified foods had higher levels of birth defects, childhood allergies, and cancer. When their plans were leaked to the public, they cancelled the study.
danglickman"What I saw on the pro-biotech side was the attitude that the technology was good, and that it was almost immoral to say that it wasn't good… and there was a lot of money invested in this, and if you're against it, you're Luddites, you're stupid."
- Dan Glickman, former Secretary of Agriculture
One of the most dangerous aspects of genetic engineering is the closed thinking and consistent effort to silence those with contrary evidence or concerns. Just before stepping down from office, former Secretary of Agriculture, Dan Glickman, admitted the following:
What I saw on the pro-biotech side was the attitude that the technology was good, and that it was almost immoral to say that it wasn't good, because it was going to solve the problems of the human race and feed the hungry and clothe the naked… And there was a lot of money that had been invested in this, and if you're against it, you're Luddites, you're stupid. That, frankly, was the side our government was on… You felt like you were almost an alien, disloyal, by trying to present an open-minded view.26
Contrast this with the warning by the editors of Nature Biotechnology: "The risks in biotechnology are undeniable, and they stem from the unknowable in science and commerce. It is prudent to recognize and address those risks, not compound them by overly optimistic or foolhardy behavior."27
Please don't become overly optimistic or foolhardy. I urge you to read the evidence amassed in my book Seeds of Deception. I do not offer opinions. I offer meticulously documented accounts, with 340 footnotes in all, showing that these foods should never have been approved and might already be creating massive health problems in our population. As you read the book, please note down any questions. Make them tough. I will be available to answer the questions, or put you in touch with scientists who may be better equipped to respond. Thank you for the opportunity to share with you what I have learned about this important topic. The following is excerpted from Seeds of Deception.
Seeds of Deception
The biotech industry's success with government leaders became apparent on May 26, 1992 in the Indian Treaty Room of the Old Executive Building. There, Vice President Dan Quayle announced the Bush administration's new policy on genetically engineered food: "The reforms we announce today will speed up and simplify the process of bringing better agricultural products, developed through biotech, to consumers, food processors and farmers. We will ensure that biotech products will receive the same oversight as other products, instead of being hampered by unnecessary regulation."28
By "receive the same oversight as other products," Quayle meant that genetically modified foods would be considered just as safe as natural, non-GM foods. Sidestepping "unnecessary regulation" meant that the government would not require safety tests or special labels identifying the foods as genetically engineered. The rationale for this hands-off policy was spelled out in an FDA document dated three days after Quayle's announcement. "The agency is not aware of any information showing that foods derived by these new methods differ from other foods in any meaningful or uniform way."29
Monsanto, under its new leadership, had what it wanted: government endorsement of safety and no regulations that would interfere with its plans for rapid worldwide sales.
Could genetic engineering be contributing to the 5,000 deaths, 325,000 hospitalizations, and 76 million illnesses related to food each year?
Political Science at the FDA
Attorney Michael Taylor had overseen the development of FDA policy. Prior to working at the agency, Taylor worked at King and Spaulding law firm; Monsanto was his personal client. Taylor helped Monsanto draft pro-biotech regulations that the industry would lobby for. While working for the FDA, Taylor could implement those laws himself. For Monsanto, there was no better person to step into a leadership role at the FDA.
Taylor did not simply fill a vacant position at the agency. In 1991 the FDA created a new position for him: Deputy Commissioner for Policy. He instantly became the FDA official with the greatest influence on genetically modified food regulation, overseeing the development of government policy.
According to public interest attorney Steven Druker, who has studied the FDA's internal files, "During Mr. Taylor's tenure as Deputy Commissioner, references to the unintended negative effects of bioengineering were progressively deleted from drafts of the policy statement (over the protests of agency scientists), and a final statement was issued claiming (a) that [GM] foods are no riskier than others and (b) that the agency has no information to the contrary."30 In 1994, Taylor became the administrator at the Department of Agriculture's Food Safety and Inspection Service, where he was also involved in biotechnology issues. He later became Vice President for Public Policy at Monsanto.
When the FDA announced its policy, the public was not aware of any internal dissent. The policy boldly claimed there was no information to indicate that genetically modified foods were different or more risky than natural varieties. Since the American public generally trusts the FDA, they assumed no such risks existed. But nearly a decade later, the agency's internal documents - made public for the first time through a lawsuit - told a different story.
Linda Kahl, an FDA compliance officer, protested that by "trying to force an ultimate conclusion that there is no difference between foods modified by genetic engineering and foods modified by traditional breeding practices," the agency was "trying to fit a square peg into a round hole." She insisted, "the processes of genetic engineering and traditional breeding are different, and according to the technical experts in the agency, they lead to different risks."31
One such expert was FDA microbiologist Louis Pribyl. "There is a profound difference between the types of unexpected effects from traditional breeding and genetic engineering," wrote Pribyl in a letter to James Maryanski, the FDA's biotech coordinator. Pribyl said that several aspects of gene splicing "may be more hazardous."32 According to the New York Times, "Dr. Pribyl knew from studies that toxins could be unintentionally created when new genes were introduced into a plant's cells."27 Moreover, Pribyl wrote "there is no certainty that [the breeders of genetically modified foods] will be able to pick up effects that might not be obvious." He declared, "This is the industry's pet idea, namely that there are no unintended effects that will raise the FDA's level of concern. But time and time again, there is no data to back up their contention."32
Pribyl was one of many FDA scientists asked to provide input during the formulation of the FDA's policy on genetically engineered food. According to Druker, records show that the majority of these scientists identified potential risks of genetically modified foods. Druker was the main organizer of the lawsuit that forced the FDA documents into the public domain; his nonprofit organization, the Alliance for Bio-Integrity (http://www.bio-integrity.org), was the lead plaintiff. Having sorted through tens of thousands of pages of FDA documents, he described the opinion of the agency's scientists as follows: "The predominant view was that genetic engineering entails distinct risks and that its products cannot be regarded as safe unless they have been confirmed to be so through appropriate feeding studies." Druker says several scientists "issued strong warnings."
The Toxicology Group, for example, warned that genetically modified plants could "contain unexpected high concentrations of plant toxicants," and described the reasons why these might be very difficult to identify.33 Their director wrote, "The possibility of unexpected, accidental changes in genetically engineered plants justifies a limited traditional toxicological study."34
The Division of Food Chemistry and Technology outlined four potential dangers:
1) "Increased levels of known naturally occurring toxins"
2) "Appearance of new, not previously identified" toxins
3) Increased tendency to gather "toxic substances from the environment" such as "pesticides or heavy metals" and
4) "Undesirable alterations in the levels of nutrients."
They warned, "unless genetically engineered plants are evaluated specifically for these changes," these four "may escape breeders' attention." The division recommended testing every genetically modified food "before it enters the marketplace."35
Gerald Guest, the director of FDA's Center for Veterinary Medicine (CVM), sent a letter to James Maryanski at the FDA stating CVM's conclusion that there is "ample scientific justification" to require testing and review of each genetically modified food before it is eaten by the public. He stated, "CVM believes that animal feeds derived from genetically modified plants present unique animal and food safety concerns." He pointed out that, "residues of plant constituents or toxicants in meat and milk products may pose human food safety concerns."36 Guest also wrote, "I would urge you to eliminate statements that suggest that the lack of information can be used as evidence for no regulatory concern."36
In spite of repeated internal memos outlining the potential for increased health risks posed by this new technology, subsequent drafts of the FDA's policy statement, overseen by Taylor, deleted more and more of the scientist's input. In a fiery memo to Maryanski, Pribyl challenged the direction the policy statement had taken: What has happened to the scientific elements of this document?
Without a sound scientific base to rest on, this becomes a broad, general, 'What do I have to do to avoid trouble'-type document… It will look like and probably be just a political document… It reads very pro-industry, especially in the area of unintended effects, but contains very little input from consumers and only a few answers for their concerns.
Pribyl pointed out a glaring inconsistency. He said that while the FDA policy says "there are no differences between traditional breeding and [genetic modification]… In fact the FDA is making a distinction, so why pretend otherwise." Pribyl also made two eerily accurate predictions:
"Industry will do what it has to do to satisfy the FDA 'requirements' and not do the tests that they would normally do because they are not on the FDA's list;" and
"There will be… less concern about safety, because of a false sense of 'knowing what one is doing' and 'its been done hundreds of times before without a problem, why check it now.'"32
White House Influence on FDA Policy
While the FDA's scientists were emphasizing caution and testing, its leaders were beholden to an altogether different lobbying effort. A March 1992 memo from FDA Commissioner David Kessler, confirmed the White House's influence in the crafting of the agency's policy. "The approach and provisions of the policy statement are consistent with the general biotechnology policy established by the Office of the President… It also responds to White House interest in assuring the safe, speedy development of the U.S. biotechnology industry."37
Even the draft of the policy Kessler praised as White House-friendly was subject to further revision as it went up the political chain of command. A May 1992 Memorandum from the Office of Management and Budget to President Bush's White House counsel made the following recommendations.
The policy statement needs to stress the role of decentralized safety reviews by producers; with informal FDA consultation only if significant safety or nutritional concerns arise. It should avoid emphasizing obligatory FDA review and oversight.
The letter also suggested that the following sentence about genetic engineering be added. "Since these techniques are more precise, they increase the potential for safe, better characterized, and more predictable foods."38
Similarly, a memo from the Office of the Assistant Secretary for Health, at the Department of Health & Human Services, expressed reservations about the length and depth of the policy statement's concern for environmental effects of genetically modified crops. The letter said, "The extensive twelve page discussion seems to be … dangerously detailed and drawn-out… In contrast to the sections on food safety, which properly imply that biotechnology is a fundamentally innocuous tool of food production and that the fruits of biotechnology will be substantially equivalent to those with which we are already familiar, the [environmental] section gives an incorrect impression that biotechnology raises significant new agricultural and environmental concerns."39
lizardThe Politics of Food
These memos reveal that as the evaluators have less and less background in science and more political accountability, the foods, and their environmental impact, are regarded as safer and safer. In the end, it was the political rather than scientific recommendations that prevailed. The agency not only ignored its scientists, it claimed their concerns never existed. The official FDA policy proclaiming ignorance of any meaningful differences between genetically modified and non-GM food became the rationale for eliminating any meaningful oversight.
Other government departments also invoked this political concept of equivalence in support of their policies. For example, the State Department's Melinda Kimble, while negotiating genetically modified trade policy said, "I want to make very clear that it is the position of the United States government that we do not believe there is a difference between GMO and non-GMO commodities."40 Likewise, a March 2003 statement by Speaker of the House Hastert declared, "There is general consensus among the scientific community that genetically modified food is no different from conventional food."41
When the FDA documents eventually became public, Maryanski defended the agency's policy. On February 28, 2000, he told the OECD Conference on GMO Food Safety in Edinburgh, Scotland, that the FDA scientists had merely been asking questions about the various issues involved in bio-engineered food. Maryanski was unpleasantly surprised when Druker, who was a member of the conference, stood up and invited the audience to read the FDA memos that were posted on his organization's website. They could see for themselves that the agency's scientists were not merely asking questions; many of their statements were quite emphatic about the unique risks of genetically modified foods.
Maryanski and other FDA officials and representatives throughout the U.S. government continue to claim there is overwhelming consensus among scientists that genetically modified foods are safe. In an October 1991 letter to a Canadian official, however, Maryanski himself had admitted that this was not true. He said, "there are a number of specific issues… for which a scientific consensus does not exist currently, especially the need for specific toxicology tests." Maryanski also said, "I think the question of the potential for some substances to cause allergenic reactions is particularly difficult to predict."42
Commenting on statements made by FDA scientists, the New York Times wrote. "The scientists were displaying precisely the concerns that Monsanto executives from the 1980s had anticipated - and indeed had considered reasonable. But now, rather than trying to address those concerns, Monsanto, the industry and official Washington were dismissing them as the insignificant worries of the uninformed."43
Many scientists who understood the dangers, however, were not convinced by the FDA's assurances. Geneticist David Suzuki, for example, said, "Any politician or scientist who tells you these products are safe is either very stupid or lying. The experiments have simply not been done."44
A January 2001 report from an expert panel of the Royal Society of Canada likewise supported the conclusions of the FDA scientists. The report said it was "scientifically unjustifiable" to presume that genetically modified foods are safe. The report explains that the "default prediction" for any genetically modified foods is that "expression of a new gene (and its products)… will be accompanied by a range of collateral changes in expression of other genes, changes in the pattern of proteins produced and/or changes in metabolic activities." This could result in novel toxins or other harmful substances. The report emphasized the need for safety testing, looking for short and long-term human toxicity, allergenicity, and other health effects.45 P
Jeffrey M. Smith is the author of the explosive new exposé, Seeds of Deception: Exposing Industry and Government Lies about the Safety of the Genetically Engineered Foods You're Eating, available at www.seedsofdeception.com, at 888.717.7000, or at bookstores near you.
1. Jeff Kamen, "Formula for Disaster," Penthouse, March 1999
2. Robert Cohen, Milk, the Deadly Poison, Argus Publishing, Englewood Cliffs, New Jersey, 1998
3. James Baxter, The Ottawa Citizen, October 23, 1998, P. Al
4. Ann McIlroy "Pierre Blais thought it was his duty," Globe and Mail (Canada)
5. Steve Wilson, "Secret Canadian Govt. Study Reveals Serious Faults with bGH Research; FDA Approval Was Based on Faulty Conclusions?" October 7, 1998, www.foxbghsuit.com/jaws1007.htm
6. Louis J. Pribyl, "Biotechnology Draft Document, 2/27/92," March 6, 1992, www.biointegrity.org
7. "Statement of Policy: Foods Derived from New Plant Varieties," Federal Register vol. 57, no. 104 at 22991, May 29, 1992
8. Emily Gersema, "FDA Opts against Further Biotech Review," Associated Press, June 17, 2003
9. "Expert Panel on the Future of Food Biotechnology," January, 2001
10. Paul Brown, "British scientists turn on genetically modified food," The Guardian, February 5, 2002, www.nutiva.com/nutrition/articles/2_british.php
11. Stanley W B Ewen, Arpad Pusztai, "Effect of Diets Containing Genetically Modified Potatoes Expressing Galanthus Nivalis Lectin on Rat Small Intestine," Lancet, Research letters, Volume 354, Number 9187, 16 October 1999
12. Sheldon Rampton and John Stauber, Trust Us, We're Experts, Jeremy P. Tarcher/ Putnam, New York, 2001, p154
13. Jeffrey M. Smith, Seeds of Deception, Yes! Books, Fairfield, IA, 2003, pp. 34-38
14. Judith C. Juskevich and C. Greg Guyer, "Bovine Growth Hormone: Human Food Safety Evaluation," Science, 1990, vol. 249, pp. 875-884
15. Robert Cohen, Milk, the Deadly Poison, Argus Publishing, Englewood Cliffs, New Jersey, 1998
16. Samuel Epstein and Pete Hardin, "Confidential Monsanto Research Files Dispute Many bGH Safety Claims," The Milkweed, January 1990
17. Barbara Keeler and Marc Lappé, "Some Food for FDA Regulation," Los Angeles Times, January 7, 2001
18. GM-FREE Magazine, vol. 1, no. 3, August/September 1999
19. Bill Freese, "A Critique of the EPA's Decision to Re-Register Bt Crops and an Examination of the Potential Allergenicity of Bt Proteins," adapted from Friends of the Earth submission to the EPA, Dec. 9, 2001, www.foe.org/safefood/comments.pdf
20. John Vidal, "GM genes found in human gut," The Guardian, July 17, 2002, www.guardian.co.uk/gmdebate/Story/0,2763,756666,00.html
21. "The Impact of Genetic Modification on Agriculture, Food and Health," British Medical Association, Board of Science and Education, May 1999.
22. Phillip A. Hertzman and others, "The Eosinophilia-Myalgia Syndrome: The Los Alamos Conference," Journal of Rheumatology, vol. 18, no. 6, 1991, pp. 867-873
23. S. E. Hankinson, and others, "Circulating concentrations of insulin-like growth factor 1 and risk of breast cancer," Lancet, vol. 351, no. 9113, 1998, pp. 1393-1396
24. June M. Chan and others, "Plasma Insulin-Like Growth Factor-1 [IGF-1] and Prostate Cancer Risk: A Prospective Study," Science, vol. 279, January 23, 1998, pp. 563-566
25. Michael Meacher, "Are GM crops safe? Who can say? Not Blair," The Independent, June 22, 2003
26. Bill Lambrecht, Dinner at the New Gene Café: How Genetic Engineering Is Changing What We Eat, How We Live, and the Global Politics of Food, St. Martin's Press, New York, 2001, p. 139
27. "Expert Panel on the Future of Food Biotechnology," January, 2001, www.rsc.ca/foodbiotechnology/GmreportEN.pdf
28. Kurt Eichenwald, and others, "Biotechnology Food: From the Lab to a Debacle," The New York Times, January 25, 2001
29. "Statement of Policy: Foods Derived From New Plant Varieties," Federal Register vol. 57, No. 104 at 22991. May 29, 1992
30. Steve Druker, www.biotintegrity.org
31. Linda Kahl to James Maryanski, about Federal Register document "Statement of Policy: Foods from Genetically Modified Plants," January 8, 1992. www.biotintegrity.org
32. Louis J. Pribyl "Biotechnology Draft Document, 2/27/92," March 6, 1992, www.biotintegrity.org
33. Edwin J. Mathews to the Toxicology Section of the Biotechnology Working Group. "Analysis of the Major Plant Toxicants." October 28, 1991, www.biotintegrity.org
34. Samuel I. Shibko to James Maryanski, "Revision of Toxicology Section of the Statement of Policy: Foods Derived from Genetically Modified Plants," January 31, 1992, www.biotintegrity.org
35. Division of Food Chemistry and Technology and Division of Contaminants Chemistry, "Points to Consider for Safety Evaluation of Genetically Modified Foods; Supplemental Information," November 1, 1991, www.biotintegrity.org
36. Gerald B. Guest to James Maryanski, "Regulation of Transgenic Plants - FDA Draft Federal Register Notice on Food Biotechnology." February 5, 1992, www.biotintegrity.org
37. David Kessler, "FDA Proposed Statement of Policy Clarifying the Regulation of Food Derived from Genetically Modified Plants - DECISION." March 20, 1992, www.biotintegrity.org
38. James B. MacRae, Jr., Office of Management and Budget, to C. Boyden Gray, President Bush's White House counsel, "FDA Food Biotechnology Policy." March 21, 1992, www.biotintegrity.org
39. Eric Katz to John Gallivan, "Food Biotechnology Policy Statement," March 27, 1992, www.biotintegrity.org
40. Bill Lambrecht, Dinner at the New Gene Café, p 322
41. "Speaker Hastert Calls for End of European Union's 'Protectionist, Discriminatory Trade Policies," U.S. Newswire, March 26, 2003
42. James Maryanski, to Dr. Bill Murray, Chairman of the Food Directorate, Canada, "The safety assessment of foods and food ingredients developed through new biotechnology," October 23, 1991, www.biotintegrity.org
43. Kurt Eichenwald, and others, "Biotechnology Food: From the Lab to a Debacle," The New York Times, January 25, 2001
44. Andrea Baillie, "Suzuki Warns of Frankenstein Foods," CP Wire, October 18, 1999
45. "Expert Panel on the Future of Food Biotechnology," January, 2001 www.rsc.ca/foodbiotechnology/GMreportEN.pdf