Posted September 19, 2008 by
A Dow Jones story last week, titled “FDA To Face Public Upbraiding Over Ingredient In Plastic,” points to a longstanding contradiction between what federal regulators consider good science and what scientists consider to be good science.
This latest example revolves around Bisphenol A (BPA), the synthetic estrogen put into the polycarbonate plastic found in baby bottles, water bottles and the liners of some food and infant formula cans. BPA isn’t bound within the plastic, so with heating or normal wear it leaches out into the food, breast milk, formula or water in these containers.
The disagreement between the FDA and the scientific community seems to be about whether or not this is okay. The FDA claims there is no science indicating that BPA poses a risk to humans. That’s because the FDA only considers the science (i.e. toxicity studies) submitted to it by pharmaceutical companies or plastics manufacturers using something called Good Laboratory Practice (GLP). GLP criteria are those ensuring cleanliness and good hygiene in the industry-operated labs or the labs they have paid to conduct the studies.
GLP does not address at all whether the work actually done by the labs is well-designed, has answered the "right" questions from a public health standpoint, or even whether the study sent to the FDA accurately reports what happened in the lab - i.e. the experimental outcomes.
On the other hand, academic laboratories don’t go to the trouble or great expense of getting themselves certified as using GLP. The quality of their work is ensured by the fact that it’s peer-reviewed, submitted for publication and the results are made publicly available.
The not-so-funny result is that the FDA ignored hundreds of published scientific studies suggesting that BPA does pose a risk to humans, and relied instead on two industry-funded studies that were negative, but which did use Good Laboratory Practice.
What the industry studies didn’t use were the most up-to-date, sensitive techniques for measuring potential effects from exposure to BPA. This isn’t uncommon. In fact, it’s typical that the requirements codified into law that dictate which tests of chemical or product safety federal regulators require of manufacturers are scientifically out-of-date. The science of testing is ever-evolving; chemical regulations often aren’t revised for decades. In fact, the Toxic Substances Control Act, the chief law regulating industrial chemicals, hasn’t been revised since 1976.
Similarly, the EPA acknowledges there are some 140 approved pesticides that it now considers toxic to the brain and nervous system. Under the code of federal regulations, however, the EPA still doesn’t require that new pesticides be tested for neurotoxicity before being put on the market. The EPA doesn’t require that any chemical--industrial or pesticide--be tested for its potential to damage the young, developing brain before being put on the market.
So, the next time you read a warning from scientists that some common chemical or pesticide may not be safe, followed by assurances from the industry that the FDA or EPA has called it “safe,” know this: both are right, depending on their view of what constitutes “safety” or good science.
Independent scientists are saying that the latest published science raises new concerns (or strengthens longstanding suspicions) about a chemical product already on the market. Industry, meanwhile, is saying that the chemical has been tested and passed the weak and often outdated testing standards that the FDA or EPA has set for them.
That’s why a regulator’s notion of “safe” may not pass a parent’s laugh test.
David Wallinga, M.D. is a physician and Director of the Food and Health Program at the Institute for Agriculture and Trade Policy in Minneapolis.
Posted September 18, 2008 by
Thanks to Business Week, I finally have a name to put on a topic that has been rattling around in my brain over the past several months - innovation economics. The September 11 issue of Business Week has a cover story called “Can America Invent Its Way Back.”
As I understand it, the concept is relatively simple and uncontroversial. "Ninety-five percent of economists agree that innovation is the most important thing for long-run growth," says Daron Acemoglu of the Massachusetts Institute of Technology. Given that near unanimity, why haven't we developed better methods of measuring innovation, and better policies for promoting it?
We know how to measure growth, and politicians and business leaders talk endlessly about promoting growth. But growth and innovation are not the same thing. Recent growth has been the result of consumption, not innovation. The rise in housing prices creates growth in the economy, but it does not necessarily mean that any innovation has occurred. A factory can develop a way of making a product more efficiently and therefore contribute to growth, but it doesn’t necessarily mean that the fundamental way of doing business has changed.
Innovation economics addresses the gap between spending and results. After all, spending billions of dollars on research and development does not guarantee that innovative technologies will emerge. The Business Week article points out that huge amounts of money have been spent on biotechnology and nanotechnology, but few breakthroughs have been commercialized.
Presidential debates on economics largely focus on things like tax policy, deficit spending and trade. These issues are of course important, but perhaps they should take a backseat to innovation policy. After all, if policies can foster a higher rate of innovation, many other fiscal problems vanish.
It’s intriguing to think of innovation economics in the context of the current concerns about rising food prices. I would argue that much of the agribusiness industry and federal agricultural R&D has abandoned innovation for efficiency. Here in the U.S. Midwest, we have spent the past 40 years developing an agricultural system based on corn and soybean production and feeding those commodities to feedlots and ethanol plants. Both public and private research tends to focus on efficiency – a couple more bushels of corn per acre, for example, or increasing the feed efficiency of livestock. Efficiency, after all, doesn’t cause turmoil in an industry like innovation sometimes does.
What about more integrated agricultural systems that can produce many, many more food calories per acre? Farmers around the world, such as Joel Salatin in Virginia, have developed extremely productive farming systems. Why do we leave that very important research to a smattering of underfunded farmers?
I wonder what would happen if USDA or some other agricultural entity took a fraction of their budget and created a food and agriculture prize that offered, say 10 annual awards of $100,000 each, to farmers for developing innovative on-farm production systems. My hunch is that we could do more for long-term agricultural productivity with such awards than the billions that have been spent to date on biotech corn.
Posted September 16, 2008 by
Under the slogan “Another World Is Possible!” more than 20,000 activists from social movements, trade unions and civil society organizations are expected to participate in the fifth European Social Forum (ESF) in Malmö, Sweden from September 17-21. This space has become an important meeting point for social activists across Europe to share their struggles, analyze recent developments, and develop joint actions against neoliberal policies promoted by their governments.
The fifth ESF takes place at an important moment in time: the European Integration process pursued by EU governments has become very unpopular. During the four days, social activists from throughout Europe will discuss alternatives and form alliances aimed at moving toward a social, democratic, ecological and peaceful Europe. The role of Europe in the world will be a key axis of debate, but representatives from social movements and trade unions in Africa, Asia, Latin America and the U.S. will also attend the Forum. Several new European-wide networks are expected to emerge from the ESF.
For the first time, food and agriculture themes will have a big presence at the Forum. A broad range of European networks--consisting of farm, environmental and consumer groups--are co-organizing a series of seminars and assemblies to discuss the current food crisis and alternatives. The overall objective is to build a European movement for food sovereignty. Given the responsibility of the U.S. and the EU in today’s failed global model of agriculture and trade, and the importance of building alternatives within these two trading powers, IATP is engaging more actively within Europe.
Collaborating with a diverse range of European-wide networks (Seattle to Brussels Network, Labor and Globalization Network, European Coordination Via Campesina and European Food Sovereignty Network, among others) IATP has helped to organize a series of seminars and discussions on food sovereignty and the EU’s external trade policy. IATP has taken the lead to organize a seminar on the explosion of food prices, as well as one on the impacts of free trade agreements on labor in Europe and the Global South. I will be blogging from the ESF throughout the week.
Posted September 12, 2008 by
Last night I was given the opportunity to speak at a forum in Adelaide, where I live, organized as part of the One Just World series. The forum is designed to educate the public on development issues, organized jointly by the International Women's Development Agency, World Vision Australia and the Australian bilateral aid agency, known as AusAID.
The highlight for me was a chance to hear an old friend and colleague speak, Farhad Mazhar. Farhad lives and works in Bangladesh, and last night he presented a movement of agro-ecological farming that now includes 2000 farmers in the country: Nayakrishi Andolon
Here is Farhad describing the movement: "In its simplest expression, it is an act of ananda, a happy way to relate with nature and enjoy life. It is production, distribution and consumption of happiness among and within the members of the world of human and non-human beings, both organic and inorganic. Why do you practice Nayakrishi? The response from the farmers is: 'I want to be happy, that's all!'"
Nayakrishi farming means using the land to generate the inputs you need: fertilizer, seed, pest management, and so on. Farhad said the movement has the seeds to grow more than 2000 varieties of rice, though that is just a fraction of the estimated 15,000 varieties that could once be found in Bangladesh alone. With the seeds is a knowledge base that is unparalleled in formal institutions such as seed banks. The movement does not eschew science or new learning, but rather, integrates it into a model that is focused on the health of the whole farm, which avoids creating dependence on external inputs.
The movement works with what people have, not looking for ways to bring in stuff from the outside (all of which would cost money--something the farmers are not endowed with). It plays to their strengths: use lots of labor; use the land for multiple purposes (raise fish in ponds or even in the rice paddies--something that makes the use of pesticides impossible; or, grow crops not just for their yield of food, but for their other uses: fodder for livestock, waste for compost or energy-generation); preserve multiple varieties so you can cope with late rains, floods, or a persistent pest that seems to like the variety you grew last year. These are all simple precepts but none of them is popular with the big development funders. They would rather subsidize fertilizer (until when? And what then?) and encourage biotech seed, which will cost money for the intellectual property and will go on costing money because the farmers are not allowed to save the seeds.
The movement was inspired in part by women, who wanted to end the use of chemical fertilizers and pesticides because of what the chemicals were doing to their health, and their children's health, as they worked on the farms. The connectedness of the thinking and vision and practice is what makes Nayakrishi so exciting--and so powerful. And the movement has sisters around the sub-continent, linked in a network called the South Asian Network on Food, Ecology and Culture (SANFEC).
The panel also included Tim Costello, CEO of World Vision, who gave an important speech on how the food price crisis is linked to climate change, and why climate change is an issue linked to fighting poverty and for justice. My speech was on why trade is not the solution to food security. A transcript of the event will be online shortly at the University of South Australia site-- UniSA (as it is known) was a co-host of the Adelaide forum.
Posted September 10, 2008 by
I wasn’t sure what to expect when I drove out to Western Minnesota to check in on Ms. Shi Yan. She has been working at the Earthrise Farm, an organic CSA (Community Supported Agriculture) farm, since early April, as part of IATP’s ongoing relationship with the School of Agriculture and Rural Development at People’s University in China. Shi Yan’s blog posts (read translated posts here) have been wonderful. She opens a window not only into the everyday life of a CSA farm but also into the heart of a young Chinese woman from a city of 20 million coming to the U.S. for the first time and finding herself on a farm. Reading the blog, it seemed that Shi Yan had fallen in love with this doubly foreign environment, but I had enough experience with farm work and Chinese politeness to worry that she might be having a harder time than she let on.
Pulling into the driveway of Earthrise Farm around supper time, I was dismayed to see broken trees, damaged crops and big piles of brush and tree limbs scattered around the yard. A big storm had come through a few days before, with hail and 90 m.p.h. winds, and although no one was hurt, it clearly hit the farm hard. One casualty of the storm was Lou T Fisk (see right), the town mascot of Madison, MN. (pop. 1654). A Norwegian-American community worthy of A Prairie Home Companion, Madison calls itself the Lutefisk capitol of the world, and old timers still say, “Takk,” instead of, “Thanks.”
After exchanging greetings, Nick, one of the full-time farm managers at Earthrise, said, “We have just been dealing with downed trees and other storm damage for the past few days. Tomorrow’ll be the first time we can actually get back into the fields.”
Shi Yan came up and gave me a big, un-Chinese hug. She looked right at home in work clothes, with an armful of vegetables she had picked for supper. She was happy to see the Chinese ingredients I had brought from Minneapolis, but quickly put them aside and joined in with the meal preparation. I got an introduction to the farm from Nick and Joan (the other manager) over supper, and met the other intern, Emma.
Only after dinner, back at the small farmhouse where the interns sleep, was I able to talk with Shi Yan alone about her experience. And to my relief, she was just as excited about organic, community-supported agriculture in person as she had been in her blog posts. She spoke with admiration about the kindness and dedication of the Fernholz Sisters, founders of Earthrise; the hard-working Nick and Joan; and her friendships with her fellow interns, one of whom had already left for school. It has been a momentous summer back in China, with the tragedy of the Sichuan earthquake and the triumphant Olympic Games in Beijing, but thanks to the internet Shi Yan has been in touch with her boyfriend and family almost daily.
Above all, organic farming has been a revelation to her. She described her plans for managing a CSA farm on a plot of land owned by her university in Beijing’s northern suburbs, how she would use student labor and get organic certification and sell vegetables on campus. And she asked about visiting farmers’ markets and grocery co-ops when she comes to Minneapolis on her way back to China, in October.
It was wonderful to see how Shi Yan has taken to rural Minnesotan life, and how the people of Chippewa County have taken to her. Thanks to the rarity of Chinese nationals in those parts, and a long profile of her in the local paper, Shi Yan is a bit of a local celebrity, but she is also clearly well-liked by those who have met her. When we visited another farm, a local Fair Trade coffeeshop or a County Board meeting, people already knew her and there were always hugs all around.
As we weeded the storm-damaged pumpkins and carrots at the farm, Shi Yan would look up and wave at every pickup that rumbled past. (And they’d wave back.) This last point might not sound odd to most readers, but take my word for it: it’s not standard operating procedure in China. Social relationships there are more formalized, and there is a much sharper distinction between people you have a relationship with and strangers. (Hence the incredibly strong Chinese family unit and gracious spirit of hospitality to guests on one hand and the regular spectacle of shoving matches or fights between strangers waiting at ticket windows or bus stops on the other.)
Intellectually, Shi Yan is getting more focused on the comparative research that she will take back with her, honing in on the aspects of her American sustainable farming experience that are and are not relevant to small farmers back home in China. But her summer as a Minnesota farmer has also been a wonderful cultural exchange that I think neither she nor the people of Chippewa County will soon forget.
Posted September 9, 2008 by
The Stockholm International Water Institute issued a new report (while many of us were vacationing in August) that is worth revisiting. The report covers an aspect of the global food crisis that is often missed: waste.
The report walks the reader through the food chain--from the field, to pre-processing, transport, storage, processing, marketing and finally, your kitchen--and estimates that up to half of all food produced is lost. These losses within the food chain are not the same for rich and poor countries. Broadly speaking, in poor countries most food losses occur at the beginning of the food chain, often in the field due to poor harvesting, or as a result of poor storage and transport facilities (made worse in hot and humid weather). In industrialized countries, the losses occur toward the end of the food chain, where food is wasted in wholesaling, retailing, and among consumers who tend to throw away a significant amount of food.
The authors point to the role of globalization in food loss and in turn make the case for stronger local food systems: "One reason for losses in the food chain is an increasing distance between the places where food is produced and where it is consumed. . .Because more and more of the world's population are moving out of agriculture and into urban centers, the food chain is becoming longer and more complex."
The SIWI report's main conclusions and recommendations are consistent with many of the conclusions of the International Assessment of Agricultural Knowledge, Science and Technology, released in April, which looked at how to address the food crisis in an era of climate change and has been endorsed by 57 countries.
Posted September 5, 2008 by
One foundation of the U.S. regulatory system are the advisory committees required by law to provide federal agencies with information and counsel. Full of hopes for good regulatory governance, I went to Washington last week to attend a National Advisory Committee on Meat and Poultry Inspection (NACMPI) meeting on international food safety equivalence, hosted by the Food Safety and Inspection Service (FSIS). NACMPI members include academics, consultants, small-scale meat processors and one consumer representative, Carol Tucker Foreman of the Consumers Federation of America. Tony Corbo, of Food and Water Watch, substituted for Carol, whom USDA had double booked to attend a biotechnology advisory committee meeting.
U.S. law (e.g. USC, Section 120) requires that exporting countries have food safety systems "at least equal to" the U.S. food safety system in order for importers to be certified by the Secretary of Agriculture. However, U.S. legislation to join the World Trade Organization changed the law to allow food imports if U.S. regulators judge the food safety measures of foreign exporters to be "equivalent" to U.S. measures in protecting consumer health. About 11 percent of all meat and two percent of poultry consumed in the U.S. are imports, largely from Canada, Australia and New Zealand. Officials from those countries made presentations urging NACMPI to recommend the expansion of equivalence agreements to cover whole food safety management systems, rather than individual food safety measures, such as the cleaning of food contact surfaces in meat processing plants. Presentations to NACMPI are posted here.
Transnational corporations with foreign export facilties (e.g. Tyson Foods in Mexico, Cargill in China, Smithfield in Poland etc.) hope to increase, perhaps double, U.S. meat and poultry imports within a few years. To do so, FSIS must certify that either exporting countries can comply directly with U.S. food safety requirements or agree that those countries have food safety measures that are "equivalent" in the protection they provide to consumers. FSIS usually leads U.S. negotiations at the Codex Alimentarius Commission, the international food standards body recognized as authoritative by the WTO on guidance for international equivalence agreements. However, FSIS said not a word about its Codex work, and instead made presentations to advocate for "risk based" inspection of meat and poultry products at U.S. ports of entry and "third party" (neither exporter nor importer) certification of export facilties as safe, in order to reduce border inspection. Mike Robach, Cargill's vice president of food safety and regulatory affairs, made the Grocery Manufacturers Association case to NACMPI for third party certification to expedit trade and target inspection resources to products and facilities identified as "high risk" by FSIS. The USDA Inspector General, in a report issued on August 27th, augmented its criticisms of the FSIS plans for risk -based inspection.
FSIS gave NACMPI subcommittees just two hours to respond to FSIS questions, including whether FSIS should drop components of equivalence agreements that the agency had already committed to supporting at Codex! I was able to speak briefly about FSIS Codex work and distribute a statement to subcommittee members that urged NACMPI to request the participation of General Accountability Office and USDA Inspector General auditors at NACMPI's next meeting to explain shortcomings in FSIS food safety management controls for protecting U.S. consumers. FSIS hopes that the industry's self-regulating audits of export facilities and the targeting of imports for inspection according to FSIS management defined risk will enable meat and poultry imports to increase sharply from the present four billion pounds a year. FSIS plans to maintain the current inspection force of 70 inspectors at 110 U.S. ports of entry. GAO identifies FSIS management as a "high risk" program. We agree with GAO and think that NACMPI should receive GAO's advice before FSIS asks it to make further recommendations on international food safety.
Posted September 4, 2008 by
On August 29th, the U.S. Federal Appeals Court in Washington, D.C. ruled against an appeal by Creekstone Farms to allow the farm to test slaughtered cattle for Bovine Spongiform Encephalitis (BSE or Mad Cow disease). Human consumption of meat infected with BSE materials is the most likely cause of the rare but invariably fatal new variant Creutzfeld-Jacob Disease. The most likely cause of BSE is the feeding of cattle or other ruminants' remnants to cattle.
Creekstone proposed to test all its slaughtered cattle as demanded by its Japanese customers, who have indicated they would be happy to pay the test's ten cents a pound cost. Creekstone would use the same testing kit employed by the U.S. Department of Agriculture, which opposed Creekstone's appeal. IATP has written occasionally about Mad Cow over the last decade, particularly regarding the failure of U.S. government agencies to enforce rules to prevent BSE and the U.S. government rationale for testing a far smaller percentage of cattle for BSE than in other countries. IATP also has joined a friend of the court brief to require greater safety enforcement from the USDA.
In the case decided last week, the USDA argued that the Virus Serum Toxin Act (VSTA) of 1913 authorized the agency to prohibit private testing of BSE on the grounds that the test was one of the "analogous products" referred to in the Act. Former IATP intern Gregory Berlowitz disputed USDA's interpretation of the VSTA in a 2006 University of Illinois Law Review article. While agreeing with Creekstone that the VSTA language did not apply to the BSE test kit as "worthless, contaminated, dangerous or harmful," the Court nevertheless deferred to USDA's regulatory authority over BSE, sustaining USDA's contention that the post-mortem test was an animal "treatment" analogous to that of a serum. IATP has only scanned the Court's ruling but believes that there are grounds for Creekstone to appeal to the U.S. Supreme Court. As Chief Judge Sentelle's dissent suggested, there is plenty of reason for Creekstone to test whether the USDA's assertion of regulatory authority is "arbitrary and capricious."
We will analyze this ruling in greater detail, but for now, the protection of U.S. consumers with regards to mad cow disease rests on faith and hope. We hope that the General Accountability Office was wrong when it criticized the Food and Drug Administration's enforcement of feed formulation rules to prevent BSE. We hope that the USDA's Inspector General exagerrated in documenting USDA's failure to enforce slaughtering and processing regulations to prevent BSE. We likewise hope that USDA's main "scientific" justification for not testing for BSE, a Harvard University Center for Risk Analysis study, was not as riddled with error and dubious assumptions, as critics like Consumers Union maintain. We hope that USDA's argument to the Court that universal testing would be "meaningless" because of BSE's long incubation period is valid, while wondering why USDA's "targeted sampling" tests are meaningful, when the Harvard risk analysis provides weak targeting rationale. Finally, we hope that McDonald's warning to its suppliers to follow the company's more stringent feed formulation and slaughter requirements or lose their supply contracts had the desired effect of securing the compliance that FDA and USDA could not.
Posted September 3, 2008 by
This week, the National Institutes of Health-published journal, Environmental Health Perspectives, included an article on yet another health benefit of omega-3 fatty acids: they appear to protect against the heart-damaging effects of toxic air pollutants. Those taking fish oil had much greater antioxidant function that did another group taking soy oil instead. You can read more here.
(ed note, this post comes from David Wallinga, M.D., Director of IATP's Food and Health program)
Posted August 27, 2008 by
While most believe the Doha Round of negotiations at the WTO are dead, a few countries, led by Brazil, are desperately trying to re-start discussions. Yesterday, IATP's Anne Laure Constantin wrote about Brazil's evolving role at the WTO: from a leading voice for developing countries when talks collapsed at the Cancun Ministerial in 2003, to a persistent advocate for a Doha deal this July in Geneva. As Anne Laure wrote, Brazil has huge agriculture export interests that stand to benefit from a deal at the WTO, particularly in this new era of rising commodity prices.
But a new analysis by researchers at Tufts University Global Development and Environment Institute points out that, unlike Brazil, most developing countries would be left out of any projected export boom, while suffering the negative consequences (loss of farmers, greater vulnerability to price volatility) due to rising food imports. The few developing countries that stand to gain are those with greater capacity for production with vast tracts of high-quality land, modernized agricultural production and infrastructure: Brazil, Argentina, China and the former Soviet Union.
The Tufts researchers write, "To emerge a winner from agricultural trade liberalization, other developing countries will need to out-compete not just the global North but these emerging agricultural export powerhouses."
The Tufts research shows yet again the weakness of a one-size-fits-all approach to agricultural trade rules being pushed at the WTO. They write, "Trade liberalization globalizes not only markets, it globalizes market failure."