A proposal by the food industry continues the onslaught of new genetically engineered crops that threaten both organic farmers and consumers who may not want GMOs in their food. The latest genetically modified crop likely to be deregulated in 2014 are Arctic® apples, which have been engineered not to brown when sliced.
Organic proponents will likely question why the world needs non-browning apples, especially as this trait is not based on the basic agronomy or pest risks of the apple.
However, there has been little controversy over the potential release so far. This may be a result of the recently posted USDA APHIS Environmental Assessment (EA) and Plant Pest Risk Assessment, which did not acknowledge the acute threat these products represent to organic apple farmers. These assessments also do not properly examine the long-term effects of the GE apples on the environment and population, although the developers of the apples claim they have 10 years of field studies that show no negative effects.
A second comment period is now open for people to discuss these Assessment Reports. The first comment period closed on September 11 and received 1,975 comments, mostly negative. Few of the comments were from growers or people with more specific knowledge of the biology of an apple orchard.
This new comment period is open until December 9. Submit your comments.
The Federal Register notice with links to the supporting documents is available online.
We urge all readers concerned about GMOs to submit comments. Here are a few bullet points to use in these comments:
- Ten years of study is not enough time to evaluate a perennial crop like an apple tree.
- All the data used in the conclusions of the reports is from the petitioner for the Arctic® apples. There appears to be no independent, third-party exploration of such subjects as the potential effects on non-target organisms or the threat of pollen transfer into organic orchards.
- No specific data is given in the reports about what happens to bees and other pollinators who ingest GE pollen over time.
- The Environmental Assessment states: "Organic farmers will not be substantially affected by a determination of non-regulated status of GD743 and GS784 apple" (page 37, section 4.2.3). The reason given is that there is no threshold for GE presence in organic regulations. This explanation ignores the potential effects on both pollinators and organic markets if contamination is picked up in testing and places the full burden on organic growers for borders and pollination control strategies.
- Along the same lines as above, other groups of apple growers, including the California Apple Commission, have come out against the Arctic® apple because they are concerned that it will bring negative publicity to apples in general and thus cause damage to apple markets.
- Section 2.6 (page 11) of the EA recommends that no isolation distances or geographic restrictions are necessary because there is no plant pest risk from these apples and therefore APHIS has no authority to set one. This is an important point to bring to the USDA beyond APHIS because this type of GMO is out of the realm of APHIS authority but still needs to be regulated by the USDA. While there may be no pest impacts, there will likely be impacts on pollinators, wildlife that feed on apples, and organic growers in nearby vicinity to these apples.
- The purpose of the non-browning trait is so the apple does not decay as quickly. Not only can this be used to disguise otherwise inferior fruit quality, but it may have secondary long-term side effects similar to other preservatives, and these have not been studied.
- Other GMOs have been linked to numerous negative health problems in animal studies: immune damage, tumors, and lowered nutrition absorption. For more details on this see www.responsibletechnology.org/gmo-dangers/65-health-risks/1notes.
While it may seem to many of us that our comments fall on deaf ears, it is still important to speak up and bring the message of environmental responsibility to the government and other observers. Continued activism on GMOs has already vastly increased awareness and resulted in the very close labelling initiatives that we have seen recently. Continuing this trajectory may well eventually lead to progress on halting the spread of GMOs.