U.S. GOVERNMENT PUBLISHING OFFICE

WASHINGTON : 

For sale by the Superintendent of Documents, U.S. Government Publishing Office

Internet: bookstore.gpo.gov Phone: toll free (866) 512–1800; DC area (202) 512–1800

Fax: (202) 512–2104 Mail: Stop IDCC, Washington, DC 20402–0001

93–965 PDF 2015

EXAMINATION OF THE COSTS AND IMPACTS 

OF MANDATORY BIOTECHNOLOGY 

LABELING LAWS 

HEARING 

BEFORE THE

COMMITTEE ON AGRICULTURE 

HOUSE OF REPRESENTATIVES 

ONE HUNDRED FOURTEENTH CONGRESS 

FIRST SESSION 

MARCH 24, 2015 

Serial No. 114–6 

( 

Printed for the use of the Committee on Agriculture 

agriculture.house.gov 

COMMITTEE ON AGRICULTURE 

K. MICHAEL CONAWAY, Texas, Chairman 

RANDY NEUGEBAUER, Texas, 

Vice Chairman 

BOB GOODLATTE, Virginia 

FRANK D. LUCAS, Oklahoma 

STEVE KING, Iowa 

MIKE ROGERS, Alabama 

GLENN THOMPSON, Pennsylvania 

BOB GIBBS, Ohio 

AUSTIN SCOTT, Georgia 

ERIC A. ‘‘RICK’’ CRAWFORD, Arkansas 

SCOTT DESJARLAIS, Tennessee 

CHRISTOPHER P. GIBSON, New York 

VICKY HARTZLER, Missouri 

DAN BENISHEK, Michigan 

JEFF DENHAM, California 

DOUG LAMALFA, California 

RODNEY DAVIS, Illinois 

TED S. YOHO, Florida 

JACKIE WALORSKI, Indiana 

RICK W. ALLEN, Georgia 

MIKE BOST, Illinois 

DAVID ROUZER, North Carolina 

RALPH LEE ABRAHAM, Louisiana 

TOM EMMER, Minnesota 

JOHN R. MOOLENAAR, Michigan 

DAN NEWHOUSE, Washington 

COLLIN C. PETERSON, Minnesota, Ranking 

Minority Member 

DAVID SCOTT, Georgia 

JIM COSTA, California 

TIMOTHY J. WALZ, Minnesota 

MARCIA L. FUDGE, Ohio 

JAMES P. MCGOVERN, Massachusetts 

SUZAN K. DELBENE, Washington 

FILEMON VELA, Texas 

MICHELLE LUJAN GRISHAM, New Mexico 

ANN M. KUSTER, New Hampshire 

RICHARD M. NOLAN, Minnesota 

CHERI BUSTOS, Illinois 

SEAN PATRICK MALONEY, New York 

ANN KIRKPATRICK, Arizona 

PETE AGUILAR, California 

STACEY E. PLASKETT, Virgin Islands 

ALMA S. ADAMS, North Carolina 

GWEN GRAHAM, Florida 

BRAD ASHFORD, Nebraska 

SCOTT C. GRAVES, Staff Director 

ROBERT L. LAREW, Minority Staff Director 

(II) 

(III) 

C O N T E N T S 

Page 

Conaway, Hon. K. Michael, a Representative in Congress from Texas, opening 

statement .............................................................................................................. 1 

Prepared statement .......................................................................................... 3 

Submitted article .............................................................................................. 77 

Davis, Hon. Rodney, a Representative in Congress from Illinois, opening 

statement .............................................................................................................. 5 

DelBene, Hon. Suzan K., a Representative in Congress from Washington, 

opening statement ................................................................................................ 5 

Kirkpatrick, Hon. Ann, a Representative in Congress from Arizona, submitted 

letter ...................................................................................................................... 79

McGovern, Hon. James P., a Representative in Congress from Massachusetts, 

submitted articles ................................................................................................. 71 

Peterson, Hon. Collin C., a Representative in Congress from Minnesota, opening statement ........................................................................................................ 4 

WITNESSES

Schmidt, David B., President and Chief Executive Officer, International Food 

Information Council and Foundation, Washington, D.C. ................................. 6 

Prepared statement .......................................................................................... 8 

Fedoroff, Ph.D., Nina V., Senior Science Advisor, Olsson Frank Weeda 

Terman Matz PC (OFW Law), Washington, D.C. ............................................. 17 

Prepared statement .......................................................................................... 19 

Supplementary material .................................................................................. 85 

Submitted questions ......................................................................................... 88 

Lidback, Joanna S., Owner, The Farm at Wheeler Mountain, Westmore, 

VT; on behalf of Agri-Mark; National Council of Farmer Cooperatives; 

National Milk Producers Federation .................................................................. 26 

Prepared statement .......................................................................................... 27 

Submitted question .......................................................................................... 91 

Clarkson, Lynn, President and Founder, Clarkson Grain Company, Inc., Cerro 

Gordo, IL ............................................................................................................... 31 

Prepared statement .......................................................................................... 33 

Submitted question .......................................................................................... 91 

Dempsey, Jr., Thomas W., President and Chief Executive Officer, Snack Food 

Association, Arlington, VA .................................................................................. 34 

Prepared statement .......................................................................................... 36 

Submitted question .......................................................................................... 92 

Policinski, Chris, President and Chief Executive Officer, Land O’ Lakes, Inc., 

Arden Hills, MN ................................................................................................... 39 

Prepared statement .......................................................................................... 41 

Submitted question .......................................................................................... 94 

SUBMITTED MATERIAL

McGinty, Scott, President, Aurora Organic Dairy, submitted letter ................... 87 

(1) 

EXAMINATION OF THE COSTS AND IMPACTS 

OF MANDATORY BIOTECHNOLOGY 

LABELING LAWS 

TUESDAY, MARCH 24, 2015 

HOUSE OF REPRESENTATIVES, 

COMMITTEE ON AGRICULTURE, 

Washington, D.C. 

The Committee met, pursuant to call, at 10 a.m., in Room 1300 

of the Longworth House Office Building, Hon. K. Michael Conaway 

[Chairman of the Committee] presiding. 

Members present: Representatives Conaway, Neugebauer, Lucas, 

Gibbs, Austin Scott of Georgia, Crawford, Gibson, Hartzler, 

Benishek, Denham, LaMalfa, Davis, Yoho, Allen, Bost, Rouzer, 

Abraham, Emmer, Moolenaar, Newhouse, Peterson, David Scott of 

Georgia, Costa, Walz, McGovern, DelBene, Vela, Kuster, Nolan, 

Bustos, Kirkpatrick, Aguilar, Plaskett, Adams, Graham, and 

Ashford. 

Staff present: Haley Graves, Jackie Barber, Jessica Carter, John 

Goldberg, Mary Nowak, Mollie Wilken, Patricia Straughn, Scott C. 

Graves, Ted Monoson, Faisal Siddiqui, John Konya, Keith Jones, 

Liz Friedlander, and Nicole Scott. 

OPENING STATEMENT OF HON. K. MICHAEL CONAWAY, A 

REPRESENTATIVE IN CONGRESS FROM TEXAS 

The CHAIRMAN. Good morning. I want to thank each of you for 

being here today to discuss agricultural biotechnology. 

Mankind has used biological technologies for more than 10,000 

years to improve crops and livestock, to make useful food products, 

such as bread and cheese, and to preserve dairy products. When 

applied to plant breeding, these technologies have led to the evolution of nearly every food product we consume. These and other 

advances have enabled us to enjoy the safest, highest-quality, most 

abundant and affordable supply of food and fiber. 

As our knowledge has increased, so has the speed and precision 

in which we are able to harness natural capabilities to improve the 

plants we cultivate. These new applications of biotechnology have 

been available to American and international consumers for nearly 

3 decades. The safety of the technology has been confirmed by the 

world’s leading scientific and public health organizations including 

the World Health Organization, the National Academies of Science, 

the American Association for the Advancement of Science, the 

American Medical Association, and the Royal Society of Great Britain. 

2 

Many scientists and farmers are optimistic and enthusiastic 

about the prospects of using scientific advances in biotechnology. 

The careful and precise addition of one or a few genes to a plant 

may make it more productive and nutritious, more tolerant to environmental stresses such as drought, and more resistant to disease 

and pests. These technologies can likewise improve the efficiency 

and therefore the productivity of agriculture, while at the same 

time reducing detrimental effects on the environment. 

This Committee has frequently reviewed these technologies. We 

have reviewed the regulatory mechanisms in place since the 

Reagan Administration and have been repeatedly assured by the 

absence of any valid concerns regarding the safety or quality of 

products derived from these production methodologies. Despite the 

facts that are universally on the side of this technology, we would 

have to search long and hard to find another issue matching the 

negative rhetoric and aggressive tactics of the detractors. In Washington and across the country, we are hearing a great deal of misinformation about so-called GMOs and the use of biotechnology in 

food and agricultural production. These unfounded attacks are not 

supported by the facts and mislead both consumers and policymakers. This misinformation would threaten our farmers’ ability to 

feed an ever-growing population and result in higher food costs for 

consumers. 

Biotechnology is an essential tool for farmers to have in the toolbox if we plan to feed an estimated ten billion people by the year 

2050 in an environmentally sound, sustainable, and affordable way. 

Unfortunately, threats exist to our ability to fully utilize this technology in the form of proposed Federal and state laws, as well as 

some state laws that will soon be implemented if we don’t act. 

A recent report by the Cornell Business School examined the consumer cost impact of a proposed mandatory label for biotechnology 

food products sold in the State of New York. According to the 

study, implementing a mandatory biotech labeling system in the 

state would mean new costs for consumers in the checkout aisle. 

The report finds that a family of four in New York could pay on 

average an additional $500 in annual food costs if mandatory labeling becomes the law. The state would also incur an estimated $1.6 

million in costs from the writing and enforcing of new regulations 

and litigating potential lawsuits related to mandatory labeling, 

which could run as high as $8 million and will also factor into the 

increased costs consumers see in their annual food bills. What this 

report does not reflect is the significant cost to food manufacturers 

associated with segregation and testing that would be passed back 

to producers, nor does it address liability costs borne by food processors and producers under the activist scheme. 

As of today 26 states have some form of biotech labeling legislation pending. These proposals are loaded with arbitrary and inconsistent policies which would create an unmanageable situation for 

food producers, processors, and distributors. Consumers would ultimately lose as a result both of higher food costs and the very real 

likelihood that the technological innovation that has filled our grocery stores with an abundance of high-quality products we enjoy 

would be stifled. As we examine the costs and impacts if states like 

Vermont move forward with mandatory labeling schemes, I think 

3 

we will agree that Congressional action to preserve interstate commerce through national uniformity is necessary. 

Although I will introduce our panel in its entirety after opening 

statements, I do want to take a moment to discuss one of our witnesses. Ms. Joanna Lidback is a dairy farmer from the State of 

Vermont and the author of a well-read blog on farming, food, and 

rural issues. This is actually Ms. Lidback’s second appearance before the Agriculture Committee to discuss biotechnology. I would be 

remiss if I didn’t acknowledge Joanna’s courage in returning since 

some of you may be aware that after her appearance last year, Joanna and her family were the subject of harassment, interfering 

with her young family’s peace. I consider the tactics of anti-biotech 

activists who harassed you reprehensible, and I want to stress that 

this shameful behavior is not acceptable and should not be tolerated. 

Joanna, thank you for being here today and for your dedication 

to this important issue. 

[The prepared statement of Mr. Conaway follows:] 

PREPARED STATEMENT OF HON. K. MICHAEL CONAWAY, A REPRESENTATIVE IN

CONGRESS FROM TEXAS

Good morning. I want to thank each of you for being here today to discuss agricultural biotechnology. 

Mankind has used biological technologies for more than 10,000 years to improve 

crops and livestock, and to make useful food products, such as bread and cheese, 

and to preserve dairy products. When applied to plant breeding, these technologies 

have led to the evolution of nearly every food product we consume. These and other 

advances have enabled us to enjoy the safest, highest quality, most abundant and 

affordable supply of food and fiber. 

As our knowledge has increased, so has the speed and precision in which we are 

able to harness natural capabilities to improve the plants we cultivate. 

These new applications of biotechnology have been available to American and 

international consumers for nearly 3 decades. The safety of the technology has been 

confirmed by the world’s leading scientific and public health organizations including 

the World Health Organization, the National Academies of Science, the American 

Association for the Advancement of Science, the American Medical Association, and 

the Royal Society of Great Britain. 

Many scientists and farmers are optimistic and enthusiastic about the prospects 

of using scientific advances in biotechnology. The careful and precise addition of one 

or a few genes to a plant may make it more productive and nutritious, more tolerant 

to environmental stresses such as drought, and more resistant to disease and pests. 

These technologies can likewise improve the efficiency and therefore the productivity of agriculture, while at the same time reducing detrimental effects on the environment. 

This Committee has frequently reviewed these technologies. We have reviewed 

the regulatory mechanism in place since the Reagan Administration and have been 

repeatedly assured by the absence of any valid concerns regarding the safety or 

quality of products derived from these production methodologies. 

Despite the facts that are universally on the side of this technology, we would 

have to search long and hard to find another issue matching the negative rhetoric 

and aggressive tactics of the detractors. 

In Washington and across the country, we are hearing a great deal of misinformation about so-called ‘‘GMOs’’ and the use of biotechnology in food and agricultural 

production. These unfounded attacks are not supported by the facts and mislead 

both consumers and policymakers. This misinformation could threaten our farmers’ 

ability to feed an ever-growing population and result in higher food costs for consumers. 

Biotechnology is an essential tool for farmers to have in the toolbox if we plan 

to feed an estimated ten billion people by the year 2050 in an environmentally 

sound, sustainable, and affordable way. Unfortunately, threats exist to our ability 

to fully utilize this technology in the form of proposed Federal and state laws, as 

well as some state laws that will soon be implemented if we don’t act. 

4 

A recent report by the Cornell Business School examined the consumer cost impact of a proposed mandatory label for biotech food products sold in the State of 

New York. According to the study, implementing a mandatory biotech labeling system in the state would mean new costs for consumers in the checkout aisle. The 

report finds that a family of four in New York State could pay, on average, an additional $500 in annual food costs if mandatory labeling becomes law. 

The state would also incur an estimated $1.6 million in costs from writing and 

enforcing new regulations and litigating potential lawsuits related to mandatory labeling, which could run as high as $8 million and will also factor into the increased costs consumers see in their annual food bills. What this report does not 

reflect is the significant cost to food manufacturers associated with segregation and 

testing that will be passed back to producers; nor does it address liability costs 

borne by food producers and processors under the activist scheme. 

As of today 26 states have some form of biotech labeling legislation pending. 

These proposals are loaded with arbitrary and inconsistent policies which would create an unmanageable situation for food producers, processors and distributors. Consumers would ultimately lose as a result both of higher food costs and the very real 

likelihood that the technological innovation that has filled our grocery stores with 

an abundance of high quality products we enjoy would be stifled. 

As we examine the costs and impacts if states like Vermont move forward with 

mandatory labeling schemes, I think we will all agree that Congressional action to 

preserve interstate commerce through national uniformity is necessary. 

Although I will introduce our panel in its entirety after opening statements, I do 

want to take a moment to discuss one of our witnesses . . . 

Ms. Joanna Lidback is a dairy farmer from the State of Vermont and the author 

of a well-read blog on farming, food and rural issues. This is actually Ms. Lidback’s 

second appearance before the Agriculture Committee to discuss biotechnology. I 

would be remiss if I didn’t acknowledge Joanna’s courage in returning since some 

of you may be aware that after her appearance last year, Joanna and her family 

were the subject harassment, interfering with her young family’s peace. 

I consider the tactics of the anti-biotech activists who harassed you reprehensible, 

and I want to stress that this shameful behavior is not acceptable and should not 

be tolerated. Joanna, thank you for being here today and for your dedication to this 

important issue. 

The CHAIRMAN. And with that, I recognize the Ranking Member 

for his statement. 

OPENING STATEMENT OF HON. COLLIN C. PETERSON, A 

REPRESENTATIVE IN CONGRESS FROM MINNESOTA 

Mr. PETERSON. Thank you, Mr. Chairman, and thanks for holding this hearing. This is an issue that I hope that we can find a 

way to address because if we don’t, we are going to have 50 states 

with 50 different labeling programs, and that is just not going to 

work. If we don’t do something to stop this, we could end up with 

something similar to what is going on right now in California with 

their egg standards. 

Consumers have expressed their interest in knowing more about 

where their food comes from, and that is a good thing. But when 

it comes to labeling, we need to be able to find a smart way to balance this consumer demand, what we know about the safety of the 

foods that our farmers produce. Done correctly, I think we can find 

a workable solution. 

The Energy and Commerce Committee has most of the jurisdiction here, so at this point our hands are a little bit tied. But I do 

think it is important for us to move forward and learn more about 

the impacts some of these state attempts at labeling genetically engineered food and food ingredients are going to have. 

So I look forward to hearing from our witnesses and thank you 

for holding the hearing. 

5 

The CHAIRMAN. I thank the Ranking Member. I appreciate that. 

I recognize Subcommittee Chairman Rodney Davis for his statement. 

OPENING STATEMENT OF HON. RODNEY DAVIS, A 

REPRESENTATIVE IN CONGRESS FROM ILLINOIS 

Mr. DAVIS. Thank you, Mr. Chairman, and thank you to all the 

witnesses that are here today. And Mr. Chairman, thank you for 

holding this hearing on the costs and impacts of the mandatory 

biotech labeling laws. And I would like to welcome one of my constituents who is on the panel, Mr. Lynn Clarkson. I am very glad 

you are here representing the small town of Cerro Gordo very, very 

well. 

Clarkson Grain, your company, turned 40 just last year, supplies 

grain to food manufacturing, animal feed industries. His products 

include corn, whole grains, and non-GMO grains and oilseeds. I appreciate your testimony about respecting all viewpoints and lowering the temperature in this very heated debate. 

I have two distinct memories from the Subcommittee hearing 

that I shared last year that Ms. Lidback was a part of. First of all, 

we discussed the needs of biotechnology, and it helps us feed a 

growing population, reduces negative impacts on our environment, 

and also helps combat plant and pest diseases. But the rhetoric, as 

Chairman Conaway said, became pretty charged after the hearing. 

I was disappointed by this rhetoric and misinformation and the 

personal attacks leveled not only at you but to those who were part 

of the hearing, including me. 

Thanks for coming back. I know you did receive some rude comments and some bullying on social media, and I really appreciate 

hearing your perspective as a dairy farmer, and as a father of three 

children myself, I appreciate hearing your perspective as a mother. 

Last, on the right-to-know argument, consumers can already find 

out information when they are at the grocery store. Food that is 

labeled as USDA certified organic does not contained genetically 

modified ingredients. I want to read something from The New York 

Times editorial just a couple of years ago. ‘‘Consumers can already 

find products free of GMO ingredients with labels voluntarily 

placed by the manufacturers. For those who want to avoid such ingredients, the surest way is to buy products certified as organic 

under Federal standards.’’ Now, this is The New York Times, not 

necessarily a hotbed of conservative rhetoric on their editorial 

board. 

So with that, Mr. Chairman, I yield back. 

The CHAIRMAN. The gentleman yields back. Thank you. I now 

recognize the Ranking Member on the Subcommittee, Ms. DelBene, 

for her statement. 

OPENING STATEMENT OF HON. SUZAN K. DELBENE, A 

REPRESENTATIVE IN CONGRESS FROM WASHINGTON 

Ms. DELBENE. Thank you, Mr. Chairman. I appreciate you holding this hearing, and I want to thank all of the witnesses for being 

here today. 

As the Ranking Member on the Subcommittee, this is an issue 

I hear about very often, not only here, but also in my district back 

6 

home in Washington State. In fact, Washington State was among 

the states which recently voted on a GMO labeling initiative, and 

one of the biggest takeaways for many of us from that initiative, 

as well as this debate generally, is that there needs to be more of 

a dialogue and more education done on all sides. 

I certainly agree that consumers have a right to know what they 

are eating, and I also believe that we need to be clear and take a 

science-based approach when we are discussing GMOs. Just as 

many of us implore folks to look at the science behind climate 

change, for example, we can’t pick and choose. We need to understand the science and its findings, including in this case. 

Genetically modified doesn’t mean just one thing or just one company, and as someone who started their career in biomedical research, I understand that this technology has the potential to provide benefits to consumers. However, we also need to ensure that 

we are having an open conversation about its impacts and its challenges. This is often an emotional argument, and it is my hope that 

moving forward we can have it be more of a fact-based open discussion on all sides. 

I am looking forward to the testimony of our panel today and am 

hopeful that we can move closer to a workable solution as a result 

for everyone. So thank you again, Mr. Chairman, for this hearing, 

and I yield back. 

The CHAIRMAN. I thank the gentlewoman. The chair would request that other Members submit their opening statements for the 

record so that witnesses may begin their testimony and to ensure 

there is ample time for questions. 

I would now like to welcome to our witness table the following 

witnesses: We have here Mr. David Schmidt, President and CEO 

of the International Food Information Council here in D.C. We 

have Dr. Nina Federoff, the Senior Science Advisor, OFW Law 

Firm here in D.C. We have Ms. Joanna Lidback, owner of The 

Farm at Wheeler Mountain, on behalf of Agri-Mark Dairy Cooperative, the National Council of Farmer Cooperatives, and the National Milk Producers Federation from Westmore, Vermont. We 

have Mr. Lynn Clarkson, President, Clarkson Grain Company at 

Cerro Gordo—is that close enough—Illinois. Mr. Thomas Dempsey, 

CEO, Snack Food Association in Arlington, Virginia, and Mr. Chris 

Policinski. I butchered that, Chris. Sorry about that. President and 

CEO, Land O’ Lakes in Arden Hills, Minnesota. 

Mr. Schmidt, begin when you are ready, please. 

STATEMENT OF DAVID B. SCHMIDT, PRESIDENT AND CHIEF 

EXECUTIVE OFFICER, INTERNATIONAL FOOD INFORMATION 

COUNCIL AND FOUNDATION, WASHINGTON, D.C. 

Mr. SCHMIDT. Thank you, Chairman Conway, distinguished 

Members. I am David Schmidt, President and CEO of the International Food Information Council and Foundation. We effectively 

communicate science-based information on food safety and nutrition issues to health professionals, journalists, educators, government officials and consumers. We are fortunate to receive support 

for our programs from leading food, beverage, and agricultural 

companies, but I must clarify that we don’t represent those industries. 

7 

Last year, IFIC conducted the 2014 Consumer Perceptions of 

Food Technology Survey. It was our 16th such survey since 1997. 

The survey polled 1,000 adults who are reflective of the U.S. population, according to the U.S. Census Bureau. Our survey begins 

with open-ended questions, which are more reliable when it comes 

to taking the real pulse of consumers than surveys with a small 

number of carefully worded questions designed to provoke concerns. 

When it comes to food labels, the results show that biotechnology, or even the phrase GMOs, is not a top-of-mind concern 

for the vast majority of consumers. Following the open-ended questions, we get more specific about biotechnology and genetic engineering, but please note that we do not use the term GMO for two 

major reasons. Number one, The U.S. FDA has provided labeling 

guidance to industry, reaffirmed as recently as April 2013, that the 

scientifically accurate terms are bioengineered, genetically engineered, or foods produced using biotechnology. Their analysis considers the term genetically modified organism, or GMO, as potentially misleading to consumers because it is a distinction without 

a difference. And as you said, Mr. Chairman, humans have been 

genetically modifying crops and animals for tens of thousands of 

years. 

Number two, our own consumer research since the early 1990s 

has found GMO, as a phrase, to be off-putting at best or even 

frightening to many consumers. And unfortunately in today’s marketplace, it is used as something to avoid and a pejorative, rather 

than a way to inform consumers. 

When we first asked if people were avoiding any particular foods 

or ingredients in their diet, only two percent of total respondents 

mentioned biotech food or even similar terms like GMOs. Then we 

asked them if they could think of any information that currently 

is not on food labels but should be. Three-quarters of them, 75 percent, said no. Just four percent said that labels should carry information about genetic engineering or related terms. Two-thirds of 

Americans said they were confident in the safety of the food supply. When we asked people about their specific food safety concerns, biotech or any related term was far down the list at seven 

percent. When we asked the respondents to offer their impressions 

of food biotechnology before mentioning any benefits, there was an 

almost-even split between 28 percent who were favorable and 29 

percent unfavorable with more than four in ten either neutral or 

didn’t know. 

The survey then asked about which sources of information on 

food biotechnology consumers trust most. Health organizations, 

cited by 50 percent of consumers ranked first, followed by Federal 

Government agencies and health professionals at 45 percent each. 

We then focused on attitudes toward particular benefits of food biotechnology. 

Referring back to my point on language above, it is not surprising that consumers may shy away when provoked to be concerned about ‘‘genetically modified organisms in your food.’’ But notice the difference in support when we use more informative language to explain some of the benefits of the technology. Seventytwo percent said they were likely to purchase products made with 

8 

oils modified by biotechnology to provide more healthful fats. Sixtynine percent were likely to buy such products if they were modified 

to reduce the potential for carcinogens, and 69 percent also said 

they would buy bread, crackers, cookies, cereals, or pasta made 

with flour modified to use less land, water, and/or pesticides. 

Next, we returned to labeling issues and tried to get at consumers’ attitudes another way, by asking whether people favored 

the current FDA policy regarding foods produced using biotechnology. We told them the policy requires special labeling only 

when biotechnology’s use substantially changes the food’s nutritional content or when a potential safety issue such as a food allergen is identified. Otherwise, special labeling is not required. Sixtythree percent of respondents supported the current FDA policy, 

while 19 percent opposed it. In fact, every survey we have conducted since 1997 has found a strong majority of Americans support this FDA labeling policy. 

When we looked more generally at the most favored uses of food 

biotechnology, reducing pesticide applications topped the list, followed by keeping food prices stable and helping feed undernourished people around the world. 

Mr. Chairman, in closing, let me emphasize that in our nearly 

2 decades of consumer research, we have learned that consumers 

are supportive of the many benefits of food and agricultural biotechnology when clearly articulated. The food label is not a playground for every bit of information someone might want to know. 

We rely on the FDA to ensure that the precious real estate available on a food label is reserved for important health, ingredient, 

and nutrition information, and it is clear that a strong majority of 

Americans have confidence in the FDA’s labeling policy for foods 

produced using biotechnology. Thank you for this opportunity to 

share consumers’ perspectives. 

[The prepared statement of Mr. Schmidt follows:] 

PREPARED STATEMENT OF DAVID B. SCHMIDT, PRESIDENT AND CHIEF EXECUTIVE

OFFICER, INTERNATIONAL FOOD INFORMATION COUNCIL AND FOUNDATION, 

WASHINGTON, D.C. 

Chairman Conaway, distinguished Members, my name is David Schmidt, and I’m 

President and CEO of the International Food Information Council, or IFIC. 

Our mission is to communicate science-based information on food safety and nutrition issues to health professionals, journalists, educators and government officials. We are fortunate to receive support for our programs from leading food, beverage and agricultural companies, but I must clarify that we don’t represent those 

industries. 

Thank you for inviting me to speak today regarding U.S. consumer attitudes toward food biotechnology and related aspects, such as labeling. 

Last year, IFIC conducted the 2014 Consumer Perceptions of Food Technology 

Survey (http://www.foodinsight.org/2014-foodtechsurvey). It was our 16th such survey since 1997, and it has offered trended U.S. consumer insights on plant and animal biotechnology and labeling longer than any publicly available data. 

Survey Methodology 

Let me begin with the methodology, which can be found in the slides that are included after my written remarks. The public can access the full text of the survey’s 

questions and answers, along with many other educational resources, at 

foodinsight.org/biotech. 

The 2014 IFIC Food Technology Survey polled 1,000 adults who are reflective of 

the U.S. population, according to the U.S. Census Bureau, and had just a three percent margin of error. 

9 

Our survey begins with open-ended questions, which are more reliable when it 

comes to taking the real pulse of consumers than surveys with a small number of 

carefully worded questions designed to provoke concerns. 

We believe this technique yields a more accurate view of what is most important 

to Americans. Throughout 18 years of conducting this research, we have not seen 

consumer perceptions about food biotechnology change dramatically. When it comes 

to food labels, the results show that biotechnology, or even ‘‘GMOs,’’ is not a topof-mind concern for the vast majority of consumers. 

Following the open-ended questions, we get more specific about biotechnology and 

genetic engineering, but please note that we do not use the term ‘‘GMO’’ for two 

major reasons: 

(1) The U.S. Food and Drug Administration (FDA) has provided labeling guidance to industry, reaffirmed as recently as April 2013, that the scientifically 

accurate terms are ‘‘bioengineered,’’ ‘‘genetically engineered,’’ or ‘‘foods produced using biotechnology.’’ Their analysis considers the term ‘‘genetically 

modified organism’’ or ‘‘GMO’’ as potentially misleading to consumers, because it is a distinction without a difference. Humans have been genetically 

modifying crops and animals for tens of thousands of years, but through far 

less precise or efficient methods than we enjoy today. 

(2) Our own consumer research since the early 1990s has found ‘‘GMO’’ to be offputting at best or even frightening to many consumers. And unfortunately in 

today’s marketplace, it is used as something to avoid and a pejorative, rather 

than a way to inform consumers. 

And now to the survey itself, and I would note that this is the precise order in 

which the questions were posed. 

Foods Avoided and Food Label Information 

We first asked if people were avoiding any particular foods or ingredients in their 

diet. Only 2 percent of total respondents mentioned biotech food—or even similar 

terms like the aforementioned ‘‘GMOs.’’ 

Then we asked them if they could think of any information that currently isn’t 

on food labels but should be. Three-quarters said ‘‘no.’’ Out of the total sample, just 

four percent said that labels should carry information about genetic engineering or 

related terms. This is a number that has barely budged over the history of our survey. 

Food Safety 

Next was the topic of food safety. Two-thirds of Americans said they were confident in the safety of the food supply. This number has remained consistently high 

since 2008, which might come as a surprise to some, given the tone and tenor of 

the rhetoric that surrounds us. Only 13 percent said they’re not confident, while 20 

percent were neutral. 

When we asked people about their specific food safety concerns, ‘‘biotech’’ or any 

related term was far down the list at seven percent. Remember, these questions are 

designed to reveal top-of-mind insights, not to guide people to a desired outcome. 

That number, while small, has indeed risen a few percentage points since 2008, 

which is undoubtedly a reflection of the heated communications environment. 

Conversely, the food safety threats that most concern consumers, both today and 

in past surveys, revolve around diseases and contamination, along with food handling and preparation—both of which were mentioned by 18 percent of respondents. 

That was followed by 12 percent who cited preservatives and chemicals, and ten 

percent who mentioned agriculture production issues. 

General Impressions of Food Biotechnology 

When we asked the respondents to offer their impressions of food biotechnology 

(before mentioning any benefits), there was an almost even split between 28 percent 

who were favorable to the technology and 29 percent who were unfavorable. More 

than four in ten were either neutral or didn’t know enough to offer a response. 

Consumer Trust 

As with much of our other consumer research, the 2014 IFIC Food Technology 

Survey then asked about which sources of information on food biotechnology consumers trust most. 

Health organizations, cited by 50 percent of respondents ranked first, followed by 

Federal Government agencies and health professionals, at 45 percent each. 

Farmers rated highly for 39 percent of respondents, while scientists were among 

the most trusted sources of 33 percent. 

10 

At the other end of the spectrum, journalists, bloggers, and celebrities were trusted by consumers only in the single digits. 

Benefits of Food Biotechnology 

At this point, we focused on attitudes toward particular benefits of food biotechnology. When consumers became aware that some products on the market or 

in the pipeline offered nutrition and health-related benefits, they were overwhelmingly positive. 

Referring back to my point on language above, it is not surprising that consumers 

may shy away when provoked to be concerned about ‘‘genetically modified organisms 

in your food.’’ But notice the difference in support when we use more informative 

language to explain some of the benefits of the technology: 

• 72 percent said they were likely to purchase products made with oils modified 

by biotechnology to provide more healthful fats. 

• 69 percent were likely to buy such products if they were modified to reduce the 

potential for carcinogens—the same number who would buy products if they 

were modified to be protected from insect damage and to require fewer pesticide 

applications. 

• 69 percent also said they would buy bread, crackers, cookies, cereals, or pasta 

made with flour modified to use less land, water, and/or pesticides. 

The list goes on, with positive perceptions of foods modified to provide enhanced 

nutritional benefits, eliminate trans fat content, improve vitamin content, or taste 

better or fresher. 

Current FDA Labeling Policy 

Next, we returned to labeling issues and tried to get at consumers’ attitudes another way, by asking whether people favored the current FDA policy regarding foods 

produced using biotechnology. We told them the policy requires special labeling 

‘‘only when biotechnology’s use substantially changes the food’s nutritional content, 

or when a potential safety issue such as a food allergen is identified. Otherwise, special labeling is not required.’’ 

Sixty-three percent of respondents supported the current FDA policy, while 19 

percent opposed it. The number of those who are opposed to the policy has risen 

a few points in recent years, while support has remained mostly steady. In fact, 

every survey we have conducted since 1997 has found a strong majority of Americans support this FDA labeling policy. 

Consumers’ Favored Uses 

When we looked more generally at the most favored uses of food biotechnology, 

reducing pesticide applications topped the list, followed by keeping food prices stable, and helping feed undernourished people around the world. 

Close behind those favored uses were food crops that can survive in extreme climates, and the reduced use of nonrenewable resources in food production. 

Conclusion 

Mr. Chairman, in closing, let me emphasize that in our nearly 2 decades of consumer research, we’ve learned that consumers are supportive of the many benefits 

of food and agricultural biotechnology when clearly articulated. 

The food label is not a playground for every bit of information someone might 

want to know. We rely on the FDA to ensure that the precious real estate available 

on a food label is reserved for important health, ingredient, and nutrition information, and it is clear that a strong majority of Americans have confidence in the 

FDA’s labeling policy for foods produced using biotechnology. 

The International Food Information Council would be pleased to offer you or your 

staff any additional resources in support of my testimony, as well as the work we 

do on food biotechnology and other issues. Thank you once again for this opportunity. 

11 

SLIDES


11407001.eps 11407002.eps
12 


11407003.eps 11407004.eps
13 


11407005.eps 11407006.eps
14 


11407007.eps 11407008.eps
15 


11407009.eps 11407010.eps
16 


11407011.eps 11407012.eps
17 

The CHAIRMAN. Thank you, Mr. Schmidt. Dr. Federoff? 

STATEMENT OF NINA V. FEDOROFF, PH.D., SENIOR SCIENCE 

ADVISOR, OLSSON FRANK WEEDA TERMAN MATZ PC (OFW 

LAW), WASHINGTON, D.C. 

Dr. FEDOROFF. Chairman Conway, Representative Peterson, 

Members of the Committee, thank you for the opportunity to testify 

before you today. I am Nina Federoff. I am a Professor of Plant Molecular Biology and Genetics. I have had 35 years of experience 

with GM techniques. I am a member of the U.S. National Academy 

of Sciences and a National Medal of Science Laureate. I served as 

Science and Technology Adviser to Secretaries of State Condoleeza 

Rice and Hillary Clinton. I authored a book titled Mendel in the 

Kitchen: A Scientist’s View of Genetically Modified Foods. 

I am here to tell you why mandatory labeling of foods containing 

GM ingredients will not help Americans make healthful food 

choices. More than that, I will tell you why such labels could well 

undermine humanity’s efforts to achieve food security. 

Now a recent poll, Pew poll, of scientists and the public gave 

startling results: Only 37 percent of the public believes GMOs are 

safe as compared with almost 90 percent of scientists. 

So why are scientists convinced? GM crops have been in commercial production for almost 20 years. They have an impeccable safety 

record and multiple environmental benefits. They have boosted 

farmers’ incomes and reduced consumer prices. These are the facts, 

and they have been documented in independent studies referenced 

in my written testimony. 


11407013.eps
18 

Scientific academies around the world concur that modern methods of genetic modification are as safe as those used by previous 

generations of plant and animal breeders. 

Now, until the development of modern GM techniques, breeders 

had to depend on either rare natural or more recently induced 

mutations—that is just another term for genetic modifications—to 

develop better crops. Today we know enough about genes to introduce a desired trait into an already highly productive plant or animal without the undesirable downsides of older methods. 

Now it is worth pointing out as the Chairman did that the history of plant and animal genetic modification extends back more 

than 10,000 years. We created corn, not Mother Nature. We created big, luscious heirloom tomatoes. Mother Nature’s are tiny and 

can be deadly. 

Now the FDA just approved Simplot’s GM potato that won’t turn 

brown after you cut it, and more importantly, it contains less of a 

natural amino acid that turns into the toxic compound acrylamide 

when the potatoes are French fried in hot oil. These potatoes will 

be more healthful and less wasteful. But today, more than 60 percent of Americans believe that GMOs are unsafe and probably 

wouldn’t choose to buy them. 

Now why is that? The reasons lie in the increasingly strident efforts of determined anti-GMO activists to convince the public that 

GMOs are bad. Some of these folks are—most prominent among 

these are the NGOs, such as Greenpeace, and marketers of organic 

foods. A recent, meticulously researched organic marketing report 

documents how organic marketers have progressively demonized 

GMOs while advancing organically grown foods as more healthful 

than conventionally grown food. 

Now some of these folks and many other kinds of anti-GMO activists have openly stated that labeling will help them drive GMOs 

out of the market. Now, the facts are these: Organic produce is no 

more nutritious than conventionally grown produce. It is more expensive because organic farming is land-inefficient and labor-intensive. The organic industry’s false and misleading marketing is a 

primary reason why consumers believe GMOs are bad and organic 

food is good. Attaching a GM label provides no consumer benefit 

since GM foods are as safe and nutritious as their non-GM counterparts. But attaching a label will send the false message that there 

is something to worry about because the FDA’s labels are there to 

alert consumers to food ingredients with health implications. 

Now my final point is that there are serious humanitarian implications should the current GMO vilification efforts succeed in driving GM technology out of agriculture. Global agricultural productivity increases are even now lagging behind population growth, 

and that is without figuring in the increasingly negative impacts 

of climate warming. 

Now the future lies in agricultural intensification. We will need 

to produce more crop per drop of water and square meter of land. 

Genetic modification of plants, in which the United States currently leads, will be the key to feeding the nine or ten billion people we expect for dinner in just a few decades. We cannot afford 

to discard the best methods we have ever invented to continue 

growing the food supply and doing it more sustainably. 

19 

Thank you very much. 

[The prepared statement of Dr. Federoff follows:] 

PREPARED STATEMENT OF NINA V. FEDOROFF, PH.D., SENIOR SCIENCE ADVISOR, 

OLSSON FRANK WEEDA TERMAN MATZ PC (OFW LAW), WASHINGTON, D.C. 

Chairman Conway, Representative Peterson, Members of the Committee, thank 

you very much for the opportunity to testify before you today. My name in Nina 

Fedoroff and I am a professor of plant molecular biology and genetics. My laboratory 

pioneered in the adaptation of genetic modification of GM techniques to plants more 

than 35 years ago. I am a member of the U.S. National Academy of Sciences and 

a National Medal of Science laureate. I served as the Science and Technology Adviser to Secretaries of State Condoleeza Rice and Hillary Clinton. I co-authored a 

book titled Mendel in the Kitchen: A Scientist’s View of Genetically Modified Foods.1

I am here to tell you why mandatory labeling of foods containing GM ingredients 

is counterproductive to Americans’ ability to make healthful food choices. More than 

that, I will tell you why such labels could well undermine humanity’s efforts to 

achieve food security. 

A recent poll of scientists and the public on GMOs gave startling results: only 

37% of the public believes GMOs are safe, compared with almost 90% of scientists.2

So what’s the evidence? GM crops have been in commercial production for almost 

20 years.3 They have an impeccable safety record and multiple environmental benefits.4 Despite anecdotal reports, often never published or subsequently retracted, no 

allergies, illnesses or deaths have been reproducibly linked to the consumption of 

GM food or feed.5, 6, 7

GM crops have boosted yields and farmers’ incomes.4, 8 The figure [below] illustrates these impacts graphically (from the cited Klu ̃mper and Qaim reference). Environmental impacts for the period 1996–2012 include the application of 503,000 tons 

less pesticide (active ingredient), greenhouse gas reductions of 16 million tons CO2

and increased soil carbon sequestration from no till farming estimated at more than 

200 million tons CO2.4

Consumers have benefited not only through continuing low food prices, but also 

directly from decreased mycotoxin contamination of corn.9 GM Bt corn contains a 

bacterial gene that encodes a protein that is toxic to certain boring insect pests, but 

not to animals or people. Such insects bore holes in developing corn plants, allowing 

fungi to enter and grow, as illustrated [below]. The fungi, in turn, produce mycotoxins, which are compounds that are toxic and can be carcinogens for people and 

farm animals. Bt corn is protected from insect attack, so no insect holes, no fungi, 

no mycotoxins. 


11407014.eps
20 

Scientific academies and scientific societies around the world concur that modern 

methods of genetic modification are as safe as those used by previous generations 

of plant and animal breeders, arguably safer.6 Appendix I shows quotations from the 

GM statements of scientific organizations. Decades of research on GMO biosafety 

have simply failed to identify hazards unique to the use of GM technology for crop 

improvement. Quoting from a recent EU report on GMO research: 10

‘‘The main conclusion to be drawn from the efforts of more than 130 research 

projects, covering a period of more than 25 years of research, and involving 

more than 500 independent research groups, is that biotechnology, and in particular GMOs, are not per se more risky than e.g., conventional plant breeding 

technologies.’’ 

Until the development of modern GM techniques, breeders had to depend on either rare natural—or more recently—induced mutations (another name for genetic 

modifications)—to develop better crops. Today we know enough about genes to introduce a desired trait into an already highly productive plant or animal without the 

undesirable downsides of older methods.11

It’s worth pointing out that the history of plant and animal genetic modification 

extends back some 10,000 years. We created corn, not Mother Nature; 12 we created 

big, luscious heirloom tomatoes—Mother Nature’s are tiny and can be deadly.13


11407015.eps
21 

The FDA just approved Simplot’s Innate potato that won’t turn brown after it’s 

peeled and—more importantly—contains less asparagine, a natural amino acid that 

turns into the toxic compound acrylamide when the potatoes are French fried in hot 

oil. These genetically modified potatoes will be more healthful and less wasteful. 

But today, more than 60% of Americans believe that GMOs are unsafe—and probably wouldn’t choose to buy them. 

Why? The reasons lie in the increasingly strident efforts of determined anti-GMO 

activists to convince the public that GMOs are bad. Most prominent among these 


11407016.eps 11407017.eps
22 

are NGOs, such as Greenpeace, and the organic food industry. A recent, meticulously researched ‘‘Organic Marketing Report’’ documents how the organic food industry has progressively demonized GMOs, while advancing organically grown food 

as more healthful than conventionally grown food.14

The facts are these. Organic produce is no more nutritious than conventionally 

grown produce.15 Quoting the conclusion of the cited 2009 analysis of more than 

50,000 publications spanning a 50 year period: 

‘‘On the basis of a systematic review of studies of satisfactory quality, there 

is no evidence of a difference in nutrient quality between organically and conventionally produced food-stuffs. The small differences in nutrient content detected are biologically plausible and mostly relate to differences in production 

methods.’’ 

Organic produce is more expensive because organic farming is land-inefficient and 

labor-intensive. Organic marketers—and many other kinds of anti-GMO activists— 

have openly stated that GMO labeling will help them drive GMOs out of the market. Appendix II shows representative quotations from both anti-GMO activists and 

organic food proponents. The anti-GMO activities of vocal NGOs, particularly 

Greenpeace, and the organic industry’s false and misleading marketing are the primary reasons that consumers believe GMOs are bad and organic food is good. 

It is often claimed that consumers have a ‘‘right to know’’ what they are eating. 

However, adding a ‘‘GM’’ label to food containing an ingredient from a GMO will 

not help the consumer make meaningful distinctions about either the food’s safety 

or its health benefits. The GM foods on the market today are as safe as and nutritionally equivalent to their non-GM counterparts. So the fact that they are GM is 

irrelevant information to the consumer. Research on consumer-decision making reveals paradoxically that more information, particularly irrelevant information, actually decreases the accuracy of a consumer’s choice, even though it increases the consumer’s confidence in the choice.16, 17

Labeling would drive up the cost of food 18 while sending the false message that 

there’s something to worry about, because current FDA policy requires that labels 

contain information on food ingredients that have health (or environmental) implications (http://www.fda.gov/Food/GuidanceRegulation/GuidanceDocuments 

RegulatoryInformation/Biotechnology/ucm096095.htm). 

My final point is that there are serious humanitarian implications should the 

GMO vilification efforts succeed in driving GM technology out of agriculture. Global 

agricultural productivity increases are even now lagging behind population 

growth 19—and that’s without figuring in the growing impact of climate warming.20

The future lies in ‘‘agricultural intensification’’.21 We will need to produce more 

crop per drop of water and square meter of land. The next big breakthrough will 

be in the efficiency of photosynthesis, the almost magical process by which crops 

turn thin air and water into food powered by sunlight.22 Genetic modification of 

plants, in which the U.S. currently leads, will be the key to feeding the nine or ten 

billion people we expect for dinner in coming decades. Neither Americans nor the 

rest of the world can afford to lose the best methods we’ve ever invented to keep 

growing the food supply sustainably. 

Endnotes 1 Nina V. Fedoroff and Nancy Marie Brown, Mendel in the Kitchen: A Scientist’s 

View of Genetically Modified Food. (Joseph Henry Press, 2004). 2Pew Research Center, Public and scientists’ views on science and society, (http:// 

www.pewinternet.org/2015/01/29/public-and-scientists-views-on-science-and-society/), 2015. 3 C. James, Global status of commercialized biotech/GM crops: 2014, (http:// 

www.isaaa.org/resources/publications/briefs/49/executivesummary/default.asp), 

2015. 4G. Brookes and P. Barfoot, GM crops: global socio-economic and environmental 

impacts 1996–2012, (www.pgeconomics.co.uk/pdf/2014globalimpactstudyfinal 

report.pdf), 2014. 5 H.A. Kuiper, G.A. Kleter, H.P.J.M. Noteborn, and W.J. Kok, Assessment of the 

food safety issues related to genetically modified foods, THE PLANT J. 27 (6), 503– 

28 (2001). 6 A.E. Richroch, Assessment of GE food safety using ‘-omics’ techniques and longterm animal feeding studies, NEW BIOTECHNOL. 30, 351–54 (2013). 7 A.L. Van Eenennaam and A.E. Young, Prevalence and impacts of genetically engineered feedstuffs on livestock populations, J. ANIMAL. SCI. 92 (10), 4255–78 (2014). 8Wilhelm Klu ̈mper and Matin Qaim, A meta-analysis of the impacts of genetically 

modified crops, PLOS ONE 9 (11), e111629 (2014). 

23 

9 Erin Bowers, Richard Hellmich, and Gary Munkvold, Vip3Aa and Cry1Ab proteins in maize reduce Fusarium ear rot and fumonisins by deterring kernel injury 

from multiple Lepidopteran pests, WORLD MYCOTOXIN JOURNAL 6 (2), 127–35 

(2013). 10 European Commission, A decade of EU-funded GMO research, 2010. 11Peggy G. Lemaux, Genetically engineered plants and foods: a scientist’s analysis 

of the issues (Part I), ANNU. REV. PLANT BIOL. 59 (1), 771 (2008). 12 Nina V. Fedoroff, Prehistoric GM corn, SCIENCE 302 (5648), 1158–9 (2003). 13 Ve ́ronique Bergougnoux, The history of tomato: From domestication to 

biopharming, BIOTECHNOLOGY ADVANCES 32 (1), 170–89 (2014). 14 Joanna Schroeder, Organic Marketing Report, (http://academicsreview.org/ 

wpcontent/uploads/2014/04/Academics-Review_Organic-Marketing-Report1.pdf), 

2014. 15 Alan D. Dangour, Sakhi K. Dodhia, Arabella Hayter, Elizabeth Allen, Karen 

Lock, and Ricardo Uauy, Nutritional quality of organic foods: a systematic review, 

AMERICAN J. CLINICAL NUTRITION 90 (3), 680–5 (2009). 16 Anthony Bastardi and Eldar Shafir, On the pursuit and misuse of useless information, JOURNAL OF PERSONALITY AND SOCIAL PSYCHOLOGY 75 (1), 19 (1998). 17 Crystal C. Hall, Lynn Ariss, and Alexander Todorov, The illusion of knowledge: 

When more information reduces accuracy and increases confidence, ORGANIZATIONAL

BEHAVIOR AND HUMAN DECISION PROCESSES 103 (2), 277–90 (2007). 18 A. Van Eenennaam, B.M. Chassy, N. Kalaitzandonakes, and T.P. Reddick, The 

potential impacts of mandatory labeling for genetically engineered food in the United 

States, CAST report (http://www.castscience.org/file.cfm/media/products/ 

digitalproducts/CAST_Issue_Paper_54_web_optimized_29B2AB16AD687.pdf), 2014. 19Deepak K. Ray, Nathaniel D. Mueller, Paul C. West, and Jonathan A. Foley, 

Yield trends are insufficient to double global crop production by 2050, PLOS ONE 8 

(6), e66428 (2013). 20 A.J. Challinor, J. Watson, D.B. Lobell, S.M. Howden, D.R. Smith, and N. 

Chhetri, A metaanalysis of crop yield under climate change and adaptation, NATURE

CLIMATE CHANGE 4 (4), 287–91 (2014). 21David Tilman, Christian Balzer, Jason Hill, and Belinda L. Befort, Global food 

demand and the sustainable intensification of agriculture, PROC. NATL. ACAD. SCI. 

USA 108 (50), 20260–4 (2011). 22 Veronica G. Maurino and Andreas P.M. Weber, Engineering photosynthesis in 

plants and synthetic microorganisms, JOURNAL OF EXPERIMENTAL BOTANY 64 (3), 

743–51 (2013). 

24 

APPENDIX I: SAFETY OF GM TECHNIQUES AND GM FOODS

‘‘The scientific consensus around the safety of genetically modified foods 

is as strong as the scientific consensus around climate change. These foods 

are subjected to more testing than any other and everything tells us that 

they’re safe.’’ 

http://www.axismundionline.com/blog/the-new-is-gm-food-safe-meme/. 


11407018.eps
25 

APPENDIX II: ANTI-GMO ACTIVISTS AND PROPONENTS OF ORGANIC FOOD ON

LABELING


11407019.eps
26 

The CHAIRMAN. Thank you, Dr. Federoff. Ms. Lidback, thanks 

again for coming, and let me reiterate my earlier comments. It is 

reprehensible. We can have differences of opinion, but to attack 

people—— 

VOICE. Yes, our own facts. 

The CHAIRMAN. Yes, ma’am. And even whether or not based on 

facts, you can still—but to resort to name-calling and threatening 

and other less genteel kinds of ways is reprehensible. So thank you 

for saddling up for a second round. You are recognized for 5 minutes. 

STATEMENT OF JOANNA S. LIDBACK, OWNER, THE FARM AT 

WHEELER MOUNTAIN, WESTMORE, VT; ON BEHALF OF AGRIMARK; NATIONAL COUNCIL OF FARMER COOPERATIVES; 

NATIONAL MILK PRODUCERS FEDERATION 

Ms. LIDBACK. Thank you. Chairman Conaway, Ranking Member 

Peterson, and other Members of the Committee. Thank you for inviting me here today. I am here on behalf of Agri-Mark Dairy Cooperative, the National Council of Farmer Co-ops, and the National 

Milk Producers Federation. 

My husband and I have a small 50 cow dairy located in northeast 

Vermont. We also make extra hay to sell. We raise Jersey steers 

to process and sell beef locally, and we market a small amount of 

composted manure. We have two young boys, ages 3 and 2. 

My husband and I are both proud to be first-generation dairy 

farmers. We believe in the science and capability of biotechnology 

and its role in protecting the sustainability of our farm. Biotech 

crops are essential to treating our cows and calves. We feed both 

GMO corn and soy products year round along with pasturing, a 

grass-based silage, and hay. 

I believe that biotech varieties improve efficiency and productivity of farming. In my written testimony, I mentioned that I could 

not find a non-GMO option available to me, but I have since found 

it. The non-GMO feed would cost $589 per ton. The same conventional feed we currently feed is $333 per ton. On our small farm, 

we purchase about 16 tons of grain per month, and if you do the 

math, that is a difference of about $4,100 a month or $49,000 a 

year. If there are any dairy economists here, this is the equivalent 

of $1,000 per cow on our farm. I don’t see how we could profitably 

farm with those increased feed costs. 

As a small farm just starting out, we are constantly exploring 

new opportunities to grow our business. One of the things we have 

been looking at recently is growing our own corn and alfalfa. In our 

short growing season, genetically engineered seeds offer the best 

options for us. Incidentally, over 97 percent of the corn grown for 

silage in Vermont is biotech crop. 

I personally believe that there is room for many different styles 

of farming. I also believe that biotechnology will play a major role 

in our ability to feed a growing world and to make improvements 

on our own individual farms. Certainly, as a dairy farmer, increasing feed costs would have a devastating impact on my business. 

But beyond our farm gate, we know that the impact would be just 

as brutal. In my area of rural northeast Vermont, 80 percent of the 

children in elementary school receive free reduced-price school 

27 

lunches. It is their families who would suffer the most from price 

increased caused by mandatory biotech labeling. 

As a mother and a consumer, I do not to purchase organic or 

non-GMO food in the store since I would be paying more with no 

added nutritional, health, or environmental benefits. I firmly believe the food I feed my two growing boys is safe. 

You must be aware that recently my State of Vermont passed a 

mandatory GMO labeling law. In New England, it is very easy to 

cross borders for various reasons, such as grocery shopping. If the 

Vermont labeling law is activated, there will likely be one label on 

food in Vermont and another on the exact same food in New Hampshire, raising questions about whether or not the product is actually the same. 

Furthermore, the Vermont law exempts meat and dairy from 

being labeled. Other states may not exempt those products as they 

consider their own GMO labeling bills. Doing so will affect my ability to market my USDA certified Jersey beef across state lines. 

This serves no one’s interests, not consumers, not farmers, not food 

producers. 

I am happy to speak up for our right to farm in whatever way 

we choose, which in our case, includes biotechnology and the use 

of GMOs. It is important to continue the conversation about the opportunities and challenges we face as modern-day farmers and parents. When I have one person or ten people reach out to me for a 

question or appreciating my practical perspective from the farm, 

then I have succeeded. 

Sometimes this isn’t an easy task. As the Chairman mentioned, 

I testified at a Subcommittee hearing on this very topic last summer and received some very rude comments from total strangers on 

social media and phone calls from them in the middle of the night. 

It was not always the most pleasant experience, but being a 

dairy farmer, I am used to having to do unpleasant jobs from time 

to time. Even with those negative encounters, or maybe because of 

them, I was eager to come back and share my experiences today. 

I am proud of how far the American farmer has come, just as I am 

proud of how far we have come on our own farm. If my sons choose 

to continue in farming, I want to know that my husband and I 

have provided them with a firm foundation to build on. 

Thanks again for the opportunity to be here with you today. 

[The prepared statement of Ms. Lidback follows:] 

PREPARED STATEMENT OF JOANNA S. LIDBACK, OWNER, THE FARM AT WHEELER

MOUNTAIN, WESTMORE, VT; ON BEHALF OF AGRI-MARK; NATIONAL COUNCIL OF

FARMER COOPERATIVES; NATIONAL MILK PRODUCERS FEDERATION

Chairman Conaway, Ranking Member Peterson, and other Members of the Committee, thank you for inviting me here today to talk about the costs and impacts 

of mandatory biotech labeling laws. Today I am here on behalf of Agri-Mark Dairy 

Cooperative, the National Council of Farmer Cooperatives and the National Milk 

Producers Federation. 

My husband and I have a small 50 cow dairy located in northeast Vermont. We 

also grow extra hay to sell, raise Jersey steers to process and sell beef locally, and 

market a small amount of composted manure. We rent the farm started by my husband’s grandfather, from his aunt and uncle, and it consists of over 200 acres of tillable land, including roughly 50 acres of pasture where we graze our herd in temperate months. We also raise all of our own young stock or replacement heifers. We 

have two young boys, ages 3 and 2. 

28 

Along with being an active partner on the farm, I have a full-time job with a 

Farm Credit Association as a business consultant, serve as First Vice President of 

our county Farm Bureau and as a dairy cattle judge for various youth and 4–H 

dairy shows across New England. I did not grow up on a farm but got involved in 

agriculture through a 4–H dairy project as a young girl in 1989. Since then, I have 

not let go of my Jersey cows. I boarded my animals on neighboring farms and as 

fate would have it met a dairy farmer who I would eventually settle down with, 

bringing my Jerseys along. I have a bachelor’s degree from Cornell University where 

I focused on agribusiness management and a master’s in business administration 

from the F.W. Olin School of Business at Babson College. 

My husband and I are both proud to be first-generation dairy farmers. Starting 

out on our own in building our farm has required a lot of hard work and at times 

has been tremendously challenging. Being able to raise our young sons in a farming 

lifestyle, and living out our dreams of caring for his family’s land and our animals 

while producing food for our neighbors and community, though, has been hugely rewarding. 

As we have started out, our overall focus is building a farm that is sustainable— 

one that is not just productive and profitable today but one that we can pass on 

to our sons 25 years down the road. They are a daily reminder of the importance 

of sustainability. That is why we have diversified and started our direct farm sales; 

and that also is why we fully embrace using technology to farm better and with less 

impact on our surroundings. 

Farming with a backdrop of rolling green pastures edged with woods and wedged 

between a mountain and a lake in a small New England town sometimes comes 

with preconceived notions. Often it seems people think that our farm is like something out of a Norman Rockwell painting. And indeed, passers-by have mistaken us 

for an organic dairy farm. Yet, we are a conventional operation and we believe that 

using tools such as biotech crops helps us to farm sustainably. 

Biotechnology crops are essential to feeding our cows and calves. When we can, 

we pasture feed our livestock. But as the past 2 months have shown, harsh New 

England weather can make this impossible in winter and early spring. So during 

those months, we feed cows and calves grass that we have processed into hay or 

grass silage. Additionally, throughout the year we rely on both corn and soy based 

feeds to complete a total mixed ration that makes the best use of our grass by balancing the needs of our cattle with the nutrients our forages provide and filling in 

what is missing. 

This gives us a unique perspective on the importance of biotechnology. I believe 

that biotech varieties improve efficiency and productivity of farming. I also believe 

that biotechnology enables us to lessen the environmental impact that growing can 

have because less fertilizer and pesticides are used to grow an abundant crop. 

The use of biotechnology on our farm is also important to the economic sustainability of our small business. In speaking with our dairy nutritionist, he pointed out 

that the only non-GMO feed he could get us right now was organic. There simply 

is no non-GMO grain available to us, or the freight cost would be so prohibitive it’s 

not a real option. Thus, an organic basic 20 percent protein complete feed would cost 

$750 per ton; the same conventional feed is currently $333 per ton. On our small 

farm, we purchase about 16 tons of grain per month. So, using 16 tons, that would 

more than double our grain bill, or in hard numbers we would spend $5,328 per 

month for regular feed or $12,000 per month on organic feed—a difference of $6,672 

a month or $80,064 per year. I do not see how we could profitably farm in the long 

term with those increased feed costs. It is important to note that we choose to not 

be organic for several reasons and thus would not receive an organic premium for 

our milk even if we used the organic grain mix simply to feed a non-GMO feed. 

As a small farm just starting out, we are constantly exploring new opportunities 

to grow our business. One of the things we have been looking at recently is growing 

our own corn and alfalfa. Given our location, we will need shorter-day corn varieties, 

meaning it would grow in less time than average. Here again, we would want the 

choice of the best seed regardless of breeding technology; genetic engineering offers 

the best options. Economically it makes the best sense. Incidentally, over 97 percent 

of the corn grown for silage in Vermont is biotech crop. 

We face a challenge brought on by what many in agriculture see as the spread 

of misinformation about modern agricultural practices, creating the potential for 

limiting our ability to use biotechnology in order to best utilize the resources we 

have in sustainable ways. In many cases, this has already happened as we saw with 

the controversy over the use of recombinant Bovine Somatotropin (rBST), a technology that has no adverse effects on human health but was rejected by some consumers for no sound scientific reason. While many said that rBST was an example 

of the evils of ‘‘big agriculture,’’ the truth is that many small dairy farms used rBST 

29 

as a way to improve and grow their businesses, better utilizing existing resources 

including land base and without needing more capital expenditures. Now, driven by 

the marketplace, our cooperative generally must restrict its members from using 

rBST. Thus, that option has effectively been taken away from us. 

Now the agriculture industry is facing increased scrutiny for its use of biotechnology—a technology that has enabled farmers to increase yields while reducing 

the use of land, pesticides, fertilizers, water, and even fuel. Despite the fact that 

there is no credible study of biotech crops that has found them unsafe for human 

and animal consumption, some special interest groups are still choosing to spread 

misinformation, reject the technology and demand it be labeled on food products. 

I welcome consumers who want to know more about how their food is produced— 

they have a right to know that the meals they serve at the family dining table every 

night is safe and nutritious. But a very small percentage of the population should 

not be able to impose their personal, non-science-based food preferences on the rest 

of us—prompting food prices to increase and driving farms like mine out of business. Certainly, as a dairy farmer, increasing food and feed costs would have a devastating impact on my business. Beyond our farm gate, though, we know the impact 

would be just as brutal. Rural northeast Vermont, like many rural areas around the 

country, has a lot of good people who put in a hard day’s work but are just barely 

getting by as best they can. This means that, for instance, 80 percent of the children 

in our elementary school receive free or reduced school lunches. It is their families 

who would suffer the most from price increases caused by mandatory biotech labeling—those who can least afford it. 

As a mother and a consumer, I choose not to purchase organic or non-GMO food 

at the store. I will support my local community, however, and may purchase organic 

or non-GMO food at a farmers’ market or directly at a farm stand. I generally do 

not believe in paying the higher premium for these foods because they provide no 

added nutritional or health benefits. With a growing family and a growing farm 

business, we have a lot of other places to spend our hard-earned money. Furthermore, I feel secure in the regulatory steps that have been taken to the food produced 

and available for sale in the grocery store to ensure it is safe to feed my family. 

The fact is that American farmers offer consumers more food choices, while providing the safest food supply than any other time in our nation’s history. Of course, 

living and working on a farm and being exposed to farm publications and reports, 

my view on how food is grown is different than that of a typical mom. There is information out there for those who are interested. It’s just a matter of getting it from 

reliable sources. Some food companies are voluntarily labeling their products, some 

participate in the transparent USDA Certified Organic program and still some use 

third-party verification and a ‘‘Non-GMO’’ label. 

Moreover, I feel even better knowing that food produced with biotechnology or 

biotech ingredients has been done so with some sort of advantage in mind—whether 

it’s environmental, health or otherwise. I certainly do not believe a mandatory 

biotech label is necessary; in fact there are more responsible ways to spend [my] 

taxpayer monies. Be that as it is, if consumers are to drive some sort of label requirement I believe it should be done in a cohesive way at the Federal level. 

You must be aware that recently my state, the State of Vermont, passed a mandatory GMO-labeling law. As you can guess, there has been a fair amount of chatter 

about it. I am frustrated with it. I believe that there are better uses of the state’s 

time, and taxpayer resources, than imposing regulations on a technology that has 

been used and proven safe for over 2 decades. I am also concerned about the impact 

this law will have on the cost and availability of food in Vermont’s grocery stores. 

I might also add that in New England, states are very close and it is very easy 

and often more convenient at times to cross borders for various reasons. Our farm, 

for example, is not too far from the border with New Hampshire; we can get there 

in an hour. If the Vermont labeling law is activated, there will likely be one label 

on food in Vermont, and another on the exact same products in New Hampshire and 

the rest of the country raising questions about whether or not the product is actually the same. This serves no one’s interests—not consumers, not farmers, not food 

producers. 

Further, our close-knit surrounding states are considering their own GMO-labeling bills. Currently, the Vermont law exempts meat and dairy from being labeled. 

Others may not exempt those products. As I sell my Jersey beef, processed at a 

USDA certified facility, to people in other states, this may directly affect my product 

and my ability to market it. 

In all of this, I think that it is so important for there to be an ongoing conversation with consumers about this topic. Too many times, farmers feel like they just 

need to tell their stories better and to ‘‘educate’’; while this is part of it, I think that 

30 

we also need to do a better job of listening to consumers, to their questions and concerns and addressing them. 

I volunteer for an online effort called Ask the Farmers. It is a collaborative resource made up of farmers from all across the country and Canada; and from all 

different aspects of farming—animal ag, biotech crops, organic, conventional, small, 

large, etc., I’m very excited to help in an effort to put more good information out 

there—be it for genetic engineering, dairy farming, animal welfare, balancing life 

with work, farm or family. I am happy to continue to speak up for our right to farm 

in the best way we know possible; which in our case includes biotechnology. 

I will continue to pursue an active presence on Facebook, Twitter and Instagram 

as well as more traditional communication routes via newspapers, church meetings 

or everyday conversation, sharing articles and ideas along with my knowledge about 

the opportunities and challenges we face as modern-day farmers and parents. If I 

have one person or ten people reach out to me for a question or appreciating my 

hands-on and practical perspective from the farm, then I have succeeded. And I 

have. 

I may add that I testified at a Subcommittee hearing on this very topic last summer and received some rude comments from total strangers on social media. I tried 

to start a conversation with those folks who were interested in having one and ignored those who were more interested in making personal comments and being bullies. It was not always the most pleasant experience, but being a dairy farmer I’m 

used to having to do dirty jobs from time to time. But even with those negative encounters, or maybe because of them, I was eager to come back to share my experiences with all of the Members of the Committee. 

I personally believe that there is room for many different styles of responsible 

farming—the freedom to operate your business or organize your life as you see fit 

is one of the things that makes America great and our economy strong. I also believe that biotechnology plays a major role in our collective ability to not only feed 

a growing global population, but to also make individual improvements on our own 

farms be it 50 cows or 5,000 cows; a cash crop operation or an apple orchard; a multiple-generation farm or a beginning farmer. Even though less than two percent of 

the U.S. population now lives on farms or is actively involved in farming, agriculture comes in all different sizes and shapes and we need every one of them. Just 

as importantly, we give consumers options when they go to the grocery store. 

We know more now than we have ever have about growing food, or caring for animals, and this helps us to achieve a level of productivity that previous generations 

of farmers would envy. I am proud of how far the American farmer has come, just 

as I am proud of how far we have come on our own farm. 

Thank you again for the opportunity to be here today and to share my experience 

with biotechnology. 

About Agri-Mark 

Agri-Mark, with more than a billion dollars in 2014 sales, markets more than 300 

million gallons of farm fresh milk each year for about 1,200 dairy farm families in 

New England and New York. The cooperative is headquartered in Methuen, Mass., 

has been marketing milk for dairy farmers since 1913, and actively represents their 

legislative interests in the Northeast and in Washington, D.C. 

About the National Council of Farmer Cooperatives 

Since 1929, NCFC has been the voice of America’s farmer cooperatives. NCFC values farmer ownership and control in the production and distribution chain; the economic viability of farmers and the businesses they own; and vibrant rural communities. We have an extremely diverse membership, which we view as one of our 

sources of strength—our members span the country, supply nearly every agricultural input imaginable, provide credit and related financial services (including export financing), and market a wide range of commodities and value-added products. 

American agriculture is a modern-day success story. America’s farmers produce 

the world’s safest, most abundant food supply for consumers at prices far lower than 

the world average. Farmer cooperatives are an important part of the success of 

American agriculture. Cooperatives differ from other businesses because they are 

member-owned and are operated for the shared benefit of their members. 

Farmer cooperatives enhance competition in the agricultural marketplace by acting as bargaining agents for their member’ products; providing market intelligence 

and pricing information; providing competitively priced farming supplies; and 

vertically integrating their members’ production and processing. There are over 

3,000 farmer cooperatives across the U.S., and earnings from their activities (known 

as patronage) are returned to their farmer members, helping improve their members’ income from the marketplace. 

31 

About the National Milk Producers Federation 

The National Milk Producers Federation (NMPF), based in Arlington, Va., develops and carries out policies that advance the well-being of U.S. dairy producers and 

the cooperatives they collectively own. The members of NMPF’s cooperatives 

produce the majority of the U.S., milk supply, making NMPF the voice of nearly 

32,000 dairy producers on Capitol Hill and with government agencies. For more on 

NMPF’s activities, visit www.nmpf.org. 

The CHAIRMAN. Thank you. I appreciate that. Mr. Clarkson? 

STATEMENT OF LYNN CLARKSON, PRESIDENT AND FOUNDER, 

CLARKSON GRAIN COMPANY, INC., CERRO GORDO, IL 

Mr. CLARKSON. Chairman Conaway, Ranking Member Peterson, 

and other Members of the Committee, thank you for inviting me 

here today. I am the President of Clarkson Grain Company located 

in Cerro Gordo, Illinois. Clarkson Grain was founded in 1974 by 

the Clarkson family, pioneering direct delivery marketing to link 

farmers directly to end-users. From that beginning, we have grown 

into a grain, oilseed, and ingredient supplier to manufacturing 

companies making food and animal feed with clients around the 

world. The company procures its raw materials, primarily corn and 

soybeans, from farmers in the United States and Canada. We operate our own commercial storage, cleaning, and handling facilities, 

a barge station, rail sidings. Our products include corn and soy 

flours, masa, lechitin, whole grains, organic, non-GMO and GMO. 

United States farmers excel in delivering the lowest cost agricultural products with a grade standard acceptable to clients. Since 

our inception, we have segregated corn and soy by variety and market distinction to realize greater value for producers and end-users. 

Buyers of these identity preserved grains are now asking for features that guarantee their access to particular markets such as 

GMO specific, non-GMO, and organic. Such buyers range from 

small family companies to the largest food manufacturers. Shipments range from a small bag to 55,000 ton vessels. 

These market preferences are increasingly defining both our domestic and international markets. To secure corn and soy sought 

by these buyers, we contract with farmers before planting to get 

particular varieties raised in accord with buyers’ wishes. We secure 

grower cooperation by paying premiums. 

Our goal is simple: a happy client. We are not in the business 

to win a scientific or political argument. We are in business to 

please clients seeking legitimate product distinctions. We don’t tell 

clients what they should want. We ask them what they want and 

try to get it for them. 

As an identity preserved (IP) merchant, Clarkson Grain is not at 

all opposed to the development and commercialization of GMO 

crops. Producers and their supply chain partners however need to 

recognize that production and handling of any crop has to be conducted in such a way that preferred market access is recognized 

and honored. Neighboring farmers must have the ability to serve 

their preferred markets, whether GMO, non-GMO, or organic. Market access and choice are critical to this. Wherever you fall on the 

GMO spectrum, it is clear to me as an ingredient supplier that an 

increasingly significant percentage of consumers want additional 

transparency in labeling. These consumers, the GMO sensitive, 

32 

have certainly proved themselves to be a significant and vocal voice 

for transparency in labeling. 

The cost of disregarding this voice is increased social conflict, expensive political battles, and uncertainty provided by prolonged 

court cases. For farmers who use GMOs, this process prolongs the 

difficulty for the biotech industry to bring traits responsibly into 

the market. Everyone would win if we could lower the temperature 

and manage the conflict over GMO technology. 

One critical way to lower the temperature is through a rational 

uniform national standard for the labeling of food that is not produced using GMO traits. Such an action is in the fundamental interests of both consumers and farmers. Consumers have a right to 

exercise their choice and avoid. Farmers have a right to take advantage of this new market. The creation of a standard could be 

accomplished through a mandatory labeling scheme, but it is my 

belief that a more appropriate approach is through a voluntary labeling program. I believe that such approach would be less contentious, less adversarial, and less expensive. 

I believe we are in a similar place to where we were with emerging organic market in the early 1990s. At that time differing state 

standards for organic products were emerging. The result was consumer confusion. Independent companies jumped in. More confusion. Each one was saying their standard was better than the next. 

So it was a negative for the entire sector. 

Once the organic sector settled on a uniform national definition 

responsibly overseen by the USDA, consumer confidence returned 

and served as the fundamental rationale for explosive growth. 

It is my belief the non-GMO market would also grow if it had 

a uniform national standard overseen by the USDA. The USDA has 

a world-class reputation of managing process-verified programs. It 

seems to me to be straightforward. Let Congress establish a uniform standard, let USDA oversee it, step back, and let the marketplace work as it does. 

To sum up, I want to offer one more rationale for establishing a 

uniform standard. Labeling drives other activities along the supply 

chain such as seed production. Many producers struggle with a 

lack of appropriate non-GMO seed. For all these pieces to work together within a reasonable time frame, farmers must have access 

to an adequate supply. 

So in closing I ask for several things. First, Congress to support 

a farmer’s freedom to produce for his preferred markets without 

being dominated by his neighbor’s market decisions. I ask Congress 

to support through adequate funding, research in non-GMO corn 

and soy varieties. I ask Congress to support a farmers’ choice of hybrids or quality attributes, GMO presence or absence, or organic or 

non-organic. I ask Congress to help those of us in the countryside 

to always balance and respect a producer’s production decisions as 

they provide a safe and abundant food supply for the world’s needs. 

Thank you. I would be happy to answer any questions later 

[The prepared statement of Mr. Clarkson follows:] 

33 

PREPARED STATEMENT OF LYNN CLARKSON, PRESIDENT AND FOUNDER, CLARKSON

GRAIN COMPANY, INC., CERRO GORDO, IL 

Chairman Conaway, Ranking Member Peterson, and other Members of the Committee, thank you for inviting me here today to talk about the costs and impacts 

of mandatory biotech labeling laws. My name is Lynn Clarkson. I am the President 

of Clarkson Grain Company, Inc., located in Cerro Gordo, Illinois, a small rural community about 3 hours south of Chicago. 

Clarkson Grain was founded in 1974 by the Clarkson family, which pioneered ‘‘Direct Delivery Marketing’’ to link farmers directly to end-users. From that modest beginning, we have grown and evolved into a grain, oilseed, and ingredient supplier 

to the food manufacturing and animal-feed industries serving clients around the 

world. The company procures its raw materials—particularly corn and soy from 

farmers in the United States and Canada. 

We operate our own commercial storage, cleaning and handling facilities as well 

as organic soy processing facilities, a barge station and rail sidings. Our products 

include corn and soy flours, masa, meal, refined soy oil, lechitin, whole grains, and 

organic and non-GMO grains and oilseeds. 

United States farmers and its supply chain partners like us excel in delivering 

the lowest cost agricultural products within a grade standard acceptable to clients 

around the world. Since our inception, we have segregated corn and soy by variety 

and market distinction to realize greater value for our producers and end-users. 

Buyers of these Identity Preserved (IP) grains are now asking for features that 

guarantee their access to particular markets such as GMO specific, non-GMO and 

organic. 

Such buyers range from small family companies to the largest food manufacturers, starch and oil processors and feeders. Shipments range from small bags to 

55,000 ton ocean vessels. 

These market preferences are increasingly defining both our domestic and international markets. To secure corn and soy sought by these buyers, we contract with 

farmers before planting to secure particular varieties raised in accord with buyers’ 

wishes. We secure grower cooperation by paying premiums that justify continuing 

participation in IP programs year after year. 

Our goal is simple; a happy client. We are not in business to win scientific or political arguments. We are in business to please clients seeking legitimate product 

distinctions. We don’t tell clients what they should want. We ask them what they 

want and help them find it. 

In the early days of our business, our major challenge was to keep corn and soy 

types segregated by variety. Buyer, seller, and grower could visibly see the distinctions. That changed with the commercial introduction of GMO traits. Within a few 

years, GMO sensitive markets brought new distinctions into play. For example, in 

those early days, Japanese buyers for the soyfood industry worked with the Association of Official Seed Certifying Agencies to develop testing and segregation protocols. 

As an IP merchant, Clarkson Grain is not at all opposed to the development and 

commercialization of GMO crops. Producers and their supply chain partners however must recognize that production and handling of any of any crop has to be conducted in a way so that preferred market access is recognized and honored. Neighboring farmers must have the ability to serve their preferred markets—whether 

GMO, non-GMO or organic. Market access and choice must be preserved. I believe 

that this respect and recognition can occur. 

Wherever you fall on the pro- or anti-GMO spectrum, it is clear to me as an ingredient supplier that an increasingly significant percentage of consumers want additional transparency in labeling so that they may purchase the food types they and 

their families desire. These consumers what one might call, GMO sensitive, have 

certainly proved themselves to be a significant and vocal voice for increased transparency in food labeling. 

The cost of disregarding this voice is increased social conflict, expensive political 

battles, and uncertainty provided by prolonged court cases. For my farmers in Illinois who use GMO’s this process simply prolongs the difficulty for the biotech industry to bring traits responsibly into the market. Those concerned about GMOs however deserve to be respected even while the biotech industry continues its efforts 

to market its traits at the consumer level. Everyone would win if we could lower 

the temperature and manage the conflict over GMO technology. 

I am convinced that one critical way to lower the temperature is through a rational uniform national standard for the labeling of food that is not produced using 

GMO traits. Such an action is in the fundamental interests of both consumers and 

farmers. Consumers have a right to exercise their choice to avoid GMOs. Farmers 

have a right to take advantage of this new market. The creation of a standard could 

34 

be accomplished through a mandatory labeling scheme but it is my belief that a 

more appropriate approach is through a voluntary labeling program. I believe that 

such an approach would be less contentious, less adversarial and less expensive. 

Here’s why I have reached my conclusion. I believe we are at a similar place in 

the labeling of non-GMO products to that of the emerging organic market in the 

early 1990’s 

At that time differing state standards for organic products were beginning to 

emerge. The result was consumer confusion. With no uniform national organic 

standard, states were free to tout their differences. The private-sector also got into 

the act. There were numerous private certifiers each claiming to be better than the 

other. Consumers didn’t understand these differences but more importantly they became put off by the sniping in the marketplace. As a result, the entire sector suffered. 

Once the organic sector settled on a uniform national definition, responsibly overseen by the U.S. Department of Agriculture, consumer confidence returned and 

served as the fundamental rationale for the explosive growth we currently see within the sector. U.S. sales of organic products in 2013 were $35.1 billion. This remarkable growth rests on one thing; a uniform national standard, responsibly, overseen 

by a Federal agency. 

It is my belief the non-GMO market would also grow if there were a uniform national standard, overseen, by USDA. USDA has world class expertise in managing 

process verified programs. It seems to me to be straightforward. Let Congress establish a uniform standard, let USDA oversee it, step back and let the marketplace 

work. 

As I begin to sum up, I want to offer one more rationale for establishing a uniform 

standard or definition of a non-GMO label. Labeling drives other activities along the 

supply chain such as seed production. Many producers struggle with a lack of appropriate non-GMO corn and soy varieties to meet specific market needs. 

I am convinced a national non-GMO labeling program would send a clear single 

to input suppliers such as seed breeders that the non-GMO marketplace is here to 

stay. I do not believe that would be the case is we had a proliferation of state labeling programs. I believe non-GMO is a legitimate and growing market and that consumers deserve to know what that is in their food so can make their choices with 

their hard-earned dollars. 

For that to occur within a reasonable time frame, farmers must have access to 

an adequate supply of high yielding non-GMO corn and soy varieties. 

In closing I offer the following thoughts as you consider an appropriate role for 

Congress to take in this emerging marketplace: 

1. I ask Congress to support a farmer’s freedom to produce for his preferred markets without being dominated by his neighbor’s production choices. As you 

can see this sword cuts both ways. 

2. I ask Congress to support through adequate funding, research in non-GMO 

corn and soy varieties so that farmers might rapidly access this new market. 

3. I ask Congress to support a farmers’ choice of hybrids or quality attributes, 

GMO presence or absence, or organic or non-organic production methods. 

4. And I ask Congress to help us in the countryside to always balance and respect a producer’s production decisions as they provide a safe and abundant 

food supply for the world’s needs. 

Thank you for this opportunity. I am happy to answer any questions you might 

have. 

The CHAIRMAN. Thank you, Mr. Clarkson. Mr. Dempsey? 

STATEMENT OF THOMAS W. DEMPSEY, JR., PRESIDENT AND 

CHIEF EXECUTIVE OFFICER, SNACK FOOD ASSOCIATION, 

ARLINGTON, VA 

Mr. DEMPSEY. I want to thank the Committee, Chairman 

Conaway, and Ranking Member Peterson for holding this hearing 

to provide a balanced review of one of the most critical issues facing the food industry today, the labeling of genetically modified organisms, or GMOs. 

My name is Tom Dempsey. I have served as the President and 

Chief Executive Officer of the Snack Food Association since 2013. 

35 

Prior to joining SFA, I was the President of one of the largest privately owned snack brands in the United States. We represent over 

400 companies in the snack industry. My members include both billion-dollar multi-category companies and small family-owned businesses in the second and third generation of management. More 

than 1⁄2 of SFA members have sales of less than $100 million a 

year, and many are the primary employers in their communities. 

Mandatory GMO labeling would impact nearly every aspect of 

my members’ businesses, upping costs by requiring increased product inventory, added complexity for packaging and distribution 

processes, and extensive new regulatory and training requirements. 

Absent a Federal solution, manufacturers will have essentially 

three options to comply with a state GMO labeling law: redesign 

their packaging, reformulate products so that no labeling is required, or halt sales to that state. Each option is difficult, costly, 

time-intensive, and at worst, could eliminate jobs and consumer 

choice in the marketplace. Smaller companies may not have these 

options at all. 

A patchwork of mandatory GMO labeling laws would pose significant burdens on the manufacturing process itself. They would 

require separate storage for GMO and non-GMO products throughout the entire supply chain beginning with the farmer and extending through the various stages of production and distribution. 

Aside from new administrative and recordkeeping burdens, snack 

makers would be forced to clean and boil the sheeting, baking, frying, and seasoning lines between GMO and non-GMO production 

runs with extensive time costly delays. 

Duplicative film labeling for the same stock keeping unit or SKU 

assigned to each product line is also a problem. Film, the industry’s 

term for snack bag packaging, would need to be changed mid-production and two separate inventories of the same finished product 

must be kept. If one, ten, or 25 states enact different GMO labeling 

laws, this process would become even more burdensome and difficult to comply with, particularly from an interstate commerce perspective. 

Significant lead times and costs would also go into bag changes. 

The cost in plate charges, new film, and administrative oversight 

could be more than $750,000 for 800 SKUs, and the process could 

take 20 to 26 weeks. 

GMO and non-GMO producers must continue to be segregated by 

state, from the factory to the grocery store, resulting in increased 

distribution costs and heightened opportunity for mistakes. 

To be clear, the hardest hit by this will be one-plant operators 

with a single line of production. These costs could put family-owned 

businesses out of business and increase consolidation in the industry. 

While it is sometimes assumed that companies could remove 

GMO ingredients from their products, this is unrealistic because 

the availability of non-GMO crops, as you have heard, is limited. 

Over 80 percent of the corn, cotton, and soybean crops in the 

United States are produced with biotechnology, all of these products, which are staple items in the snack food production. 

Our members will not have the opportunity to increase their contracts with farmers or mills for non-GMO corn, for instance, for 

36 

over 2 years. Transitioning to GMO-free production will not happen 

overnight from genetically engineered plants. 

Some manufacturers may choose to end distribution in states 

that require GMO labeling resulting in fewer product options for 

consumers and causing a ripple effect in the grocery industry. Even 

if manufacturers notify grocers of their intent to stop selling in a 

state, manufacturers could run the risk of being fined if retailers 

do not comply or if mistakes happen in the distribution process. 

Fewer players in the aisle could mean less incentive to keep 

quality high and prices low. Fewer products could disproportionately cause job losses for some in the distribution chain. 

Ultimately, a patchwork of state GMO laws will hit consumers 

the hardest in result in either increased cost at the grocery store 

or less availability of products on store shelves. Current Federal 

law mandates food labels for safety and nutritional purposes, and 

because GMOs as you have heard have proven to have no material 

difference than non-GMOs, there is no food safety or nutritional 

difference that requires an additional label. Going down a path 

which calls for mandatory GMO labels sets a bad precedent for future calls for mandatory labels for issues that are not related to 

food safety or nutrition. 

Consumers already have the option to purchase non-GMO foods, 

and these options continue to expand. For over a decade, both the 

USDA’s National Organic Program and the independent Non-GMO 

Project have certified that foods are organic and GMO-free respectively. 

Many SFA members have already made the significant investment in marketing decisions to display these voluntary labels. 

Forcing companies to re-label more than 80 percent of their products does nothing but add cost, confusion, and may limit the 

choices. 

SFA does not have a single member company that manufactures, 

distributes, and sells in just one state which makes a state labeling 

law incredibly complex. Multiply these challenges by five, ten, or 

25 states and an insurmountable burden is placed on the supply 

chain. SFA supports a voluntary labeling standard which eliminates the proposed patchwork of state laws and allows the market 

forces that are already in place to continue to inform the consumer. 

As more and more states continue to pursue different mandatory 

GMO labeling laws, manufacturers and consumers alike need the 

consistency of a Federal standard, and we need it urgently. 

Thank you for your time and consideration. 

[The prepared statement of Mr. Dempsey follows:] 

PREPARED STATEMENT OF THOMAS W. DEMPSEY, JR., PRESIDENT AND CHIEF

EXECUTIVE OFFICER, SNACK FOOD ASSOCIATION, ARLINGTON, VA 

Introduction 

First, I would like to thank the House Agriculture Committee, Chairman 

Conaway, and Ranking Member Peterson for holding this hearing to review of one 

of the most critical issues facing the food industry today, the labeling of genetically 

modified organisms, better known as GMOs. I appreciate the opportunity to be here. 

My name is Tom Dempsey. I have served as the President and Chief Executive 

Officer of the Snack Food Association (SFA) since 2013. Prior to joining SFA, I was 

the President of one of the largest privately owned snack brands in the United 

States (U.S.) where I spent 24 years in total, 5 of which I served as the President 

overseeing all areas of sales, marketing, finance, human resources, manufacturing, 

37 

distribution, research and development, and purchasing. Today at SFA, I represent 

more than 400 companies who produce a wide variety of snacks ranging from potato, tortilla, and pita chips to pork rinds and meat snacks, to crackers, popcorn, 

granola bars, and trail mix, as well as dried fruit and nut mixtures. SFA members 

range from billion-dollar multi-category companies to small family owned and operated businesses, some of which are in the second and third generation of management. More than half of SFA members do less than $100M/year in sales and many 

are the primary employer in their community. 

GMO Labeling Debate 

Over the last several years there have been a number of state ballot initiatives 

calling for mandatory GMO labeling. While voters have rejected ballot initiatives 

calling for mandatory GMO labeling in four states: California, Washington, Colorado, and Oregon, the Vermont State Legislature approved the nation’s first mandatory GMO labeling law, Act 120, in April 2014. Two other states, Connecticut and 

Maine have mandatory GMO labeling laws on the books, but don’t become effective 

until certain population or surrounding state triggers are met. In addition, since 

January 2015, 28 states and Puerto Rico have introduced over 70 different pieces 

of legislation calling for some type of mandatory GMO labeling of foods. 

Mandatory GMO labeling at the state level would impact nearly every aspect of 

SFA members’ business, upping costs by requiring increased product inventory, 

added complexity for packaging and distribution processes, and extensive new regulatory and training requirements. 

Absent a Federal GMO solution, manufacturers will have essentially three options 

in order to comply with a state labeling law such as Vermont’s Act 120: order new 

packaging for products, reformulate products so that no labeling is required, or halt 

sales to that state. Each option is difficult, costly, time-intensive, and at worst, could 

eliminate jobs and consumer choice in the marketplace which I will further discuss. 

I will also outline why some food manufacturers, most likely small and midsize family businesses, do not have all of these options available and could be impacted the 

most. 

Production Processes 

One of the biggest barriers that prevents a company from complying with state 

by state GMO labeling laws is the manufacturing process itself. 

First, it would require separate storage for GMO and non-GMO products throughout the entire supply chain. Farmers will need to separate their crops in planting 

and when transporting to grain elevators or manufacturers. Once a grain elevator 

or manufacturer receives the raw materials from farmers they too will need to store 

and produce GMO and non-GMO materials separately. Aside from new administrative and recordkeeping burdens, manufactures will need to add separate storage 

areas to their facilities in order to segregate these products. Tortilla processing provides an excellent example. The story begins with the corn. There are two ways to 

begin the process: one, by cooking the corn into a mash and the other by purchasing 

corn masa (flour), adding water to it, and then sheeting it for cutting into the triangle shapes we all know as tortilla chips. A mandatory labeling scheme would require two different silos to hold GMO and non-GMO bulk corn and masa (flour). 

Given the expense of manufacturing machinery, snack makers may be forced to 

use the same equipment and conduct thorough cleaning of the sheeting, baking, frying, and seasoning lines between GMO and non-GMO production runs to ensure no 

contamination occurs. Such a process could take nearly 2 hours and would lead to 

a loss in valuable production time. It is not likely a manufacturer would have the 

financial means or the floor space to invest in separate equipment for GMO and 

non-GMO production. 

Another complicating factor is the need for duplicative labeling film for the same 

stock keeping unit or SKU assigned to each product line. In order to comply with 

a state labeling law, our members will need to change film in mid-production and 

then keep two separate inventories of the same finished product: one with GMO 

identification specifically for sale in a state that enacts mandatory GMO labeling, 

and the other for the rest of the distribution area. Companies would not be able to 

use a single state-required label for all of its products if a patchwork of varying 

state rules were enacted. Separating finished products for not only one, but five, ten, 

or even twenty states with various labeling requirements would be incredibly challenging and nearly impossible for a manufacturer to carry out. Such a labeling 

scheme impedes on interstate commerce. 

Significant lead times and costs also go into a bag design change. One SFA member estimated they would need to change over 800 SKUs to continue to sell in 

Vermont alone. The cost in plate charges, new film, and administrative oversight 

38 

1 United States Department of Agriculture Economic Research Service. ‘‘Recent Trends in GE 

Adoption’’. July 14, 2014. Retrieved from: http://www.ers.usda.gov/data-products/adoption-ofgenetically-engineered-crops-in-the-us/recent-trends-in-ge-adoption.aspx. 2Dyson School of Applied Economics and Management, Cornell University. ‘‘Costs of Labeling 

Genetically Modified Food Products in N.Y. State’’. May 2014. Retrieved from: http:// 

dyson.cornell.edu/people/profiles/docs/LabelingNY.pdf. 

in this instance could be more than $750,000. The actual cost of the run after converting the film would be approximately 25 percent higher due to the shorter production runs of non-GMO product that would be required to fulfill orders in 

Vermont, for example. The actual process of designing, compliance review, plate 

making, and lead-time for film would be 20–26 weeks. This would become even more 

complicated if additional states pass their own onerous regulations with different 

specific requirements. 

After production, the distribution of most snack foods comes off, in most cases, 

a route truck with direct service to the grocery store. A state law such as Vermont’s 

Act 120 will mandate a dual inventory for each SKU for every step along the distribution channel. The end result will be increased distribution costs and heightened 

opportunity for mistakes. 

To be clear, the hardest hit by this will be the small, family-owned companies 

with just one plant or just a single line of production. Quite frankly, these costs 

could put some companies out of business and thereby increase consolidation in the 

industry by reducing the players to a few multi-category, multi-national players that 

can better take on the added cost of sourcing and segregating GMO and non-GMO 

crops. All of these changes will add final product costs to the consumer. The precise 

amount of added cost depends on each company’s cost structure. 

Sourcing Challenges 

In order to avoid the need for duplicate labels in a state like Vermont, it is sometimes assumed that companies could simply remove the GMO ingredients from their 

products altogether. This is unrealistic because the availability of non-GMO crops 

is very limited. My understanding is that over 80 percent of the corn, cotton, and 

soybean crops in the U.S. are harvested from genetically engineered plants.1 Snack 

food companies purchase a large majority of their ingredients derived from these 

plants. 

For instance, the process for producing potato chips begins with developing a 

large network of growers for potatoes, contracting quantities in advance of plantings 

and harvests, and purchasing cooking oils such as cottonseed or soybean in advance 

to secure quantities and pricing. The same goes for other crops. One tortilla chip 

manufacturer told me that they would not have the opportunity to increase their 

contracts for non-GMO corn for a minimum of 2 years. Transitioning to GMO-free 

production could not happen overnight, or even by 2016, as is specified in Vermont’s 

Act 120, for example. 

Impact on Consumers and the Economy 

On the other hand, manufacturers could also choose to end the distribution of 

their lines specifically in states that require mandatory GMO labeling. However, 

ceasing distribution isn’t simple. Aside from limiting product options to consumers, 

there would be a ripple effect in the grocery industry. Retailers would need to be 

notified of the decision to stop selling in a state and manufacturers could run the 

risk of being fined if retailers do not comply. 

Fewer players in the aisle could mean less incentive to keep quality high and 

prices low. Decreased promotion and distribution means fewer route sales people 

needed to deliver the product and job losses for some in the distribution chain, such 

as drivers, warehouse personnel, account executives, and field management. Fewer 

jobs could also lead to a decrease in tax revenue in a particular state. 

Ultimately, a patchwork of state and local GMO labeling laws will hit consumers 

the hardest resulting in either increased costs at the grocery store or less availability of products on store shelves. 

A recent study performed by economists at Cornell University concluded that 

mandatory GMO labeling laws would increase the cost of food by about $500 per 

family per year on average with some families bearing an increased cost of up to 

$1,500 per year.2 These amounts don’t include the regulatory costs the government 

will incur to actually implement the law that would likely be passed onto consumers 

in the form of taxes. 

Role of Labels 

Current Federal law mandates food labels for safety and nutritional purposes. 

And because GMO’s have proven to have no material difference than non-GMOs, 

39 

there is no food safety or nutritional difference that requires an additional label. 

Going down a path in which calls for mandatory GMO labels sets a bad precedent 

for future calls for mandatory labels for issues that are not related to food safety 

or nutrition. 

GMO-Free Options Already Exist 

While we firmly believe the science shows that our GMO products are safe, SFA 

members support providing consumers with options in the marketplace. It is important to note that consumers can already choose to purchase non-GMO items and 

these options continue to expand. For over a decade both the United States Department of Agriculture’s (USDA) National Organic Program and a nonprofit organization, the Non-GMO Project have certified foods which are organic and non-GMO, respectively. A company cannot display a USDA Organic Seal or a Non-GMO Project 

Verified Seal without going through an intensive and costly certification process. 

The Non-GMO Project alone has certified over 20,000 non-GMO products and this 

number continues to grow. 

Many SFA members have already made the large investment required to gain 

these voluntary certifications that give our customers the freedom to choose between 

products that are produced, distributed, and marketed as Organic and non-GMO 

and labeled as such. Forcing companies to re-label more than 80 percent of their 

current products does nothing but add cost, confusion, and, ultimately, may limit 

the choices available to consumers. 

Conclusion 

SFA is concerned both about the burden state-level GMO labeling would put on 

interstate commerce, as well as the increased costs that could drive food companies 

out of business or increase food prices for consumers while potentially limiting their 

options in the marketplace. 

SFA does not have a single member company that manufactures, distributes, and 

sells in just one state making a state labeling law incredibly complex to deal with. 

Multiply the challenges I’ve presented here for compliance in Vermont’s Act 120 

times five, or ten, or even 25 states and you place an insurmountable burden on 

our food supply chain and add significant increased cost to our consumers. 

For this reason, SFA supports Federal legislation which eliminates the current 

proposed patchwork of state GMO labeling laws by creating one voluntary GMO 

standard which eliminates confusion, advances food safety, and provides much-needed consistency for manufacturers and our consumers. 

Again, thank you for your time and consideration of our views. I look forward to 

answering your questions. 

The CHAIRMAN. Thank you, Mr. Dempsey. Mr. Policinski? Chris, 

go ahead, 5 minutes. I am sorry about that. 

STATEMENT OF CHRIS POLICINSKI, PRESIDENT AND CHIEF 

EXECUTIVE OFFICER, LAND O’ LAKES, INC., ARDEN HILLS, MN 

Mr. POLICINSKI. Thank you. Thank you, Chairman Conaway, 

Ranking Member Peterson, and Members of the Committee. Thank 

you for holding today’s hearing on the costs and impacts of mandatory biotechnology labeling laws. 

I appreciate the opportunity to testify on this important issue. I 

am Chris Policinski, President and CEO of Land O’ Lakes. I also 

serve as Chairman of the National Council of Farmer Cooperatives 

and am a Board Member of the Grocery Manufacturers Association. 

Land O’ Lakes, based in Arden Hills Minnesota, is a farmerowned cooperative, meaning it is owned, governed, and controlled 

by farmers and local agricultural cooperatives. Land O’ Lakes 

touches more than 300,000 farmers across the country making us 

well-positioned to understand the benefits of biotechnology and the 

impact of measures designed to mandate the labeling of GMO products. 

Biotech crops have been around for 2 decades and provide extraordinary benefits to farmers and consumers: higher crop yields 

per acre, less tilling of the land, decreased use of natural resources 

40 

such as water and land, reduced use of insecticide, better soil quality, and lower consumer prices are just some of the benefits GM 

crops provide. 

Despite these benefits and the proven safety of GMOs, some are 

pushing for states to pass laws that would mandate the labeling of 

GMO foods. We are told this is about consumer choice. The consumers already have these choices and many others. Some choose 

to pay a premium for food that is produced by certain methods, 

such as organic or does not contain certain ingredients, such as 

those that are gluten-free. Others prioritize affordability, accessibility, convenience, or taste. Voluntary labeling currently presents 

all of these choices in the marketplace, and that is the model that 

should exist for GMO labeling as well. 

Mandating GMO labeling runs contrary to the essential purpose 

of government-mandated labeling, which is to provide consumers 

with accurate and relevant information regarding the safety of the 

foods they eat. Every major health and regulatory organization has 

found that GMOs are as safe as any other food and as such do not 

require any special labeling. 

Mandated GMO labeling is an effort to stigmatize a form of technology in an attempt to drive it out of the marketplace. You don’t 

have to take my word for it. Two months ago an activist association 

published an article admitting that the push to enact state-wide 

GMO labeling is part of a larger effort to drive GMOs off the market. In addition to stigmatizing biotechnology, a state-by-state 

patchwork of mandated food labeling laws would be a logistical 

nightmare creating dozens of different standards, different definitions, and different exemptions. 

Fortunately, Congress has the authority and the responsibility to 

protect the free flow of goods across state lines. Uniformity in our 

nation’s food labeling ensures consumers have consistent, accurate 

information on dairy, poultry, meat, and other foods. Under Federal preemption, Congress can create a voluntary uniform national 

solution to the labeling of food products derived from ingredients 

using biotechnology. The value of this approach is that it not only 

respects a consumer’s right to choose but it also respects a farmer’s 

right to choose to use a safe, proven technology. 

Stigmatizing GMO foods through a patchwork of state labeling 

mandates or even mandatory Federal labeling jeopardizes innovation and threatens the future of development and use of technology 

in agriculture. As a result, farmers will have fewer choices of what 

to plant. We will see higher costs due to crop segregation, lower 

yields, a decline in productivity, and an increased environmental 

footprint. That is dangerous for everyone. 

And this threat is real and imminent. There is currently some 

form of GMO labeling legislation pending in over 1⁄2 of our state 

legislatures, and Vermont’s GMO labeling mandate is scheduled to 

take effect next year. That is why I strongly urge Congress to enact 

a common-sense law that will provide farmers and consumers with 

the clarity and certainty needed for meaningful, voluntary food labeling. 

Last year our company supported the Safe and Accurate Food 

Labeling Act, and we understand that similar legislation will be introduced soon. Updates to the bill from last year may include the 

41 

creation of a voluntary, non-GMO verification program run by the 

U.S. Department of Agriculture. We would support such a provision 

which would ensure that consumers get accurate information while 

preserving choices available to shoppers and farmers. 

Thank you again for the opportunity to testify before this Committee. I look forward to working with each of you this year to pass 

a common-sense solution that meets the demands and expectations 

of the American people. 

[The prepared statement of Mr. Policinski follows:] 

PREPARED STATEMENT OF CHRIS POLICINSKI, PRESIDENT AND CHIEF EXECUTIVE

OFFICER, LAND O’ LAKES, INC., ARDEN HILLS, MN 

Chairman Conaway, Ranking Member Peterson, and Members of the Committee, 

thank you for holding today’s hearing on the costs and impacts of mandatory biotechnology labeling laws. I appreciate the opportunity to testify on this important 

issue. I am Chris Policinski, President and CEO of Land O’ Lakes, Inc. I also serve 

as Chairman of the National Council of Farmer Cooperatives, am on the Board of 

the Grocery Manufacturers Association, and have over 30 years of experience in the 

food and agriculture industry. 

Background on Land O’ Lakes, Inc 

Land O’ Lakes, Inc., based in Arden Hills, Minnesota, is a farmer cooperative, 

meaning it is owned, governed and controlled by farmers and local agricultural cooperatives. Land O’ Lakes, Inc. touches more than 300,000 farmers across the country. 

While Land O’ Lakes is best known for our dairy business, we are also comprised 

of two other important business units: Winfield, one of the country’s leading distributors of agricultural seed and crop protection products; and Purina Animal Nutrition LLC, which provides a valued portfolio of complete feeds, supplements and 

ingredients for animals and livestock. 

Our company touches nearly every aspect of the food supply chain—from farmers, 

to seeds, to production, to handling, to food processing and distribution, to consumer 

foods sales and marketing. Within those sectors, we also represent a cross-section 

of preferences and products. For example, we sell biotech, conventional and organic 

products. This broad and diverse business model makes Land O’ Lakes well positioned to understand the benefits of biotechnology, and the impact of measures designed to mandate the labeling of GMO products. 

Benefits of Biotechnology 

Biotech crops have been around for 2 decades, and provide extraordinary benefits 

to farmers and consumers. Higher crop yields per acre; less tilling of land; decreased 

use of natural resources such as water and land; reduced use of insecticide, better 

soil quality, and lower consumer prices are just some of the benefits GM crops provide. 

As the head of a broad agricultural and food company and speaking on behalf of 

our farmer-owners, providing consumers with safe, nutritious, affordable food is our 

number one priority each and every day. That is why we have embraced biotechnology. 

Our farmers and cooperatives don’t just use biotechnology, they have adopted this 

technology very quickly. That’s because the benefits that biotechnology provides 

across the board—for producers, the environment and to consumers—are substantial and have been well-established over decades. 

Our farmers have also adopted this technology because they have confidence in 

the safety of biotechnology. Time and again, biotechnology and genetically modified 

ingredients have been proven safe by organizations such as the American Association for the Advancement of Science, the World Health Organization, the U.S. Food 

& Drug Administration, the American Medical Association, and more. Today, 70– 

80% of the foods we eat in the United States contain ingredients that have been 

genetically modified. 

Options in the Market for Consumers 

We know that customers want accurate and consistent information about the food 

they are buying because we talk with them constantly. We also know that different 

customers prioritize information differently. Our cooperative’s branded lines voluntarily offer many products to meet specific consumer preferences, such as organic, 

42 

cage-free and low fat. The U.S. Department of Agriculture’s Certified Organic program is a prime example of an effective system that informs consumers and certifies 

products which are available in most grocery stores across the U.S. 

Consumers should, and do, have choices in the marketplace. Some choose to pay 

a premium for food that is produced by certain methods, such as organic, or that 

does not contain certain ingredients, such as those that are gluten-free. Others 

prioritize affordability, accessibility, convenience or taste. Voluntary labeling currently presents all of these choices in the marketplace, and that is the model that 

should exist for GMO labeling as well. 

Mandatory, Varying Standards Creates Chaos 

Instead, some are pushing for a different approach. They are working in states 

to pass laws that would mandate the labeling of GMO foods. 

Mandating GMO labeling runs contrary to the essential purpose of governmentmandated labeling—which is to provide consumers with accurate and relevant information regarding the safety of the food they eat. 

Every major health and regulatory organization has found that GMOs are as safe 

as any other food and as such do not require any special labeling. This is what our 

own FDA has concluded and is further supported by a 2011 summary report from 

the European Commission covering a decade of publicly funded research, 130 research projects and 500 research groups, which concluded there is no scientific evidence of higher risks from GE crops. 

Mandated GMO labeling is an effort to stigmatize a form of technology and attempt to drive it out of the marketplace. You don’t have to take my word for it, 2 

months ago, the Organic Consumers Association published an article admitting that 

the push to enact statewide GMO labeling laws is part of a larger effort to ‘‘drive 

GMOs . . . off the market.’’ 

In addition to stigmatizing biotechnology, a state-by-state patchwork of mandated 

food labeling laws would be a logistical nightmare, creating dozens of different 

standards, different definitions, and different exemptions. 

Some say this approach is about a ‘‘consumer right to know,’’ but knowledge depends on consistent, accurate information, and their approach fails this basic test. 

Under their patchwork approach, a product may require a GMO label in one state 

but not another. 

Even within states an attempt to mandate GMO labeling will create confusion. 

For example, in the State of Vermont, which has enacted a mandatory GMO labeling law, a can of vegetable soup might be labeled as GMO, but a can of vegetable 

beef soup with roughly the same ingredients will not because meat is exempt from 

the GMO label. This approach doesn’t inform consumers; it creates confusion. 

Inequitable attempts to mandate GMO labeling have been defeated in a number 

of states. However, some groups continue to ignore the science and push a statebased agenda that could put our nation’s efficient food supply system at risk. This 

year alone, there is some form of GMO labeling legislation pending in over 1⁄2 of 

our state legislatures. Vermont’s GMO labeling mandate is scheduled to take effect 

next year. 

While it’s a small state in terms of population, Vermont’s law will have a significant impact in the region and the nation. This law alone would require dozens if 

not hundreds of manufacturing, transportation and logistics changes not to mention 

thousands of labeling changes. A single food company may be forced to change its 

sourcing, its storage, its manufacturing, its labeling and its transportation. The companies least capable of making these adjustments are going to be the small, independent businesses that many customers want to support. 

A National, Voluntary Non-GMO Label is the Solution 

Fortunately, Congress has the authority and the responsibility to protect the free 

flow of goods across state lines. Uniformity in our nation’s food labeling ensures consumers have consistent, accurate information on dairy, poultry, meat and other 

foods. As a result, Americans can go into a grocery store anywhere in the country 

and be confident that their food is subject to the same standards, certifications and 

labels. 

Under Federal preemption, Congress can create a voluntary, uniform national solution to the labeling of food products derived from ingredients using biotechnology. 

This approach supports efforts already underway in the marketplace, such as the 

USDA certified organic program. More importantly, it appropriately places trust in 

the intelligence of consumers to make choices best suited to their preferences. 

The value to this approach is that it not only respects a consumer’s right to 

choose, but also farmers’ right to choose to use a safe, proven technology. As the 

Members of this Committee know, our nation’s farmers are tasked with an awesome 

43 

responsibility. Not only do they provide sustenance to our nation but to countries 

all over the world. At the same time, they face extraordinary challenges such as 

fluctuating commodity prices, uncertain weather patterns, and global competition. 

Given the importance of agriculture, our government has been and is focused on 

ways to help farmers. I know this Committee agrees with that sentiment, and is 

committed to doing just that. But a patchwork approach of state labeling mandates 

will make a farmer’s job more difficult, with problems that will extend to every part 

of our nation’s food production and distribution system. 

For farmers, a GMO labeling mandate will stigmatize GMO products driving 

down demand for GMO crops. As a result, our farmers will have fewer choices of 

what to plant, will see higher costs due to crop segregation, lower yields, a decline 

in productivity, and an increased environmental footprint. 

For suppliers, mandates mean building new supply chains—one for GM crops and 

a separate for non-GM crops. New supply chains mean new warehouse and storage 

space. 

For manufacturers, mandates will require separate production runs for individual 

states. New labels will need to be designed to comply with each state’s unique laws. 

Production runs will then be interrupted for labels to be changed, creating idle 

equipment and idle workers. 

For distributors, mandates will require new delivery routes. These new routes 

won’t be based on efficiency as they are now, but will be based on borders. 

And for consumers, each of these impacts imposes new costs. In October 2013, the 

Washington State Academy of Sciences published a report on the cost of mandatory 

labeling. This unbiased, scientific analysis concluded that mandatory labeling is 

likely to affect trade and will impose higher costs on production. Ultimately, this 

cost will be passed onto consumers of GM and non-GM products alike. Further, a 

recent study by Cornell University found that state-based GMO labeling mandates 

could increase a family’s annual grocery costs by up to $500. 

Ensuring that farmers have a freedom of choice is not about convenience, it’s 

about necessity. 

The world’s population is estimated to grow from 7.2 billion to 9.6 billion by 2050. 

We will need to feed more people in the next 40 years than the last 10,000 years, 

combined. Already, we are falling short with one in eight people on Earth not getting enough to eat. 

If farmers are expected to meet the growing demand, then they must be able to 

utilize every tool available to them, especially biotechnology. This technology will 

allow us to grow more food using less land and fewer natural resources. 

Stigmatizing safe, proven biotechnology through patchwork state labeling mandates or even mandatory Federal labeling jeopardizes innovation and threatens future development and use of technology in agriculture. That’s dangerous for everyone. In conclusion, I strongly urge Congress to enact a common-sense law that will provide farmers and consumers with the clarity and certainty needed for meaningful, 

voluntary food labeling. 

Last year, our company supported the Safe and Accurate Food Labeling Act, and 

we understand that similar legislation will be introduced soon. Updates to the bill 

from last year may include the creation of a voluntary, non-GMO certification program run by the U.S. Department of Agriculture. We would support such a provision which would ensure that consumers get accurate information while preserving 

the choices available to shoppers and farmers. 

Thank you again for the opportunity to testify before this Committee. I look forward to working with each of you this year to pass a common-sense solution that 

meets the demands and expectations of the American people. 

I am pleased to answer any questions. 

The CHAIRMAN. Thanks, Chris. I appreciate that. The chair 

would remind Members that they will be recognized for questioning 

in order of seniority for Members who were here at the start of the 

hearing. After that Members will be recognized in order of arrival, 

and I appreciate Member’s understanding. 

With that, I would like to yield my 5 minutes to the Subcommittee Chairman Rodney Davis. Rodney? 

Mr. DAVIS. Thank you, Mr. Chairman. Obviously with a constituent in the room, I would like to start my questioning with Mr. 

Clarkson. Again, thank you for being here. Thank you for your testimony. In your testimony you touch on this, but do you prefer the 

44 

producers be able to voluntarily market their products as biotech, 

non-biotech, or both? And should either of these marketing claims 

be mandated? 

Mr. CLARKSON. I prefer that the farmer have the choice to pick 

his market. I wouldn’t mandate. I would do what I could to protect 

the integrity of his product. It gets into the issues of cross-pollination and seed purity and other issues, but it should be an entirely voluntary process. 

Mr. DAVIS. Well, thank you very much for your response. In your 

testimony you also say everyone would win if we could lower the 

temperature on biotechnology. And this is a very important point 

that many touched on in their opening statements. 

Can you expand on this, Mr. Clarkson, and as the labeling debate continues, what advice do you have in communicating with 

the many stakeholders that could help bridge the gap between 

those who support biotech and those who don’t? 

Mr. CLARKSON. Well, the emotion of this issue carries a lot of 

people away to unfortunate behaviors which my colleague on the 

panel was subjected to last year. The fundamental interest here is 

the consumer making the choice. Consumers don’t choose their food 

entirely on safety at all. They make consumer choices on all sorts 

of values. I think that should be honored. It has created a market 

for the farmer that currently is paying him about a 15 percent premium, ten to 15 percent premium to offer non-GMO and three 

times as much as conventional to offer organic products in the marketplace. 

If we can respect the fundamentals, the interest that seems to 

be driving the emotion around the marketplace is to be able to detect GMOs in at the grocery store. If we can set up a voluntary labeling program, we define it and make it standard around the 

United States, that gets everybody paddling the canoe in the same 

direction—— 

Mr. DAVIS. Well, thank—— 

Mr. CLARKSON.—while people make their choices. 

Mr. DAVIS. Thank you very much for that response. Ms. Lidback, 

I have three school-aged children at home. There is obviously a lot 

of false information about the health and safety of biotech crops 

that is driving this debate, and we both saw that after the Subcommittee hearing last year. Can you expand on why these products are safe for your children and also mine? 

Ms. LIDBACK. Thank you. Yes, food made with genetically engineered crops happen to be the most rigorously tested portion of the 

food that is available out there. People can rest assured, I can rest 

assured, you can rest assured, that they are safe. They are no more 

risky than other conventional non-GMO or organic counterparts. 

Mr. DAVIS. Okay. Thank you. Mr. Policinski? Did I pronounce 

that semi-correctly? 

Mr. POLICINSKI. Yes. 

Mr. DAVIS. Thank you. Thank you. You run one of the largest 

farmer-owned companies in the country. Why has your company 

made investments in biotech and what does labeling mean for food 

and agricultural companies like yours? 

Mr. POLICINSKI. Our farmers have embraced biotechnology faster 

than any technology in history, and they have done that because 

45 

the benefits to their economics on farm, the environment, less land 

and water use, less crop protection products use, and the consumers are so readily apparent. So this technology is central to the 

way our farmers, our farmer-owners, operate their businesses. So 

we have embraced that in terms of the way we manage our business. We have a business unit called Winfield Solutions that sells 

seed and crop protection products to farmers. We sell all types of 

seed and crop protection products to farmers. We sell biotechnology, biotech plants. We sell conventional seeds. So we believe in farmer choice, and it has been a good business for our 

farmers. It has been a good business for us, and it is good for the 

consumer in terms of the benefits of lower costs and a lower environmental footprint. 

Mr. DAVIS. Well, thank you very much. Thank you all for your 

testimony. And Mr. Chairman, I have one question for the panel, 

but I will wait until my turn. So I will yield back. 

The CHAIRMAN. The gentleman yields back. The Ranking Member is recognized for 5 minutes. 

Mr. PETERSON. Thank you, Mr. Chairman. Mr. Clarkson, critics 

of the voluntary labeling say that it will not address the consumer 

demand for labeling and will create additional consumer confusion. 

And I frankly can’t understand that. The USDA’s organic program 

has been out there and it seems to me it has met consumer expectations. If it hasn’t, how can we have a $35 billion organic market 

in the United States? What am I missing here? 

Mr. CLARKSON. Congressman, I don’t think you are missing a 

thing. I think you are right on the money on that. I think the organic program is certainly getting support because consumers believe in it. It is a voluntary label. I think a voluntary label would 

take care of the underlying consumer interest in knowing and not 

punish the industry and others that don’t want to be involved with 

the cost. I don’t think there would be any additional cost because 

the people that want that market are already labeling for that 

market. It is already taken into account. 

Mr. PETERSON. Thank you. Mr. Policinski and Mr. Dempsey, if 

states like Vermont, are going off and doing their things like the 

mandatory labeling there, and we hope that that gets overturned 

in the courts, which some people are optimistic about, but if it 

doesn’t, what is going to happen with companies such as yours that 

have labeling for the whole country? Are you going to create a separate label for Vermont where, if they end up with their law being 

upheld, are you going to run a separate run in your companies just 

for Vermont? Or are you going to basically say we are not going 

to sell in Vermont, which is what I would hope you would do. 

Mr. POLICINSKI. Congressman Peterson, we haven’t yet decided. 

I think Mr. Dempsey outlined the three choices very well. First is 

to stop selling to any individual state, second is to relabel our products at considerable expense, and third is to re-engineer our supply 

chain and reformulate our products at even greater expense. None 

of those are good choices. All of those choices would result in either 

denying consumers access to products which we wouldn’t support, 

but they would also yield the other two choices short of not selling 

in any one individual state are much higher costs passed along to 

consumers. So I would agree with Mr. Dempsey’s outline of the 

46 

three basic choices. As a company, we haven’t yet decided. There 

are no good choices in any of those. 

Let me outline as well that the idea of not selling a product in 

Vermont is also a very difficult choice because we would be liable 

for any of our products that might find their way into Vermont, 

and the cost of that liability is extraordinary. I think the penalty 

is $1,000 per item. So even if you said you wanted to pursue that 

first option, it is really not a viable option, which is why we so 

strongly support a Federal voluntary labeling law here. 

Mr. DEMPSEY. I would agree. Obviously we have, as I said, companies that are multi-category, multi-billion dollar companies and 

small family-owned businesses. This is going to be much harder for 

that small family-owned business with one plant to do anything to 

adhere to the Vermont law as well as sell their product across 

other states. So those options are much more limited for the small 

manufacturer family-owned businesses than they would be for a 

multi-plant, multi-billion dollar business. So I would be repeating 

what we just already said to go further, but it would be a difficult 

decision for every company to decide what to do in Vermont. 

Mr. PETERSON. I thank both of you. Dr. Federoff, am I saying 

that right? If a voluntary non-GMO labeling program were to move 

forward, can we define what a GMO is so that the consumers 

would understand the label? 

Dr. FEDOROFF. I would hope we could do a better job because the 

label, genetically modified is, as several people have pointed out, 

misleading. We have been genetically modifying crops and animals 

for many thousands of years. 

I think that Mr. Schmidt’s suggestions are very good ones. Biotechnology is a little bit less of a negative buzzword. 

Mr. PETERSON. Well, I don’t know where the GMO came from. 

I guess it was Europe, and there was obviously a purpose behind 

it. So thank you, Mr. Chairman, I yield back. 

The CHAIRMAN. The gentleman yields back. Mr. Gibbs, for 5 minutes? 

Mr. GIBBS. Thank you, Mr. Chairman. It is a great panel, and 

I want to commend Ms. Lidback for your work and also a young 

couple starting in the agriculture industry, that is commendable, 

and you say you have two kids, 2 and 3. Really, if more kids could 

grow up on the farm, it would be great for our country I believe. 

I want to kind of look back for a little perspective. Back in 1950, 

my understanding is the national corn yield was 50 bushels to the 

acre. In 1975, 40 years ago when I started farming, my goal was 

to have 100 bushels an acre. And now we are pushing 200 bushels 

an acre here nationally. Anything under 150 bushel would be considered a disaster. I know Land O’ Lakes is shaking his head there. 

And it was pointed out, this change from 1950 to 1975 where we 

doubled the production, I always contend it is from figuring out soil 

nutrient fertility, also hybrid selection, natural hybrid selection, 

and then I would contend from this period forward now where we 

have pretty much doubled the yield again, it is because we have 

been able to select the genetics in a faster way like Dr. Federoff 

says. We have been doing it for thousands of years or at least from 

our perspective, 100 years or so. So we have been able to identify 

those genes and do it exponentially in the lab. So it is really no difVerDate Mar 15 2010 11:51 Jun 08, 2015 Jkt 041481 PO 00000 Frm 00050 Fmt 6633 Sfmt 6601 P:\DOCS\114-06\93965.TXT BRIAN
47 

ferent. So that is one of the reasons why the scientists say it is 

safe, because we know what those genes are. We can identify them. 

But the benefits, we are growing—we are having 14 billion bushels 

of corn crops a year now annually on less acres. Every year it is 

less acres. So it is really a food security issue. The American farmers have provided the food for this country, and we also export 1⁄3

of it. It is a food security yield but it is about yields. And if we 

didn’t have what has happened in the last 25 years of this yield, 

we would be having food shortages. Do you agree with that, Mr. 

Policinski? 

Mr. POLICINSKI. Yes, I do. I think there is a tremendous productivity story here. In fact versus 2–21⁄2 generations ago, we are growing 61⁄2 times more corn on 13 percent fewer acres. 

We often talk about that in terms of per-bushel yield, but I will 

tell you, there is a tremendous sustainability story there in terms 

of less water and land use, less protection and crop—— 

Mr. GIBBS. Yes, you say that. In my 40 years now—I just figured 

it out. It has been 40 years since I have been farming. The crop 

protection, the herbicides we used back then, had residuals. They 

didn’t break down. They weren’t biodegradable. The crop protection 

we are using now is virtually—a lot of them don’t have any residuals. I tell people that come to my farm, it is interesting. You see 

my neutral soybeans out there, and we have to—we do a burndown application before we plant, and then sometime in June, we 

come through and we apply a herbicide again, but we have to time 

it in such a way that it is done right before, to kill those weeds 

that came up, and then when the soybeans, you get this canopy to 

provide the shade so that new weeds won’t come because there is 

no protection if we miss that timing. 

And so we are using safer herbicides, and we are increasing the 

yield and also protecting the environment that way. 

I would also go on to say that I agree with all of the panelists 

of the voluntary aspect because better than 80 percent of the grain 

grown in this country—was mentioned—is genetically modified in 

the lab. Even though it is natural selection, it was just done in a 

lab in my opinion. You would have to label everything if it is mandatory, genetically modified, which just scares consumers and it 

puts this country at a risk of food security. And it hurts the environment in the long run because we go backwards. 

So I support voluntary labeling. If a producer out there can find 

a niche market—I am sure there is a market out there. We see it 

in organics, and they can demonstrate that it hasn’t been modified 

in the lab, that they can have that market. But they can put on 

there that it is not—I would say artificially modified—I don’t know 

what the term is—versus naturally hybrid selection like we did 

back in the 1960s and 1970s and the 1980s. 

So I want to commend you all for your testimony. Dr. Federoff, 

go ahead. 

Dr. FEDOROFF. What people don’t realize that it is in the 20th 

century we used chemical mutagens and radiation to hasten the 

mutation process. So there isn’t back then just breeding and now 

this artificial method. That is one point. The second point is that 

people have looked at the amount of genetic change that accompanies using these different techniques, and the evidence supports 

48 

the conclusion that these are the safest and least-disturbing techniques, whether you are looking at the genetics or the epigenetics. 

That is the kind of control level of genetic expression. 

So these really are the best techniques, the least disturbing, having the lowest probability of causing a problem that we have ever 

developed. 

Mr. GIBBS. Well, I thank you and the panelists and your good 

work. Thank you, Mr. Chairman. 

The CHAIRMAN. Thank you. The gentleman yields back. Mr. 

McGovern, for 5 minutes. 

Mr. MCGOVERN. Thank you, and thank you all for your testimony. Let me begin by saying everybody is reading from the same 

sheet of music here, but nobody here is in favor of mandatory GMO 

labeling, am I correct? If we are going to have a thoughtful discussion on this, we ought to have more of a diversity of opinion at a 

hearing like this because it is important to hear all sides of the 

subject. 

But let me begin by saying that I am a believer in science. I rely 

on the scientists to give me informed information. That is why I believe in climate change as well. That is a subject for another hearing. But the point of the matter is that there is great value in our 

sciences. So I am not here to demonize GMOs or the technology behind them. I don’t think anybody should be fear-mongering about 

GMOs. I don’t think anybody should be threatening anybody who 

wants to produce GMO crops or whatever. We ought to be able to 

have a more kind of a measured conversation on this. 

But I do believe in transparency, and I do believe people ought 

to have a right to know what they want to know. The consumers 

ought to have the right to know what they are eating and what 

they are feeding their kids, and how they use that information in 

their food choices is up to them, not up to us, but up to them. 

There is great confusion with the labeling system now. I mean, I 

saw a poll from Consumer Union that found 60 percent of consumers believe that products that say natural means non-GMO 

when in fact that is not the case. More consumers think natural 

means non-GMO than think organic means non-GMO. 

The current system, and even kind of a voluntary system is lacking. We were told that changing labels will cost food companies. 

Food companies change their labels all the time. It is a false argument to say that labeling requirements will drive up the cost of 

food. I do believe there ought to be a national standard because I 

do understand the patchwork of various state initiatives is not in 

anybody’s interest. 

In response to the idea that if a product said, ‘‘contains GMOs’’ 

or whatever the label would be, that somehow that would discourage people from buying those products, you have 64 country around 

the world already require labeling of GMO foods. Brazil, a country 

whose consumption patterns are similar to those in the United 

States, has required GMO labeling since 2001. And from what I 

can tell, there has been no significant change in consumption patterns. 

But let me just raise one point here. I am deeply troubled by Friday’s announcement from the World Health Organization’s International Agency for Research on Cancer, that glyphosate, the herVerDate Mar 15 2010 11:51 Jun 08, 2015 Jkt 041481 PO 00000 Frm 00052 Fmt 6633 Sfmt 6601 P:\DOCS\114-06\93965.TXT BRIAN
49 

bicide most commonly used on GMO crops, is a probable human 

carcinogen. Now, IARC is made up of some of the most renowned 

scientists in the world, and if they are saying that glyphosate is a 

likely cause of cancer, I mean, that may be something that people 

want to know. 

So I guess my question is, because GMO corn and soybeans, for 

example, are designed to withstand glyphosate, the use of that herbicide has grown dramatically in recent decades, and given Friday’s 

announcement, I mean, don’t you think people should have the 

right to know how their food is grown and make their own decisions? Anybody wants to—— 

Mr. POLICINSKI. Well, let me just respond because there are a 

few things that I would agree with. First, I agree there is great 

confusion in the marketplace right now, and state level labeling 

laws would increase that. I agree, and the Pompeo bill that was offered last year said we need to define natural, and that would be 

important to do. I think that a voluntary national standard would 

provide consumers with that choice and the information they need 

to make a decision. I think to do it the other way around and to 

mandate the label does stigmatize the ingredient and infers there 

is something that must be wrong with it versus how we have done 

organic in a certified USDA organic program. We didn’t ask all food 

to be certified non-organic to be able to communicate to consumers 

the value of the choice to make an organic food. 

There is some agreement that we do have tremendous confusion, 

and that is why we support very firmly a national labeling legislation that has voluntary options. I do agree that we do need to define natural, and that is in the proposed legislation. But I don’t 

agree that it should be mandatory because that does stigmatize—— 

Mr. MCGOVERN. Does anyone want to talk about the glyphosate 

finding? I mean that is a legitimate scientific organization. 

Dr. FEDOROFF. I am glad to address that. That is not based on 

any new data, and it is not the case that there have been many, 

many studies on glyphosate. We do have an Environmental Protection Agency, and they require considerable testing. So the organization has labeled it as—— 

Mr. MCGOVERN. Probable. 

Dr. FEDOROFF. Possible carcinogen doesn’t mean anything has 

changed or any new data has been produced. 

Mr. MCGOVERN. But I guess the point is, shouldn’t consumers 

have a right to be able to know that? I mean, that is the—— 

Dr. FEDOROFF. If there is evidence that it is a carcinogen, yes. 

I think that is correct. But there have been so many studies over 

the years on this particular compound that have failed to identify 

any carcinogenic potential that for one group to say, ‘‘Oh, well, it 

just might be, then do we put that on a label?’’ I mean, this doesn’t 

make any sense. 

The CHAIRMAN. The gentleman’s time has expired. Mr. Gibson, 

for 5 minutes. 

Mr. GIBSON. Well, thank you, Mr. Chairman. I appreciate the 

hearing, and thank you to the panelists, too, for being here today. 

I believe that people have a right to know what it is that they 

are consuming, and I also feel very strongly about science and recognize the fact that we have avoided famine, because as was menVerDate Mar 15 2010 11:51 Jun 08, 2015 Jkt 041481 PO 00000 Frm 00053 Fmt 6633 Sfmt 6601 P:\DOCS\114-06\93965.TXT BRIAN
50 

tioned, we have modified over the years. So I recognize that as 

well. 

I represent 11 counties in Upstate New York. I am a fervent and 

a strident advocate for my farmers. Ensuring the viability of our 

family farms is critical, a principle that we can’t drop as we move 

forward reconciling right-to-know and science. And so I thank Ms. 

Lidback for being here today, and thank you for your testimony. 

I also have tremendous faith in the American people that empowered with information—I guess I don’t agree with some of the 

assessments that they would change their consumption habits. I 

think that they will make good choices. And so I just want to put 

that on the record, too. As it relates to right-to-know, if we thought 

about it more broadly, we get fixated on labels immediately. I 

would be interested in the panel’s response to the possibility of 

right-to-know with an approach that provided details on modification on a website where individuals could go to get information. I 

would be curious to know what their reaction would be to that 

technique. 

Mr. POLICINSKI. Congressman, I would like to respond to your 

question because there is a desire in the industry to engage with 

consumers around this great dialogue where their food comes from. 

But we want to do it in a science- and fact-based way. This actually 

is part of that, having an orderly Federal law that is voluntary 

around labeling GMO products, would create an environment that 

we can engage with consumers in a constructive way. There are a 

number of things that are going on in a variety of industry association, two that I am part of, the National Council of Farmer Cooperatives and the Grocery Manufacturers Association. Everything 

from facts up, from to a discussion of how we can do exactly what 

you have described, to engage consumers in a dialogue, which is 

bigger than a package panel, regarding where their food comes 

from and help them understand that there are a lot of modern 

business practices that give us the safest, lowest-cost, most-abundant food supply in our history. 

So that is under way, and this is part of that process, to create 

an orderly environment to engage consumers in that discussion. 

Mr. CLARKSON. Congressman, when we receive an order from a 

Japanese food company, it often comes with a list of 100+ chemical 

residues that we are supposed to test for. Realistically, it would 

cost about $16,000 to $20,000 to test grain going into a container, 

which is more than the grain than the container would be. But that 

is because they are concerned about residues. I fully expect we will 

be asked to certify that we are delivering products that didn’t have 

Round-Up in it, glyphosate in it, within a matter of days. Everybody supports science-based, but science doesn’t speak with a single voice, and that confuses people. It is beyond my capability to 

know which scientific argument is right. So I prefer to make the 

distinction, if enough people have asked for it, and let them decide 

going to the Internet and gathering what information from whatever source and making their consumer decision. 

Ultimately, the market will decide. The market has decided right 

now to pay a farmer $3.80 in Illinois for conventional corn, about 

$4.20 for non-GMO, and about $12.50 for organic. So the market 

is speaking with its dollars and asking people to perform. I think 

51 

labels help in the grocery store, and science is an excellent foundation, the only foundation, but just what does science say is confusing. 

Ms. LIDBACK. I would like to chime in. Congressman, I walked 

away from the Subcommittee hearing last year feeling like absolutely consumers have a right to know. No one here is contesting 

that statement. And in fact, since then, more and more resources 

have popped up just exactly the way you have described them, 

websites with good information, including one from my alma mater, 

Cornell University has a great website, the Alliance for Science, 

that explains a bit more in detail some of these growing processes 

and what the details are that lead to farmers making the choices 

to use the biotechnology that they do in their everyday practices. 

Dr. FEDOROFF. Maybe I would just like to make a point that addresses Mr. Clarkson’s comment about how do we decide. In science 

we have a concept called the weight of the evidence. If you have 

two studies and one says something is dangerous and one says it 

is not, you don’t know what to decide. If ten studies say it is not 

dangerous and one study says it does, you have a pretty good 

chance of believing that one. If 100 studies or 1,000 studies say it 

is not dangerous and one still keeps saying it is dangerous, you are 

very comfortable going with the weight of the evidence, which is on 

safety. 

Now, in this particular area of GMO, one study often gets disproportionate attention. There is a famous study by a man by the 

name of Seralini who claimed that glyphosate caused tumors in 

rats. The study was retracted. The data were terrible, but that 

dominates people’s thinking. Should we bow to that or should we 

go with the weight of the evidence? 

Mr. GIBSON. I know my time is expired, Mr. Chairman. I want 

to make one final comment and that is that arming people with the 

information is really what we are talking about here. My family—— 

The CHAIRMAN. The gentleman’s time has expired. Really, we 

have other folks, Chris. 

Mr. GIBSON. You bet. 

The CHAIRMAN. So Mrs. Kirkpatrick for 5 minutes? 

Mrs. KIRKPATRICK. Thank you, Mr. Chairman, and I have for the 

record a report that I would like to enter from Cardinal Peter 

Turkson, President of the Pontifical Council for Justice and Peace. 

The CHAIRMAN. Without objection. 

[The document referred to is located on p. 79.] 

Mrs. KIRKPATRICK. I want to read a portion of that, and then I 

will ask my question. He says, ‘‘hunger in the world is a very serious injustice that shows fundamental disrespect for human dignity. 

Pope John Paul II called it the first and fundamental form of poverty. Persistent hunger, starvation, and malnutrition represent a 

global failure of humanity that, to our shame, has dragged on for 

decades. It is a plague and a long-term indicator of a system that 

does not function properly. Some point to the economic crisis of recent years as the reason why the world cannot do better, but that 

is just an excuse. Food insecurity has persisted for decades through 

prosperous times as well as more difficult times.’’ 

52 

And the panel, I want to explain to you. I represent the Navajo 

Nation in Arizona where household food insecurity is above 75 percent. And so my question is, do you think it is possible to feed a 

world population of over nine billion people without the use of genetic engineering and the full use of agricultural technology? And 

I will just open that up to the panel, whoever wants to address 

that. 

Mr. POLICINSKI. I would be glad to offer my perspective which is 

based on a few things, but I do agree that we have talked about 

this biotechnology and biotech traits in large part in farmer terms, 

yield per acre. We haven’t done enough of a discussion around the 

benefits to the environment, less land, less water use, less crop inputs, more benign crop inputs. 

We haven’t talked enough about it in terms of cost and the benefits to consumers, in terms of lower-cost foods, because we get a 

crop—just a couple of years ago we had the drought. We got a crop. 

The weather patterns were not that dissimilar from the late 1980s 

when we didn’t get a crop. So we don’t talk enough about the benefits beyond yield per acre. 

I think you raised another benefit and that is the ability to feed 

the soon-to-be nine to ten billion people on the planet in an increasingly productive and sustainable way and adapt to climate change 

along the way. I do not think we can feed that nine to ten billion 

people that are soon to be on the planet without chewing up a lot 

of natural resources without biotechnology. 

Mrs. KIRKPATRICK. Anyone else on the panel want to comment? 

Ms. LIDBACK. I would, Congresswoman. I appreciate your sentiment. And just for example in our country alone, you must be 

aware, that less than two percent of our population lives on farms. 

So in my opinion, we are going to need every farmer that we can 

get, organic, non-GMO, conventional, whatever it takes, and certainly biotechnology offers a tremendous amount of tools beyond 

genetic engineering in order for us to do the best that we can. 

Mrs. KIRKPATRICK. Anyone else? 

Dr. FEDOROFF. Yes, I would like to address it. Today we produce 

enough calories to feed everyone in the world a reasonable number, 

and it is a matter of unequal distribution of resources. Today if you 

have the money, you can buy food. We are looking at a future 

where we do not know what the impact of climate change will be. 

It is already negatively impacting our productivity worldwide. 

There are still places in the world that productivity can be increased by conventional methods, but in the end, if we want to reduce the footprint of agriculture even further—and conventional 

breeding and mutagenic breeding has done a phenomenal job of reducing the required acreage to grow a certain amount of food. In 

the future, the real barrier is the ability of plants to collect sunlight and drive, to convert—it uses sunlight to convert air and 

water into foodstuffs. In the next breakthrough, the next big breakthrough has to be in the efficiency of photosynthesis. We can’t do 

that by conventional techniques. We will have to understand, we 

will have to use all of the science tools that we have including genetic modification of plants to make the next big breakthrough that 

will allow us to reduce the footprint, make agriculture more sustainable, and yet continue to increase the food supply. 

53 

Mrs. KIRKPATRICK. Thank you very much. I appreciate the testimony that you are giving us today, and I yield back. 

The CHAIRMAN. I thank the gentlelady. Mr. Benishek, for 5 minutes. 

Mr. BENISHEK. Thank you, Mr. Chairman. Thanks to the panel 

for being here today. Dr. Federoff, are the changes that have been 

made in the lab, treatment of plants, changed their properties any 

different than the way we have been doing it for thousands of 

years? 

Dr. FEDOROFF. Yes. They are very much more precise because in 

the last half-century, we have learned more about what genes are, 

what they do, what they do in a different context than we ever 

knew before. So in a way, we were stumbling blind. We used 

chemicals and radiation kind of as a shotgun. Now we can take just 

one gene, we know what it does, or half-a-dozen genes. It doesn’t 

matter. But it is a small number of very well-defined genes that 

will confer new properties on plants and animals. This is something we never could do before. 

Now, does that mean that we will never create a plant or an animal that is substantially different from what was before? No. So 

regulation really needs to be based on the properties of the organism, the environment it is going into, and what is being added. 

And all of that, I have to—I can’t resist pointing out that that is 

exactly what the National Academy of Sciences recommended in 

1987. 

Mr. BENISHEK. Well, thank you. I appreciate that. Going back, 

you are exempt from the rules apparently in Vermont, is that correct? 

Ms. LIDBACK. Currently, yes. 

Mr. BENISHEK. So if you had to comply with those rules, would 

you be able to keep farming? 

Ms. LIDBACK. That is an interesting question. It sort of depends 

on what kind of a price we would then be able to receive. So for 

example, generally speaking, when you convert to the organic, you 

also are then able to collect an organic premium in the market. So 

probably initially no, but if the change were to happen overnight, 

the increasing costs I detailed in my earlier statement would put 

us right out of business. 

Mr. BENISHEK. I guess I don’t understand. There is labeling requirements in the State of Vermont except that the Vermont producers don’t have to—is there only certain producers don’t have to 

comply or is it all Vermont producers? 

Ms. LIDBACK. It is by industry, and it is really about the food 

product itself. So the dairy and meat would be exempt as well as 

food sold in restaurants would be exempt from being labeled, 

whether it was produced using genetically engineered ingredients 

or not. 

Mr. BENISHEK. Let me ask a question, this time of the panel perhaps. Does anyone disagree that a voluntary labeling Federal rule, 

would that not give the consumers all the information they need 

to know? I don’t understand any reasoning against that. Mr. 

Dempsey? 

Mr. DEMPSEY. We do think that is exactly the case. I mean, we 

have a template for that. The organic labeling has given the conVerDate Mar 15 2010 11:51 Jun 08, 2015 Jkt 041481 PO 00000 Frm 00057 Fmt 6633 Sfmt 6601 P:\DOCS\114-06\93965.TXT BRIAN
54 

sumer who wants that product all the information they have needed. As somebody said earlier, we don’t force companies to form labels that say non-organic. So that doesn’t make much sense along 

that pattern that we would change anything different for GMO-free 

labeling. 

The information is there on a voluntary basis. If somebody wants 

it, they seek it out and purchase that product. 

Mr. BENISHEK. Right. Right. Anybody else have a different opinion? 

Dr. FEDOROFF. My view is that if more information were provided, if the law stipulated that you had to put together a lot more 

information to offer the consumer, then it would depend on who 

was doing it, how it was done, how accurate it was, and so forth. 

Mr. BENISHEK. All right. Thank you. 

Mr. POLICINSKI. No, I would agree, just something to add to Mr. 

Dempsey’s statements, that I would agree. We support the Federal 

voluntary labeling program. I think it does allow us to provide consumers a choice, but importantly it allows us to continue to engage 

with consumers in a dialogue regarding where their food comes 

from, which is important. I just don’t think the front of the label 

is where it should be. And as I said earlier, there are a number 

of efforts going on in the industry, in individual companies and 

within industry associations to further that desire to engage with 

consumers around where their food comes from in the modern business practices that give us this great lowest-cost, most-abundant, 

safest food supply that we have had in our history. 

Mr. BENISHEK. Thank you. I am out of time it seems. 

The CHAIRMAN. The gentleman’s time has expired. Mr. Aguilar, 

for 5 minutes. 

Mr. AGUILAR. Thank you, Mr. Chairman. Ms. Lidback, in your 

testimony you mentioned that the marketplace is already sorting 

out some of the non-GMO labeling without legislative mandates. I 

wanted to just get your feeling and your perception and that of 

your peers I suppose on the Whole Foods discussion, that in 2018 

they plan to have all their products in the United States and in 

Canada labeled. 

Can you give the Committee your views on these kind of privatesector driven initiatives? 

Ms. LIDBACK. Thanks for your question. Yes, it is a topic of—oftentimes we talk about it a lot, my peers and I. And one of the 

frustrations we have is sort of this clash between providing factual 

information and wanting to market a product. It was Mr. McGovern earlier that talked about transparency and consumers wanting 

transparency when there are a lot of different conflicting ideas and 

statements out there. 

For example, a great example is in chicken. I just learned you 

are not allowed to label chicken packages as antibiotic-free. You 

can use the terms grown without the use of antibiotics, but you 

can’t label it antibiotic-free. And there are various restaurants in 

the country that will have on their menus antibiotic-free chicken. 

So in my opinion, that is misleading. That is misleading the consumer. So the Whole Foods effort to sort of have a labeling initiative, I don’t necessarily agree with it. They are listening to their 

customers, certainly, and they are trying to provide what they 

55 

want, but at the same time, are they stigmatizing genetically engineered foods? And that is what the debate surrounds. 

Mr. AGUILAR. Thank you. I appreciate the answer. 

Dr. FEDOROFF. Let me just add to that that many of the products—since I know what GMOs are on the market and what are 

not, many of the products that they are attaching that label to 

today are not genetically engineered, never have been. Okay? So it 

is basically deceptive marketing. 

Mr. AGUILAR. Thank you. Mr. Policinski and maybe Mr. Clarkson 

can also handle this next one. Sir, you mentioned earlier that there 

are some industry components. What I heard you say was there are 

some industry components within possible legislation that you 

could support, such as the definition of natural, you mentioned, in 

addition to the voluntary labeling that we have heard extensively. 

What are some other policy components that you feel industry can 

get behind showing consumers as you mentioned more about where 

their food comes from? 

Mr. POLICINSKI. Well, I don’t know if it is policy or not. I think 

policy that we have had in this country and our regulatory agencies 

have been very fact- and science-based, and that needs to be continued. We need to be very fact- and science-based in the policies 

that do come out and the regulations that do come out from our 

regulatory bodies. And I would say that needs to be continued, and 

in large part, that is what we are talking about today. 

Other engagement that is going on is voluntary and by individual companies, and what I am describing and to some degree 

even your question about Whole Foods is individual companies can 

choose to market how they choose to market, and consumers could 

choose to make their own decisions based on that. I do think that 

we are seeing very healthy outgrowth of this conversation and others. Consumers are more interested in where their food is coming 

from, and we will see more, I know we will see more, organizations 

on a voluntary basis provide that information on websites and 

through a variety of means. 

So I don’t think that is a matter of policy. I think that is the individual companies trying to be very transparent with their consumers. 

Mr. AGUILAR. Sure, but one of the panelists just said that it was 

deceptive. So you are saying that we might gravitate toward that, 

but one of the panelists just mentioned that those efforts were deceptive. 

Mr. POLICINSKI. Yes. Well, let me be clear. I am not for deceptive 

marketing in any way. 

Mr. AGUILAR. Right. 

Mr. POLICINSKI. The record will reflect that, right. And nor am 

I accusing anybody of that. I think the notion is just increased 

transparency of where your food comes from. There are a lot of 

modern business practices that contribute to, as I have said before 

and we need to keep saying it, the safest, lowest-cost, most-abundant food supply in our history and arguably in the world. 

Biotechnology is just one of those modern business practices that 

yields that statement. There are other practices such as advanced 

breeding on dairy farms that lead to very efficient dairy cows that 

56 

produce milk more—there are a lot of practices that we need to 

talk more about. 

Mr. AGUILAR. Mr. Clarkson, do you want the last comment? 

Mr. CLARKSON. Yes, Congressman Aguilar, one of the key policy 

issues is to define what we mean by the term. When we end up 

with multiple definitions, the market is in great confusion that 

causes trouble for all the players. 

So the other thing is in respecting the choice of one farmer to do 

something and farmers who are neighbors need to work together. 

And it would be nice to have some policies that would encourage 

that. 

Mr. AGUILAR. Thank you so much. Thank you for your answers. 

Thank you, Mr. Chairman. 

The CHAIRMAN. Mr. Allen from Georgia. 

Mr. ALLEN. Thank you, Mr. Chairman, and once again, I appreciate the panel here and basically the comments that you have had 

about this particular issue. One of the things, Dr. Federoff, that I 

have been sitting here thinking about is as far as the testing of 

these products. Are there any risks for consumers to choose organic 

foods? 

Dr. FEDOROFF. Are there risks? 

Mr. ALLEN. Yes. 

Dr. FEDOROFF. To choose organic? 

Mr. ALLEN. Yes. 

Dr. FEDOROFF. Indeed. We share our pathogens with animals, 

and the primary tenant of organic farming is a prohibition on synthetic nitrogen fertilizers. They use green manure or cow manure 

or other manures. 

Mr. ALLEN. Right. Okay. 

Dr. FEDOROFF. Okay? And as I said, we share our pathogens 

with animals. And a number of the food poisoning incidents are 

coming out of organic farming. The outbreak that killed some 50 

people in Europe a couple of years ago was traced to organic 

beansprouts. 

Mr. ALLEN. Okay. 

Dr. FEDOROFF. And this is something that people are just simply 

not aware of. 

Mr. ALLEN. And that is what—— 

Dr. FEDOROFF. Now, properly treated manure is safe, but there 

is always that probability because there is no uniformity to that 

treatment. 

Mr. ALLEN. Ms. Lidback, I grew up on a dairy farm, and the best 

decision that my dad made was to get out of that business. And 

here you are, first-generation. I applaud you. I chose to be the 

clean-up person because I got to sleep a little later. And speaking 

of cow manure, I am in trouble there because that is what I did, 

is clean that place up every morning, every night. But I can tell 

you this, if they get too tough on you there in Vermont, you are 

welcome to come to the State of Georgia and we will do everything 

we can to help you do business down there. 

Ms. LIDBACK. Thank you. 

Mr. ALLEN. Yes, I will take any other comments. What we want 

is a solution to this and what is the Federal Government’s role in 

57 

this. We have less than about 21⁄2 minutes, and I would like to 

open it up. What do we need to do on this? 

Mr. DEMPSEY. Just one comment that Congressman Aguilar 

made that is important and is kind of overlooked in this Committee 

or even on the whole discussion and that is defining the term natural. Many of my member companies are in numerous litigation between the different perceptions of what is natural and what isn’t 

natural, and the part of the bill, my understanding is, that it mandates a Federal definition of natural. And certainly that is something that we would advocate very strongly that has to done. 

Dr. FEDOROFF. And of course, corn would be totally unnatural by 

any definition because we created it. 

Mr. ALLEN. Right. 

Mr. POLICINSKI. Congressman, not to be redundant, but I want 

to come back to the Pompeo-Butterfield bill that was offered before 

that by establishing a national voluntary standard does clear up 

confusion. It does provide consumer choice in the same manner 

that organic, USDA-certified organic does, and it does preserve 

farmer choice. It allows the marketplace to determine then the size 

of those businesses and the size of the use of that technology. 

There is a simple solution. 

Mr. ALLEN. Okay. 

Mr. SCHMIDT. If I could also add, too, in terms of my testimony 

and my history, earlier in my career I worked for the USDA Food 

Safety and Inspection Service and worked with many talented regulators, with the career staff, also at the Food and Drug Administration, and we have had a lot of discussion about who knows? Who 

do we trust? I mean, these are the people that tax dollars go to determine what is important health, nutrition, and safety information? They, as many have testified, can regulate within the current 

needs, and there can be more legislation. But in the meantime, 

those are the folks who make those important decisions. Otherwise, 

there is chaos out there if we let everybody make those delineations. 

Mr. ALLEN. Well, that is why I asked the question about organic 

side. It seems like the GMO is kind of on everybody’s radar. So let 

us let everybody know what is going on because the consumer does 

need to know and the consumer needs to have the ability to make 

that choice. Thank you very much, and I yield back the remainder 

of my time. 

The CHAIRMAN. The gentleman yields back. Mr. Scott, for 5 minutes. 

Mr. DAVID SCOTT of Georgia. Thank you, Mr. Chairman. This has 

been a fascinating hearing. I think basically what this boils down 

is do we have—because all of the consumers need to know what is 

in the food. It is basically whether it is one national standard or 

state by state. But there is another issue here that purveys, that 

runs from the farmer, the producer, all the way up to the consumer, and that is economics. Mr. Dempsey, you hit two very important points that we need to pay a little attention to. 

You mentioned in your statement that, first, 1⁄2 of your busi- nesses in your association earn less than $1⁄2 million a year, or should I say it was $100 million gross. And second, which means 

they are basically small businesses. And the other point was that 

58 

in some of these communities, that particular business is the primary source of employment. 

We ought to look at these two and how they basically impact. So 

tell us just how critical is the need for the Federal Government to 

intervene here with a national standard, rather than as it seems 

to be a state-by-state approach? What is that economic impact on 

the jobs and on small businesses? 

Mr. DEMPSEY. Thank you, Congressman. As I said, most of our 

businesses are smaller, family-owned businesses, second-, third-, 

fourth-generation. The snack industry is a very regional, localized 

business. So you have a lot of small manufacturers who are employing, the main employers, and the manufacturing process in 

their areas. 

To be able to basically navigate a list of state laws would take 

additional people, additional costs, or painful decisions to exit a 

certain market. And in many cases, those markets are the markets 

on the border that they would have a hard time complying with 

state-by-state laws, especially if those laws have different nuances 

and different regulations. 

So the hard decisions are you sell or you stop manufacturing and 

walk away. 

Mr. DAVID SCOTT of Georgia. Okay. So the impact would be considerable? 

Mr. DEMPSEY. The impact would be considerable both in more 

warehouse space, more SKUs, more film, a greater distribution 

burden based upon more SKUs on a truck. It would be significant, 

yes. 

Mr. DAVID SCOTT of Georgia. All right. And Mr. Policinski. 

Mr. POLICINSKI. Yes. 

Mr. DAVID SCOTT of Georgia. Policinski. 

Mr. POLICINSKI. Perfect. 

Mr. DAVID SCOTT of Georgia. Wonderful. Tell me, we haven’t discussed much, but tell me about science-based? What exactly is 

science-based voluntary labeling and just how critical is a voluntary label to your business? 

Mr. POLICINSKI. Yes. First, science-based: Dr. Federoff did a good 

job talking about science-based decisions and how they are made. 

I think that as it relates to this topic of biotechnology and biotech 

traits, clearly the weight of the sciences, that the technology is 

safe. And that has been reinforced by a variety of agencies over 20 

years, thousands of studies. So that is the first point. And our company is very interested in that as is the entire food industry. 

Second, the voluntary national labeling standard in the PompeoButterfield bill just makes order out of a potentially chaotic situation of state-by-state labeling. That is, as you have heard from Mr. 

Dempsey, a situation that is not just another label. It is often characterized as that. And we do have products on the marketplace 

that are modified at the end of the system, for a new flavor, for 

example. But this change would extend all the way back through 

the food supply chain, right to the farm, the seeds that are chosen, 

the inventory of the seeds that are carried, the segregation of the 

crop, the transportation and distribution of a separate crop, the 

storage of those raw materials that are factories in separate facilities or storage areas, and then the segregation of the manufacVerDate Mar 15 2010 11:51 Jun 08, 2015 Jkt 041481 PO 00000 Frm 00062 Fmt 6633 Sfmt 6601 P:\DOCS\114-06\93965.TXT BRIAN
59 

turing process where we would have to run one technology and 

then clean the lines and then run another technology. I haven’t yet 

gotten to the forward segregation of the supply chain when we ship 

and distribute goods to the grocery store, which again, would require segregation. 

So the reason we are so supportive of a voluntary national labeling standard, the Pompeo-Butterfield bill that was offered last 

year, is it makes order out of that potential chaos or complexity 

and saves cost. 

Mr. DAVID SCOTT of Georgia. Thank you, sir. Thank you, Mr. 

Chairman. 

The CHAIRMAN. The gentleman yields back. Mr. Bost, for 5 minutes. 

Mr. BOST. Thank you, Mr. Chairman. First off, we probably went 

down this earlier, but I have been bouncing in and out of the room. 

Mr. Policinski, I would like to know if I can what your company 

is already—because Vermont has already passed a law. Are you 

preparing already and whether those costs that you are seeing and 

everything for one state and how you are going to handle it. Because I know we have talked about three different options that 

could be available. And where are you going with that at this time? 

Mr. POLICINSKI. Congressman, we did talk about this and the 

bottom line is we have not decided. There are no good choices. The 

three choices that are often mentioned are don’t ship to that state. 

Well, let me remind you that it is Vermont right now, but there 

are 26 states with pending legislation 

Mr. BOST. That is pending, yes. 

Mr. POLICINSKI. Second, labeling or segregation, the second and 

third choices, are difficult and costly as I just tried to explain. I 

also want to outline, and you may have been out of the room when 

we talked about this, that the idea of not shipping to a state like 

Vermont is really a non-starter in my opinion because of the legal 

liability. Let us say that was a choice we made, which I am not advocating that. We would still be held accountable for the fact that 

any of the products we might ship to neighboring states would 

show up in Vermont, and the penalty there is substantial. I believe 

the Vermont legislation has a penalty of $1,000 per day per SKU. 

That is a very substantial penalty. And by the way, that is enforced 

by the Vermont Attorney General’s Office, not the usual regulatory 

bodies that we work with because it is a violation of their law. 

So this is a very onerous situation. In all these paths, there are 

no good decisions there. They are all higher-cost decisions. 

Mr. BOST. Mr. Dempsey, did you want to—— 

Mr. DEMPSEY. Let me just add that supermarkets are national 

in scope as well. So the decision not to sell in Vermont is more 

complicated by how you bring your product to market, whether it 

is DSD, direct store delivery, or through warehouse distribution. 

If you are shipping product into an Ahold store in Massachusetts, 

the Stop and Shop, the chances of that product being sent erroneously to Vermont are magnified many times so that you have supermarkets that are operating in four or five or six different states 

but the burden, at least in Vermont’s law, is on the manufacturer 

to make sure that your product is not on those shelves. 

60 

It really becomes a liability to the manufacturer to even ship to 

a grocery store who is doing business in many states. So there are 

a whole bunch of repercussions that come out of that system. 

Mr. BOST. Just to continue and maybe even a statement as I am 

continuing questions, as we deal with GMOs, okay, in our own family, we have had to deal with gluten-free. My wife is gluten-free. 

Companies automatically, voluntarily, mark their products as gluten-free to encourage the sales of those to those who are. What 

would be the difference here in this, proposing that it would be voluntary? 

Mr. DEMPSEY. A broader statement is that companies make products to sell them, and whatever they can do to sell them, to entice 

the consumer to purchase them, they are going to do, whether it 

is to go for organic certification or whether it is to go for GMO-free 

or to manufacture products that are gluten-free. That information 

for that segment of the market is available from a marketing perspective of those companies. I see no difference between that and 

labeling everything else that this does contain gluten which is already in the nutritional—— 

Mr. BOST. That is right. Thank you, Mr. Chairman. I yield back. 

The CHAIRMAN. Thank you. The gentleman yields back. Mr. 

Walz, for 5 minutes? 

Mr. WALZ. Thank you, Mr. Chairman, and thank you all for your 

testimony. I think it is appropriate we are here. Tomorrow, March 

25, would have been the 101st birthday of Minnesota graduate and 

researcher, Norman Borlaug, so the discussion we are having falls 

directly into that. And I am appreciative of all of your time and effort. 

I would point out, and we are trying to get to the heart of this, 

our responsibility in Congress and our responsibility I would argue 

each of you is to define a problem, gather the information, and then 

make correct assumptions to that, and that is what we are trying 

to get at. 

January 2015 Pew Research Center study came out and showed 

that 89 percent of scientists believe that GMOs are safe, that 37 

percent of the public did. And I am going to come back to this. Yes, 

it is the 800 pound gorilla in the room, but the science and the preponderance of the evidence on this seems to warrant where we are 

headed. And we can get into this issue with Norman Borlaug’s position, with 12 billion people on the horizon for 2100, with the idea 

of how we are going to feed these people, but the problem we have 

in this place is you can’t be selective when the preponderance of 

the evidence shows something. And we do that. And there better 

be some soul searching on both sides of the aisle on this, as to let 

the science and the research drive us to come up with conclusions 

that work. And it is important, both for consumer safety and sense 

of fairness. 

The point was brought up, Mr. Clarkson’s point about ratcheting 

down the rhetoric is exactly it. But while I would make the argument, and I respectfully say, that the Chairman will run his Committee as he wants to. The questions that Mr. McGovern brought 

up, there should be some dissenting voices here or we end up in 

the situation like the outlandish situation in Florida where state 

officials can’t talk about climate change. Well, you give a percepVerDate Mar 15 2010 11:51 Jun 08, 2015 Jkt 041481 PO 00000 Frm 00064 Fmt 6633 Sfmt 6601 P:\DOCS\114-06\93965.TXT BRIAN
61 

tion that there is something you don’t want people to talk about. 

The evidence is clearly here that this is a way to feed people. It 

always has been. It is as much about Mesopotamia as it is about 

Monsanto, and that is the discussion that we have to have and 

have fairly so that we can make good decisions. 

And I am just troubled that we will go down a road. And there 

are some interesting things. Dr. Federoff, you brought up a good 

point. This one has always gotten me a little bit. Orange juice, for 

example, the Florida citrus folks, and they want to sell them. They 

label no GMOs on there. There are no GMO oranges. But here is 

the thing. There may need to be soon with the greening, the citrus 

greening disease, that is coming. So they may regret that decision 

that we are going to end up with those eventually, because of this 

new entrance into the environment. 

So I applaud all of you for being here. I would ask my colleagues, 

this gives us an opportunity to reset on some of these things. You 

can’t say, wow. The preponderance of the evidence and the scientific consensus is nearly whole on this issue and then walk to another committee room and have the exact same folks. Now, I get 

it. There is 11 percent of scientists here. I bet you they are not 

egronimous that are part of that. And to bring in someone else in 

an unrelated field and use that, that is the outlier that Dr. Federoff 

said, and we are going to base our decisions on that. Because I 

would make this argument here as feeding the world’s population, 

continuing to advance, continuing to do. The things you do is feed, 

clothe, and power the world, is going to involve a simultaneous discussion on climate change as it deals also with GMOs. And I wish 

we would have the maturity, the ability to be able to do what you 

all have clearly laid out today. 

And Ms. Lidback, I apologize for those people who would question you because you have the audacity to talk about the science. 

Trust me, it happens on other issues, too, unfortunately. But your 

willingness to come here and speak about this and talk about it, 

and the powerful thing here, too, just hearing this, the organic 

folks can make three times more. Well, good for them if they are 

going to be able to. And that is where we are at. We are not trying 

to stop that. 

But it is an important point and an important discussion that we 

cannot drive policy, whether it is on labeling or how we go about 

things that is not based on the evidence, that is not based on research, because that will lead to bad outcomes all the way around. 

So I want to thank each of you for being here. I want to ask my 

colleagues to have the courage to discuss these things as they are 

and then to come up with good solutions. And that shouldn’t be all 

that difficult. The good news here is that our producers continue 

to be the most productive in the world. Our researchers continue 

to be the most innovative, and we are able to provide the most 

abundant, safest, affordable food supply in the world, and we can 

do that around the world. So this is an important discussion. It is 

broad, it is important, and I applaud each of you for continuing to 

bring it to the forefront and hopefully we will get a good solution 

for you and for the consumers. Thank you. 

The CHAIRMAN. The gentleman yields back. Mr. Emmer, for 5 

minutes? 

62 

Mr. EMMER. Thank you, Mr. Chairman. And first to the panel, 

thank you for being here. And I apologize. I had to step out and 

come back. This is quite an operation in this place. You have several meetings all at the same time in different buildings, and there 

must be a better way to run the train station. 

Be that as it may, I respect your time. Listening to my colleague 

from Minnesota talk about there should be dissenting voices in the 

room, most of us would agree that if the world would just agree 

with our position, it would be a much better place to live in. But 

that doesn’t happen. And somebody can correct me, but it was 

Bobby Kennedy that said something to the effect that if you can 

get the American public, 80 percent of the American public to agree 

on anything, that should be considered unanimous. And in this 

case, when you have 90 percent of the science out there agreeing, 

that is pretty close to being unanimous. 

I want to go at this very quickly from a different—again, forgive 

me if somebody has already done this. I wasn’t here. So please be 

patient with me. I want to go at it from the specific costs and break 

it down by level. 

Mrs. Lidback, you are running a dairy operation. You have costs 

that are going to be added on for—you talked about the inputs 

when I was here earlier. You were talking about the cost of feed. 

Aren’t there other costs in terms of having to manage and record, 

get inspections, certification. Have you talked about those already 

today? 

Ms. LIDBACK. No. So beyond the feed, I mean, to keep milk segregated from cows fed non-GMO feed versus feed with GM, you 

would have to put in a second bulk tank and you have to put in 

a second grain bin. And so you are talking about capital expenditures, and as you can imagine, on a 50 cow dairy, there is really 

not a whole lot of extra left to go around to sort of fulfill those 

needs so that kind of consideration might be a deal-breaker for us. 

Mr. EMMER. Wow, and I was just thinking, labor. You and your 

husband are going to have to have some more kids in order to do 

this thing. 

Mr. Dempsey and anybody else, I want to go to the next level because we have the processors, those that have to put these products 

out. You talked about two lines, but it is much greater than that, 

isn’t it? Aren’t you going to have to hire all kinds of new staff to 

keep track of all these things? And then there are storage costs? 

Mr. DEMPSEY. Yes. The answer is the two lines refer to just having one state that mandated the labeling and everybody else who 

didn’t. So there is significant input, depending on the number of 

states who have different regulations. But yes, all up and down the 

line as we talked, our grain is kept in masa, it is kept in separate 

silos. You have to have separate silos for that. The distribution 

changes would be significant because you have to keep track of various different strains of products going to different states, the same 

product but labeled differently. So the multipliers in cost come up 

with how many different labels you have to keep and how many 

different infrastructure you need to build to hold those. 

Mr. EMMER. Very quickly because this just adds, it compounds, 

as you go each level. And it wouldn’t be fair if I didn’t go to the 

Minnesota guy with the time that I have left. 

63 

Mr. Policinski, farmers are interested in operating a business, 

raising their families. They want to produce quality product that 

can be sold the world over. I imagine in the farmers that I know, 

they don’t much care for the litigation system if they can stay away 

from it. What are the concerns and the costs that could be put into 

this at every level when you talk about the legal ramifications? 

Aren’t those just as big? 

Mr. POLICINSKI. Yes. First, farmers are pretty savvy businessmen, and they have adopted this technology at record pace. Of all 

the technologies over all the years, this has been the one that has 

been adopted by farmers the most quickly and it is because they 

see the benefits so clearly to their operations, to the environment, 

less land and water, and to cost, to consumers. I think farmers 

have voted. 

What we are trying to do here in the discussion is preserve their 

choice of how they want to farm as well as provide consumer 

choice. And again, the Pompeo-Butterfield legislation that was proposed clearly affords that opportunity through developing a national standard—— 

Mr. EMMER. Right. 

Mr. POLICINSKI.—and a voluntary national standard. I think 

your comment on legal costs would pass through the system to 

ownership, and in our instance, we are a farmer-owned company. 

Mr. EMMER. Right. 

Mr. POLICINSKI. We did have a discussion a couple of times now 

on how onerous it is to have a state law or a series of state laws, 

and if you chose not to serve those areas, the implications of legal 

liability would be very onerous. 

Ms. LIDBACK. Can—— 

Mr. EMMER. And at the end of the day, it all gets passed onto 

the consumer. I am sorry, Ms.— 

Ms. LIDBACK. No, it is okay. I just wanted to add, Mr. Emmer, 

when I was trying to locate a non-GMO source for grain, I first of 

course started my own grain company, and they simply don’t have 

the capacity either. They are already satisfying an organic grain 

distribution system as well as conventional. So they don’t have the 

capacity for a non-GMO option, either 

Mr. EMMER. And again. Thank you all. My time has expired. Mr. 

Chairman and to the Ranking Member, thank you for having this 

hearing because it seems like everybody here is interested in a win/ 

win for everybody. 

The CHAIRMAN. Thank you. The gentleman’s time has expired. 

Mr. Costa, 5 minutes? 

Mr. COSTA. Thank you very much, Mr. Chairman. I think this is 

not only a critical issue here in our country but also as it relates 

to the labeling issues, a critical issue as we negotiate these trade 

agreements, both with the European allies and as well as in Asia. 

I, Mr. Schmidt, was interested in your comments earlier on in 

terms of the polling sampling that you have taken and undergone, 

and what it really made me think about—and Dr., is it—— 

Dr. FEDOROFF. Federoff. 

Mr. COSTA. Dr. Federoff, is our lack of consumer education related to risk assessment or risk management? If it were not for all 

of the technology that we have employed post-World War II with 

64 

regards to food and food safety, we would not have the longevity 

or the healthy lifestyle that we enjoy today. While we have problems with obesity and other things, it is more related to choices 

people make, as opposed to the quality of the food that we have. 

How can we do a better job in educating folks about the better 

level of quality and the technologies that have been employed to 

make foods healthier and safer today? 

Mr. SCHMIDT. Well, thank you. I think you have identified some 

of the things that have come forward today, that this is not a 

science debate or a safety debate. It has come down to a communications debate. And sometimes as you indicated, people are faced 

with fear and risk, and it has almost become a cult following 

among some to oppose this technology without any demonstration 

of actual harm or safety risks. 

And so there needs to be even more leadership, whether it is 

Congress and the Administration, the industry, or academia to 

speak up, to have the bravery like Ms. Lidback to be steadfast with 

the facts, and there is strength in numbers. So the more people—— 

Mr. COSTA. A lot of the food processors and other companies and 

agricultural associations have tried to do education. I don’t think 

it has been well-coordinated. But we do see that on occasion. 

When you talked about 97 percent of the scientists, Dr. Federoff, 

were you talking about the safety of genetically modified foods? 

The general perception is obviously not at that level in terms of 

safety? 

Dr. FEDOROFF. Indeed. This is the pith hole that needs to be addressed by scientists across the board. That includes physicists and 

psychologists and economists and so forth. If you polled the claims 

of biologists who have used these techniques, you will be closer to 

100 percent. 

But that is not the issue. I think as Mr. Schmidt identified, it 

is more about communication. And the problem is that our current 

system which has very big regulatory costs to get a GM product to 

market prevents academic scientists, scientists in public research 

institutions, from getting genetically modified—— 

Mr. COSTA. This is a real challenge. 

Dr. FEDOROFF.—for example. Right. 

Mr. COSTA. Especially in Europe right now. 

Dr. FEDOROFF. You bet. 

Mr. COSTA. We have a process for it. We have only been able to 

register a limited amount, and it is a lengthy and cumbersome 

process. 

Dr. FEDOROFF. Correct. 

Mr. COSTA. Trying to get agreement on the best science is always 

a challenge, and in some cases, let us be frank, it is used for basically leverage purposes as it relates to trade. 

Dr. FEDOROFF. Absolutely. But let us just talk about here in the 

United States. If we could manage to make the process less onerous based on the accumulation of almost 40 years of research now, 

it would be possible to vet genetically modified fruits and vegetables. So a colleague of mine in England has developed a beautiful 

wine red tomato which is better for you because it has the same 

kinds of compounds in it that you have in blackberries and blueberries which are good for you. When people—— 

65 

Mr. COSTA. My time is almost up. 

Dr. FEDOROFF. Okay. So familiarity, we don’t have those—— 

Mr. COSTA. No, I know. 

Dr. FEDOROFF.—products in the market. 

Mr. COSTA. Ms. Lidback, as a person who grew up on a Portuguese dairy farm, I want to commend you for your efforts and encourage you to stay with it. I, too, know what to do with, the word 

manure. I grew up in that same setting as you and your family. 

I want to commend you and encourage you for your efforts and 

your courage to testify here today. 

The CHAIRMAN. The gentleman’s time has expired. Mr. Yoho, for 

5 minutes. 

Mr. YOHO. Thank you, Mr. Chairman, and Mr. Costa, being a 

veterinarian, large animal practitioner that earned a living on the 

south end of a north-bound horse or cow, it wasn’t manure. It was 

fertilizer until it hit the ground. 

I appreciate you all being here, and we as the people in government—because government is a non-entity. It is only as good as the 

people that are involved in it, in all branches of it, that we need 

to do a better job on educating both us and government and the 

public on educating people and in public venues to get the best, the 

current, and the correct information out to the public that is updated and is based on peer-reviewed science, and it is stemming 

from accurate research. And we also need to do a better job of making current the information and policies on a website of what a 

GMO is and what it is not and keep agendas or politics out of it 

and let the facts speak for themselves. 

Dr. Federoff, if you could take us briefly through the process of 

taking a genetically modified product from the beginning to the 

market in less than a minute, I would be really appreciative if you 

could. But just the research that goes behind that before it is approved. 

Dr. FEDOROFF. Okay. Let me try to summarize it really quickly. 

So to begin with, you have to identify the gene that you want to 

introduce. You have to introduce it into the organism. This is not 

a trivial process for a plant such as corn. You make a lot of these, 

put them in the greenhouse, figure out which ones and you take 

bits of the plant and you analyze it genetically by DNA sequencing 

and so forth. But then you have to check everything from testing 

the product of the gene for toxicity and allergenicity to putting together all of the dossiers that are required by the various agencies 

that need to approve that product. In some cases it has to be the 

EPA, the FDA, and the USDA. 

Mr. YOHO. And the USDA. 

Dr. FEDOROFF. Okay? And in the case of animals, genetically 

modified animals, like AquaBounty salmon, it is even more onerous 

because the FDA has decided to regulate them like drugs. 

Mr. YOHO. And what you have done is adequate because it is 

years of research, years of studies, years of feed studies, and then 

the tissue samples and all those things that come with that, and 

it costs millions if not billions of dollars, and it finally does get the 

approval of USDA, the FDA, the EPA. We have a variety in Florida 

of a papaya that they have been working on for 10 years for rig 

spot virus. The EPA signed off on it. But yet, it is still not to marVerDate Mar 15 2010 11:51 Jun 08, 2015 Jkt 041481 PO 00000 Frm 00069 Fmt 6633 Sfmt 6601 P:\DOCS\114-06\93965.TXT BRIAN
66 

ket because of this GMO scare around it, and it needs to be approved. 

With the studies, are you aware of any peer-reviewed real studies that you know of that have proven to be deleterious or detrimental effects on humans, animals, plants, or the environment—— 

Dr. FEDOROFF. None. 

Mr. YOHO.—of a product. 

Dr. FEDOROFF. There are occasional—— 

Mr. YOHO. What was that? 

Dr. FEDOROFF. None. 

Mr. YOHO. I just wanted to hear it again so—— 

Dr. FEDOROFF. Yes. 

Mr. YOHO.—so everybody heard that. None. 

Dr. FEDOROFF. None. There are occasional anecdotal reports. 

Mr. YOHO. Anecdotal. 

Dr. FEDOROFF. Very often, the publication is retracted or never 

gets published but gets into the social media and Internet and 

stuff. 

Mr. YOHO. Let me ask you all this. Would a GMO that had any 

deleterious effects to humans, animal, plants, or the environment 

ever get approved by the USDA, FDA, or EPA? So there was really—the science is on our side on these labelings. It is a marketing 

thing. So if a GMO has been approved by the USDA, one should 

rest assured that that product is as safe as any non-GMO product 

or it wouldn’t be out there. 

In addition, we have been doing GMOs for 20, 30, 40 years. 

Mother Nature has been doing it since the beginning of time. We 

would not have wheat had the plants not cross-pollinated to form 

the wheat we have today, and tomatoes, as we know, comes from 

a toxic source, so do potatoes, the Solana family. And they are 

toxic. They are related to nightshade. 

Dr. FEDOROFF. You bet. 

Mr. YOHO. Yet through genetic modification of Mother Nature, 

they have healed themselves, and we have what we have. And if 

we didn’t have the GMOs today, I would hate to think what the 

food security of this world would be. In my home State of Florida 

when I graduated from veterinary college, we produced about 75 

bushels of corn. That was a great yield. Today we are doing 250 

to 275 bushels of corn on poor soil, and therefore, the common 

sense of the sound science that leads to the approval of the GMOs 

should not be overshadowed by the environmental McCarthyism of 

the anti-GMO crowd. And I just want to thank you for being out 

there, for being in the fight, and for standing up, Ms. Lidback. Like 

last time when we talked about this, we got a lot of hate mail. 

Hang tough because you are on the right side of the science. Thank 

you. 

Mr. Chairman, I yield back. 

The CHAIRMAN. Ms. Adams? 

Ms. ADAMS. Thank you, Mr. Chairman, and thank you to our 

guests today. There has been a lot of confusion over what qualifies 

as a label for food that contains ingredients derived from a GMO. 

Consumers I believe deserve to know what is in their food, but it 

is also necessary that FDA implement regulations to ensure that 

the labeling of GMO products is fair and standardized and transVerDate Mar 15 2010 11:51 Jun 08, 2015 Jkt 041481 PO 00000 Frm 00070 Fmt 6633 Sfmt 6601 P:\DOCS\114-06\93965.TXT BRIAN
67 

parent. Market-driven labeling ensures that the information they 

demand about the food being sold is clear and accurate without the 

confusion of dozens of different labels. 

Mr. Clarkson, your testimony indicated that the best way to support consumers is through a national standard that includes a voluntary labeling program. So if the program is voluntary, how long 

would you expect for retailers and producers to begin participating 

in the program? 

Mr. CLARKSON. Well, there are quite a few retailers and processors participating in private programs right now that would 

quickly switch to a national definition enforced by the USDA. So 

I would expect within a year you would see very significant movement toward the national standard usage. 

Ms. ADAMS. As a follow-up, GMO crops are often sprayed with 

high amounts of herbicide since they can survive being sprayed in 

Round-Up. This may wash into lakes and streams. Mother Nature 

eventually takes its course and weeds may become resistant to a 

chemical, thus requiring the use of more toxic herbicides. 

Here is my question: how can we work with farmers to improve 

crop rotation so that weeds don’t become resistant to herbicides so 

quickly? 

Mr. CLARKSON. That would involve using multiple approaches to 

weed control rather than a single approach. It would involve rotations of crops. It would involve use of cover crops, all of which are 

projects that are under way. And we are starting to see benefits 

from those. 

Ms. ADAMS. Thank you. Mr. Schmidt, last summer your group 

conducted a survey to engage Americans’ views of foods containing 

bioengineered ingredients. How do consumers view the current 

FDA policy allowing voluntary labeling for food products through 

biotechnology? 

Mr. SCHMIDT. Thank you, Ms. Adams. Our survey found that 63 

percent of U.S. consumers support the current FDA policy that 

says that there should not be any special labeling of foods produced 

through biotechnology unless there is a change in the nutritional 

content, introduction of a safety issue such as an allergen, and 

even then, you would identify what that change was, not the process used to produce the product. And so Americans do—so it is a 

case of when you explain information and give consumers credit, 

they tend to understand it and support it. 

Ms. ADAMS. All right. Thank you very much, and Mr. Chairman, 

I yield back. 

Mr. AUSTIN SCOTT of Georgia [presiding]. Thank you for being 

here, ladies and gentlemen, and I will try to be brief. One of my 

concerns is not only that this labeling stop at the state level but 

that you could actually see individual counties and municipalities 

trying to come up with their own labeling standards. And therefore, 

you have six, seven, eight different standards in any given state. 

That would obviously have a tremendous impact on business owners, the grocery retailers, on the one side of the county line or city 

limit sign versus those who were on the other side. 

I would typically steer toward states’ rights on these issues. This 

is one where I do believe that without a uniform standard, we are 

68 

going to see tremendous increases in the cost of groceries for the 

American citizen. 

I will also tell you that this is a perception issue, and the more 

times we use the initials GMO or genetically modified, the worse 

it is for us. The term biotechnology, is a more accurate description 

of what we are using to get across where we actually use less pesticides and less herbicides. We don’t want to put those things on 

our land. They cost money to apply them, and we as farmers want 

a clean environment as well. 

It is interesting this past week as I listened—my wife and I were 

blessed to have a little girl, and I listened to the midwife as she 

was talking about groceries in making sure that they had no 

GMOs, and at the same time she turned around and recommended 

a tremendous number of things that were also products of biotechnology. And my wife suggested I shouldn’t say anything to her 

because she might be delivering our daughter, but now that our 

daughter is here, I am free to say some of those things. 

But the misperception out there has to be addressed. Biotechnology has made our life better, whether it is through pharmaceuticals or whether it is through our crops. And if I go to the Land 

O’ Lakes’ website, I can look up Land O’ Lakes butter, and I know 

exactly what is in the products that I am consuming. This isn’t 

about what is in the products that we eat. It is about what is in 

the seed that is planted. And I wonder if the same advocates for 

the labeling of our food supply, why aren’t they suggesting that it 

should be done in our pharmaceutical supply as well because those 

are the things that we ingest. 

So again, just reiterating, and Mr. Schmidt, I will go to you since 

we are down to 2 minutes. The use of biotechnology for our food 

and agriculture and pharmaceutical products have made our lives 

better. We are living longer than we ever have. Americans eat hundreds of millions of meals a day, literally. And my question is, how 

would it impact our ability to provide affordable and nutritious food 

to the American families, and would it not raise the cost of food, 

thereby hurting low-income Americans more than anybody, if we 

are not able to come up with a uniform labeling standard? 

Mr. SCHMIDT. I have to say we have not done the economic studies ourselves, but you have heard some very compelling testimony 

from the panel regarding the economics of this, I just think in general everyone wants to provide an informed choice for consumers, 

but that word informed is critical. And too often we are allowing 

misinformed choices out there by not standing up and correcting 

misinformation in the marketplace. So that is the opportunity to be 

transparent, to provide as much information as possible that meets 

consumer interest and demand, while also keeping the marketplace 

fair for accurate information on food and nutrition. 

Mr. AUSTIN SCOTT of Georgia. Do you see any movement to label 

anything other than agricultural products with the same type of 

skull and crossbones, if you will? 

Mr. SCHMIDT. Yes. As a communications group we hear ideas 

about labeling lots of different things. We know other industries— 

there has been some discussion about the alcohol industry, some 

calling for labeling there as well. You can ask consumers in general, would you like X to be labeled, and if you make it sound scary 

69 

enough, everyone is going to say yes. And that is the thing about 

technology. It is easy to make it sound scary. Maybe it is less interesting to say that it is safe and effective, but those are the facts. 

Mr. AUSTIN SCOTT of Georgia. Well, the fact that Americans eat 

hundreds of millions of meals a day and we spend less for food 

than virtually any other industrialized nation out there is proof 

that what we have been doing is working, and if it wasn’t, our life 

expectancy wouldn’t be continuing to expand. 

So thank you very much for being here. With that, I will turn 

it back over to the big Chairman. 

The CHAIRMAN [presiding]. I want to thank the panel for being 

here today. Dr. Federoff, a couple of things. 

You were about to finish your comments about Round-Up and 

also from responding to Ms. Adams’ comments—she had some 

question about Round-Up or glyphosate that you were going to answer. Did you have any comments about that one statement that 

came out Friday? 

Dr. FEDOROFF. Only that the preponderance of studies shows it 

to be safe and not carcinogenic. The current ruling of the UN body, 

the cancer, IARC or something like that, is not based on any new 

information. 

The CHAIRMAN. Okay. The overall weight, just to be crystal clear, 

the overall weight, the preponderance of the evidence, is that—and 

I am going to get with Mr. Schmidt. I want to use your bioengineered, genetically engineered—the weight, Dr. Federoff, is that it 

is safe and that it is—I am just using in reference to Mr. Schmidt 

because he told me to use something other than GMO because that 

is fairly pejorative. 

VOICE. He wants you to—— 

The CHAIRMAN. Let us just stay with you, Dr. Federoff. The preponderance of the science is that bioengineered— 

Dr. FEDOROFF. The food—— 

The CHAIRMAN.—processing is safe. 

Dr. FEDOROFF. The current biotechnologically altered food crops 

and potentially animals are as safe as their non-GM counterparts. 

The CHAIRMAN. All right. 

Dr. FEDOROFF. I am afraid that GM label is going to stick. It is 

the fastest thing to call it. 

The CHAIRMAN. I got you. Well, again, we thank the panel for 

coming today and spending your time with us. Ms. Lidback, I hope 

it doesn’t repeat your experience from last year, and if it does, well, 

it is a shame. It is unfortunate, because we could all have differences of opinion. Dr. Federoff, you said those opinions ought to 

be based in fact. We don’t have any requirement for that, but it 

ought to be the case, and we hope that this hearing today sheds 

some light on a really important issue. 

Well, for those on the Committee, the record of today’s hearing 

will remain open for 10 calendar days to receive additional material and supplementary written responses from the witnesses to 

any questions posed by a Member. This hearing of the Committee 

on Agriculture is adjourned. 

[Whereupon, at 12:12 p.m., the Committee was adjourned.] 

[Material submitted for inclusion in the record follows:] 

71 

* Editor’s note: the referenced summary is included as ATTACHMENT. 

SUBMITTED ARTICLES BY HON. JAMES P. MCGOVERN, A REPRESENTATIVE IN

CONGRESS FROM MASSACHUSETTS

International Agency for Research on Cancer (IARC), World Health Organization 

IARC Monographs Volume 112: Evaluation of Five Organophosphate Insecticides and Herbicides 

20 March 2015 

Lyon, France, 20 March 2015—The International Agency for Research on Cancer (IARC), the specialized cancer agency of the World Health Organization, has assessed the carcinogenicity of five organophosphate pesticides. A summary of the 

final evaluations together with a short rationale have now been published online in 

The Lancet Oncology,* and the detailed assessments will be published as Volume 

112 of the IARC Monographs. 

What were the results of the IARC evaluations? 

The herbicide glyphosate and the insecticides malathion and diazinon were classified as probably carcinogenic to humans (Group 2A). 

The insecticides tetrachlorvinphos and parathion were classified as possibly 

carcinogenic to humans (Group 2B). 

What was the scientific basis of the IARC evaluations? 

The pesticides tetrachlorvinphos and parathion were classified as possibly carcinogenic to humans (Group 2B) based on convincing evidence that these agents 

cause cancer in laboratory animals. 

For the insecticide malathion, there is limited evidence of carcinogenicity in humans for non-Hodgkin lymphoma and prostate cancer. The evidence in humans is 

from studies of exposures, mostly agricultural, in the USA, Canada, and Sweden 

published since 2001. Malathion also caused tumours in rodent studies. Malathion 

caused DNA and chromosomal damage and also disrupted hormone pathways. 

For the insecticide diazinon, there was limited evidence of carcinogenicity in humans for non-Hodgkin lymphoma and lung cancer. The evidence in humans is from 

studies of agricultural exposures in the USA and Canada published since 2001. The 

classification of diazinon in Group 2A was also based on strong evidence that 

diazinon induced DNA or chromosomal damage. 

For the herbicide glyphosate, there was limited evidence of carcinogenicity in humans for non-Hodgkin lymphoma. The evidence in humans is from studies of exposures, mostly agricultural, in the USA, Canada, and Sweden published since 2001. 

In addition, there is convincing evidence that glyphosate also can cause cancer in 

laboratory animals. On the basis of tumours in mice, the United States Environmental Protection Agency (http://www.epa.gov/opp00001/chem_search/ 

cleared_reviews/csr_PC-103601_30-Oct-91—265.pdf) (U.S. EPA) originally classified 

glyphosate as possibly carcinogenic to humans (Group C) in 1985. After a re-evaluation of that mouse study, the U.S. EPA changed its classification to evidence of noncarcinogenicity in humans (Group E) in 1991. The U.S. EPA Scientific Advisory 

Panel noted that the re-evaluated glyphosate results were still significant using two 

statistical tests recommended in the IARC Preamble (http://monographs.iarc.fr/ 

ENG/Preamble/index.php). The IARC Working Group that conducted the evaluation considered the significant findings from the U.S. EPA report and several more 

recent positive results in concluding that there is sufficient evidence of carcinogenicity in experimental animals. Glyphosate also caused DNA and chromosomal 

damage in human cells, although it gave negative results in tests using bacteria. 

One study in community residents reported increases in blood markers of chromosomal damage (micronuclei) after glyphosate formulations were sprayed nearby. 

How are people exposed to these pesticides? 

Tetrachlorvinphos is banned in the European Union. In the USA, it continues 

to be used on livestock and companion animals, including in pet flea collars. No information was available on use in other countries. 

Parathion use has been severely restricted since the 1980s. All authorized uses 

were cancelled in the European Union and the USA by 2003. 

Malathion is currently used in agriculture, public health, and residential insect 

control. It continues to be produced in substantial volumes throughout the world. 

Workers may be exposed during the use and production of malathion. Exposure to 

the general population is low and occurs primarily through residence near sprayed 

areas, home use, and diet. 

72 

Diazinon has been applied in agriculture and for control of home and garden insects. Production volumes have been relatively low and decreased further after 2006 

due to restrictions in the USA and the European Union. Only limited information 

was available on the use of these pesticides in other countries. 

Glyphosate currently has the highest global production volume of all herbicides. 

The largest use worldwide is in agriculture. The agricultural use of glyphosate has 

increased sharply since the development of crops that have been genetically modified to make them resistant to glyphosate. Glyphosate is also used in forestry, 

urban, and home applications. Glyphosate has been detected in the air during 

spraying, in water, and in food. The general population is exposed primarily through 

residence near sprayed areas, home use, and diet, and the level that has been observed is generally low. 

What do Groups 2A and 2B mean? 

Group 2A means that the agent is probably carcinogenic to humans. This category is used when there is limited evidence of carcinogenicity in humans and sufficient evidence of carcinogenicity in experimental animals. Limited evidence means 

that a positive association has been observed between exposure to the agent and 

cancer but that other explanations for the observations (called chance, bias, or confounding) could not be ruled out. This category is also used when there is limited 

evidence of carcinogenicity in humans and strong data on how the agent causes cancer. 

Group 2B means that the agent is possibly carcinogenic to humans. A categorization in Group 2B often means that there is convincing evidence that the agent 

causes cancer in experimental animals but little or no information about whether 

it causes cancer in humans. 

Why did IARC evaluate these pesticides? 

The IARC Monographs Programme has evaluated numerous pesticides, some as 

recently as 2012 (anthraquinone, (http://monographs.iarc.fr/ENG/Monographs/ 

vol101/mono101-001.pdf) arsenic and arsenic compounds (http://monographs.iarc.fr/ENG/Monographs/vol100C/mono100C-6.pdf)). However, substantial 

new data are available on many pesticides that have widespread exposures. In 2014, 

an international Advisory Group (http://www.thelancet.com/journals/lanonc/article/PIIS1470-2045%2814%2970168-8/fulltext) of senior scientists and government 

officials recommended dozens of pesticides for evaluation. Consistent with the advice 

of the Advisory Group, the recent IARC meeting provided new or updated evaluations on five organophosphate pesticides. 

How were the evaluations conducted? 

The established procedure for Monographs evaluations is described in the Programme’s Preamble (http://monographs.iarc.fr/ENG/Preamble/index.php). Evaluations are performed by panels of international experts, selected on the basis of their 

expertise and the absence of real or apparent conflicts of interest. For Volume 112, 

a Working Group of 17 experts from 11 countries met at IARC on 3–10 March 2015 

to assess the carcinogenicity of tetrachlorvinphos, parathion, malathion, 

diazinon, and glyphosate. The in-person meeting followed nearly a year of review 

and preparation by the IARC secretariat and the Working Group, including a comprehensive review of the latest available scientific evidence. According to published 

procedures (http://monographs.iarc.fr/ENG/Preamble/index.php), the Working 

Group considered ‘‘reports that have been published or accepted for publication in 

the openly available scientific literature’’ as well as ‘‘data from governmental reports 

that are publicly available’’. The Working Group did not consider summary tables 

in online supplements to published articles, which did not provide enough detail for 

independent assessment. 

What are the implications of the IARC evaluations? 

The Monographs Programme provides scientific evaluations based on a comprehensive review of the scientific literature, but it remains the responsibility of individual governments and other international organizations to recommend regulations, legislation, or public health intervention. 

Media inquiries: please write to com@iarc.fr. Thank you. 

ATTACHMENT

www.thelancet.com/oncology Published online March 20, 2014 http:// 

dx.doi.org/10.1016/S1470-2045(15)70134-8 

73 

Lancet Oncol. 2015 Published Online March 20, 2015 http://dx.doi.org/10.1016/S1470- 

2045(15)70134-8. For more on the IARC Monographs see http://monographs.iarc.fr. 

Upcoming meetings 

June 2–9, 2015, Volume 113: Some organochlorine insecticides and some chlorphenoxy herbicides 

Oct. 6–13, 2015, Volume 114: Red meat and processed meat Monograph Working Group 

Members 

A. Blair (USA)—Meeting Chair; L. Fritschi (Australia); J. McLaughlin; C.M. Sergi (Canada); 

G.M. Calaf (Chile); F. Le Curieux (Finland); I. Baldi (France); F. Forastiere (Italy); H. Kromhout 

(Netherlands); A.‘t Mannetje (New Zealand); T. Rodriguez [unable to attend] (Nicaragua); P. 

Egeghy [unable to attend], G.D. Jahnke; C.W. Jameson; M.T. Martin; M.K. Ross; I. Rusyn; L. 

Zeise (USA) 

Invited Specialists 

C. Portier (Switzerland) 

Representatives 

M.E. Gouze, for the French Agency for Food, Environment and Occupational Health and 

Safety (France); J. Rowland, for the U.S. Environmental Protection Agency (USA) 

Observers 

M.K. Boye Jensen, for Cheminova (Denmark); B. Fervers, for the Le ́on Be ́rard Centre 

(France); E. Giroux, for University Jean-Moulin Lyon 3 (France); T. Sorahan, for Monsanto Company (USA); C. Strupp, for the European Crop Protection Association (Belgium); P. Sutton, for 

the University of California, San Francisco (USA) 

IARC/WHO Secretariat 

L. Benbrahim-Tallaa; R. Carel; F. El Ghissassi; Sonia El-Zaemey; Y. Grosse; N. Guha; K.Z. 

Guyton; C. Le Cornet; M. Leon; D. Loomis; H. Mattock; C. Scoccianti; A. Shapiro; K. Straif; J. 

Zavadil 

For the Preamble to the IARC Monographs see http://monographs.iarc.fr/ENG/Preamble/index.php. 

For declarations of interests see http://monographs.iarc.fr/ENG/Meetings/vol112-participants.pdf. 

News 

Carcinogenicity of tetrachlorvinphos, parathion, malathion, diazinon, and 

glyphosate 

In March, 2015, 17 experts from 11 countries met at the International Agency for 

Research on Cancer (IARC; Lyon, France) to assess the carcinogenicity of the 

organophosphate pesticides tetrachlorvinphos, parathion, malathion, diazinon, and 

glyphosate (table). These assessments will be published as volume 112 of the IARC 

Monographs.1

The insecticides tetrachlorvinphos and parathion were classified as ‘‘possibly carcinogenic to humans’’ (Group 2B). The evidence from human studies was scarce and 

considered inadequate. Tetrachlorvinphos induced hepatocellular tumours (benign or 

malignant) in mice, renal tubule tumours (benign or malignant) in male mice,2 and 

spleen haemangioma in male rats. Tetrachlorvinphos is a reactive oxon with affinity 

for esterases. In experimental animals, tetrachlorvinphos is systemically distributed, 

metabolised, and eliminated in urine. Although bacterial mutagenesis tests were 

negative, tetrachlorvinphos induced genotoxicity in some assays (chromosomal damage in rats and in vitro) and increased cell proliferation (hyperplasia in rodents). 

Tetrachlorvinphos is banned in the European Union. In the USA, it continues to be 

used on animals, including in pet flea collars. 

For parathion, associations with cancers in several tissues were observed in occupational studies, but the evidence in humans remains sparse. In mice, parathion increased bronchioloalveolar adenoma and/or carcinoma in males, and lymphoma in 

females. In rats, parathion induced adrenal cortical adenoma or carcinoma (combined),3 malignant pancreatic tumours, and thyroid follicular cell adenoma in males, 

and mammary gland adenocarcinoma (after subcutaneous injection in females).4

Parathion is rapidly absorbed and distributed. Parathion metabolism to the bioactive metabolite, paraoxon, is similar across species. Although bacterial 

mutagenesis tests were negative, parathion induced DNA and chromosomal damage 

in human cells in vitro. Parathion markedly increased rat mammary gland terminal 

end bud density.4 Parathion use has been severely restricted since the 1980s. 

The insecticides malathion and diazinon were classified as ‘‘probably carcinogenic 

to humans’’ (Group 2A). Malathion is used in agriculture, public health, and resiVerDate Mar 15 2010 11:51 Jun 08, 2015 Jkt 041481 PO 00000 Frm 00077 Fmt 6621 Sfmt 6621 P:\DOCS\114-06\93965.TXT BRIAN
74 

dential insect control. It continues to be produced in substantial volumes throughout 

the world. There is limited evidence in humans for the carcinogenicity of malathion. 

Case-control analyses of occupational exposures reported positive associations with 

non-Hodgkin lymphoma in the USA,5 Canada,6 and Sweden,7 although no increased 

risk of non-Hodgkin lymphoma was observed in the large Agricultural Health Study 

cohort (AHS). Occupational use was associated with an increased risk of prostate 

cancer in a Canadian case-control study 8 and in the AHS, which reported a significant trend for aggressive cancers after adjustment for other pesticides.9 In mice, 

malathion increased hepatocellular adenoma or carcinoma (combined).10 In rats, it 

increased thyroid carcinoma in males, hepatocellular adenoma or carcinoma (combined) in females, and mammary gland adenocarcinoma after subcutaneous injection 

in females.4 Malathion is rapidly absorbed and distributed. Metabolism to the bioactive metabolite, malaoxon, is similar across species. Malaoxon strongly inhibits 

esterases; atropine reduced carcinogenesis-related effects in one study.4 Malathion 

induced DNA and chromosomal damage in humans, corroborated by studies in animals and in vitro. Bacterial mutagenesis tests were negative. Compelling evidence 

supported disruption of hormone pathways. Hormonal effects probably mediate rodent thyroid and mammary gland proliferation. 

75 

Activity (current status) Evidence in humans (cancer sites) Evidence in animals Mechanistic evidence Classification * 

Tetrachlorvinphos Insecticide (restricted in the EU and for 

most uses in the USA) 

Inadequate Sufficient •• 2B 

Parathion Insecticide (restricted in the USA and 

EU) 

Inadequate Sufficient •• 2B 

Malathion Insecticide (currently used; high production volume chemical) Limited (non-Hodgkin lymphoma, pros- tate) Sufficient Genotoxicity, oxidative stress, inflam- mation, receptor-mediated effects, 

and cell proliferation or death 

† 2A 

Diazinon Insecticide (restricted in the USA and 

EU) 

Limited (non-Hodgkin lymphoma, 

leukaemia, lung) 

Limited Genotoxicity and oxidative stress † 2A 

Glyphosate Herbicide (currently used; highest global production volume herbicide) Limited (non-Hodgkin lymphoma) Sufficient Genotoxicity and oxidative stress † 2A 

EU=European Union. * See the International Agency for Research on Cancer (IARC) preamble for explanation of classification system (amended January, 2006). 

†The 2A classification of diazinon was based on limited evidence of carcinogenicity in humans and experimental animals, and strong mechanistic evidence; for malathion and glyphosate, the mechanistic evidence provided independent support of the 2A classification based on evidence of carcinogenicity in humans and experimental animals. 

Table: IARC classification of some organophosphate pesticides 

76 

Diazinon has been applied in agriculture and for control of home and garden insects. There was limited evidence for diazinon carcinogenicity in humans. Positive 

associations for non-Hodgkin lymphoma, with indications of exposure-response 

trends, were reported by two large multicentre case-control studies of occupational 

exposures.5, 6 The AHS reported positive associations with specific subtypes, which 

persisted after adjustment for other pesticides, but no overall increased risk of nonHodgkin lymphoma.11 Support for an increased risk of leukaemia in the AHS was 

strengthened by a monotonic increase in risk with cumulative diazinon exposure 

after adjustment for other pesticides. Multiple updates from the AHS consistently 

showed an increased risk of lung cancer with an exposure-response association that 

was not explained by confounding by other pesticides, smoking, or other established 

lung cancer risk factors.12 Nonetheless, this finding was not replicated in other populations. In rodents, diazinon increased hepatocellular carcinoma in mice and 

leukaemia or lymphoma (combined) in rats, but only in males receiving the low dose 

in each study. Diazinon induced DNA or chromosomal damage in rodents and in 

human and mammalian cells in vitro. Some additional support for human relevance 

was provided by a positive study of a small number of volunteers exposed to a 

diazinon formulation.13

Glyphosate is a broad-spectrum herbicide, currently with the highest production 

volumes of all herbicides. It is used in more than 750 different products for agriculture, forestry, urban, and home applications. Its use has increased sharply with 

the development of genetically modified glyphosate-resistant crop varieties. 

Glyphosate has been detected in air during spraying, in water, and in food. There 

was limited evidence in humans for the carcinogenicity of glyphosate. Case-control 

studies of occupational exposure in the USA,14 Canada,6 and Sweden 7 reported increased risks for non-Hodgkin lymphoma that persisted after adjustment for other 

pesticides. The AHS cohort did not show a significantly increased risk of nonHodgkin lymphoma. In male CD-1 mice, glyphosate induced a positive trend in the 

incidence of a rare tumour, renal tubule carcinoma. A second study reported a positive trend for haemangiosarcoma in male mice.15 Glyphosate increased pancreatic 

islet-cell adenoma in male rats in two studies. A glyphosate formulation promoted 

skin tumours in an initiation-promotion study in mice. 

Glyphosate has been detected in the blood and urine of agricultural workers, indicating absorption. Soil microbes degrade glyphosate to aminomethylphosphoric acid 

(AMPA). Blood AMPA detection after poisonings suggests intestinal microbial metabolism in humans. Glyphosate and glyphosate formulations induced DNA and 

chromosomal damage in mammals, and in human and animal cells in vitro. One 

study reported increases in blood markers of chromosomal damage (micronuclei) in 

residents of several communities after spraying of glyphosate formulations.16 Bacterial mutagenesis tests were negative. Glyphosate, glyphosate formulations, and 

AMPA induced oxidative stress in rodents and in vitro. The Working Group classified glyphosate as ‘‘probably carcinogenic to humans’’ (Group 2A). 

We declare no competing interests. 

Kathryn Z Guyton, Dana Loomis, Yann Grosse, Fatiha El Ghissassi, Lamia 

Benbrahim-Tallaa, Neela Guha, Chiara Scoccianti, Heidi Mattock, Kurt Straif, on 

behalf of the International Agency for Research on Cancer Monograph Working 

Group, IARC, Lyon, France International Agency for Research on Cancer, Lyon, 

France 

Endnotes 1 International Agency for Research on Cancer Volume 112: Some 

organophosphate insecticides and herbicides: tetrachlorvinphos, parathion, malathion, diazinon and glyphosate. IARC Working Group. Lyon; 3–10 March 2015. 

IARC Monogr. Eval. Carcinog. Risk Chem. Hum. (in press). 2Parker C.M., Van Gelder G.A., Chai E.Y., et al. Oncogenic evaluation of 

tetrachlorvinphos in the B6C3F1 mouse. FUNDAM. APPL. TOXICOL. 1985; 5: 840–54. 3 National Toxicology Program. Bioassay of parathion for possible carcinogenicity. 

Natl. Cancer. Inst. Carcinog. Tech. Rep. Ser. 1979; 70: 1–123. 4 Cabello G., Valenzuela M., Vilaxa A., et al. A rat mammary tumor model induced 

by the organophosphorous pesticides parathion and malathion, possibly through 

acetylcholinesterase inhibition. ENVIRON. HEALTH PERSPECT. 2001; 109: 471–79. 5Waddell B.L., Zahm S.H., Baris D., et al. Agricultural use of organophosphate 

pesticides and the risk of non-Hodgkin’s lymphoma among male farmers (United 

States). CANCER CAUSES CONTROL 2001; 12: 509–17. 6McDuffie H.H., Pahwa P., McLaughlin J.R., et al. Non-Hodgkin’s lymphoma and 

specific pesticide exposures in men: cross-Canada study of pesticides and health. 

CANCER EPIDEMIOL. BIOMARKERS PREV. 2001; 10: 1155–63. 

77 

7 Eriksson M, Hardell L, Carlberg M, Akerman M. Pesticide exposure as risk factor 

for non-Hodgkin lymphoma including histopathological subgroup analysis. INT. J. 

CANCER 2008; 123: 1657–63. 8 Band P.R., Abanto Z., Bert J., et al. Prostate cancer risk and exposure to pesticides in British Columbia farmers. PROSTATE 2011; 71: 168–83. 9Koutros S., Beane, Freeman L.E., et al. Risk of total and aggressive prostate cancer and pesticide use in the Agricultural Health Study. AM. J. EPIDEMIOL. 2013; 177: 

59–74. 10 U.S. Environmental Protection Agency. Peer review of malathion: 18-month carcinogenicity study in mice. http://www.epa.gov/opp00001/chem_search/ 

cleared_reviews/csr_PC-057701_undated_004.pdf (accessed March 6, 2015). 11 Alavanja M.C., Hofmann J.N., Lynch C.F., et al. Non-Hodgkin lymphoma risk 

and insecticide, fungicide and fumigant use in the agricultural health study. PLOS 

ONE 2014; 9: e109332. 12 Jones R.R., Barone-Adesi F., Koutros S., et al. Incidence of solid tumors among 

pesticide applicators exposed to the organophosphate insecticide diazinon in the Agricultural Health Study: an updated analysis. OCCUP. ENVIRON. MED. 2015 (in press). 13 Hatjian B.A., Mutch E., Williams F.M., Blain P.G., Edwards J.W. Cytogenetic 

response without changes in peripheral cholinesterase enzymes following exposure to 

a sheep dip containing diazinon in vivo and in vitro. MUTAT. RES. 2000; 472: 85– 

92. 14De Roos A.J., Zahm S.H., Cantor K.P., et al. Integrative assessment of multiple 

pesticides as risk factors for non-Hodgkin’s lymphoma among men. OCCUP. ENVIRON. 

MED. 2003; 60: E11. 15WHO/FAO. Glyphosate. Pesticides residues in food 2004 Joint FAO/WHO Meeting on Pesticides Residues. PART II TOXICOLOGICAL. IPCS/WHO 2004; 95–162. 

http://www.who.int/foodsafety/areas—work/chemical-risks/jmpr/en/ (accessed 

March 6, 2015). 16 Bolognesi C., Carrasquilla G., Volpi S., Solomon K.R., Marshall E.J. Biomonitoring of genotoxic risk in agricultural workers from fi ve Colombian regions: association to occupational exposure to glyphosate. J. TOXICOL. ENVIRON. HEALTH A. 2009; 

72: 986–97. 

SUBMITTED ARTICLE BY HON. K. MICHAEL CONAWAY, A REPRESENTATIVE IN

CONGRESS FROM TEXAS

Bundesinstitut fu ̃ r Risikobewertung 

Does glyphosate cause cancer? 

www.bfr.bund.de 

BfR Communication No 007/2015, 23 March 2015 

In its recent evaluation from March 2015, the International Agency for Cancer Research (IARC), as the specialized cancer agency of the World Health Organization 

(WHO), came to the conclusion that glyphosate should now be classified as a carcinogenic substance in Group 2A (probably carcinogenic to humans), based on ‘‘limited evidence’’ in human-experiments and ‘‘sufficient evidence’’ in animal-experiments. This classification was published in a short report in the ‘‘Lancet’’ journal 

on 20 March 2015. 

As the ‘‘Rapporteur Member State’’ for the active substance glyphosate within the 

framework of EU re-evaluation, the Federal Institute for Risk Assessment (BfR) was 

responsible for the human health risk assessment and has assessed glyphosate as 

non-carcinogenic. This was supported by competent national, European and other 

international institutions for health assessment including the WHO/FAO Joint 

Meeting on Pesticide Residues (JMPR). BfR is therefore issuing its comments on 

this classification by IARC based on the published short report. 

The International Agency for Research on Cancer (IARC) is the specialized cancer 

agency of the World Health Organization. The main objective of the IARC is to promote international collaboration in cancer research. The evaluations of carcinogenic 

risk are made by international working groups of independent scientists and are 

qualitative in nature. No recommendation is given for regulation or legislation. For 

this reason, 17 experts from 11 countries met at the International Agency for Research on Cancer (IARC; Lyon, France) in March 2015 in order to assess the carcinogenic or potentially carcinogenic effects of four organophosphates and 

glyphosate. The working group classified glyphosate as ‘‘probably carcinogenic to humans’’. This assessment will be published as volume 112 of the IARC Monographs. 

78 

In the opinion of BfR, the classification of glyphosate as ‘‘carcinogenic in Group 

2A’’ (probably carcinogenic to humans) as published in the 20 March 2015 issue of 

the ‘‘Lancet’’ journal comes as a surprise, since other evaluations performed by supranational bodies such as the WHO-Panel of the Joint Meeting of Pesticide residues (JMPR, 2004), and also by national regulatory agencies such as the U.S. EPA 

had concluded the contrary, i.e., that glyphosate was not carcinogenic. Unfortunately, the database on which the IARC evaluation is based is not known, since a 

background monograph that is usually produced by IARC following the evaluation 

meetings has not yet been released. Therefore, a comprehensive and scientifically 

sound consideration of the data and arguments that led to the IARC- conclusion is 

simply not possible at the moment. 

In addition, Germany is the ‘‘Rapporteur Member State’’ in the ongoing reevaluation process of glyphosate in the EU. For this purpose, an extensive ‘‘Renewal Assessment Report’’ (RAR) was provided in 2013 and has been revised in 2014 and 

again in 2015. The 2013 report was circulated by EFSA to the EU Member States 

and was made available for public consultation in 2014. Revisions were made to 

take into account the several hundred comments and remarks. The toxicological and 

residue chapters of the report have been prepared by the Federal Institute for Risk 

Assessment (BfR). For this purpose, BfR has compiled the most comprehensive toxicological database, presumably worldwide, for glyphosate. This database comprises 

hundreds of studies that were performed by or on behalf of the many manufacturers 

of glyphosate and thousands of references from the open literature. This huge 

amount of data makes glyphosate nearly unique among the active substances in 

plant protection products. BfR thinks that the entire database must be taken into 

account for toxicological evaluation and risk assessment of a substance and not 

merely a more or less arbitrary selection of studies. 

In the absence of more reliable information from IARC, BfR has tried to allocate 

the findings that are mentioned in the brief ‘‘Lancet’’ publication to certain studies 

in our database and, by doing that, to put them into perspective. 

The new IARC classification for glyphosate as a carcinogenic substance is based 

firstly on ‘‘limited evidence’’ in humans. This risk is derived from three epidemiological studies in the USA, Canada and Sweden based on a statistical correlation between exposure to glyphosate and an increased risk of non-Hodgkin lymphoma. 

However, this assessment was not confirmed in a very large cohort of the also cited 

‘‘Agricultural Health Study’’ or in other studies. A recent publication from 2012 has 

reviewed the epidemiologic literature to evaluate whether exposure to glyphosate is 

associated causally with cancer risk in humans and the relevant methodological and 

biomonitoring studies of glyphosate. The review found non-consistent patterns of 

positive associations indicating a causal relationship between total cancer or any 

site-specific cancer and exposure to glyphosate. The current report of BfR to the EU 

based on the evaluation of over 30 epidemiological studies came to the overall assessment that there is no validated or significant relationship between exposure to 

glyphosate and an increased risk of non-Hodgkin lymphoma or other types of cancer. 

Secondly, IARC points to findings of studies based on animal experiments submitted by the producers of glyphosate as evidence for the carcinogenic effect of 

glyphosate. All these findings were also considered in the glyphosate assessments 

of BfR, which did support the conclusion of the Joint Meeting on Pesticide Residues 

(JMPR) of the FAO/WHO responsible for the assessment of active substances in pesticides: ‘‘In view of the absence of a carcinogenic potential in animals and the lack 

of genotoxicity in standard tests, the Meeting concluded that glyphosate is unlikely 

to pose a carcinogenic risk to humans’’. BfR does not have any information as to 

how many of the 11 long-term studies on rats and mice that were assessed as valid 

were available to IARC. 

Moreover, IARC concluded that a glyphosate formulation promoted skin tumours. 

In general, testing of formulations should not be used for toxicological evaluation 

of active substances because co-formulants may alter the outcome to a large extent. 

Therefore, the claim, based on this two-stage cancer model in mice, that a highly 

concentrated, skin-irritating formulation containing the active substance promotes 

skin tumours is not considered by the institutions in the EU to be evidence for the 

carcinogenic properties of glyphosate. 

It is not possible to fully examine the indications for the genotoxic potential of 

glyphosate based on the short report published by IARC, in particular due to the 

fact that the assessment included studies using formulations that are not specified 

in any detail. 

The fact that different bodies assess issues differently due to differing information 

and assessments of experimental data is part and parcel of the risk assessment 

process. BfR will therefore perform a thorough review of the classification issued by 

IARC once the monograph becomes available. 

79 

1 Vatican II, Gaudium et Spes, § 1. 2Pope Francis, Address, 38th Conference of the Food and Agriculture Organization of the 

United Nations, 20 June 2013. 3 Vatican II, Gaudium et Spes, § 3. 4Gaudium et Spes, § 21; cf. § 40. 5 Cf. Pope Francis, Audience for Pontifical Council for Justice and Peace Conference on Pacem 

in Terris, 3.10.2013. 6 Cf. Is, 24, 1–13. 7 Cf. Rm, 8, 21. 

SUBMITTED LETTER BY HON. ANN KIRKPATRICK, A REPRESENTATIVE IN CONGRESS

FROM ARIZONA

Pontificium Consilium de Iustitia et Pace 

The World Food Prize 

Borlaug Dialogue International Symposium 

17 October 2013 

On behalf of the Pontifical Council for Justice and Peace, I thank you warmly for 

your very kind invitation to participate in the World Food Prize event of this year, 

and for your warm welcome. 

As you may know, about 50 years ago, the Second Vatican Council carefully reviewed the mission of the Catholic Church in the modern world. The Council found 

it urgent that the Church, with all her resources, accompany humanity in its walk 

through history. She made her own ‘‘the joys and the hopes, the griefs and the anxieties of the [people] of this age, especially those who are poor or in any way afflicted.’’1 Recently Pope Francis put it straightforwardly to a meeting of the Food 

and Agriculture Organization of the United Nations (FAO): ‘‘the Catholic Church, 

with all her structures and institutions, is at your side,’’ 2 that is, at the side of everyone who seeks in good faith to meet the challenges of world hunger. 

The Vatican Department that was mandated to study and to promote the 

Church’s accompaniment of humanity is the Pontifical Council for Justice and 

Peace, which I preside over. And the spirit of our work—and of my presence—is 

beautifully expressed by Vatican II with these words: ‘‘Giving witness and voice to 

the faith of the whole people of God gathered together by Christ, this Council can 

provide no more eloquent proof of its solidarity with, as well as its respect and love 

for the entire human family, than by engaging with it in conversation about these 

various problems.’’ 3

To engage in conversation about the problems of hunger that afflict our world: 

that is why I join you at this International Symposium. When we share a common 

commitment to conversation, we should be in a good position to exchange views 

about concerns we have and positions we take, even when they are at variance. 

And yet because the stakes are high, tempers tend to run short, and sharply divergent views make the conversation shrill. When that happens, as Vatican II foresaw, we must courageously go even further and deeper than conversation, into dialogue: ‘‘The Church sincerely professes that all [people], believers and unbelievers 

alike, ought to work for the rightful betterment of this world in which all alike live; 

such an ideal cannot be realized, however, apart from sincere and prudent dialogue.’’ 4

And when you juxtapose the World Food Prize and the Occupy World Food Prize, 

at first glance the divergence can appear and sound like polar opposition. The urgency of world hunger and food insecurity certainly cries out for ‘‘rightful betterment’’, and therefore calls for dialogue. And for that I have come, too: to call for 

conversation and to promote dialogue. The Church promotes listening, dialogue, patience, respect for the other, sincerity and even willingness to review one’s own opinion. The Church encourages, orients and enriches discussion and debate.5 It strives 

to indicate directions for the work of those who are technically and politically responsible for dealing with concrete problems. 

The Church Converses with the World Food Prize 

Let me, then, begin the conversation: The earth, as Scriptures tell us, was created 

as the home of the human family. The earth is beautiful, good and perfect in serving 

its purpose of giving sustenance to human life. Later, however, the Prophet Isaiah 

tells us that ‘‘the earth languishes and suffers’’ 6 from the sins of its human inhabitants. In view of this pitiful situation, Saint Paul will announce the hope of the 

earth’s redemption, with man who was given custody of it, through Christ.7

Entrusted with the custody of the earth, the human family has a mission to love 

God’s creation, to accompany it towards its ultimate perfection, and to make it fruitVerDate Mar 15 2010 11:51 Jun 08, 2015 Jkt 041481 PO 00000 Frm 00083 Fmt 6621 Sfmt 6621 P:\DOCS\114-06\93965.TXT BRIAN
80 

8LEO XIII, Rerum Novarum, n. 9. 9Pontifical Council for Justice and Peace, Compendium of the Social Doctrine of the Church, 

Libreria Editrice Vaticana, Citta ̆ del Vaticano 2004, § 473. 10 Ibid. 11 John Paul II, Address to the Members of the Pontifical Academy of Sciences, 23.10.1982, 

§§ 5–6. 

12 John Paul II, Address to the Participants in the XIV General Assembly of the FAO, 

13.11.1987, § 5. 13 John Paul II, Address to the Participants of the Study Week organized by the Pontifical 

Academy of Sciences, 18.05.1990, § 2. 

ful: a fruitful creation that is to be enjoyed by the present and future generations, 

and that satisfies all the needs of humanity. That is why Pope Leo XIII says: ‘‘that 

which is required for the preservation of life, and for life’s well-being, is produced 

in great abundance from the soil, but not until [people have] brought it into cultivation and expended upon it [their] solicitude and skill.’’ 8 Similarly, the Compendium 

of the Social Teaching of the Church observes: ‘‘The Christian vision of creation 

makes a positive judgment on the acceptability of human intervention in nature, 

which also includes other living beings, and at the same time makes a strong appeal 

for responsibility’’.9

In Catholic thought, then, ‘‘nature’’ is neither sacred nor divine, neither to be 

feared nor to be revered and left untouched. Rather, it is a gift offered by the Creator to the human community to be lived in and used, entrusted to the intelligence 

and moral responsibility of men and women. Therefore it is legitimate for humans 

with the correct attitude to intervene in nature and make modifications. In the 

words of the Compendium as applied to biotechnology: ‘‘For this reason the human 

person does not commit an illicit act when, out of respect for the order, beauty and 

usefulness of individual living beings and their function in the ecosystem, he intervenes by modifying some of their characteristics or properties.’’ 10

‘‘Intervening By Modifying’’: The Church, Catholic Social Doctrine and Biotechnological Research 

There are no a priori limits on the notion of ‘‘intervening by modifying’’. It does 

not even preclude actions taken on what may be considered as the most intimate 

part of living organisms: the genome. 

Blessed John Paul II, for example, in a speech to the members of the Pontifical 

Academy of Sciences, expressed support for genetic research, saying: ‘‘It is also to 

be hoped, with reference to your activities, that the new techniques of modification 

of the genetic code, in particular cases of genetic or chromosomic diseases, will be 

a motive of hope for the great number of people affected by those maladies’’. 

He continued in a similar way about food production, saying: ‘‘Finally, I wish to 

recall, along with the few cases which I have cited that benefit from biological experimentation, the important advantages that come from the increase of food products 

and from the formation of new vegetal species for the benefit of all, especially people 

most in need.’’ 11

Again, addressing the 24th General Assembly of the FAO, where he observed how 

hostile climate affects food production in poor countries, he said: ‘‘The findings of 

science must be put to use in order to ensure a high productivity of land in such a 

way that the local population can secure food and sustenance without destroying nature.’’ 12

Finally, at a study week of the Pontifical Academy of Sciences and the Swedish 

Academy of Sciences on Tropical Forest and the Conservation of Species, John Paul 

II referred to how ‘‘other plants possess value as sources of food or as a means of 

genetically improving strains of edible plants.’’ 13

At this point in the conversation, and in the light of the above, we should rejoice 

in the memory and achievements of Dr. Norman Borlaug: He was awarded the 

Nobel Prize in 1970 in recognition of his lifetime of work to feed the hungry of the 

world. He struggled endlessly to integrate research and viable technologies into 

wheat production in Mexico. His work extended from research stations to farmers’ 

fields. In the words of Pope Francis, Dr. Borlaug had ‘the smell of the sheep’, or in 

Iowan farmers’ language: ‘‘He had manure on his boots’’. The result was called the 

Green Revolution: the production of seeds with broad and stable disease resistance, adapted to varying growing conditions and with high yield potential; and he 

conceived and set up the World Food Prize to encourage continued work towards 

food security and to meet the zero hunger challenge. 

This is also why we have reason today to congratulate our three World Food Prize 

winners this year: Dr. Marc Van Montagu of Belgium (http:// 

81 

14Founder and Chairman of the Institute of Plant Biotechnology Outreach at Ghent University in Belgium. 15Founder and Distinguished Fellow of Syngenta Biotechnology. 16 Executive Vice President and Chief Technology Officer of Monsanto. 17 John Paul II, Address to the Members of the Pontifical Academy of Sciences, 23.10.1982, § 6. 18 Cf. John Paul II, Address to the XXXV General Assembly of the World Medical Association, 

29.10.1983, § 6. 19 Idem. 20 John Paul II, Message, World Food Day 2001, 16.10.2001. 21FAO, Food wastage footprint, Impacts on natural resources. Summary report, 2013, p. 6. 

www.worldfoodprize.org/en/laureates/2013_laureates/#Dr._Marc_Van_),14 and Dr. 

Mary-Dell Chilton (http://www.worldfoodprize.org/en/laureates/2013_laureates/ 

#Dr._Mary-Dell_) 15 and Dr. Robert T. Fraley (http://www.worldfoodprize.org/en/ 

laureates/2013_laureates/#Dr._Robert_T._Fraley) 16 of the United States, and to 

commend them for carrying on the legacy of Dr. Borlaug, putting biotechnology and 

research towards improving food production. 

But times have also changed: Dr. Borlaug’s achievements were greeted with great 

enthusiasm, and the Green Revolution with great optimism. Why then is there so 

much displeasure and distrust today, so much skepticism and strong opposition? 

Never before, having accepted an invitation, have I received so much mail, some of 

it urging me to withdraw, a bit of it affirming the value of GMOs, much of it recounting destruction and suffering in relationship with globalized industrial agriculture promoting GMO crops. What can be going wrong, seeing that Pope John 

Paul spoke positively about such research? 

Let me now go back to Pope John Paul II to continue the conversation. For when 

he encouraged genetic research to enhance food production, he also clearly stated 

the parameters within which such research may be carried out. ‘‘In terminating 

these reflections of mine,’’ he said to the Pontifical Academy of Sciences, ‘‘which show 

how much I approve and support your worthy researches, I reaffirm that they must 

all be subject to moral principles and values, which respect and realize in its fullness 

the dignity of man.’’ 17

It is clear, then, that in the mind of John Paul II, the various operations that can 

be called ‘‘genetic manipulation’’ must be the object of a true moral discernment. ‘‘To 

speak the truth,’’ he said on another occasion, ‘‘the expression genetic manipulation 

is ambiguous.’’ While it is characterized by beneficial applications in the area of animal and plant biology, very useful for food production, it can also yield to adventurism.18 In the latter case, it can be arbitrary and unjust, especially when it loses 

sight of the total well-being of the human person. This is why, for John Paul II, 

it is absolutely necessary to overcome the separation between science and ethics, 

and to discover their radical unity.19

Accordingly, the desired dialogue will have to go very deep. It will need to include 

the motivation and vision which guide biological and genetic research and biotechnology—in other words, not only so-called ‘‘pure’’ research but also the vision 

and motivation that guide its translation into policies, commerce, agriculture and 

trade in many different situations around the world. And for the dialogue to 

progress in good faith, all the stakeholders must genuinely be represented and 

meaningfully take part. 

The Problem of Food Insecurity 

Hunger in the world is a very serious injustice that shows fundamental disrespect 

for human dignity. Pope John Paul II called it ‘‘the first and fundamental form of 

poverty’’.20 Persistent hunger, starvation and malnutrition represent a global failure 

of humanity that, to our shame, has dragged on for decades. It is a plague, and a 

long-term indicator of a system that does not function properly. Some point to the 

economic crisis of recent years as the reason why the world cannot do better; but 

that is just an excuse—food insecurity has persisted for decades, through prosperous 

times as well as more difficult ones. 

But the problem is not, of course, an overall scarcity of food. 

Today the world produces more than enough food to feed its seven billion inhabitants, but the world has one billion hungry people (about one in seven), the United 

States 50 million (about one in six). But much is lost after harvesting or just thrown 

away: in a very recent document, ‘‘FAO estimates that each year, approximately 1⁄3

of all food produced for human consumption in the world is lost or wasted’’.21 Some 

estimates are even higher than 1⁄3. 

Since the 1980s, the Popes, supported by FAO statistics, have pointed out that 

the supply of food per capita on the planet is steadily increasing. So it is clear that, 

in large part, hunger is a problem of distribution of food or access to it. It does not 

reach some people, or they cannot buy it. To others, however, it comes in abundance, 

82 

22 Cf. FAO, Food wastage footprint, pp. 11–13. 23 Compendium of the Social Doctrine of the Church, §§ 472–480. 

even from afar—abundant enough that they can waste it.22 In other cases, finally, 

the systems for storage of harvests or the supply chains are deficient. 

Let me suggest a little parable. A man is anxious to improve the strength of his 

arms. A surgeon offers to transplant muscles from his legs into his arms: ‘‘This will 

quickly make your arms big and strong’’. ‘‘What will happen to my legs?’’ the man 

asks. ‘‘They will become much weaker,’’ replies the surgeon, ‘‘and may have to be 

amputated.’’ The man is horrified and rejects the surgeon’s solution. 

In some circumstances, the promise of food security merely through higher agricultural productivity is similar. New technologies are promoted with the claim of 

making more food available for everyone. But that is not the whole picture. In reality, the innovations are so designed or implemented as to benefit relatively few 

interests that are already well-off. 

Along the way, many small producers will inevitably be excluded and/or moved 

off their land. They will be amputated from their traditional occupations and way 

of life. The uprooting of individuals, families and communities is not only a painful 

separation from land; it extends to their entire existential and spiritual environment, threatening and at times shattering their few certainties in life. 

It should not surprise us if some populations reject certain innovations, not because they are faulty or perceived as such, but because the manner of their delivery 

entails unbearable costs to those who are supposed to benefit from them. It is not 

they who are missing the point. Rather, like the surgeon who thinks only of a set 

of arms, not the whole person, whoever refuses to look at the whole food insecurity 

picture—people and their dignity and their lives as well as food production and distribution—will miss the point. 

How does the Church ‘‘know’’ about world hunger, sustainable agriculture or 

GMOs? First of all, the Church is in touch with the direct experience of her people. 

Another important way that we know about these topics is through members of the 

Church who are scientists or professionals working in a wide variety of positions 

in universities, government and industry. And a third way would be in the work 

of different departments of the Roman Curia: the Pontifical Academy for Life, the 

Pontifical Academy of Science, the Pontifical Academy of Social Science, the Congregation for the Doctrine of the Faith, the Holy See Missions to the World Food 

Organization and to other international bodies, the Secretariat of State and our own 

Pontifical Council for Justice and Peace. 

In 2004 our Pontifical Council produced a Compendium of the Social Doctrine of 

the Church. Nine of its 583 paragraphs are devoted to biotechnology: not to the 

science or the industry, but to the ethical criteria that people of good will should 

apply to the development and use of these technologies. I warmly recommend this 

text to everyone involved in working on GMOs.23

Broad Directions 

Here is what I can offer to whoever tries to fight hunger, especially in the field 

of biotechnologies applied to the agricultural sector. I implore you, your colleagues, 

and others whom you influence such as your students, to always proceed along an 

ethical path of discernment. 

It is common to find some scientists and advocates who strongly hold one position 

and others who hold its opposite. They attack and even ridicule the opposed views— 

perhaps not in scientific meetings and journals, but certainly in the media. And all 

this attack, defense and counter-attack leave the public deeply confused. 

There is a different approach, which takes its stand in dialogue, in the patient 

exchange of positions and objections. When there is something as important to humanity as hunger, and something as controversial as GMOs, let us encourage research under solid (not flimsy) ethical guidelines, and then, sharing the results, let 

us do so in a climate of listening and dialogue. 

We know since Gaudium et Spes in the mid-1960s that the Church accompanies 

science. This is because science cannot proceed without ethics. Ratio goes along with 

fides, as Benedict XVI taught so clearly. Bios, which means life, must be handled 

ethically and respectfully, and maybe this is especially true with respect to biotechnology. It is hazardous—and ultimately absurd, indeed sinful—to employ biotechnology without the guidance of a deeply responsible ethics. For instance, nearly 

50 years ago, Pope Paul VI called for prudence, responsibility and unselfishness in 

this domain: 

By dint of intelligent thought and hard work, man gradually uncovers the hidden laws of nature and learns to make better use of natural resources. As he 

83 

24Paul VI, Populorum Progressio § 25. 25 John Paul II, Address to the Rural Community of Saint Patrick, Des Moines, 4.10.1979. 26 Instrumentum Laboris of Synod for Africa, 19.03.2009, § 58. 27 Benedict XVI, Caritas in Veritate, § 67. 28Pope Francis, Address to the 38th Conference of the Food and Agriculture Organization of 

the United Nations in Rome, 10.06.2013, §§ 2, 3, 4. For a comprehensive presentation of the principles here mentioned, consult the Compendium, especially §§ 472–80. 

takes control over his way of life, he is stimulated to undertake new investigations and fresh discoveries, to take prudent risks and launch new ventures, to 

act responsibly and give of himself unselfishly.24

Blessed Pope John Paul II was supportive of research in biotechnology to feed the 

world. Moreover, when he visited Des Moines in 1979, standing in a corn-bedecked 

fields, he challenged agriculture in America and around the world to ‘‘foster sustainability of the land and water and plants, and to use the harvest to feed the hungry 

in the world.’’ 25

The study-document preparing for the II Synod for Africa in 2009 identified the 

true problems of agriculture in Africa: ‘‘the lack of cultivatable land, water, energy, 

access to credit, agricultural training, local markets, road infrastructures, etc.’’ 

These true problems should not be overlooked or side-stepped by those who promote 

the planting of genetically-modified seeding as the definitive solution.26

In his important encyclical Caritas in Veritate of 2009, Pope Benedict XVI counted 

food security among the urgent global issues which require ‘‘a greater degree of 

international ordering’’. He asserted that the problem of food insecurity ‘‘needs to 

be addressed within a long-term perspective, eliminating the structural causes that 

give rise to it and promoting the agricultural development of poorer countries. This 

can be done by investing in rural infrastructures, irrigation systems, transport, organization of markets, and in the development and dissemination of agricultural 

technology that can make the best use of the human, natural and socioeconomic resources that are more readily available at the local level, while guaranteeing their 

sustainability over the long term as well. All this needs to be accomplished with the 

involvement of local communities in choices and decisions that affect the use of agricultural land.’’ Having enumerated the many conditions that cry out for improvement, Pope Benedict went on to welcome ‘‘the new possibilities that are opening up 

through proper use of traditional as well as innovative farming techniques, always 

assuming that these have been judged, after sufficient testing, to be appropriate, respectful of the environment and attentive to the needs of the most deprived peoples’’.27

For Pope Benedict, it is clear that ever-increasing production as the primary 

path—let alone the sole option—to reducing world hunger is too narrow a vision and 

can lead to false solutions, which may actually undermine food security in the long 

term. 

Guidelines 

I have quoted the recent Popes Paul VI, John Paul II, Benedict XVI and now Pope 

Francis. Having considered the general directions they laid out, let me now spell 

out more specific ethical orientations that need to accompany work in science and 

technology, including biotechnology, as well as international trade and commerce. 

This is still not a Church position on GMOs as such, but rather, the assistance of 

the Church in the form of guidance based on her Social Doctrine. 

A. Spirit of courage: Face up to the reality of hunger decisively and with genuine charity and openness of heart. In the words of Pope Francis: ‘‘Something 

more can and must be done in order to provide a new stimulus to international activity on behalf of the poor, inspired by something more than mere 

goodwill or, worse, promises which all too often have not been kept . . . There 

is a need to move beyond indifference and a tendency to look the other way, 

and urgently to attend to immediate needs, confident that the fruits of today’s 

work will mature in the future. We cannot devise programs which are bureaucratic and antiseptic, which do not work today.’’ Keep on studying the causes 

of world hunger as broadly and deeply as possible, seeking the greatest variety of possible solutions, since we need ‘‘a complete knowledge of particular 

situations, suitable preparation, and ideas which take into account every individual and every community.’’ 28

B. Ethics of all human endeavors: Some would claim that research is ethically neutral, and only its application or implementation may be good or bad. 

But any activity which deserves the name ‘‘human’’ requires ethical guidance 

if it is to serve the common good. Therefore, a researcher always should work 

84 

29Pope Francis, FAO, § 1. 30 Cf. Statement of the Holy See at the World Trade Organization Council on Trade-Related 

Aspects of Intellectual Property Rights, Geneva, 8 June 2010, §§ 5–7. 31Pope Francis, FAO, § 2. 32Pope Francis, FAO, § 3. 

‘‘to satisfy the demands of justice, fairness and respect for every human 

being’’; 29 not merely for the sake of profit. The same criteria apply to those 

who are responsible, in later phases of the process, for industrial production, 

international trade, commercial distribution, and so forth. There should be no 

‘‘washing of the hands’’ at any step along the way. 

C. Prudence: The full costs and consequences of introducing genetically modified organisms may emerge only with time, in the long-term. Therefore let us 

apply the principle of precaution or prudence by taking every reasonable 

measure of caution beforehand, to avoid the risk of damaging human health 

or the environment. Such prudence, I might add, is a necessary element of 

any effort to advance the common good through public, that is governmental, 

action. 

D. Transparency: Adopt the highest standards of communication with the public, as well as rules of labeling in order to guarantee producers’ and consumers’ right to information. This is necessary for everyone to have a true 

choice. This is the principle of transparency. 

E. Access: Patents and intellectual property rights are legitimate, but they need 

to be monitored and regulated. Fair ways must be found to share the fruits 

of research and ensure that developing countries have access both to natural 

resources and to innovations. Otherwise whole populations can be discriminated against, exploited and deprived of what they rightly should have a 

share in.30

F. Biodiversity: Bio-diversity is humanity’s patrimony. It needs to be protected, 

indeed privileged. The development of new types should not require, or lead 

to, the disappearance of traditional species. 

G. Subsidiarity: A very healthy principle of Catholic Social Teaching is 

subsidiarity, which favors the exercise of responsibility at every level and resists ‘‘top-down’’ approaches where inappropriate. It is often better to support 

local efforts than to provide or even impose solutions from elsewhere. And 

given the complexities of globalization, effective coordination of efforts at all 

levels is also increasingly required. 

H. Commerce: Analyze, condemn and fight ‘‘financial speculation, which presently affects the price of food, treating it like any other merchandise and overlooking its primary function.’’ Abandon any form of ‘‘short-sighted economic interests and the mentality of power of a relative few who exclude the majority 

of the world’s peoples, generating poverty and marginalization and causing a 

breakdown in society.’’ 31 And educate our youth to do the same. . . . with criteria of justice and solidarity governing the commercial and economic conditions, avoiding any commercial-economic monopoly 

I. Finally, conversation and dialogue. Sharp differences of opinion (e.g., between WFP and ‘‘Occupy’’) about agriculture and biotechnology show how important are these issues. Their importance does not justify harshness (polemic) or manipulation (bullying). At every level from the global to the local, 

one might ask, what should be people’s input into research, agricultural and 

trade policies, development policies, funding priorities, and so forth. ‘‘Every 

proposal must involve everyone,’’ Pope Francis insists. ‘‘To move forward constructively and fruitfully in the different functions and responsibilities involves 

the ability to analyze, understand, and engage, leaving behind the temptations 

of power, wealth or self-interest and instead serving the human family, especially the needy and those suffering from hunger and malnutrition.’’ 32

I will stop here. There may be other desirable or even essential criteria for serious, realistic, honest and courageous dialogue on this topic. If so, let them be put 

on the table. For the diverse parties to participate in good faith, they must hold 

themselves as well as others to such criteria. The world needs everyone, the heirs 

of Bishop Maurice Dingman and the heirs of Dr. Norman Borlaug, to stay at the 

table and solve these issues, rather than abandon the dialogue and leave the world’s 

poor at an empty table. 

85 

33Far from it—where would genetics be without the contribution of the Augustinian friar 

Gregor Mendel, where would pharmaceutical knowledge be without the herbalists in countless 

monastery gardens! 34Pontifical Council for Justice and Peace, Vocation of the Business Leader: A Reflection. First 

published in 2011 and now available in about a dozen languages, the handbook can be 

downloaded at http://www.iustitiaetpax.va/content/giustiziaepace/it/archivio/pubblicazioni/ 

vocation-of-the-business-leader--a-reflection-.html. 

Conclusion 

The world’s food security challenges are not to be overcome with a referendum 

on science. Scientific research is good. It is right to celebrate the achievements of 

our three World Food Prize Laureates. The Church is not anti-science.33 Nor do we 

wish to promote a referendum on technology or biotechnology. Nor even a referendum on business—the Church is not against business or the market. In fact, 

while we have critiqued some aspects of the world financial system—inattention to 

the common good, disrespect for the rights of weaker members, tolerance for monopolies and cartels—my Council has sponsored a major publication that encourages 

the vocation of business leaders in carrying out God’s plan for humanity.34

The Church sees the GMO debate as a complex choice among various means— 

the means offered by advances in biotechnology and by innovations in agriculture, 

as well as the human, natural and socioeconomic means which can be developed locally and regionally. Among the goals we embrace are food security for all, quality 

of life of land-based populations, biodiversity and long-term sustainability. We see 

many sides to the coin of ‘‘world food’’. 

So we wish to promote meaningful dialogue amongst the stakeholders, whether 

in the United States or in other parts of the world. All sides of the controversy are 

using many of the same key phrases such as ‘‘overcoming hunger’’ and ‘‘sustainable 

agriculture’’, thus it will only be by mutual and respectful listening, by a genuine 

desire to learn from the other, indeed from all the stakeholders, that the better and 

truly enduring, sustainable solutions will be found. May I cite my own African experience of ‘‘palaver’’? Palaver is the extremely patient and thorough exploration of a 

whole problem until one reaches consensus. It means to talk and to talk, to listen 

and listen, thoroughly to explore every facet of a complex issue, with mutual respect 

and without hostility. Sooner or later, a truly consensual conclusion will arise. But 

in order to find the best way forward, ALL the stakeholders must be represented 

around the palaver circle—a circle characterized by humble and respectful listening, 

honest speaking, reconciliation of deep differences—a circle of true collaboration. 

Thank you for allowing me, in the name of the Church as convener and teacher, 

to offer to facilitate some of the needed dialogue. 

Cardinal PETER K.A. TURKSON, 

President, Pontifical Council for Justice and Peace. 

SUPPLEMENTARY MATERIAL SUBMITTED BY NINA V. FEDOROFF, PH.D., OLSSON FRANK

WEEDA TERMAN MATZ PC (OFW LAW) 

Hon. K. MICHAEL CONAWAY, 

Chairman, 

House Committee on Agriculture, 

Washington, D.C.; 

Hon. COLLIN C. PETERSON, 

Ranking Minority Member, 

House Committee on Agriculture, 

Washington, D.C. 

Dear Chairman Conaway and Mr. Peterson: 

Thank you, again, for the opportunity to testify on the importance of biotechnology the potentially detrimental impacts of mandatory GMO labeling. I really 

appreciated your questions and the interaction with the Members. As several questions pertained to the recent glyphosate study conducted by the International Agency for Research on Cancer (IARC), please allow me to provide some materials for 

the record and supplement my response. Glyphosate is the world’s most widely produced herbicide. Hence, the great interest in this chemical. 

The IARC concluded that glyphosate is a probable carcinogen to humans, yet 

noted there is limited evidence of such a link and, as I mentioned at the hearing, 

the study does not contain any new research. Moreover, the report contradicts the 

overwhelming consensus by the world’s most respected regulatory authorities and 

86 

scientific organizations, and the preponderance of all evidence where glyphosate has 

been found not to present a carcinogenic risk to humans. 

• First, and foremost, the IARC results contradict conclusions reached by the 

Joint Meeting on Pesticide Residues (the Meeting), which is an internationally 

recognized expert body administered jointly by the United Nations Food and Agriculture Organization and IARC’s parent body, the World Health Organization 

(WHO). ‘‘In view of the absence of a carcinogenic potential in animals and the 

lack of genotoxicity in standard tests, the Meeting concluded that glyphosate is 

unlikely to pose a carcinogenic risk to humans.’’ Joint Meeting of the FAO Panel 

of Experts on Pesticides Residues in Food and the Environment and the WHO 

Core Assessment Group, Rome, Italy 20–29 September 2004. 

• In 2013, the U.S. Environmental Protection Agency (EPA) ‘‘concluded that 

glyphosate does not pose a cancer risk to humans’’ and ‘‘Therefore, a dietary exposure assessment for the purpose of assessing cancer risk is unnecessary.’’ 

2013 Federal Register Notice (FR 25396, Vol. 78, No. 84, May 1, 2013). The 

EPA is also conducting a comprehensive re-review, which all chemicals go 

through every fifteen years, and will consider all new information that is scientifically based. 

• Germany’s Federal Institute for Risk Assessment (BfR), acting as Rapporteur 

Member State for the European Union’s renewal of approval for glyphosate, 

found that ‘‘In epidemiological studies in humans, there was no evidence of carcinogenicity and there were no effects on fertility, reproduction and development 

of neurotoxicity that might be attributed to glyphosate.’’ Glyphosate Renewal 

Assessment Report, Germany as Rapporteur Member State for the European Renewal of Approval for Glyphosate (2015) IARC’s classification, therefore, came 

as a ‘‘surprise’’ to BfR given Germany’s findings were based on ‘‘the most comprehensive toxicological database, presumably worldwide, for glyphosate. This 

database comprises hundreds of studies that were performed by or on behalf of 

the many manufacturers of glyphosate and thousands of references from the 

open literature. This huge amount of data makes glyphosate nearly unique 

among the active substances in plant protection product. BfR thinks that the 

entire database must be taken into account for toxicological evaluation and risk 

assessment of a substance and not merely a more or less arbitrary selection of 

studies.’’ Germany Federal Institute for Risk Assessment’s Response to the IARC, 

BfR Communication No 007/2015, 23 March 2015. 

• According to the Australian Pesticides and Veterinary Medicines Authority, 

‘‘The APVMA currently has no data before it suggesting that glyphosate products registered in Australia and used according to label instructions present any 

unacceptable risks to human health, the environment and trade . . . The 

weight and strength of evidence shows that glyphosate is not genotoxic, carcinogenic or neurotoxic.’’ Australian Government, Australian Pesticides and Veterinary Medicines Authority (2013). 

• The Argentine Interdisciplinary Scientific Council found that ‘‘The epidemiological studies reviewed showed no correlation between exposure to glyphosate and 

cancer incidence, nor adverse effects on reproduction, or Hyperactive-Attention 

Deficit Disorder in children. It is estimated that no significant risks would exist 

for human health regarding adverse effects on the genetic material. Under responsible use conditions for this herbicide, the intake of food and water would 

not imply risks for human health.’’ ‘‘Evaluacio ́n De La Informacion Cientifica 

Vinculada Al Glifosato En Su Incidencia Sobre La Alud Humana Y El 

Ambiente,’’ (‘‘Assessment of scientific information related to glyphosate and its 

incidence on human health and the environment’’) (2009). 

• The Canadian Pest Management Regulatory Agency reported that ‘‘Health and 

Welfare Canada has reviewed the glyphosate toxicology database, which is considered to be complete . . . The submitted studies contain no evidence that 

glyphosate causes mutations, birth defects or cancer.’’ Doliner L.H. (1991) PreHarvest use of glyphosate herbicide [Preharvest application of glyphosate 

(Roundup) herbicide]. Discussion Document D91–01. 98 pp. Pesticide Information Division, Plant Industry Directorate, Agriculture Canada. 

On reviewing all of the available data, both published and unpublished, regulatory authorities have consistently concluded that glyphosate does not cause cancer 

in either animals or humans. 

In short, Mr. Chairman and Mr. Peterson, while I respect the WHO–IARC, its report needs to be put in context. The IARC looks at whether a substance has the 

potential to cause cancer, rather than the probability it will considering the way it’s 

used in the real world. Furthermore, the IARC’s recent conclusions appear to be the 

87 

result of an incomplete data review that has omitted key evidence, and so needs to 

be treated with a significant degree of caution, particularly in light of the wealth 

of independent evidence demonstrating the safety of glyphosate. 

Thank you, again, for this opportunity, and I remain available to the Committee 

at any time. 

Sincerely, 

Dr. NINA FEDOROFF. 

SUBMITTED LETTER BY SCOTT MCGINTY, PRESIDENT, AURORA ORGANIC DAIRY

March 24, 2015 

Hon. K. MICHAEL CONAWAY, 

Chairman, 

House Committee on Agriculture, 

Washington, D.C. 

Dear Chairman Conaway, 

Aurora Organic Dairy is a leading supplier of USDA certified organic milk to retailers nationwide. We operate farms in Colorado and Texas, including a 3,000 acre 

farm in Erath County near Dublin, TX. Established only 10 years ago, we employ 

over 500 people and market milk from 25,000 cows thanks to strong demand for our 

products. These herds consume roughly 70,000 acres worth of organic crops, giving 

rural families the opportunity to participate in a growing sector of American agriculture. 

Consumers buy our products at leading mainstream grocers across America, including Kroger, Costco, Walmart, BJs, Safeway, Giant and many others. They buy 

organic milk because of the rigorous production and monitoring practices required 

by the National Organic Program (NOP) and they trust the USDA organic seal as 

a symbol of its certification. This law strictly prohibits the use of synthetics such 

as antibiotics, pesticides, herbicides, unapproved synthetics and genetically modified 

organisms (GMOs) in the production of certified organic food. In organic milk, this 

prohibition explicitly applies to the production of the feed. In fact, for milk to be 

certified organic, each feed ingredient in the animal’s ration requires its own organic 

certificate to verify production under these standards. Furthermore, each of these 

USDA organic requirements adds significantly to the cost of our company’s milk production. 

In turn, organic milk is frequently labeled with the specific attributes of the 

USDA NOP rule to convey that the product is certified organic. Common claims 

found on USDA organic milk are ‘‘produced without the use of GMOs’’, ‘‘produced 

without GMO ingredients’’, and ‘‘produced without synthetic pesticides or growth 

hormones.’’ Consumers buy this milk because they trust that these are not used 

anywhere in the production of the product—not on the farm, not in the feed, and 

not in the cow. 

As stated above, the law requires organic producers to make very large investments during conversion from conventional farms to organic farms. Then, organic 

producers spend a great deal more to produce organic food. Because certified organic 

feed costs so much and because being organic means lower yields from organic 

farms and cows, the cost of organic production per gallon of milk can be twice as 

much as conventionally produced milk. In Aurora Organic Dairy’s business, this 

amounts to more than $50 million spent each year to comply with the law on top 

of the estimated $80 million in one-time organic conversion costs. The organic industry as a whole spends billions in incremental production costs to comply with the 

USDA NOP in order to deliver certified organic food to American families. 

Given your consideration of biotechnology and GMO labeling legislation, we ask 

the Committee to recognize that any requirements for non GMO production under 

the NOP be extended to any new non GMO definitions. Non-GMO production has 

been defined in the consumer marketplace in accordance with the USDA’s organic 

program and the term should have the identical meaning under any new program. 

Any non-GMO labeling claim on milk should mean a complete prohibition of GMO 

feed use for consistency with NOP requirements. American families would expect 

nothing less. 

With the consumer in mind, we must avoid the confusion of inconsistent nonGMO meanings on labels. Given consumer sentiment for food transparency today, 


11407021.eps
88 

a conflicting non-GMO milk definition allowing GMO feed or other inputs would result in harsh consumer criticism and represent a large step backwards. 

For farmers, it is equally important that any non GMO requirements under one 

USDA program are the same as non GMO requirements under any other under the 

USDA or the Food and Drug Administration (FDA). To allow otherwise, would create a double standard and enable conventional milk producers using GMO feed to 

ride on the coattails and pocketbooks of certified organic farmers. A large class of 

producers would suffer severe economic loss as a result. 

We also believe that the introduction of a second USDA label for non-GMO food 

would result in consumer confusion with the existing USDA organic program and 

be a waste of scarce taxpayer dollars. As the recent farm bill process clearly showed, 

there is hardly enough funding for existing agriculture programs without creating 

new ones that duplicate efforts. 

To be clear, we do not oppose the use of biotechnology in food or the effort by Congress to create national labeling standards. It is very important labeling laws avoid 

unnecessary barriers to interstate commerce. We believe in creating choices for consumers and agricultural producers and applaud your support of USDA programs 

that stimulate such choices and expand the economic opportunities for the American 

farmer. For these programs to be trusted by their participants and American families, the definition of non-GMO and its associated labeling claims should remain free 

of any inconsistency. 

To put this idea into a real context, imagine a young mother at the grocery store. 

She is pushing a stroller, buying groceries for her family at home and the toddler 

who is looking up at her from below. With a glance at her shopping list, she says 

to herself ‘‘frozen pizza, diapers, and a gallon of milk:’’ Smiling at her baby, she remembers how she had avoided the pizza before she stopped nursing. She reaches 

the milk section and comes across two brands; one of them is the organic item she 

normally buys. The prices are quite a bit different so she looks closer and sees that 

‘‘non-GMO’’ is printed on both labels. She thinks to herself, ‘‘I’d love to save a couple 

dollars. Since they’re both made without GMOs, I think I will.’’ 

Now ask yourself, would she know that the two GMO claims have different definitions? Would she feel deceived to learn that the milk she bought was produced using 

GMO feed? Our law-making decisions must eliminate the potential for this sort of 

consumer deception. 

For these reasons, we submit that H.R. 4432, as introduced in 2014, would in fact 

create a double standard for the labeling of milk, undermine existing organic law 

and mislead consumers. Its provisions under section 103 clearly allow milk products 

produced with GMO feed to be labeled ‘‘non-GMO.’’ This definition of such a claim 

under any legislation would directly conflict with the definition of the term under 

the existing organic program. We strongly urge the Committee to consider this consequence and amend the language to preserve consistency with current law. 

We are grateful for the opportunity to submit this letter to the hearing record and 

thank you for considering our comments. We look forward to working with you and 

the Committee over the coming months during this review of mandatory biotechnology laws in agricultural production. 

Sincerely, 

Aurora Organic Dairy 

SCOTT MCGINTY, 

President. 

SUBMITTED QUESTIONS

Response from Nina V. Fedoroff, Ph.D., Senior Science Advisor, Olsson 

Frank Weeda Terman Matz PC (OFW Law) 

Question Submitted by Hon. David Rouzer, a Representative in Congress from North 

Carolina 

Question. Dr. Nina Fedoroff, thank you for the information you presented. Biotechnology is such a useful tool in the daily lives of the public, even if they don’t 

realize it. Genetic engineering helps to diagnose, treat, and prevent diseases, such 

as cancer, arthritis, diabetes, cystic fibrosis, sickle cell anemia, multiple sclerosis, 

cardiovascular disease, Hepatitis B, meningitis, and whooping cough. 


11407020.eps
89 

* Editor’s note: the witness did not differentiate the submitted responses; therefore they are 

printed as received. 

With that said, we hear from opponents to biotechnology that the science is making natural plants unsafe. I would like to ask you about poisonous, unsafe plants 

found in nature that science has been able to modify into useful, safe tools that benefit people’s health. I can think of a few examples: chemicals found in the Rosy periwinkle have been isolated and used in chemotherapy treatments; chemicals in the 

black henbanehas have been isolated and used in prescription drugs targeting muscle spasms and symptoms of Parkinson’s disease; and foxglove’s chemicals are used 

in medicines for people with congestive heart failure. 

Can you please speak to any further examples you have of biotechnology helping 

in this way? Also, can you please speak to how this public shaming of biotechnology 

is putting these advancements of science in danger? 

Questions Submitted by Hon. Dan Newhouse, a Representative in Congress from 

Washington 

Question 1. Can you briefly explain what benefits we could experience from a nutrition, food safety, and efficiency standpoint by using biotechnology? Also, do you 

believe publicly shaming or generating a culture of fear around these products jeopardizes their possible benefits? 

Question 2. Dr. Federoff, given the nature of the targeted, specific modifications 

that this technology uses, do you believe we actually know significantly more about 

the final, modified product in these instances than we might know with conventional breeding? 

Question 3. Dr. Federoff, in your experience, are plants that have been genetically 

modified using modern biotechnology materially different from their non-genetically 

modified counterparts? 

Question 4. So based on that assessment, should the FDA distinguish and regulate crops or livestock based on the method of modification or the material composition and why? Also, if you had to speculate, how difficult would it be for a farmer 

in the field to distinguish between a modified seed and a non-modified seed? Would 

a worker in a grocery store be able to tell the difference between a non-modified 

ear of corn and a modified one? 

Answers.* 

Medical Benefits 

There are more than a hundred compounds originally derived from plants that are 

currently used as drugs in one or more countries. The following website has an excellent table that lists the chemicals, their clinical uses and their plant sources: 

http://www.rain-tree.com/plantdrugs.htm. 

However, today’s new drugs are increasingly proteins produced through GM technology (also known as ‘‘recombinant DNA’’ technology). That is, our knowledge of 

genes and proteins has advanced to the point that we can make human proteins 

in large amounts in either cultured cells or in lower organisms, such as yeast and 

bacteria. The classic example is human insulin. Before GM technology, insulin was 

largely derived from pigs and often had adverse effects in humans. Today’s insulin 

is human insulin produced in microorganisms through GM technology. Other widely 

used human proteins produced in microorganisms are human growth hormone, clotting factors for treatment of hemophilia, and proteins used in vaccines. 

Nutrition, Food Safety, Agricultural Efficiency 

Many of the plants we use for food have a long history of genetic modification to 

make them more suitable as food plants by making them less toxic (potatoes, for 

example, contain toxic glycoalkaloids), easier to grow and harvest (bigger, softer 

grains that stick to the plant until harvest), and more appealing to eat (bigger, redder, sweeter fruits and vegetables). This is called domestication and much of it happened before we understood genes and genetics. But in the 20th century, growing 

knowledge of genetics was put to work in plant breeding by employing such scattershot methods of accelerating genetic change as chemical and radiation mutagenesis. 

About half of the crops on the market today have such a mutagenesis step in their 

history. Genetic modification by modern molecular methods, what we now call GM 

or GE, is just starting to be used to make nutritional improvements, although the 

Bt corn that is now grown very widely makes corn safer by decreasing contamination by fungal toxins (fungi get into the corn through holes bored by insects. No 

holes, no fungi, no toxins). 

GM foods in the pipeline that will offer advantages through improved nutrition 

or decreased waste include oils with omega-3 fatty acids, apples that don’t turn 

90 

brown when cut, potatoes that have lower levels of a natural amino acid that turns 

into the toxic compound acrylamide when the potatoes are fried in hot oil, and nonallergenic peanuts. 

However, perhaps the most important accomplishments of GM technology have 

been, and will continue to be, in making it possible to continue increasing the productivity of our (and our animals’) primary calorie sources (corn, soybeans, wheat, 

rice, canola) while decreasing the environmental footprint of agriculture and making 

it more sustainable by decreasing the use of toxic chemicals to control pests. In this 

regard, the 18 year history of current GM crops has been exemplary. As I reported 

in my initial testimony, a recent meta-analysis revealed that GM crop adoption has 

increased yields by 22% and farmers’ profits by 68%, while reducing pesticide use 

by 37%. GM crops have also been a major factor in decreasing topsoil loss by facilitating no-till farming. 

Safety of GM Techniques 

The current, highly conservative regulatory process was developed when little was 

known about the health and environmental impacts of GMOs. Today, we have more 

than a quarter century’s research on GM biosafety, all of which shows that modification of organisms by GM techniques is as safe as modification by older techniques 

and arguably safer. Indeed, a number of recent studies have revealed that there is 

much less genetic and epigenetic disturbance when plants are modified by adding 

a gene than when they are modified through older techniques such as genetic 

crosses (aka cross-breeding) or through either chemical or radiation mutagenesis. 

This is because the older techniques either bring together thousands of genes for 

the first time or cause damage that can reverberate through the genome, while GM 

technology can introduce just one or a small number of genes without disturbing the 

genome in general. 

What We Know About Today’s GMOs 

In addition to the fact that GM techniques cause less genetic disturbance than 

older techniques, the GM crops currently on the market are the most extensively 

studied crops ever to have entered our food chain. This is in part because analytical 

techniques have improved with the widespread development and use of techniques 

that allow monitoring of all genes, gene expression levels, proteins and metabolites. 

It is also because the current regulatory requirements are focused only on crops 

modified by GM technology and require that the developer demonstrate that the 

plant is substantially equivalent to the parent plant and that the substance to be 

expressed in the GM plant be neither toxic nor allergenic. That has never been required for a crop developed using any previous genetic modification technique, including radiation and chemical mutagenesis. Thus the answer to the question about 

whether a crop modified by modern biotechnology is materially different from its 

non-genetically modified counterpart is simply: no. They must be shown to differ 

just in the added component and that added component must be shown to be safe. 

That said, it must be kept in mind that biological organisms are constantly changing genetically, people included. So substantial equivalence does not mean genetic 

identity. 

Should Regulation By FDA (and USDA and EPA) Be Process-Based? 

More than 3 decades of biosafety research have failed to identify a hazard unique 

to the use of modern GM techniques. Indeed, there is growing evidence that modification of organisms by modern GM techniques is less disruptive of genomic structure and function than older methods. This means that regulation of organisms 

based on the modification method is simply unwarranted. Genetically modified 

organisms should be regulated based on their properties, not on the method of modification. 

The GM crops on the market today look identical to and are nutritionally equivalent to their non-GM counterparts. Thus neither a farmer nor a grocery store clerk 

could distinguish any of today’s GM crops from their non-GM equivalents by their 

appearance. Certain identification requires a still-costly molecular test. 

GMO Shaming 

The issue of GMO shaming, which is better described as vilification, is already 

serious and potentially calamitous. It is now standing firmly in the way of easing 

the regulatory burden on plants and animals improved through GM techniques, as 

the anti-GMO clamor tends to slow down decision-making in the regulatory agencies, in part out of fear of litigation. To give just one example of the slow and cumbersome regulatory process, the GM Aquabounty salmon, genetically identical to its 

wild progenitor except that it grows faster (and no, it is not a threat to wild salmon 

as it will be produced as sterile females only) has been in the regulatory approval 

91 

process for more than a decade. The company has complied with all of the FDA’s 

requirements, but the agency has simply failed to issue a decision, well past its own 

decision timeline. Developers have experienced similar prolonged decision-making 

stretching to years in the other agencies, the USDA and the EPA, that regulate 

GMOs. 

Why is the shaming/vilification of GMOs potentially calamitous? In the larger 

scheme of the world’s food supply, our population growth rate is now clearly exceeding the rate at which agricultural productivity is increasing. The extraordinary agricultural advances of the 20th century have put humanity in a position to supply the 

entire world’s population with an adequate diet today, despite the rapid growth of 

the human population over the previous century. Today’s hunger is the result of 

poverty, not an inadequate global food supply. But productivity increases are lagging, the population continues to grow, and climate warming is beginning to have 

a negative impact on agriculture globally. Without the innovations, amongst which 

the continued improvement of crop plants is arguably the most important, we face 

a future of increased food-based strife. 

Today there is a small, but extremely vocal and influential anti-GMO lobby in the 

U.S., comprising individuals such as the self-proclaimed expert Jeffrey Smith, organizations such as Greenpeace and the organic food industry’s marketers. These use 

any and all available scare tactics to vilify GMOs (and conventional agriculture in 

general) in order to maintain their revenue streams and, in the case of the organic 

food industry, to increase their market share. The preponderance of companies and 

public sector researchers developing GM crops are U.S.-based today. The objectives 

of the anti-GMO organizations and the organic food industry are to drive all GM 

foods off the market and convert U.S. agriculture to ‘‘organic.’’ Success in this endeavor could drive the major biotech industry players out of crop improvement using 

GM techniques and is already creating an almost complete impediment to public 

sector crop improvement using these techniques because of the high cost of complying with the complex regulatory requirements. This would compromise—and 

could even terminally cripple—the world’s efforts to achieve food security and make 

agriculture sustainable. Hungry people bring down governments, as we’ve already 

seen in recent food price spikes. 

Response from Joanna S. Lidback, Owner, The Farm at Wheeler Mountain, 

Westmore, VT; on behalf of Agri-Mark; National Council of Farmer Cooperatives; National Milk Producers Federation 

Question Submitted by Hon. Dan Newhouse, a Representative in Congress from 

Washington 

Question. Ms. Lidback, I’m a farmer myself and my state nearly adopted a similar 

law to what Vermont is preparing to impose, so I can deeply appreciate where you’re 

coming from. How do you believe it might impact your business if neighboring states 

like New Hampshire, or New York, or varying municipalities throughout the Northeast adopt mandatory, though inconsistent, labeling laws from each other? 

Answer. Thanks for your question, Representative Newhouse. We often work 

closely with folks in neighboring states. New England is a relatively small area and 

it’s very easy to cross state borders for everyday tasks. In fact, we choose to have 

our Jersey beef processed at a USDA facility versus state-certified so that we can 

bring our meat to other states to sell it, should the opportunity arise. A state-certified facility would only allow us to sell within Vermont. If each state had its own 

law that was different than the others, it would pile on regulations thereby increasing regulatory burden—burden we already face in other areas where quite frankly, 

it is more warranted such as water quality, food safety and labor management. We 

know currently if the Vermont law is put into place, dairy products and meat would 

be exempt from a label but we are not guaranteed that same consideration in other 

states’ laws. I believe it is important for farmers and others to share their hands 

on experience with genetically engineered crops with the general public so as to diffuse the stigma that has been placed upon them from a very vocal minority. Increased costs associated with a patchwork of biotech labeling laws would be felt 

most by those who can least afford it. The potential unintended consequences of 

these laws would be numerous. 

Response from Lynn Clarkson, President and Founder, Clarkson Grain 

Company, Inc. 

Question Submitted by Hon. Dan Newhouse, a Representative in Congress from 

Washington 

Question. Mr. Clarkson, from your testimony it appears you support a voluntary, 

standardized labeling regime, and your support for this policy stems from your expeVerDate Mar 15 2010 11:51 Jun 08, 2015 Jkt 041481 PO 00000 Frm 00095 Fmt 6621 Sfmt 6621 P:\DOCS\114-06\93965.TXT BRIAN
92 

rience with the emergence of foods being labeled as ‘‘organic’’ by producers. Can you 

tell me a bit more about your experience with the ‘‘organic’’ label, and how that has 

influenced your perspective regarding the need for a labeling standard? 

Answer. Clarkson Grain began merchandising certified organic products in 1994 

at the request of a few organic farmers in Illinois seeking better market access. At 

that time, there was no one national standard for organic certification. Instead there 

were several private groups and some states each certifying producers, handlers, 

and processors to their own standard. Each state and each group claimed that their 

standard was better than the others. That left buyers, handlers and farmers all confused about which certifier to use. Certifiers began competing with each other for 

business, some loosening standards to attract farmers and handlers, others tightening standards to attract more consumers. The grand challenge was to select the 

right certification to match successful marketing passage through the entire supply 

chain to the consumer. There were continual meetings as certifiers tried to respond 

to pressure to harmonize their standard. Since each wished to be unique, such efforts to standardize the standards never seemed to work. Some certifiers failed due 

to internal dissension or competitive pressure, throwing those who had chosen that 

certifier into disarray and exclusion from markets. Finally, the pressure to develop 

a national standard finally bore fruit thanks to the lead of the USDA. Contrary to 

the fears of those long championing organic production, the standards proposed and 

amended by the USDA satisfied almost everyone—farmers, handlers, processors, retailers and consumers. The openness of the regulations to citizen inputs allowed for 

an evolution in the rules. Finally, one national standard managed and enforced by 

the USDA helped organize supply chains that had the confidence of the consumer. 

Once that national standard came into place symbolized by the USDA’s organic 

label, the organic market soared, even growing during the recession. It continues 

to grow with all associated players knowing in significant detail what the rules require. 

Clarkson Grain has also been supplying non-GMO corn and soy to buyers since 

1994. Initial demand came from clients in Japan. Unfortunately there is no clear 

GMO standard. The same confusion that troubled organic markets before our national community defined ‘‘organic’’ now plagues non-GMO markets—domestic and 

international. Some of our international clients have abandoned the U.S. as a supplier of non-GMO corn and soy because there has been no government effort to 

standardize the meaning of non-GMO or support labeling, either voluntary or mandatory. There are already at least two private certifiers of non-GMO with a host of 

states considering standards, standards that vary by certifier. The largest private 

certifier lacks the resources to handle national and international demand and suffers internal conflicts as to its own standards. These markets would be significantly 

rationalized and improved if there were a single national standard managed by the 

USDA. Such a standard would support a label in which buyers and suppliers could 

have confidence. 

Should the label be mandatory or voluntary? Clearly some advocate mandatory 

labeling of any food containing GMOs. If the underlying consumer interest to be protected is the opportunity to choose non-GMO products, then voluntary labeling of 

non-GMO products to a known standard would certainly respect that choice. Targeted voluntary labeling would also be much less intrusive than mandatory labeling 

of almost every product in the grocery store. Since those currently offering non-GMO 

as well as those wanting to offer non-GMO products intend to label for market advantage, there would be no unnecessary labeling costs. In my opinion, a national 

standard linked to voluntary labeling would meet consumer needs and facilitate 

markets without any unnecessary costs. A labeling program backed by the USDA 

with tolerance levels openly established to meet consumer values would inspire 

more confidence throughout the supply chain and among consumes than competing 

labels offered by various private groups and government entities. 

Response from Thomas W. Dempsey, Jr., President and Chief Executive Officer, Snack Food Association 

Question Submitted by Hon. Dan Newhouse, a Representative in Congress from 

Washington 

Question. My home State of Washington narrowly defeated a mandatory labeling 

ballot initiative in 2013. However, many other states and municipalities have since 

passed initiatives, all of course with different definitions, standards, and labeling requirements from each other. Mr. Dempsey and Mr. Policinski—can you both briefly 

describe what your companies or member companies would experience if this trend 

continues? How would producers comply with a conflicting patchwork of state and 

local labeling and production requirements? 

93 

Answer. First, I would like to again thank the House Agriculture Committee for 

providing a forum for a balanced review of one of the most critical issues facing the 

food industry today, the labeling of genetically modified organisms (GMOs). The 

Snack Food Association represents more than 400 companies who produce a wide 

variety of snacks ranging from potato chips, to meat snacks, to crackers, to dried 

fruit and nut mixtures. SFA members range from billion-dollar multi-category companies such as Frito Lay and ConAgra Foods which have manufacturing facilities 

in Washington, to small family owned and operated businesses. More than half of 

SFA members have less than $100M/year in sales and many are the primary employer in their community. 

SFA is concerned both with the burden state-level GMO labeling would put on 

interstate commerce as well as the increased costs that could drive food companies 

out of business or increase food prices for consumers while potentially limiting their 

options in the marketplace. 

Over the last several years there have been a number of state ballot initiatives 

calling for mandatory GMO labeling. While voters have rejected ballot initiatives 

calling for mandatory GMO labeling in four states including Washington, the 

Vermont state legislature approved the nation’s first mandatory GMO labeling law, 

Act 120, last year. In addition, since January 2015, more than 20 states have introduced nearly 70 different pieces of legislation calling for some type of mandatory 

GMO labeling. If enacted, these rules would impact nearly every aspect of SFA 

members’ business, upping costs by requiring increased product inventory, added 

complexity for packaging and distribution processes, and extensive new regulatory 

and training requirements. 

As I mentioned during my testimony, the hardest hit by these new burdens would 

be the small, family-owned companies with just one plant with just a single line of 

production. Quite frankly, these costs could put some companies out of business and 

thereby increase consolidation in the industry. SFA does not have a single member 

company that manufactures, distributes, and sells in just one state, which adds additional layers of complexity if differing laws were enacted in multiple states. 

In order to avoid the need for duplicate labels, it is sometimes assumed that companies could simply remove the GMO ingredients from their products altogether. 

This is unrealistic because the availability of non-GMO crops is very limited. One 

SFA member indicated that they could not increase contracts for non-GMO corn for 

a minimum of 2 years. Transitioning to GMO-free production could not happen overnight, or even by 2016, as is specified in Vermont’s Act 120. 

Some food manufacturers may be forced to end the distribution of their products 

in states that require mandatory GMO labeling. This would have a ripple effect 

across the distribution chain, impacting drivers, warehouse personnel, account executives, and field management. And while consumers in some states, such as 

Vermont, may have the option to cross state lines to shop for goods if products were 

pulled from grocery shelves, however that is simply not feasible for everyone. Additionally, if product made its way onto the store shelves, despite a manufactures desire to cease distribution, the manufacturer, in the case of the Vermont law would 

be held liable, not the retailer. 

We agree with you that a national standard for GMO labeling—rather than a 

state-by-state patchwork of arbitrary rules—is the best approach. Absent a Federal 

GMO solution, manufacturers will have essentially three options in order to comply 

with a patchwork of state labeling laws. Those choices would be to order new packaging for products, reformulate products so no labeling is required, or halt sales to 

that state. As I have outlined, each option is difficult, costly, time-intensive, and at 

worst, could eliminate jobs and consumer choice in the marketplace. 

For all of these reasons, I would also like to thank you Rep. Newhouse for your 

leadership in supporting critical bipartisan legislation, the Safe and Accurate Food 

Labeling Act of 2015 (H.R. 1599) which represents a dramatic step in the right direction to address the problems associated with mandatory GMO labeling. SFA’s 

members appreciate that H.R.1599 balances the desire of some consumers for an additional label with the recognition that mandatory labels should be reserved for 

safety and nutrition concerns. Experts agree that the safety of GMO products is not 

a concern. The safety of GMOs is backed by FDA, USDA, EPA and 20 years of experience in the field. 

Again, thank you for your consideration of our views. We hope this lays the 

groundwork for a Federal solution to the threat of a costly and confusing patchwork 

94 

of state labeling rules. SFA would be happy to be a resource should you have any 

additional questions. 

Sincerely, 

TOM DEMPSEY, 

President and CEO, 

Snack Food Association. 

Response from Chris Policinski, President and Chief Executive Officer, 

Land O’ Lakes, Inc. 

Question Submitted by Hon. Dan Newhouse, a Representative in Congress from 

Washington 

Question. My home State of Washington narrowly defeated a mandatory labeling 

ballot initiative in 2013. However, many other states and municipalities have since 

passed initiatives, all of course with different definitions, standards, and labeling requirements from each other. Mr. Dempsey and Mr. Policinski—can you both briefly 

describe what your companies or member companies would experience if this trend 

continues? How would producers comply with a conflicting patchwork of state and 

local labeling and production requirements? 

Answer. Our farmers have embraced biotechnology faster than any technology in 

history. They’ve done that because of the benefits to their economics on farm, the 

environment, less land and water use, and less crop protection products used. Simply put, they are safe, and beneficial. Stigmatizing GMO foods through a patchwork 

of state labeling mandates, or even mandatory federal labeling, jeopardizes innovation and threatens the future development and use of technology in agriculture and 

the availability of these tools to our growers. The challenges from a food industry 

perspective are no less significant than those faced on the farm. Each state where 

mandatory labeling legislation is pending has a different labeling requirement. For 

example, in Washington State the ballot initiative would have required products 

that contain any ingredients grown from biotech seeds as ‘‘partially produced with 

genetic engineering’’ or ‘‘may be partially produced with genetic engineering.’’ Meanwhile, proposed legislation in other states would require labels to say ‘‘contains genetically engineered ingredients.’’ Additionally, the state regulatory body charged 

with drafting and enforcing these standards also varies depending on the state legislature, as does the scope of food products covered or exempted and the penalties imposed. The three choices we see under a state-by-state regulatory scheme are: (1) 

to stop selling in the state, (2) to relabel our products at considerable expense, and 

(3) to re-engineer our supply chain and reformulate our products at even greater expense. None of those are good choices. All of those choices would result in either 

denying consumer’s access to products or raise consumer costs. According to a Cornell University study, families may pay up to an average of $500 per year more per 

year in food costs due to mandatory labeling. That’s why we strongly support a voluntary national labeling standard, as proposed by the Safe and Accurate Food Labeling Act. 

Æ 


11407022.eps