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Genetic engineering is an "excluded method" in organic farming and processing, according to the National Organic Program (NOP). However, organic certifiers say the NOP rule is unclear because it doesn't specify whether products of genetic engineering should also be prohibited. This has led to inconsistencies in interpreting the rule among organic certifiers. Meanwhile, GMO contamination continues to be a bigger threat to organic integrity.
David Gould, director of technical services at FoodChain Global Advisors, highlights the limitations of the NOP's "excluded method" rule with a question. "What is the maximum genetically modified content that a certified organic product can have?" Theoretically, Gould says the product could have 100% GM content as long as the processor can show that they didn't use the excluded method, genetic engineering.
The NOP would allow the processor to be certified because the processor did not use genetic engineering. The fact that the processor may have jnowingly or unknowingly used certified organic ingredients contaminated by GMOs, or non-organic ingredients that may be products of genetic engineering, is not covered by the NOP rule.
This extreme example highlights the dilemma facing organic certifiers when evaluating inputs and ingredients for GMO risk.
Inconsistent interpretations of GMO prohibition
"The rule says an organic product must be produced and handled without the use of excluded methods, but this could be interpreted in different ways," says Gwendolyn Wyard, processing program reviewer at Oregon Tilth, an organic certifier.
For example, vitamin E (tocopherols), which is used as an ingredient in organic products, is derived from soybeans, raising GMO concerns. Some organic certifiers accept letters from the supplier stating that the tocopherols were tested and don't contain GMOs. Other certifiers require documentation showing that the tocopherols were derived from non-GMO soybeans.
Wyard says the lack of clarity has created loopholes that some organic companies have taken advantage of.
The problem is the language of the NOP rule. "Had the NOP included language that said, 'excluded methods and products thereof,' it would have been more specific," she says.
Jessica Walden, technical specialist at Quality Assurance International (QAI) agrees. "The regulation should clearly prohibit materials which 'contain, consist of or are produced from GMOs.' The way the regulation reads now the organic operation cannot use the excluded methods (the technology itself). The intention of the regulation, I believe, is to also prohibit products and materials that are developed from genetic engineering, such as seed, inoculants, inputs, ingredients and processing aids."
Citric acid: GMO or not?
Annie Berical and Cindy Elder, certification specialists at Organic Crop Improvement Association, say more guidance from the NOP is needed on evaluating ingredients for GMOs. For example, citric acid is derived from a fungus, Aspergillus Niger, which may be GM. The fungus is combined with a substrate made from corn, which could also be GM. During a fermentation process, the substrate is removed and does not appear in the final product. "It's really tough for processors to locate a citric acid produced on a non- GMO substrate. Is this really necessary?" Berical says.
In the absence of guidance, Elder says OCIA takes the most conservative approach and requires that the substrate be non-GMO.
On the other hand, the Organic Materials Review Institute (OMRI), says the GM corn substrate is not a concern because it is removed, but that the use of a GM fungus to make citric acid is not acceptable.
"So many layers where GMOs might have been used"
Interpreting the GMO status of other non-organic ingredients allowed in organic processing is challenging. Enzymes, used to convert starch to sugar, clarify fruit juice or make cheese, are often produced from GM microorganisms, which are removed during food processing. A natural flavor may contain alcohol as a solvent, which may have been produced using a GM enzyme. Many vitamins are produced using GM microorganisms. Yeast is grown on a molasses medium derived from sugar beets, which are now GM, or corn syrup, another GM source. Berical and Elder say livestock feed additives may also contain GMOs.
"The more you dig, the more you realize that there are so many layers where GMOs might have been used," Walden says.
The question certifiers ask is, "How far back in the chain do you go looking for GMOs?"
"More clarity is needed from the NOP on how far certifiers should go in determining whether or not a material, which may have been produced at some stage in the process with GMO technology, is prohibited for use in organic products," Walden says.
Oregon Tilth and CCOF have developed flowcharts or "decision trees" to help farmers or processors evaluate the GM status of ingredients. QAI developed a GMO Declaration that its clients submit to verify the non-GMO status of ingredients.
The decision trees are based on one developed by OMRI for evaluating inputs for crops, livestock, and processing. OMRI also published a policy paper "Genetic Engineering Considerations in The Evaluation of Inputs for Organic Farming and Food Processing" (www.omri.org/OMRI_GMO_ policy.html).
"GMO issue will need to be dealt with"
Organic certifiers say more guidance is needed on evaluating GMOs from the NOP or National Organic Standards Board (NOSB). "The NOP either needs to provide a guidance document to the industry to clarify the intention of the regulation (with regard to GMOs) or the wording in the regulation needs to be changed to provide clarity," Walden says.
Wyard says achieving consistency in interpreting the GMO prohibition should begin with the Association of Accredited Certifiers (ACA). "We can start with ACA, getting all the certifiers on the same page, take it to the NOP, and then to the NOSB."
Wyard admits that the NOP has had to focus on more pressing issues, but says, "The GMO issue is going to need to be dealt with."
Walden and Wyard point to European organic regulations, which were revised to be more specific in evaluating GMOs.
GMO contamination is the problem
"More clarity and consistency in the NOP rule is good," says Gould. "But the amount of GMOs is a problem."
Increasing acreage of GM crops threatens organic farms while the proliferation of GMOs in non-organic ingredients challenges organic processors.
Gould says the best solution may be the Non-GMO Project, which aims to create non- GMO supply chains, from seed and grains to ingredients and food products. "The Project has a consensus definition of what are the best practices for excluding GMOs," he says.
Is Organic Really Free of Genetically Engineered Organisms?
Certifiers say organic rules limited in addressing GMOs
By Ken Roseboro, ed.
The Organic and Non-GMO Report, June 2009
Straight to the Source