It is inspiring to see the growing passion being focused on the problem of GMO contamination; it is a massive challenge, and widespread collaboration is a prerequisite for positive progress. The recent discussion paper put forth by The Organic Agriculture Protection Fund (OAPF) raises important questions and creates a valuable opportunity for dialogue. By way of preface, I would like to emphasize that the Non-GMO Project wholeheartedly shares the Saskatchewan Organic Directorate’s concerns about GMO contamination. Although the Project is obviously committed to providing consumers with informed choices, another primary objective (as evidenced by our mission statement, below), is to control contamination and make sure that non-GMO crops, ingredients and food are available into the future. Our strategy is to leverage the power of the marketplace toward that end.

The Non-GMO Project is a non-profit multi-stakeholder collaboration committed to preserving and building sources of non-GMO products, educating consumers, and providing verified non-GMO choices.

CONTAMINATION REALITIES

From the beginning, the Project has been committed to eliminating GMOs. As the discussion paper accurately notes, absence of GMOs remains a stated target for the Project. In fact, the Non-GMO Project Standard explicitly states that “Absence of all GMOs is the target for all Non-GMO Project Standard compliant products” (section 2.6). Where the discussion paper is misguided is in suggesting that the Non-GMO Project’s current thresholds represent a “radical shift.” The unavoidable scientific fact, unfortunate though it may be, is that as long as there are GMOs grown in open fields, contamination is inevitable. Because GMOs were commercially cultivated for over a decade before the Non-GMO Project was created to control them, and because of their growing prevalence,

the risk of contamination to both conventional and organic crops is consistent and serious. From the beginning, it was the intention of the Project to address this contamination risk in a pragmatic and rigorous way, using appropriate thresholds.

It is critical to understand that the ONLY way to identify (and control) GMO contamination is through testing. The organic standards do not require testing; the Non-GMO Project Standard does.

It is worth noting that over half of the companies participating in the Non-GMO Project produce certified organic products. These companies have chosen Non-GMO Project Verification in addition to their organic certification because they are committed to keeping their products non-GMO, and are concerned that organic certification is not adequate. Many organic companies joined the Project after their internal GMO testing indicated a growing risk of contamination.

While the Non-GMO Project sets a goal of zero GMO presence, it also requires that continuous improvement practices toward achieving this goal be part of the Participant’s quality management systems. This is where the thresholds come in. The thresholds, like all aspects of the Non-GMO Project Standard, were arrived at through the Project’s ongoing twice-yearly public comment periods. The transparent, consensus-based nature of the Project Standard’s development process is fundamental to the organization’s approach, which values participation from all stakeholders. Accusations that the thresholds are a result of “pressure from industry” are unfounded.

The thresholds were agreed upon through a transparent, public process after considering all available data on current contamination levels in the “non-GMO” (conventional and organic) food supply in North America.

The thresholds were also designed to allow some consistency with the European Union, where products containing more than 0.9% GMO must be labeled as GMO (and by extension, products below 0.9% GMO are considered non-GMO).

The criticism of the Project’s thresholds expressed in the discussion paper belies a lack of information about the current contamination risks faced by the organic sector. It assumes that the lack of thresholds in organic standards is a “zero tolerance” policy, while in fact the opposite could also be said: without thresholds, there is no limit to contamination. By setting thresholds and requiring testing, the Non-GMO Project establishes much greater rigor with regard to GMO control than do the organic standards. It is critical to understand that even for certified organic companies, the Non-GMO Project’s current thresholds are rigorous and challenging because of the GMO contamination levels commonly seen in North America at this time.