Posted September 18, 2014 by Dr. Steve Suppan
How much would you pay for a pork chop that was two percent leaner? Would you eat such a pork chop if nanoscale minerals were mixed into the hog feed to achieve that two percent reduction? Such questions are before the Food and Drug Administration (FDA) as it considers what to advise the animal feed and mineral supplement industry about their efforts to incorporate atomic- to molecular-sized materials into feed.
This summer, the FDA requested comment on what to advise the animal feed industry about nanomaterials. IATP and others have repeatedly called for the FDA to require pre-market and post-market safety assessment of nanomaterials prior to their commercialization. To the latest FDA request, IATP responded that if FDA continues to not require adequate pre- and post-market safety assessments, it should at least strongly urge the industry to report to FDA in great detail about its nano-feed products. We also said that industry reported data affecting public health, the environment and worker safety should be not classified as Confidential Business Information (CBI) not available to the public.
IATP joined an International Center for Technology Assessment lawsuit in 2011 to sue the FDA for failure to regulate nanomaterials. In lieu of mandatory rules on nanotechnology, the FDA is issuing voluntary guidance documents that do not carry legal obligations but advise industry on what FDA suggests. These guidance documents do not require nano-feed additive developers to do anything about their use of nanomaterials and nanotechnology. (IATP commented last month about two other FDA Guidance documents on nanotechnology.)
Feed for agricultural animals is largely formulated from grains and oilseeds, mostly corn and soy. A very small fraction of the feed, perhaps four percent (measured in grams per kilogram), comprises a premix of essential minerals and vitamins. Nanomaterial additives to feed are measured by micro-grams, i.e., millionths of a gram, although it is not clear how such minute material can be weighed accurately. According to recent research, nano-sizing feed, or indeed, food, additives enables more rapid and complete absorption of essential minerals and vitamins. As a result, for example, hogs consuming nano-sized chromium result in leaner and “better” pork.
The FDA draft guidance advised industry not to assume that because a mineral in conventional feed had been deemed Generally Recognized As Safe (GRAS) by the FDA, that the nanoscale version of the same mineral would also be GRAS. IATP strongly supported this commonsensical advice. The draft guidance also implied some important questions.
The FDA asked the feed industry how it would ensure that nanomaterials were uniformly mixed in feed so that a hog or a cow would not be overdosed with a nano-scale essential minerals, such as zinc or chromium. IATP suggested that the FDA also ask how that uniformity would be maintained after manufacture, since nanomaterials, if not chemically bound, are highly mobile. A uniform mixture during feed additive manufacture might become less so during feed storage and on-farm use.
FDA informed industry that every use of a nanomaterial would be reviewed on a case-by-case basis. We urged FDA to require both a pre-market and post-market safety assessment of all nanomaterials and to prohibit industry Confidential Business Information claims about data in such assessments that pertain to human, animal and/or plant health, and worker safety. However, FDA is budget hamstrung by zealously anti-regulatory members of Congress, so we urged the agency to evaluate the nanomaterials that bio-accumulate in humans and animals first, including nano metal oxides, metals and carbon nanotubes (used, e.g., to strengthen automobile parts).
Evidently, a byproduct of feeding livestock with nanomaterials would be manure laced with nanomaterials. We recommended that FDA share anonymized data supplied by industry to enable the Environmental Protection Agency to plan and carry out research about the effect of nanomaterial residues in manure on soil, water and plant health. We also asked the FDA to share data with the Occupational Safety and Health Administration to help it protect feed mill workers manufacturing feed with nanomaterials and farmers mixing their own feed with nanomaterials in mineral and vitamin pre-mixes. Both kinds of data sharing could result in protections for workers, farmers and the environment even in the absence of formal regulation of nanomaterials in animal feed.
As far as we know, nano feed additives have not been commercialized but remain in the research and development phase. If so, IATP urges FDA to use the information and data gathered from the animal feed industry in the voluntary consultations with the FDA to do pre-market safety assessment. If nano-food additives have been commercialized without FDA pre-market safety assessment, IATP urges the agency to force withdrawal of those products from the market until FDA and other agencies demonstrate that they safe for consumption by animals, safe for the environment and safe for the workers who manufacture and use nano feed additives.
FDA and other U.S. federal agencies with legal obligations to protect public health, the environment and worker safety, invest hundreds of millions of dollars every year in the research and development of products that are enabled by nanotechnology and/or that incorporate nanomaterials. This use of the taxpayers’ money should include public meetings about whether specific nanotechnology applications are the optimal means to achieve a technical or policy objective. It may well be the case, particularly in food and agricultural applications of nanotechnology, that technologies or agricultural practices already exist to achieve the National Nanotechnology Initiative (NNI) co-funded or supported objectives less expensively and with less risk.
Posted September 17, 2014 by Dr. M. Jahi Chappell
Nearly 70 scientists and scholars of sustainable agriculture and food systems sent an open letter to the Food and Agriculture Organization of the United Nations (FAO) today, praising the organization for convening an International Symposium on Agroecology for Food and Nutrition Security. Given the multiple, overlapping challenges posed by continued food insecurity, rural poverty, climate change, drought and water scarcity, the letter calls for a solid commitment to agroecology from the international community.
According to the letter, agroecology’s broad base in science and society means it is uniquely suited to address today’s challenges in food and agricultural systems. It can be considered a science, a set of practices, and a social movement for food sovereignty and justice. As a science, agroecology integrates multiple disciplines into a "trans-discipline," drawing on fields such as ecology, agronomy, political economy and sociology. As a set of practices, it can provide multiple benefits to society and the environment, from reducing pollution from agriculture and supporting the conservation of the environment to boosting nutrition security and improving resilience in a changing climate. As a movement, it can address the vitally important issues of distributive and procedural justice in food and agriculture—that is, who gets access to what resources and how to decide. The letter points out that, according to well-established science, social movements and addressing distributive and procedural justice are just as crucial as scientific and technical innovation in sustainably implementing the right to food.
International institutions are currently using a variety of different terms, with different meanings, to identify a way forward for agriculture and food systems to address critical crises including climate change and food security. The FAO and other international institutions like the World Bank have supported other approaches which they call “climate-smart” agriculture and “sustainable” intensification. The letter criticizes these as vague terms that are subject to abuse through misleading or incomplete definitions. In contrast, agroecology is a holistic approach with a long history and an extensive body of knowledge grounded in science and in the experiences and leadership of farmers themselves.
The scholars call on FAO member states and the international community to build upon the proceedings of this symposium in order to launch a U.N. system-wide initiative on agroecology as the central strategy for addressing climate change and building resilience in the face of water crises. Such an initiative could form one of the pillars the future work of the Committee on World Food Security (CFS) and make an invaluable contribution to negotiations about agriculture within the U.N. Framework Convention on Climate Change process and the post-2015 Sustainable Development agenda. The letter closes with a hope that the FAO will consider this proposal at the forthcoming Committee on World Food Security meeting on October 13–18, 2014.
Posted September 12, 2014 by Tara Ritter
The World Meteorological Organization (WMO) is taking a new approach to engage the public on climate change: invite television weather forecasters around the world to release weather reports from the year 2050. The reports, which can be viewed here, are based on climate science and provide a frightening visual of what life could be like in a few short decades if the world continues emitting greenhouse gases at current levels.
These videos are being launched throughout September in the lead-up to the U.N. Climate Summit in New York later this month. Over 100 Heads of State, including President Barack Obama, will gather on September 23 to discuss global action on climate change. Though the Summit is not an official U.N. negotiation, leaders will make key announcements about steps their countries will take to mitigate climate change. The summit is expected to build momentum leading up to the U.N. Conference of Parties (CoP) in Paris at the end of 2015, where a new global climate change agreement may emerge.
Many avenues exist to cut global greenhouse gas emissions but not all of them are beneficial at the community level. As global discussions on climate change mitigation progress, community-level adaptation must also be emphasized. Communities will experience the direct impacts of climate change on their economies and infrastructure—including flooding, drought, storms and volatile temperatures—and therefore must begin to adapt now to prepare for the climate of 2050. In addition, community-based, decentralized energy systems will be necessary to reduce greenhouse gas emissions. A strong global climate change agreement may reduce overall greenhouse gas emissions, but it will not prevent extreme weather events as a result of the warming that has already occurred.
Most recently, the U.S. Weather Channel released a mock weather report for the WMO series highlighting a hurricane submerging Miami’s South Beach, a killer heat wave in Chicago, and a persistent “mega-drought” in the Southwest. This kind of reporting, though speculative, gives us a glimpse of what we can expect as climate change causes weather to become more extreme and more erratic. U.N.-level discussions about cutting global greenhouse gas emissions and building low-carbon economies are urgently needed, but communities need to convene their own discussions on how to prepare for the climate change impacts on their infrastructure, businesses, public institutions, families and daily living.
Posted September 4, 2014 by Jim Harkness
The headline of last week’s Science Insider blog was eye-catching: “China pulls plug on genetically modified rice and corn.” (The RT version was even better: “End of the line: GMO production in China halted.”) What actually happened was far less dramatic or definitive. On August 17, biosafety permits for research on two strains of GM corn and one of GM rice expired and were not renewed by the Chinese Ministry of Agriculture. But exactly why this happened and what it means for the future of genetic engineering of food in China is uncertain. (This is being debated in the Chinese press.)
The apparent tightening of enforcement is not limited to GMO experiments. Since last fall, several large shipments of corn from the U.S. have been turned back on the grounds that they contained a Syngenta GE variety that has not been approved for sale in China.
Whatever the reason for these actions, the stakes are high in the larger game of China’s agricultural and food policies. Once fully self-sufficient and cut off from global trade, China is now more and more deeply integrated into the global food system as both an importer and exporter. But open as its food economy has become, the government seems deeply ambivalent about GMOs. GM cotton is grown widely in western China and GM soy is imported from the U.S. and Brazil, but GM rice and wheat have never been approved for sale or consumption. China’s shifting regulatory decisions can have major reverberations around the world. U.S. grain trade groups told Bloomberg News Service that losses in 2014-15 due to the rejection of GE corn from the U.S. could top $6 billion, and the question of who should bear those losses is driving a wedge between farmers, traders and seed companies. So it’s worth taking a critical look at the various reasons that have been put forward to explain China’s recent actions.
There is a very messy public debate about GM food in China, and both sides now claim that last week’s decision was the work of anti-GMO forces in society. In an op-ed posted in The Conversation, Nottingham-based biotech researcher Cao Cong writes that unlike the UK, (Where regulators recently OK’d field trials for a GE oilseed.) China has “an anti-GM movement whose power and influence are more than matched by its fervour [sic] and sheer, undiluted paranoia.” Cao concludes that this movement has now effectively smothered China’s hopes for feeding itself. (This is an interesting image, contrasting the UK’s “rational” regulators with their Chinese counterparts who are held hostage by the whims of a superstitious public!)
Opposition to GE food in China comes from a variety of sources. Some opposition comes from the international environmental movement. Greenpeace has fought this issue for a decade, most notably through their discovery of experimental GE rice being sold illegally as early as 2005 in Hubei province. Although people on both sides say their opponents are tools of foreign powers, most anti-GMO sentiment in China seems to be homegrown, coming from farmers, scientists, consumers and members of the national defense establishment. And while a few high-profile anti-GMO activists seem to fit Cao Cong’s image of paranoid fear-mongering, his argument glosses over the more reasonable and pragmatic concerns that may have motivated last week’s decision.
The most immediate of these concerns stems from the discovery last month that GE rice is again being sold illegally to the public. That story was broken by News Probe, an investigative television program that commissioned testing of rice from a supermarket in the city of Wuhan. One of the strains they found was a pest-resistant variety developed by Zhang Qifa at South China Normal University, which is also in Wuhan, and the permit for continued cultivation of that strain is one of the three that were subsequently not renewed. It is entirely possible that, embarrassed by the revelation of their regulatory failure, the Ministry of Agriculture simply decided not to renew any of the three permits.
While last week’s decision appears to be a response to scandal, the ongoing rejection of GE corn shipments may have nothing to do with biosafety concerns. China’s recent corn harvest have been huge, as its farmers responded to new price supports and other production subsidies, so some say the sudden vigilance of customs toward cheap U.S. imports is economically motivated. As one American corn broker put it, “China can overlook GMOs when stocks are tight, but when they're trying to protect their domestic farmers or they're in surplus, they can come up with things to mess with us…”
The negative news about GMOs during 2014 is a surprising contrast to just a year ago, when the official media published a series of pro-GMO statements from Agriculture Ministry officials and interviews with scientists that seemed designed to pave the way for broader acceptance of GE foods. Now the pendulum has swung to the other extreme. Chinese politics and governance have long been characterized by cycles of loosening and tightening (“fang/shou”) of control. In politics, this means turning a blind eye to free expression or dissent at certain times, and then suddenly cracking down at others. Similarly, Chinese environmental and health regulations may be very strict on paper, but enforcement tends to be uneven, tightening in response to major scandals but otherwise loose, sporadic or selective. In the cases of GE experiments and import restrictions there has been no policy or rule change, merely a stricter enforcement of existing rules. US grain traders can complain, but strictly speaking they are the ones who are in the wrong for trying to sell China a seed variety that the Chinese government has not yet approved.
There is also a bigger question of whether or not China really needs GMOs in order to feed itself, as biotechpromoters claim. China’s chemical-intensive farming system is causing a variety of environmental and public health problems. The introduction of Bt cotton (now the most widely planted GE crop) was initially hailed for dramatically reducing pesticide use, but subsequent studies found that after several years, exploding populations of pests that were not susceptible to Bt eliminated those initial advantages. And as the economic and environmental returns to GE crops diminish, China’s non-GE agriculture—warts and all—continues to achieve bumper food harvests.
One final factor in all of this is the current high-level political situation in China. The tightening up of regulations on GMOs is taking place in a general atmosphere of re-centralized control in Chinese society as new President Xi Jinping consolidates his position. After Tiananmen, China’s leaders seemed to regard deregulation and opening up as the recipe for national prosperity. (With notable exceptions such as Falun Gong, Tibet and Xinjiang!) That formula brought rapid GDP growth, but at a tremendous cost in terms of social inequality, corruption and environmental degradation. Xi doesn’t want to growth to stop, but seems committed to imposing new discipline in the Party, the economy and society, and a more assertive nationalist position in foreign affairs and trade. Regulators in Agriculture and Customs taking a harder line to rein in research and trade in GMOs is consistent with this broad trend toward reassertion of central control.
So on one side of the balance sheet, the GMO crops that China approved turned out not to be a game-changer after all. On the other side, there are biosafety questions, a lack of effective regulation, economic competitiveness issues, a highly skeptical public and major export markets like Japan and Europe that reject GMO foods. Seen in this light, China’s reluctance to embrace GMOs makes perfect sense.
Jim Harkness is IATP's senior advisor on China and the former president of IATP.
Posted September 3, 2014 by Karen Hansen-Kuhn
A few weeks ago IATP received a leaked draft proposal for the chapter on Sanitary and Phytosanitary (SPS, or food and plant safety) measures in the Transatlantic Trade and Investment Partnership (TTIP), being negotiated between the U.S. and EU. Steve Suppan has been tracking food safety issues in trade for decades, and quickly wrote an analysis outlining the ways this proposal could weaken existing standards and make it harder to implement new food safety rules. Like most such drafts, it was partial information, a snapshot of what the negotiators (in this case, probably EU negotiators) hoped to table at the trade talks.
Steve noted that there are fundamental contradictions inherent in mandating “least trade restrictive” norms for SPS regulations that otherwise would seek to optimize public health. The chapter indicates negotiators continue to subordinate SPS regulations to the object of maximizing trade. The text supports the U.S. approach to not require port of entry food inspections and testing, meaning food contamination outbreaks will be harder to trace to their origin, and liability harder to assess—a win for U.S. meat and food companies that could jeopardize food safety for consumers. “While many key details regarding things like GMOs are still hidden,” he said, “it’s clear public health is losing out to corporate interests in a big way.”
Surprisingly, EC spokesman Isaac Valero Ladrón responded to Steve’s analysis in an article on Law360, claiming that he got it wrong. “There is no contradiction between a commitment to seek ‘least trade restrictive measures’ and the enforcement of high safety standards,” he said, and anyway there is no reason to worry since the proposals don’t go beyond what’s already been decided at the World Trade Organization.
This kind of email exchange is still a far cry from an informed public debate, but we saw it as an opening to consult with a few partners. We issued a short joint reply to EU Commissioner for Trade Karel De Gucht, with Friends of the Earth Europe and Compassion in World Farming, which clarified, but didn’t contradict, our earlier analysis. In an article in Euractiv.com covering the new analysis, Mute Schimpf from Friends of the Earth Europe stated, ''The concerns of European citizens that the free trade agreement with the USA would undermine public safeguards were scoffed at by the Commissioner in charge of the negotiations. Now leaked documents show that the public has every right to be concerned.”
EU officials have asserted recently that the TTIP talks are the most transparent trade talks ever (something the EU Ombudsman is contesting). It’s a little hard to figure out how they can say that. Three separate drafts of the proposed Free Trade Areas of the Americas, including brackets indicating areas of disagreement, are still posted online, as are drafts of the ongoing WTO talks. If we had negotiating texts for TTIP, we would know exactly what’s on the table, and engage in a public dialogue. Until then, we’ll continue to piece together what we can from bits of text and exchanges like this one.
Posted September 3, 2014 by Dr. M. Jahi Chappell
In a new paper led by collaborators at Leuphana University Lueneburg (Germany) and just released in print in the scientific journal Frontiers in Ecology & the Environment, my colleagues and I question one of the buzzwords in international conversations about hunger and conserving the environment: sustainable intensification (SI). Explained briefly, sustainable intensification seeks to produce the most food, on the least land, with the lowest environmental impact.
SI has been the subject of a recent European Union report, proposals by prominent scholars, and is a major theme area of the Food and Agriculture Organization of the United Nations. SI is often seen by some experts as “key” to agriculture’s future, particularly in Africa, and has been the subject of a number of high-profile publications in some of the world’s top scientific journals. It is, in short, an idea on the rise.
Despite the term’s popularity among national and international aid organizations and top thinkers, it is getting more attention than it warrants, at least in its current form. Given how readily powerful groups are taking to it, there’s a serious danger that it will drain both funds and attention from the larger and altogether different reforms necessary to fight hunger and food insecurity today, and in the future.
My colleagues and I question, however: Is it a good idea, or a sufficient one, for the problems at hand? Our piece addresses two basic arguments:
In other words, if our goal is dignified and rightful access to culturally appropriate, healthy food for everyone at all times (food security) while being environmentally sustainable, we should not confuse this with undue emphasis on “sustainable intensification.”
In light of persistent misconceptions around sustainability and food production, some relevant basic facts we reference in our piece:
With upcoming meetings this fall like the FAO International Symposium on Agroecology and the Committee on World Food Security, and the nascent Global Alliance on (so-called) Climate Smart Agriculture, it is imperative that these issues be understood, and that addressing these complex problems not be simply swapped out for the far less effective idea of producing more food using less land and fewer resources.
It is true growing more food in a more sustainable manner is something that will need to be done in some places, and at some times. But whenever it’s talked about in the context of hunger, food security or feeding the future, it must come after discussion, participation and planning specifically with those who face hunger and food insecurity, be they small farmers, landless workers or urban residents. Ignoring the issues of procedural justice (who gets to make the decisions and how) and distributive justice (how and who has access to the food produced) is ignoring both the established science and the need for democratic justice that will truly bring us into a food secure and food sovereign future. Organizations and scholars embracing SI need to rethink its usefulness, and its potential to distract us from evidence-based and effective approaches based in human dignity and food sovereignty.
Posted August 25, 2014 by Olivia LaVecchia
This entry is part of IATP's Story of Drought, examining the impacts, causes and perception of drought in the U.S. and around the world.
Lamar, Colo. – In a good year, the wheat on the Hixsons’ farm should stand waist high by mid-summer. This year, though, much of the crop isn’t even tall enough for the combine to harvest.
Jillane Hixson hasn’t seen regular rainfall since 2002. She and her two brothers, Ron and Eric, farm 3,000 acres of wheat here in southeast Colorado, the same land that their father farmed before them. After 12 years of drought, "The ground is just like brown flour," Hixson says. When the wind picks up, what was once soil coats her car, her windows, and even her counter tops.
"Every morning when you get up, the first thing you do is vacuum down the kitchen table and wipe down the coffee pot just to be able to make a cup of coffee," Hixson says. "You can't escape it."
With regular rain, the Hixsons harvest around 40 bushels of wheat an acre. This June, much of their land yielded merely four bushels an acre, or one-tenth that. The Hixsons’ crop insurance covers just enough for them to buy seed and fertilizer and try again, but it doesn’t pay anything near what a full harvest does.
"The insurance just barely lets you stay in business and actually keep borrowing more money," Hixson says. "You start this vicious cycle of borrowing and borrowing and borrowing in hopes that the weather cycle will change and the crops will come in."
All throughout eastern Colorado and western Kansas, farmers and ranchers are waiting for rain. “We’re in the midst of a prolonged drought,” says Duke Phillips, a Colorado rancher who manages cattle on about 200,000 acres. “Everybody is operating at deficiencies and praying for more.”
The extreme weather brings with it differing strategies for pulling through, from the day-to-day to the long-term. On Phillips’s ranches, drought means planning. Part of that planning happens years in advance, as Phillips installs infrastructure that allows him to rest as much of his pasture as possible at any given time. Part of it happens as he watches the sky, and uses preset benchmarks to determine how many cows he’ll ship to slaughter if he doesn’t get a certain amount of rain by June, by July, by August.
Other farmers and ranchers have their own techniques, from planting cover crops to simply planting earlier. “People are planting a month earlier than they used to be,” says Donn Teske, president of the Kansas Farmers Union and vice president of the National Farmers Union. “There’s more likely moisture to make a crop before the heat of summer.”
There are, too, efforts to make the most of the water the land does get. Mike Callicrate, who runs a business out of Colorado Springs, Colo. and ranches in St. Francis, Kan., is designing a permaculture program for portions of his land, and in believes in capturing as much water as possible using terracing, catchments, ponds, and similar techniques. “I’d like to find ways to make sure that no water leaves a farm,” Callicrate says.
While the farmers search for ways to keep going until it rains, elsewhere, others are focused on broader solutions to the question of water. Take New Belgium Brewing, the major craft brewery based out of Fort Collins, Colo. Water is the primary ingredient in beer, and in 2007, sustainability-minded New Belgium began formally tracking how much of it they use.
Since then, New Belgium has installed sub-meters to monitor where it’s losing water and beer. It’s added features to its bottling line that have saved more than two million gallons of water per year. It’s a member of a state greywater pilot project. All told, even after a few years increasing production and making more water-intensive hoppy beers, New Belgium is on track this year to use less water than it did back in 2007.
For those who take the long view, there are bigger ideas to achieve resilience in the face of extreme weather. At The Land Institute, based in Salina, Kan., the ideal system of agriculture resembles the prairie, a perennial polyculture that supplies its own fertility. Perennial plants are around in the winter to absorb moisture from snow, and in the dry heat of summer, have years-old taproots to plunge into the ground’s deep reserves of moisture.
One of the plants in The Land Institute’s test plots is a distant relative of the sunflower, a perennial called silphium integrifolium. The Land Institute first heard about silphium a few years back, when a Texas-based scientist let them know that, in the middle of a withering southern drought, this plant still seemed to be thriving. Not long after The Land Institute began to work with silphium, they went through a serious drought themselves.
“All the rest of our crops were struggling, but the silphium integrifolium hardly batted an eye,” explains Josh Svaty, vice president at The Land Institute. “It was a demonstration to us that you can find some plants that manage drought differently than others.”
The Land Institute still has a lot of questions about silphium, ranging from whether it’s a good idea for a perennial crop to “keep going 60 miles an hour in 100 degree weather,” as Svaty puts it, to just what makes it so resilient, to whether they’ll be able to breed it to be a viable oil seed crop. What they do know, though, is that it’s a plant with possibilities.
Back in Lamar, Colo., for now, the Hixsons and farmers like them are doing what they can. The Hixsons have switched from tilling to spraying for weed control, in order to disrupt the ground as little as possible. To avoid more of their soil blowing away, they’ve paid for a nearby feedlot to come and spray their fields with manure. They’re talking to their state legislators about policy fixes that would help them get through the short term, like a waiver on expensive state vehicle registrations for farm equipment that’s sitting idle.
All the while, they’re doing what farmers have always done: hoping.
“I just try to keep my faith,” says Ron Hixson, as he rides the combine over his fields. “Hopefully we’ll have a good crop this time next year.”
Posted August 21, 2014 by Patrick Tsai
A new report released today from IATP takes an in-depth look at how tar sands have developed from an unconventional, inefficient energy source to the spotlight of the corporate agenda as conventional oil supplies dwindle. Tar Sands: How Trade Rules Surrender Sovereignty and Extend Corporate Rights follows the development of energy policy from NAFTA up to current free trade negotiations to illustrate that while energy sources evolve, one trend remains constant: The protection of corporate profits at the expense of human rights, sovereignty and the environment. With new free trade agreements in negotiation, the time for action is here: The public needs a seat at the negotiating table.
The Washington Post’s disclosure last month of yet another leaked EU Transatlantic Trade and Investment Partnership (TTIP) negotiating document on Energy and Raw Materials (ERM) brings to light the overwhelming emphasis placed on dismantling the United States’ ability to govern its own energy resources. Pressure to repeal the Energy Policy and Conservation Act (EPCA), due to new-found U.S. energy reserves through hydraulic fracturing, stands as most controversial to environmentalist and anti-globalist.
Instituted in 1975 in response to the 1973 OPEC oil crisis, the EPCA ensures domestic supply of oil by preventing U.S.-produced crude oil from being exported to foreign countries. As Senator Edward Markey puts it, the EPCA supports “American consumers, our economy and our national security by ensuring that crude oil produced in the United States remains in the United States.” Within the leaked document text, the EU would like the U.S. to rescind the EPCA and impose legally binding commitments by “guaranteeing the free export of crude oil and gas resources by transforming any mandatory and non-automatic export licensing procedure into a process by which licenses for exports to the EU are granted automatically and expeditiously.”
Following the EU proposal would not only reduce U.S. sovereignty over its natural resources, but also expose U.S. crude oil to greater demand in world markets, depleting domestic supply stocks and inevitably increasing gas prices at the pump. Deputy U.S. Trade Representative Michael Punke has stated that U.S. domestic law will not change, but the continued concessions made to what constitute a petroleum product will only liberalize energy trade in a less offensive way to the public leading to a similar end as repealing the EPCA.
John D. Rockefeller has been quoted as saying, “Try to turn every disaster into an opportunity.” Not one to let opportunity slip away, the EU has seized upon the Ukrainian crisis to qualify liberalizing energy trade through TTIP. Though the EU even acknowledges reducing trade barriers will not provide relief from their current precarious energy situation, they instead hypothesize Trans-Atlantic energy trade as the answer to future energy scarcity.
The leaked document states, “The current crisis in Ukraine confirms the delicate situation faced by the EU with regard to energy dependence […] lifting bilateral restrictions on gas and crude oil, will show our common resolve to increase security and stability through open markets. Of course, while this may—for several reasons—not have immediate effects, it would increase potential sources of supply in the future.”
To many this appears to be a reasonable request, however this Trojan horse would only lead to increased fracking and environmental degradation. Ilana Solomon of Sierra Club has translated the key points of the leaked document very well in her Huffington Post piece. Jean-Claude Junker, European Commission President-elect, has voiced his opposition to fracking, but the leaked EU negotiating document and leaked EU ERM draft chapter seem to tell a different story. The message inferred from these documents suggest the EU would like the U.S. to incur all the environmental and social externalities while the EU reap the energy benefits at U.S. domestic prices (Article E Dual Pricing).
Sadly, trade skirmishes over access and control of natural resources are nothing new. During the North American Free Trade Agreement (NAFTA) negotiations the U.S. was vying for, and eventually received, almost limitless access to Canadian resources. Today, the tar sands of Alberta are characterized by extreme (and inequitable) wealth and environmental degradation. As such, the debate about the tar sands has been reduced to an argument over jobs and the environment. Both points valid, but both seemingly insufficient. Missing from the discussion is an analysis of the systemic drivers of unfettered resource extraction occurring in Alberta.
In our new report, we hope to shed light on some of the key failures of trade and how neoliberalism has led to such a subversive system in the Alberta tar sands. NAFTA’s proportionality clause (article 605) and Investment chapter (chapter XI) have compromised Canadian sovereignty over natural resources and expanded corporations’ ability to influence laws resulting in large land acquisitions and the unmitigated extraction of Canadian natural resources by transnational corporations at the expense of human health and the environment. As the TTIP negotiations progress we need to ask ourselves, will the US and its new found energy reserves be another story of mismanagement driven by globalization?
An increasing number of people are beginning to realize that the term “free trade” denotes an extension of corporate rights and profits at the expense of sovereignty, labor and the environment. The current free trade negotiations of the Trans-Atlantic Trade and Investment Partnership (TTIP), Trans-Pacific Partnership (TPP) and Comprehensive Economic and Trade Agreement (CETA) are being negotiated behind closed doors. The opaqueness of government and corporation backroom dealings remove citizens from the conversation when it is these citizens who are subjected to the outcome of negotiations: affecting working standards, resource allocation and the environmental aftermath of reckless foreign direct investment. Yet we only get a glimpse of negotiating content through leaked documents. Transparency is necessary for democratic decision making. As citizens we need to know if it is our interests, or corporate interests being negotiated in these trade agreements. More than 20 years ago Ralph Nader wrote about NAFTA and General Agreement on Tariffs and Trade (GATT):
[W]ith citizens shut out of the process at every turn, it is no surprise that these trade agreements pose such a threat to the procedural gains of citizen movements in numerous countries in recent decades, to their potential to rein in multinational corporations, and to both Third World and industrialized countries’ ability to maintain control over their economies through some measure of feasible self-sufficiency. On procedural grounds alone, the authoritarian exclusion of citizen participation condemns the GATT and NAFTA operations. Are people to struggle for such rights as only to lose these rights in closed international negotiations dominated by corporate interests and their bureaucratic allies?
Nader’s statements are more relevant today than ever, and the stakes are even higher as we experience depleting natural resources, climate change, increasing economic inequality and economic instability. In the end, multinational corporations are interested in profit not the social and environmental externalities that affect everyone. In order to progress social standards we must demand the opening of trade negotiations to the public and oppose undemocratic mechanisms such as “fast track.”
Posted August 20, 2014 by Dr. Steve Suppan
Earlier this summer, the U.S. Food and Drug Administration (FDA) advised the food industry what a manufacturer should do if it puts nanomaterials in food: Please call us. The human health effects of ingesting nanomaterials are not well understood, but a few food manufacturers claim to include nanomaterials in their products. The FDA’s advice could have been worse: Don’t call us. But it could have been a lot better by requiring pre-market and post-market safety assessments and testing of any “food substance” containing nanomaterials.
Nanotechnology, the synthesis, visualization, configuration and manipulation of atomic to molecular size particles, has been practicable since the Nobel-prize winning invention in 1981 of a kind of microscope that made nano-visualization and manipulation possible. (See the superb “Timeline: Nanotechnology” published in April by the University of Ottawa.) The application of nanotechnology to industrial processes, such as coating semi-conductors and other electronic parts with infinitesimally thin layers of metal oxides, has enabled the production of computer server farms and cell-phones, to name just two of the most famous applications.
However, the application of nanotechnology to food and agriculture products in the new millennium presents environmental, health and safety (EHS) problems of an order magnitude greater than what currently exists for industrial nano-coatings. Among these problems is the near dearth of studies on the effects on the chronic consumption of nanomaterials in food, despite the presumed the bio-accumulation of some nanomaterials in the human body. Furthermore, there is a lack of agreed ways and measures to test toxicity of nanomaterials, regulatory definitions for nanotechnology and nanomaterials, and other elements of a nano-specific regulatory system. In the face of such challenges, what is the FDA, charged under the Food, Drugs and Cosmetics Act, with protecting human health, to do when product developers claim to incorporate nanomaterials in commercialized foods?
Thus far, the FDA and other U.S. regulatory agencies with EHS obligations, have sought the cooperation of industry by voluntary means and by building the agencies’ regulatory scientific capacity to evaluate nanotechnology applications. Earlier this summer, FDA released three final voluntary guidance to industry documents on nanotechnology. Although guidance documents do not impose any legal requirements on nanotechnology product developers, they do present FDA’s official understanding of nanotechnology and recommend when nano-product developers should consult with the agency at the research and development stage of those products.
When the draft guidances were first posted in 2012, IATP analyzed the documents concerning the application of nanotechnology to foods and to cosmetics. The draft documents contained in outline most of the features of the final guidances and did not respond to a 2006 petition by the International Center for Technology Assessment (ICTA) and others to issue mandatory rules on nano-titanium dioxide, used in sunscreen and food packaging to block ultra-violet rays. (IATP was a co-plaintiff in a 2011 lawsuit against FDA filed by the ICTA et al, to require regulation of some nanomaterials and applications of nanotechnology in FDA regulated products. The lawsuit did not succeed in its objective.) In July 2012, IATP submitted a regulatory comment on FDA’s draft guidance document about nanomaterials in “food substances.” Then we waited for the final guidances.
On August 12, I gave an overview of two of the guidance documents in a Spanish language presentation on Nanotecnologia do avesso (Nanotechnology Inside Out), a webcast program of the Brazilian Research Network on Nanotechnology, Society and Environment (Renanosoma). One guidance concerned how FDA understands whether or not a material used in FDA regulated products is a nanomaterial. This guidance received input from every office in the FDA because it applies to all FDA regulated products. The other guidance, drafted by the Center for Food Safety and Applied Nutrition, explained how FDA understands the use of nanomaterials in food processing and food packaging.
The “whether nano or not” guidance urges, but does not require, nanotech product developers to consult with the agency early during the research and development phase, if 1.) a product incorporates an Engineered Nano-scale Material (ENM) measuring between one and 100 nanometers (the diameter of a human hair is about 80,000 nanometers) or 2.) if the application of nanotechnology results in physical, chemical or biological changes to materials measuring up to 1000 nanometers. In a footnote to the second criterion, the guidance notes that the European Commission has also proposed a 1000 nm threshold of pre-regulatory concern. The FDA laudably states that its pre-regulatory focus is not just on the size of the material, but how nano-sizing and configuration affects the chemical, physical and biological properties of materials in FDA-regulated products.
The guidance does not say what will happen to any industry proposed nanotechnology application as a result of a FDA consultation, but at this point, we can be sure that the FDA cannot require nano-product developers to do anything under the guidance.
Like the European Commission’s recommendation for a regulatory definition of “nanomaterials,” FDA excludes from regulatory concern ‘incidental’ nanomaterials that result from the “food substance” manufacturing process, as opposed to the intentional use of Engineered Nano-scale Materials (ENMs). (The European Consumers Organization urged the European Parliament in March to reject the Commission’s definition, in part because of the intentional use definition of nanomaterials.) There is no scientific basis for this exclusion. Nanomaterials in a given product, whether incidental or not, have the physical, chemical and biological reactivity of ENMs in that product. Therefore, both “incidental” nanomaterials and ENMs must be subject to a safety assessment to determine whether their use or consumption poses unacceptable risks to human health, worker safety and/or the environment.
Both documents state that FDA’s consultation with nano-product developers will take place on a “case-by-case” basis. The case-by-case approach is not unique to FDA but is dictated by a White House Office of Science and Technology policy first applied in 1992 to the deregulation of genetically modified organisms. As I argued in a recent fact sheet on synthetic biology, the case-by-case approach to regulatory or pre-regulatory review facilitates deregulation for the underfunded and understaffed EHS agencies under pressure to commercialize new technologies and products.
About half of the guidance on manufacturing methods for “food substances,” including use of nanotechnology, summarizes existing FDA regulations that apply to all FDA regulated foods. Within this summary is an outline of the steps that FDA takes to determine that a food is safe to consume. Among these steps is an evaluation of the “self-limiting level of use” by the food product developer, who is presumed to know how much of a given food additive can be added to achieve a targeted “technical effect,” such as a certain thickness, before the food becomes unpalatable or inedible.
Traditionally, “self-limiting level of use” pertains to ingredients measured in terms of mass. However, as IATP noted in our June 2012 comment letter on the draft guidance, mass-based measurements are irrelevant to determining “self-limiting levels of use” of food grade ENMs. The mass of ENMs is far too small to be a toxicologically relevant metric for FDA’s safety assessment methodology. The final guidance on ENMs in food does not provide any insight into how FDA believes that it can use the concept of “self-limiting levels of use” for assessing the safety of ENMs in food. Nano-toxicological relevant metrics have been proposed, but not for chronic exposure to ENMs in food.
One praiseworthy feature of the guidance is that FDA alerts industry that it is very unlikely to assume that ENMs in food can be Generally Recognized As Safe (GRAS). For example, just because macro forms of silicon dioxide, a processed food thickener, are GRAS, food manufacturers should not assume that FDA will consider nano-sized silicon dioxide to be GRAS. Given the differences in chemical, physical and biological properties of nano and macro forms of the same material, it may seem self-evident, that ENMs must not be assumed to qualify for FDA GRAS certification. However, following the General Accountability Office’s criticism of FDA’s GRAS determinations, it is a small relief to read FDA’s alert to industry.
Finally, the guidance states that FDA has yet to receive any applications to commercialize “food substances” incorporating nanomaterials. However, there is test-based evidence, summarized in a 2013 report by As You Sow, that such goods are already in our food system. It is alarming that the FDA is not proposing to test food products for ENMs or to publish the results of such tests of products by those manufacturers that already claim to use ENMs in food or food packaging. Perhaps the FDA is just turning a blind eye to those possible uses in order to protect itself.
If the FDA doesn’t officially recognize the use of ENMs in food, it’s not violating its obligations under the Food, Drug and Cosmetic Act to determine the safety of “significant new process changes” in manufacturing foods with ingredients that the agency is unlikely to characterize as GRAS. That legal strategy may be understandable in light of the constant pressure by industry, federal trade agencies and Congress to make regulations “least trade restrictive.” But the voluntary guidance to industry documents provide very little evidence that the FDA has scientific resources or political will to initiate mandatory rule-making to protect consumers from nano-food products on the market or about to be commercialized with or without the agency’s official knowledge.
Posted August 5, 2014 by Pete Huff
Today, Missouri goes to the polls to decide—among other things—if they want to amend the state’s constitution to include what is being referred to as the “right to farm.” This debate has been a fiercely pitched and costly battle to enshrine a right that many farmers rightly assume they already have.
The National Agricultural Law Center notes on their website that “All fifty states have enacted right-to-farm laws that seek to protect qualifying farmers and ranchers from nuisance lawsuits filed by individuals who move into a rural area where normal farming operations exist, and who later use nuisance actions to attempt to stop those ongoing operations.” In short, farmers and ranchers everywhere, including Missouri, are protected from those who complain about their daily operations on the basis of comfort.
So why such an adamant fight for something redundant? The simple truth is that the proposed Amendment 1—which would ensure the right of Missouri citizens to engage in agricultural production and ranching practices without infringement—has nothing to do with the protection of Missouri citizens at all. Despite the seemingly local origins of a measure to protect local farmers from “unreasonable regulations” and outside groups, the effort is nothing more than a national corporate wolf in a local sheep’s clothing. While the fate of Missouri will be known later today, it is important to understand the national context of fights like these.
Right-to-farm amendments, regardless of the state claiming them as their own, are the product of a national effort aimed at furthering corporate interests under the veneer of freedom and states’ rights. The mill that produces the stock right-to-farm legislation is the DC-based American Legislative Exchange Council (ALEC). From agriculture to education, ALEC offers generic “model legislation” aimed at the advancement of “limited government, free markets, and federalism at the state level through a nonpartisan public-private partnership of America’s state legislators, members of the private sector and the general public.” Simply, they create fodder legislation that favors big business and use private money to push it through as many state legislatures as possible via pseudo-grassroots initiatives.
Ironically invoking agrarian Thomas Jefferson in their agriculture principles, ALEC’s right to farm legislation trades the vigilance of democracy—which, despite its challenges, protects the rights of citizens above all else—for the indifference of corporations in the governance of the common good. The exhaustive list of the corporations that support and fund the formation and rollout of ALEC’s model legislation swiftly extinguishes any notion that any right-to=farm effort is for citizens.
To further understand the pervasiveness of ALEC’s national efforts to advance the interests of business over the citizens, one only has to move up the food chain. ALEC’s opposition to efforts to increase food worker wages is publically available and driven by the National Restaurant Association (NRA), a trade association and political front group for over 170 corporate restaurant chains that include the most dominant brands on the national food landscape. Backed by ALEC political influence, the NRA has been the predominant force working against state minimum wage increases and paid sick leave for workers over the past 20 years.
In the case of the right-to-farm push in Missouri, the amendment would essentially prevent the state legislature or local governments from responding to the needs of its citizens by passing laws or enacting regulations that might change the current agriculture or ranching status quo. Beyond the protection from nuisance complaints, this would also exempt agriculture and ranching operations from future legislative efforts to protect the environment and labor. The intentionally broad language of the measure effectively turns the determination of what is considered acceptable agriculture and ranching practices over to the courts, favoring the interests with the greatest capacity to litigate.
This state-by-state charade of corporate sheltering must be combated by authentic grassroots and public awareness efforts to maintain the right of a state to self-determine based on the yet unknown future. While ALEC quotes Thomas Jefferson’s 1787 letter to George Washington by saying “[a]griculture is our wisest pursuit, because it will in the end contribute most to real wealth, good morals, and happiness,” as mandate for its right-to-farm efforts, it must reconcile with his 1809 letter to Colonel Larkin Smith in which Jefferson warns of "the selfish spirit of commerce [that] knows no country, and feels no passion or principle but that of gain.”