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2004 Essays - Part I (June/July)

"GENES, BEANS AND GREENS: A TASTE OF THE GENETICALLY MODIFIED FOODS DEBATE, PART I" (June-July 2004 Essay)

    *This initial piece for summer 2004 was an attempt at something new: an interactive essay. Although it can be read as is, links are embedded at various points in the article. By clicking the link you can read more about the particular topic being discussed, then return to the essay. (The links are included for informations purposes only. No guarantees are made as to the accuracy of the materials presented on the sites, although every effort has been made to search out reliable and respected sources of information.) Please note: some links have changed since 2004 or are no longer in existence. Where it is possible, they have be updated to reflect the changes. Changes which have been made are not included in the body of the text but are noted in the "Links List" at the bottom of the page. Footnotes and a bibliography are also included at the end for anyone wishing to learn more about the subject. The materials represented here are only a small fraction of what is available on this very complicated issue. The glossary link below has been provided as a reference for use as needed. Click here to reach the glossary.

    Frankenfoods. It's a word designed to strike fear in the hearts (or stomachs!) of consumers about the foods they eat. It may conjure up images of scientists tinkering away in labs, busy creating plants or organisms like none anyone has ever known. It's also a word which has been used to describe and categorize the products of genetic engineering, or plants of modern agricultural biotechnology. It is not a word, however, which does anything to explain the subject or shed light on the debate concerning genetically modified (GM) food.

    Consider the following: last year about 80% of the soybeans and 40% of the corn grown in the U.S. were grown from GM, or transgenic, seeds.(n1) Perhaps you're thinking, "Well, I don't eat tofu or drink soymilk, and I don't eat that much corn, so what does this have to do with me?" A quick trip down the grocery store aisles can answer that question easily. Pick up a bottle of salad dressing, a jar of pasta sauce, or many varieties of packaged desserts and crackers. What are some of the ingredients on the label? Soybean oil or soy flour. Some of your favorite sports/energy bars or cereals? Soy protein. Soft drinks and some juices? Corn syrup. By some estimates as much as "70% of the human food products in the marketplace"(n2) today contain some ingredients made from transgenic crops. [To view a diagram of the edible uses of soybeans, click here.]

    From the first wide-scale planting of GM crops in 1996(n3), their cultivation has skyrocketed. By 2002, 145 million acres of GM soybeans, corn, canola and cotton were grown in 16 countries,(n4) by far the greatest percentage in the United States. As the products of agricultural biotechnology have surged, so has the debate concerning their safety, regulation, risks and benefits, alternatives and future uses.

    So just what is it that everybody's talking about?

The Genes: A Primer on Modern Agricultural Biotechnology

    Now take a walk over to the produce section of the grocery store. In recent years the bins have been filled with new, interesting items such as golden kiwi, broccoflower (a cross between cauliflower and broccoli), and pluots, plumcots and apriums (crosses between plums and apricots). These, however, are not products of modern genetic engineering. They are the outcome of the same type of conventional plant breeding that has been taking place for hundreds or thousands of years and has produced much of the food eaten today.

    Pick up an ear of corn, though. Look at it, touch it, smell it. If it was grown from genetically modified seeds, you would have no way of knowing, for there is no difference in outward appearance between the current types of GM corn and its non-GM counterparts. The corn, soybeans, cotton and canola mentioned earlier are all products of a much different process. That process involves altering the microscopic building blocks of a plant's genes.

    What are genes? A textbook definition of a gene is that it "is a section of a threadlike molecule called deoxyribonucleic acid, or DNA. DNA, the hereditary material that passes from one generation to the next, dictates the inherent properties of a species. Each cell in an organism has one or two sets of the basic DNA complement, called a genome. The genome itself is made up of one or more extremely long molecules of DNA that are called chromosomes."(n5). [If you would like to learn more about DNA and genes, click here.] If you took that ear of corn to a geneticist, he or she could determine whether or not it was genetically modified much in the same way a doctor might handle a paternity test, or the police might analyze DNA evidence from a crime scene.

    These soy, corn and other crops being discussed are all the products of what is called modern agricultural biotechnology. In general, the term "biotechnology" refers to "any technique that uses living organisms or substances from those organisms to make or modify a product for a practical purpose."(n6). This broad definition can also include processes like fermentation or pasteurization. Modern agricultural biotechnology, the products of which are the subject of debate, has a more specific definition. The process "includes a range of tools that scientists employ to understand and manipulate the genetic make-up of organisms for use in the production or processing of agricultural products"(n7), many of which end up in the food on grocery store shelves. [To go to a basic introduction to biotechnology, available in both English and Spanish, click here.]

    The soybeans and corn discussed so far are called transgenic because scientists created them by taking genetic material from one species, such as bacteria, and inserting the material into the genome of another species, such as soy. One aspect of the debate centers around objections to the technology itself based on moral, religious, or evolutionary grounds. Some feel it is "an area [which] should be left to nature rather than man,"(n8) since it entails "crossing lines that divide living organisms, which involves making irreversible permanent changes for future generations."(n9) The Pew Initiave on Food and Biotechnology has held a panel discussion on the subject which they called "Playing God or Doing God's Work?" To learn more about the outcomes of that discussion, click here. Also, to view a longer, more detailed report on the social and ethical issues surrounding biotech crops, click here.

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"Bangkok, Thailand" © 1985 Dorothy A. Birsic

The Beans: Products of Modern Agricultural Biotechnology

    In order to understand the rationale behind some of the earliest (i.e. first generation or first wave) transgenic crops, it is first necessary to understand a bit about modern commercial farming, generally referred to as agribusiness. Today's agribusiness is heavily dependent on chemical fertilizers, pesticides and herbicides for achieving high yields from the crops that are sown. In some cases, since 1945, it has taken a "ten-fold increase in pesticide use to achieve the higher output."(n10). In addition, "a crop's susceptibility to attack by pathogens and animal pests increases with yield."(n11). Many of the companies which supply farmers with the chemicals used to treat their crops are also ones developing genetically modified seeds for farmers to plant in their fields. In part due to the working of modern agribusiness, by 2000 approximately three quarters of all genetically modified crop traits which had been tested in developed countries were designed to make plants (soybeans, corn, cotton, etc.) either resistant to insects, tolerant of herbicides, or both (referred to as "stacked" traits).(n12)

    How exactly is this done? If you don't mind a little bit of scientific detail, it's fairly easily explained. Take insect-resistant crops to begin with. Although the seeds for the crops have trademarked names based on the company that developed them, they are generally referred to as Bt soy, Bt corn and Bt cotton. This is because a gene from the soil bacterium Bacillus thuringensis has been inserted into the plant genome. "The bacteria, [once a part of the growing plant], produces a protein that is toxic to certain Lepidopteran insects (ones that go through a caterpillar stage)," especially one called a corn borer.(n13) It is toxic because it "creates a protein that bonds to specific receptors in the midgut of sensitive insects but does not affect mammals or insects that lack those receptors, [and] is harmless to humans, fish, wildlife and beneficial insects."(n14) "It is a novel approach to controlling insects because it is produced throughout the plant for its entire life. Therefore, the insecticide is more effective than conventional and biological insecticides because it cannot be washed off by rain or broken down by other factors."(n15)

    Herbicide tolerant crops also have trademarked names which most often reflect the identity of the company that developed the seeds. Two examples of this are Roundup Ready® Soybeans (Monsanto) and LibertyLink® Corn (BayerCropScience). These types of plants are the most widely-adopted transgenic crops and "were developed to survive the application of specific herbicides that previously would have destroyed the crop along with the targeted weeds."(n16) Roundup is a common herbicide found even in local home improvement stores. The active ingredient in Roundup is glyphosate, and it kills plants "by interfering with the function of an enzyme called EPSP synthase."(n17) Roundup Ready® plants are made to tolerate the herbicide; humans do not possess the EPSP synthase enzyme so they cannot be harmed by it."(n18) [To view a list of transgenic products on the market now and within the next six years, click here.]

    This first wave or first generation of transgenic crops has primarily benefitted farmers, and they are some of the biggest proponents of the technologies. To understand a bit more about their perspective, click here. The benefits of the second and third generation, or next waves of biotech crops, should be more visible to consumers,(n19) but also potentially more contentious and controversial. They include things such as "improved" fruits and vegetables, and "edible vaccines" grown in crops such as bananas and potatoes.(n20) These will be discussed at greater length in next month's essay. It is important to note here that although transgenic crops may provide benefits, there are also potential environmental and human health risks associated with their cultivation. The ultimate custodian of the public safety when it comes to monitoring and regulating their approval and use is the federal government. The discussion will turn briefly to a look at the risks associated with GM food products and the government controls that allow them to eventually become part of the nation's food supply.

Regulation and Risk

    The material covered up to now is undoubtedly a lot of information to digest (no pun intended). Perhaps you're thinking to yourself that you want to go out to the kitchen and get something to eat or drink before continuing. Please do. While you're on your way, take a look at some of the labels on the food items in your pantry or refrigerator. Unless you've purchased something from a company that voluntarily notes whether or not their products contain GMOs, you have no way of knowing if anything you're eating has come from a transgenic crop. Compare this to a law which took effect throughout the European Union (EU) in April of this year. The EU law states that "Any food or feed containing, consisting of or produced from genetically modified organisms (GMOs) will need to be labelled in a way that indicates it contains GMOs. For GMOs that are currently approved in the EU, . . . levels of up to 0.9% will be permitted without the need for labelling. GMOs that have received neither EU approval nor a favorable risk evaluation will be forbidden. The labelling requirements do not apply to food products for which the manufacturing process commenced before April 18, 2004."(n21)

    Voluntary labelling in the U.S. versus mandatory labelling in the E.U.? Why the difference? Differences across the Atlantic may be due to many factors, but partly to matters of philosophy (when it comes to assessing risk) and practice (when it comes to labelling). The philosophical framework behind much of the decision-making in the U.S. on GM products is a doctrine called "substantial equivalence." The principle was originally developed by international organizations such as the World Health Organization (WHO), the Food and Agriculture Organization of the United Nations (FAO) and the OECD. "The underlying concept is the requirement that any safety assessment should show that a genetically modified variety [of plant, in this case] is as safe as its traditional counterparts [substantially equivalent] through a consideration of a wide range of both intended and unintended effects. This involves consideration of a wide range of information including agronomic properties, phenotypic changes, and . . . data on critical nutrients and toxicants."(n22)

    The more prevalent doctrine in Europe is known as the "precautionary principle." Although there are several definitions of the term, it is essence is a belief [that] there is an obligation to be certain that our actions (or . . . chemicals, food ingredients or technologies) do not cause harm or potential harm to people."(n23) The differences between the two play out in the assessment of risk and uncertainty over the effects of a new substance or technology. "The utilitarian/science model as used in the U.S. would have it that if the probability of harm is judged to be low and it the genetically modified foodstuffs are of some social benefit, then the introduction or use of those substances is 'safe.' A strict application of the precautionary approach says that if there remains any uncertainty or the extremely remote possibility of a disaster, prudence and ethics demand the substance/technology in question not be permitted."(n24) Application of the principle in the EU, especially as it applies to food labelling, may reflect the notion that people should be allowed to " exercise their autonomy to be able to choose not to consume or be exposed to possibly risky substances."(n25)

Photograph "Old-Fashioned Drinking Fountain, Tokyo" © 1991 Dorothy A. Birsic

    As a contrast to this, in "North America, regulators and companies agree that mandatory labels should be reserved for those products carrying a documented health risk or substantial change in nutritional composition. If the GM products are 'substantially equivalent' to conventional counterparts, companies argue, the GM label would be 'misleading,'"(n26) since they have already been determined to be 'safe.'

    So who makes the decisions in the United States when it comes to these products? In the U.S., three agencies share responsibility for regulating the products of modern agricultural biotechnology.

  • The Animal and Plant Health Inspection Service (APHIS) of the USDA regulates the field testing and commercial sale of agricultural bioengineered plants.(n27)

  • The Environmental Protection Agency (EPA) is responsible for regulating pesticides, including what they call the "plant incorporated protectants", or insecticidal properties, of transgenic plants.(n28)

  • The Food and Drug Administration (FDA) regulates the safety of foods and the safety and efficacy of pharmaceuticals and animal feeds, as well as elements of labelling.(n29)

The three agencies together maintain the U.S. Regulatory Agencies Unified Biotechnology Website. Click here to visit the site and learn more about the regulatory process for GMOs in the United States. Also, to view a searchable database of legislation concerning all aspects of GMOs which have been introduced in the state and federal legislatures, click here.

    Throughout history, new technologies have brought with them risks and benefits, intended and unintended consequences. The debate on GM plants cannot be fully understood without looking at some of the specific risks associated with modern agricultural biotechnology, risks both to the environment and to human health. These risks include:

  • Gene flow (pollen from GM plants finding its way into native plants producing new plants with adverse or unintended effects)

  • Emergence of new forms of resistance and secondary pest or weed problems

  • Recombination of the viruses or bacteria [from the GM plants] to produce new pathogens

  • Direct and indirect effects of new [plant-based] toxins

  • Changes in farm practices leading to changes in biodiversity.(n30)

These five risks are classified as risks to the environment. The two primary risks to human health which have been identified to date are: 1) the new substances in transgenic crops might cause allergenic or immune system reactions, and 2) antibiotic resistance that might be transferred to humans from organisms used in developing the GM crops (antibiotic resistance marker genes).(n31) It is important to note here that no adverse effects on human health (from genetically modified foods) have been reported.(n32) However, it has also been suggested that "there could, in theory, be long-term effects on human health that have not yet been detected because GM foods have been available for less than ten years."(n33) [To view these issues in greater detail, you can click here to link to a 2002 report entitled Benefits and Risks of Food Biotechnology. The report also contains extensive information about transgenic plants in California.]

    The issues of risks versus benefits, and how those risks versus benefits should be handled in the interest of mankind, are significant portions of the overall debate on GM food and modern biotechnology in general. As much as been said about proponents of the technologies such as some farmers, industry organizations, scientists, agribusiness companies and others, there are also very vocal opponents to GM foods.

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The Greens: Organics and Environmentalists

    Few consumers may realize that there is a family of products which by definition and by law must be free of GMOs. These are organic products. Although some major grocery stores have begun devoting small portions of their produce sections to organics, for many the term still conjures up images of the social and political movements of the 1960s and 1970s. Sales of organic products, however, have been increasing at about 20% per year, from about $1 billion in 1993 to about $13 billion in 2003.(n34)

    What exactly is organic farming? The organic farming philosophy centers "on practices designed to improve the richness and stability of the soil by restoring its organic matter and avoiding synthetic fertilizers, pesticides and herbicides."(n35) A goal of this type of agricultural practice is "to optimize the health and productivity of interdependent communities of soil life, plants, animals and people."(n36) [Click here to read more about organic farming and organic products.]

    Congress passed the Organic Foods Production Act (OFPA) back in 1990. Its objective was to ensure consumers that foods labelled "organic" met a defined set of production criteria,(n37) which now has come to specifically exclude GM products. (These are deemed to be incompatible with the practices of organic farming.) The Act established the National Organic Program (NOP) within the USDA, and NOP regulations require that all food labelled as organic originate from farms or handling operations certified by a state or private entity that has been accredited by the USDA. [For further information on the NOP and organic standards, click here.]

    The pictures below depict two of the types of labels which can be found on organic products. The one on the left is the official seal of the USDA. This seal may only appear on foods which consist of at least 95% organically produced ingredients. The words "organic" or "100% organic" may also appear on the labels of such items. Processed foods containing at least 70% organic ingredients may use the phrase "made with organic ingredients," but not the seal. All other products may not use word "organic" on the main display portion of the label.

                    

    The label on the right (image courtesy of QAI) is from one of the certification agencies accredited by the USDA. Organizations such as this one, Quality Assurance International (QAI), verify that growers, processors and handlers of organic products meet all applicable standards, statues and regulations.(n38) Both of the seals may appear on products marked "organic" or "100% organic." Anyone intentionally violating the label laws may be fined up to $10,000; operators whose gross agricultural income from organic sales is less than $5,000 is exempt from them. The full text of laws governing growers can be found in the Code of Federal Regulations, 7 CFR Subchapter M, Part 205.

    In general, organic farming is part of the much broader organic movement. The organic movement also "encompasses such tenets as animal welfare, energy efficiency, social justice and the simple agrarian ideals of small farms growing produce for local communities."(n39) As such, the movement finds close kin in many environmental organizations. Some of the largest of these organizations have taken the most prominent and visible stands against transgenic products. To read some of their positions on the debate, click on the links below. Where possible, direct links have been made to the pages stating positions on agricultural biotechnology and/or GM foods.

    How can the debate and all these issues play out? This year a California county, Mendocino County, became the first in the nation to pass a local ballot measure concerning genetically modified organisms. The measure specifically prohibits the cultivation of GM crops within the county. To view the text of that measure, click here.

Photograph "Nepalese Rice Paddies" © 1985 Dorothy A. Birsic

Conclusion and a Look Ahead to Part 2

    "Plants are remarkable in their capacity to synthesize a variety of organic substances, such as vitamins, sugars, starches and amino acids. As many as 80,000 different substances are synthesized in plants, including macronutrients and micronutrients significant to human health."(n40) In Part 1, much of the "mechanics" of the debate on modern agricultural biotechnology have been discussed. Part 2, coming next month, will look at what modern agricultural biotechnology might look like in the future. Vitamin-enhanced rice and plant-based medicines (nutraceuticals) are just two of the products in the GM pipeline of tomorrow. Also, no discussion of the GM food debate would be complete without looking at the hopes for transgenic crops as a solution to hunger in the third world. The "debate" will continue next month. . . Hope you'll be back!


A special thanks to Norman E. Ellstrand, Professor of Genetics and Director of the Biotechnology Impact Center, Alan McHughen, Biotechnology Specialist and Plant Geneticist, and Carl Cranor, Professor of Philosophy, all of the University of California Riverside, for their insight and input during the writing of this essay.

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FOOTNOTES - The following are the footnotes indicated in the text in parentheses with the letter "n" and a number. If you click the asterisk at the end of the footnote, it will take you back to the paragraph where you left off.

n1 - United States Department of Agriculture (USDA), National Agricultural Statistics Service (NASS), Acreage Report, Washington D.C., June 2003, pp. 24-25(*)

n2 - California Council on Science and Technology, Benefits and Risks of Food Biotechnology, Sacramento, 2002, p. 5 (*)

n3 - USDA, Economic Research Service, Economic Issues in Agricultural Biotechnology, AIB-762, Washington D.C., February 2001, p. 4 (*)

n4 - James, Dr. Clive, ISAAA, Global Status of Biotech Crops in 2002, in Council for Biotechnology Information, Good Ideas are Growing: Plant Biotechnology, Washington D.C., 2003, p. 4 (*)

n5 - Griffiths, Anthony, Miller, Jeffrey H., Suzuki, David T., Lewontin, Richard C., and Gelbart, William M. An Introduction to Genetic Analysis, 5th Edition, W.H. Freeman and Company: New York, 1993, p. 2 (*)

n6 - On-line document. United Nations, Food and Agriculture Organization (FAO), The State of Food And Agriculture: 2003-2004, www.fao.org/docrep/006/Y5160e/y5160e07.htm, Chapter 2, p. 1 (*)

n7 - Ibid. (*)

n8 - Kirby, Sarah L. "Genetically Modified Foods. More Reason to Label Than Not." 6 Drake Journal of Agricultural Law 351, Fall 2001. p. (*)

n9 - Ibid. (*)

n10 - Degregori, Thomas R. Agriculture and Modern Technology: A Defense. Ames, Iowa: Iowa State University Press, 2001, p. 143 (*)

n11 - Ibid., p. 141 (*)

n12 - Huang, Jikun, Pray, Carl, and Rozelle, Scott, "Enhancing the Crops to Feed the Poor," Nature 418, August 8, 2002, p. 681 (*)

n13 - Fernandez-Cornejo, Jorge, and McBride, William D., USDA, Economic Research Service, Adoption of Bioengineered Crops, AER-810, May 2002, p. 4 (*)

n14 - Monsanto, Key Facts About Food and Feed Safety: The Products of Plant Biotechnology, company brochure #00499185, p. 3 (*)

n15 - Fernandez-Cornejo and McBride, p. 4 (*)

n16 - Ibid. (*)

n17 - Lurquin, Paul F. High Tech Harvest: Understanding Genetically Modified Food Plants, Boulder, CO: Westview Press, 2002, p. 99 (*)

n18 - Ibid. (*)

n19 - www.document. www.bio/org/speeches/pubs/er/food.asp (*)

n20 - Pretty, Jules. ":The Rapid Emergence of Genetic Modification in World Agriculture: Contested Risks and Benefits," Environmental Conservation, 28 (3) p. 251. (*)

n21 - Craddock, Neville. "Flies in the Soup: European GM Labelling Legislation," Nature Biotechnology, Vol. 22, No. 4, April 2004, p. 384 (*)

n22 - Tomlinson, Nick, "The Concept of Substantial Equivalence," in Ruse, Michael and Castle, David, eds. Genetically Modified Foods, New York: Prometheus Books, 2002, p. 204 (*)

n23 - Burkhardt, Jeffrey, Thompson, Paul B., and Peterson, Tana Rae, "The First European Congress on Agricultural and Food Ethics and Follow-Up Workshop on Ethics and Food Biotechnology. A U.S. Perspective," Agriculture and Human Values, Vol. 17, No. 4, December 2000, p. 329 (*)

n24 - Ibid. (*)

n25 - Ibid. (*)

n26 - McHughen, Alan. Pandora's Picnic Basket, Oxford: Oxford University Press, 2000, p. 203 (*)

n27 - California Council on Science and Technology, p. 102 (*)

n28 - Ibid., p. 103 (*)

n29 - Ibid., p. 104 (*)

n30 - Pretty, pp. 250-253 (*)

n31 - Ibid., p. 253-254 (*)

n32 - www document. Krebs, John. "Chairman's Report," The OECD Edinburgh Conference on the Scientific and Health Aspects of GM Foods," 2000, www.OECD.org/dataoecd/34/30/2097312.pdf (*)

n33 - Ibid. (*)

n34 - Federal Register, National Organic Program, Amendments to the National List of Allowed and Prohibited Substances, Vol. 68, No. 211, October 31, 2003, p. 61989 (*)

n35 - MacIlwain, Colin. "Organic: Is It the Future of Farming?" Nature 428, April 22, 2004, p. 792 (*)

n36 - Klonsky, Karen. "Forces Impacting the Production of Organic Foods," Agriculture and Human Values, Vol. 17, No. 3, September 2000, p. 235 (*)

n37 - Ibid. (*)

n38 - QAI, FAQ Brochure (*)

n39 - Gewin, Virginia. "Organic FAQs," Nature 428, April 22, 2004, p. 796 (*)

n40 - Dandekar, Abhaya M. and Gutterson, Neal. "Genetic Engineering to Improve Quality, Productivity and Value of Crops," California Agriculture, July-August 2000, p. 50 (*)

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The list of links included in the essay is as follows*:

  • Glossary - www.fao.org/biotech/index_glossary.asp

  • Uses of Soy - www.soystats.com/2003/edibleuses.htm. ( Also: www.soystats.com will take you to a page from which you can link to a number of different years.)

  • DNA - www.dnafromthebeginning.org

  • Biotech Tutorial - www.dupont.com/biotech/intro/quick.html. ( No exact replacement has been found for this link. Try www2.dupont.com/Biotechnology/en_US/intro/index.html.)

  • Pew Initiative - pewagbiotech.org/events/0726/. ( The Pewagbiotech site is not longer in existence. All references to Pewagbiotech will take you to www.pewtrusts.org/our_work_detail.aspx?id=442.)

  • Social/Ethical Implications - www.nuffieldbioethics.org/publications/pp_0000000009.asp. (This link now takes you to the organization's general publications page.)

  • Products on Market - www.bio.org/er/agri_products. (The main site, www.bio.org is still in existence, but the page is not.)

  • Farmers' Perspective - www.tomorrowsbounty.org. ( This site no longer exists.)

  • U.S. Government Unified Biotech Website - http://usbiotechreg.nbii.gov

  • Legislation Tracker - www.pewagbiotech.org/resources/factsheets/legislation. ( The Pewagbiotech site is not longer in existence. All references to Pewagbiotech will take you to www.pewtrusts.org/our_work_detail.aspx?id=442.)

  • CCST Report - www.ccst.us/ccst/pubs/gmf/gmf01.html

  • Organic Farming - www.sciencedaily.com/encyclopedia/organic_farming. (Go to www.sciencedaily.com and search on "Organic Farming.")

  • National Organic Program - www.ams.usda.gov/nop

  • Greenpeace USA - www.greenpeaceusa.org/campaigns/intro?campaign_id=503428. (Try www.greenpeace.org/us/campaigns/genetic_engineering.)

  • Sierra Club - www.sierraclub.org/biotech

  • Friends of the Earth - www.foe.org/camps/comm/safefood/index.html. (Try www.foe.org.)

  • The Campaign - www.thecampaign.org

  • Mendocino GMO - internal website document reference

*Some of the links have changed since 2004, and some are no longer in existence. Where possible, they have been updated to reflect the changes.

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