Please reverse your 2013 Policy Memorandum that allows mutant seeds in organic.
The memorandum states: “Mutagenesis (treatment of plants with radiation or chemicals to induce random mutation) is considered part of traditional breeding programs.”
Genetic modification isn’t allowed in organic. Neither is radiation. Why is mutagenesis allowed when it is a form of genetic modification that employs radiation?
Like genetically modified seeds, mutant seeds present human health risks. Mutagenesis can produce dramatic shifts in genetically determined traits, triggering unknown toxins or allergens. Some blame recent increases in wheat allergies and intolerances on the fact that 99 percent of modern wheat, including organically grown wheat, is the product of mutation breeding.
I am concerned that your approval of mutant seeds may lead to the approval of mutant microorganisms.
The National Organic Standards Board has approved DHA and ARA, two synthetic nutrients used in baby formula and other organic foods, which are linked to severe gastrointestinal distress, prolonged periods of vomiting and painful bloating.
DHA and ARA are the product of mutant algae that have been genetically modified with radiation. The patents for DHA and ARA use mutagenesis interchangeably with recombinant DNA techniques of genetic engineering.
You should exclude DHA and ARA from organic because they are the product of mutagenesis.
Organic Consumers Association
This petition closed 10 months ago
In order for a product to meet the criteria for USDA organic certification, neither the product nor any of its ingredients can be genetically engineered, or genetically modified. Certified...
In order for a product to meet the criteria for USDA organic certification, neither the product nor any of its ingredients can be genetically engineered, or genetically modified. Certified organic products and ingredients also can't be irradiated.
So why is it that organic regulators allow the process of mutagenesis in organic—even though mutagenesis is a form of genetic modification
that uses radiation?
Tell the USDA National Organic Program: Mutagenesis Doesn't Belong in Organic!
What is mutagenesis?
Mutagenesis is a method of plant breeding that involves subjecting plants to radiation, or dousing them in chemicals, in a way that scrambles their genes in order to produce new traits. The goal is to produce plants suitable for modern industrial agriculture, where crops are grown in vast monocultures with the aid of chemicals and machinery.
Sound a lot like genetic engineering? It is.
Mutagenesis doesn't involve transferring the genes of one species into another. But just like genetic engineering, mutagenesis is an imprecise and uncontrolled process. The intent may be to produce a specific, desired trait. But there is no way to predict or control the unintended consequences.
How did mutagenesis come to be allowed in organic?
The regulations governing organic are very clear when it comes to genetic engineering. They exclude "methods used to genetically modify organisms . . . by means that are not possible under natural conditions."
That means no GMOs in organic. It should also mean no mutagenesis in organic. So why doesn't it?
According to the regulations, genetic engineering doesn't include the use of "traditional breeding." Promoters of mutagenesis claim the process is just another form of traditional breeding, and thus should continue to be allowed in organic. Efforts to prove them wrong have so far gone nowhere. In 2013, the National Organic Program issued a memorandum interpreting the regulation's reference to "traditional breeding" to include mutagenesis.
If we want to get mutagenesis out of organic, we have to convince the NOP to change its interpretation of the regulations governing organics.
What are the risks associated with mutagenesis?
Like genetic engineering, mutagenesis can cause dramatic shifts in genetically determined traits, producing unknown toxins or allergens. Wheat Belly author Dr. William Davis blames mutagenesis, which is used to produce modern wheat—including organically grown wheat—for increases in wheat allergies and intolerances.
Mutagenesis, like genetic engineering, also leads to increased use of pesticides—another health hazard, especially for children.
For example, BASF used mutagenesis to engineer an herbicide-resistant wheat variety. Clearfield wheat is grown on more than 1 million acres in the US. According to a Bloomberg news report:
"BASF, the world's biggest chemical company, is having success with its line of Clearfield crops. The German company made the crops tolerant of its Clearfield herbicide through chemical mutagenesis. It alters the crops' DNA by dousing seeds with chemicals such as ethyl methanesulfonate and sodium azide, according to company filings in Canada, the only nation that regulates such crops."
Bloomberg reported that BASF enlists the help of 40 seed companies, including DuPont Co. and Dow Chemical Co. in the U.S., to sell Clearfield crops in markets that reject GMOs. Clearfield wheat, rice, lentils, sunflowers and canola are planted from Russia to Argentina and the U.S. without regulatory review, according to Bloomberg.
"Without regulatory review" is bad enough. But to allow the use of mutagenesis, a process that involves "dousing seeds with chemicals," in organic is a serious breach of consumer trust in the USDA organic certification program.
How can you avoid food grown from mutant seeds?
How do you know if your organic food comes from mutant seeds? You don't. If you buy local, you can ask your local farmer.
Alternatively, you can avoid rice, wheat, barley, pears, cotton, peppermint, sunflowers and grapefruit. These are some of the mutant crops that you could potentially find in the organic section.