genetically modified organisms in agriculture || gmo regulations

Consumer Issues – Food Safety/Labeling

GMO Regulations: FoodSafety or Trade Barrier?Malcolm KaneHead of Food Safety, Sainsbury’s Supermarkets Ltd (1980–1999)

Icannot think of a more important subject matter facing the US soya (soybean)and maize (corn) export industries than the current controversy about GMfoods and the European attitudes and responses to them. If I can serve to

throw a little light upon this fraught subject here in the US, I will be profession-ally very satisfied.

Food is a subject of enduring passion, and has been for many generations.Not only that, but the international reputation for culinary excellence has beena matter of pride between nations for as long as humans have traveled.

Now this reinforces my personal belief that in the whole business of interna-tional relations in all sectors of the food trade there resides a degree of naturalsuspicion, which is entirely understandable when one reflects upon the variousexamples of venerable disputes that have exercised our respective diplomats . . .dare I mention bananas?

My task is to dispel your suspicions that the issue of genetically modifiedfoods falls into this category of diplomatic barter, and convince you that there isa real and serious consumer issue in Europe that may well spill over here. Whenfirst approached by the conference organizers, I was given six guideline ques-tions to address which at first sight led me to think I would have the quickestand easiest paper to deliver of all time.

The questions asked were:

1. What changes have there been in European consumers’ attitudes towardsspecific products? Answer?From an ill-informed indifference to an outright hostility.

Background 234A Non-GM Strategy 235Herbicide Resistance 236Insect Resistance 237Summary 238

23

Genetically Modified Organisms in Agriculture Copyright © 2001 Academic PressISBN 0-12-515422-4 All rights of reproduction in any form reserved

GMO in Agriculture 21/2/01 16:38 Page 233

2. What products have European consumers rejected? Answer?Everything . . . doubled and redoubled.

3. What has been the effectiveness of consumer advocacy groups? Answer?100%. They have won the argument . . . period.

4. What are the different strategies for meeting consumer demands? (GMlabeling is effectively a health warning)Answer?One strategy . . . total rejection of GM foods.

5. What are the costs of consumer assurances?Answer?Businesses have been severely damaged.

6. What specific examples illustrate consumers’ objections to GMOs andretailers’ responses to these objections? Answer? Soya, maize, and tomato paste, on the latter of which I will now give morespecific details.

Background

Three years ago, Sainsbury’s and Safeway (UK) supermarkets were the first tolaunch a canned tomato paste, boldly and properly labeled made from geneti-cally modified tomatoes. It was sold at a 25% price premium, and achieved a150% market share, over ordinary (Italian) tomato paste. Although this mayseem a good ratio of price premium to market share, those of you familiar withthe marketing realities will know this result was modest.

But it was on the positive side, and the prevailing sentiment at the time wasto persevere with the promotion of GM foods as the vision of the future. In myview there is a tendency among a certain section of food scientists to becomeover-enthusiastic with what I call the ‘appliance of science’ to food. This is incau-tious as it risks upsetting some very deep, fundamental human attitudes andresponses to the food we eat.

It is not for nothing our shared language is peppered with clichés like breadand butter, mother’s milk, motherhood and apple pie, milk of human kindness,have your cake and eat it, etc.

I will return to this theme, but to continue the history of GM tomato paste inSainsbury’s and Safeway, the product was launched well (i.e., it was clearlylabeled and offered with a non-GM alternative choice). In short, no supermarketchains besides Sainsbury’s and Safeway had taken such a bold, positive, sup-portive position on GM foods.

All that changed in February 1999 when the combined efforts of consumeradvocacy groups and the press created a consumer awareness of the GM foodsissue that resulted in what today is being described, in the UK, as the greatestever victory for consumerism. This is a victory that may well set a precedent forconsumer advocates as they learn to develop this newfound power to influenceconsumer purchasing behavior.

234 Part 2: Perspectives on the Controversies

GMO in Agriculture 21/2/01 16:38 34

From sales of 150% over conventional Italian tomato paste, the sales slumpedrelative to the conventional product. In other words, sales fell off a cliff. And theynever recovered.

Additionally, customers stopped coming through the doors. They positivelyshifted their trade to smaller chains that were taking advantage of the furore byadvertising that non-GM foods only were sold in their stores. They may or may nothave had justification for making these claims, but they were not challenged by theadvocacy groups about that. They were in fact supported by the advocacy groups.

A Non-GM Strategy

At this time I was then instructed to find a way of delivering a credible com-mercial non-GM strategy to our customers. Our previous promotion of GMtomato paste was unfortunately actually working to our disadvantage. Thefocus was upon GM soya in the first instance, with GM maize not far behind,and animal feed next in priority.

Conventional wisdom, supported at the time by advice from the industry,was that separation of GM soya from non-GM soya was impossible.

We had a very simplistic approach. The GM issue was more a problem of foodsafety perception than of food safety reality. But the marketing dictum is thatperception is reality.

To understand the forces of perception and reality at work in this complexarea, we prepared a mind-map. This maps out not our personal views, but thetotality of views, opinions, facts and fallacies that are firmly embedded in con-sumers’ minds and influencing their behaviors.

We therefore applied the basic principles of food safety control that we hadbeen applying for 20 years to real food safety issues, to this new ‘perceived’ foodsafety issue. And it worked.

The statistics bear the evidence. From the European perspective, it was evi-dent that two-thirds of world soya production came from Brazil and the US. Ofthis about 50% of the US production, and 95% of the Brazilian production wasnon-GM, a total of at least 50 million tonnes. In all, more than double the totalEuropean soya imports was available in non-GM soya from either the US orBrazil.

The issue was not if but how we could deliver non-GM soya. In other wordsit was a management problem of how to ensure security of supply by establish-ing systems of traceability which paralleled those we were already using tosecure Italian olive oil as distinct from Greek olive oil. Or Florida orange juice asdistinct from Brazilian or Spanish orange juice.

What was needed was a management system of control. And that is pre-cisely what we developed. We arranged for a British company, LawLaboratories, who collaborated with an American company, Genetic ID, to pro-duce a management control standard which delivered three elements:

• It defined what we meant by GM and non-GM food.• It described a HACCP based audit and traceability scheme.• It defined GM analysis to achievable standards of accuracy, reproducibil-

ity and repeatability.

GMO Regulations: Food Safety or Trade Barrier? 235


In addition, we organized a consortium of European supermarkets who allhad similar commercial imperatives, to deliberately get the weight of numberspublicized and a momentum of thinking within the industry, that it was possi-ble to deliver a credible non-GM sourcing policy.

Together we agreed to reformulate soya products out of our own brand linesin a deliberate move to signal the seriousness of our intentions. The simplestproduct was soya oil. This could easily be substituted with rapeseed (canola) oilor sunflower oil. Similarly, we found that soya protein products could in manyinstances be substituted with non-soya proteins. This may upset the soya proteinscientists, but the fact of the matter is that in many markets the benefits of soyaprotein over alternative proteins had been oversold. Actually this is not uniqueto soya – many food ingredients are substitutable.

As a result, a concerted effort by seven of the leading European supermarketsto formulate soya derivatives out of their own brand products had a dramaticcommercial effect.

This commercial support was reinforced by the recruitment of the majorEuropean international food manufacturing groups in support. The reason fortheir support is significant. Firstly they had been experiencing severecross-branding effects with GM labeling. The legal requirement to label foodscontaining GM ingredients impacted adversely not only upon the individualproduct line, but also upon all product lines under the same brand umbrellaregardless of whether they all had GM ingredients or not.

Secondly, they were unaware of the ‘Due Diligence’ requirement to imple-ment chemical residue surveillance of herbicide residues in GMherbicide-resistant crops.

Herbicide Resistance

Why would anyone put weedkiller onto their food crops? Conventional foodcrops would self-evidently be destroyed, and in fact historically, weedkillershave not been approved for use on food crops. The answer is of course thatweeds compete with crops for soil moisture and nutrients, reducing crop yields.So the farmer’s need for weed control is understandable.

GM herbicide-resistant crops allow the easy and effective application ofweedkiller without fear of crop damage and economic loss.

But this means that weedkillers are being used in a new way, i.e., they arebeing sprayed onto food crops for which new approval has been required, andhas been obtained, a fact which has been poorly appreciated by professionalmanagers within the food industry till now.

As with all pesticides, weedkillers (or herbicides) will leave residues withinthe food crops they are applied to. And as with all pesticides, it will now be nec-essary for the food industry to conduct regular, ‘Due Diligence’ herbicideresidue analysis. The cost of this has never been introduced into the GM debate,and the UK has been importing herbicide-resistant soya for three years, withlittle herbicide residue analysis being done in any UK laboratories anywhere.

More importantly, if we care to consider the severe consumer confidenceissues surrounding any question of chemical residues in foods, then the onlyconclusion can be that food professionals have been ill-informed at best, to have



ignored or neglected this as a potentially serious ‘consumer perception’ issue.Glyphosate, the active agent involved with the main herbicide-resistant soyaproduct, is at the lower end of the toxicity spectrum of herbicide chemicals, butthat is not likely to change the perception of this issue by the average Europeanconsumer, i.e., the principle of applying weedkiller to foods.

The biotechnology companies cannot be blamed for focusing on their prod-uct’s advantages but they are not likely to focus on potential disadvantages; nocommercial organization will. The law of caveat emptor applies. It is up to foodindustry professionals to protect their business interests by thinking throughsuch issues and highlighting the potential disadvantages regarding adverse con-sumer safety perceptions. Had the food industry scientists done so, instead ofbeing blinded by the elegance of the GM technology, we all might have beenspared the stresses of the last couple of years.

The dilemma in which European food businesses (i.e., food retailers andmanufacturers alike) found themselves is whether they should preemptivelyreact to these ultra-sensitive issues, or do nothing. The overwhelming prevailingresponse of the food industry was to act openly in accordance with their under-standing of consumer sensitivities. The food industry also calculated that theonly way to rescue the GM issue from the grip of the consumer advocacy groupswas by being seen to take the lead on behalf of the consumer. A similar approachwas taken with GM insect-resistant crops.

Insect Resistance

Pesticide residue surveillance data confirms that in the UK, and very probablyin the US, we usually experience an incidence of pesticide residues in food cropsof less than 1%. The level of residue contamination is typically less than 0.5 ppmwithin that 1% incidence, and we accept such statistics as good evidence ofwell-managed agricultural operations. Farmers generally manage their cropswell.

In introducing the Bt gene into food crops, scientists have created crops withBt toxin throughout the crop tissue fluids. All crops will be affected, i.e., the inci-dence of toxin presence within the crop will be 100%, by definition. This is 100times the incidence of conventional pesticide presence.

With well-established integrated crop management systems, and effectiveadherence to pre-harvest intervals (PHI), i.e., where crops are not harvested forset periods of several days after the last pesticide application, there is an accept-able level of control, which results in acceptable residue levels as above.However, there can be no pre-harvest interval with GM insect-resistant crops.Genes cannot be programmed to switch off a set number of days before anunpredictable harvest date. GM insect-resistant crops will be harvested andconsumed with the biologically active concentration of toxin present withintheir tissues. This can apparently be 10 ppm or more, i.e., many times the residuelevel of conventional pesticide. Combining these two points means that con-sumers of GM pesticide-resistant crops will consume many times as much(natural) toxin as they will of conventional pesticides from conventional crops.The claim that the Bt toxin is natural is contentious as frankly there is nothingnatural about the process of taking a bacterial gene and transferring it into a

GMO Regulations: Food Safety or Trade Barrier? 237


plant, to express a toxin in concentrations for human consumption which areseveral orders of magnitude greater than could possibly be the case in nature.Additionally there is no established maximum residue level (MRL) for the Bttoxin, because it is classified as a natural toxin.

As an aside, should professionals not have asked why this new use of Bttoxin in GM insect-resistant crops should not have triggered the introduction ofMRLs for Bt toxin?

Summary

There is comparatively little concern within the European food industry aboutthe fundamental safety of GM foods in principle (though there are some notableand very respectable exceptions). We are aware of the widespread use of GMtechnology in the production of enzymes and other processing aids, which hasso far attracted little concern.

The potential benefits of GM technology in human and animal health care areimmense and there is a real danger that the crisis of consumer confidence overGM food and food ingredients will act to the detriment of advances in healthcareand medicine. This would be a tragedy. The medical benefits of GM technologymust be fully supported, rather than undermined by hasty commercial GMfood developments.

Most of us, including myself, would defend the use, for example, of GM-derived enzymes as delivering real customer benefit. GM-derived cheesecoagulant for instance, delivers both animal welfare benefits in the eyes of thecustomer, and hygiene benefits in the eyes of the food safety professional. Inshort it is important in this debate to distinguish between the different applica-tions of GM-derived food materials.

The key issue is that any new food product/ingredient/processing aid canonly hope to be commercially successful in today’s market if it is seen to delivera tangible customer benefit. GM insect resistance and GM herbicide resistancehave failed to be seen to deliver this. There may be tangible customer benefitsassociated with them, but if so they have not been seen to be so. Which meansthey have not been communicated.

This failure to employ effective customer communication, coupled with aninsufficiently critical appraisal of customer benefits by the food industry beforeaccepting GM foods, is the final conclusion that must be drawn over the eventsof the last couple of years.

The lessons must be learned.

1. We must critically appraise all novel food, GM or otherwise, for a real cus-tomer benefit before accepting them.

2. We must develop robust defenses for the use of GM-derived food materi-als such as enzymes, where we are confident of the customer benefit.

3. We must communicate the food industry view of both those GM foods weapprove of and those we do not. Only in this way will we wrest control ofthe agenda from out of the hands of the press and consumer advocacygroups, into the hands of the food professionals, where it belongs.



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