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Comment to USDA Regarding GMO Regulation
By Zen Honeycutt, Moms Across America
August 2, 2019 

The words of this comment are partially attributed to the Center for Food Safety, and partially to Moms Across America (in italics).

The new GMO regulations threaten America and beyond in the following ways

Health:

Our federal health care spending topped 3.5 trillion in 2018. Food is the most impactful factor of our health. American food is toxic, and it is making us sick. It could make us bankrupt.

Rather than strive to enforce regulations to reduce toxic chemicals and genetically modified foods in our food supply which have been shown to increase health issues, this administration is releasing rules that would make almost every GMO exempt from regulation. By allowing companies that make GMOs to decide the safety of their own products before selling them the USDA is putting the preferences and profits of the corporations over the health and safety of Americans and countries that import our products. This policy change is dangerous for the health and future of our country and for the stability of our economy. Studies showing harm from GMOs are below.

These new voluntary review system regulations leave it up to chemical companies—like Monsanto/Bayer and Dow, companies that have been facing lawsuits for decades for poisoning our waterways and towns—to “self-determine” whether or not their GE plant experiments should even be reported to USDA at all. 

How can any consumer or importer trust our regulatory system if Monsanto/Bayer, Dow/DuPont, etc. are calling the shots? It has been shown that Monsanto was caught ghost writing their own “science” which showed that their glyphosate products were “safe.” Monsanto has also claimed that DDT, PCBs, and Agent Orange were safe. These chemicals have left hundreds of thousands dead and generations dealing with birth defects in their wake.

We all know that given the opportunity, GMO/chemical companies will sell products that harm the public but earn them big profits. This is not sustainable for the health, productivity, economy, or future of America or the world.  Trusting these companies to regulate themselves will NOT make for a healthy and prosperous country or inspire exporters. 

Contamination:

One of the big problems with GMOs is their ability to cross-contaminate with conventional, organic crops as well as with plants in wildlife refuges and crops which are exported. Our local farmers livelihoods and our ecosystem is at risk.

Even in the rare instances when a company will volunteer to have their GE plant experiment regulated by USDA, the agency is proposing such a narrow scope of its review that it will only have a meaningful review process for a tiny percentage of GMOs. This allows for the illusion of regulation, while actually letting the companies go scot-free. 

In reality, deregulating nearly all GMOs with no oversight will dramatically increase the frequency of contamination—which has already cost U.S. farmers billions of dollars over the past decade. When you go from bad oversight to no oversight, many more incidents of contamination are sure to follow.

Exports and Economy:

If the United States does not regulate the GMOs grown in our country, how can other countries expect the food we export to them to be uncontaminated and safe?

Allowing unregulated GMOs to go straight to farm fields to be planted or to market to be sold is unpredictable and dangerous. Moms Across America asks the USDA to protect our local farmers, do your job and regulate GMOs.

These proposed regulations rely on chemical companies deciding whether or not their GE plant experiments should be reviewed by a government agency at all. They do not address the massive increase in overall pesticide use that GMOs have caused or the continuing epidemic of increasingly pesticide-resistant “superweeds.” They fail to protect endangered species or farm workers. They even leave dangerous new “biopharm” GMOs completely unregulated, making our food system vulnerable to contamination from experimental pharmaceuticals. These rules leave our public health and environment completely at the mercy of chemical companies.

These rules threaten our economy by increasing the likelihood that international importers of our crops will refuse them due to risk or actual contamination of GMOs as a result of our administration’s failure to regulate. This is not only dangerous; it is bad business. 

Would anyone want to buy food from a grocery store that is not regulated? Where fruit is mixed in with car cleaning chemicals and vegetables are next to laundry powder? That is how foreign countries will see the mess of our unregulated food supply. No country will want to shop from the breadbasket of America....putting our farmers and our economy in great jeopardy.

Moms Across America calls upon the USDA to maintain common sense and be responsible for your obligation to regulate genetically modified foods and their related agro chemicals. Protect the health and economy of our great country and please, protect us and our economy.

Genetically Modified Foods

• Report: "Forcing The Farm: How Gene Drive Organism Could Entrench Industrial Agriculture and Threaten Food Sovereignty"
• Genetically Modified Organisms (GMOs) as Invasive Species
• New Study Shows Gut Damage From GMO CORN
• BT Toxin GMOs as Human Gut Pathogen
• A long-term toxicology study on pigs fed a combined genetically modified (GM) soy and GM maize diet
• Clear English Summary of the Pig Tox Study (listed above)
• Changes in the Protein Profile of Pigs' Blood During Feeding With GM Soybeans
• Scientists have identified major molecular differences between a GMO corn and its non-GMO parent
• Synthetic biology: GMOs 2.0 - a great explanation of this new and dangerous technology
• Are GMOs 2.0 In Your Food and Cosmetics? - A Shopper's Guide to Synthetic Biology
• Genetically engineered crops, glyphosate and the deterioration of health in the United States
• Pathology reports on the first cows fed with Bt176 maize (1997–2002) - Gottfried Glöckner1 and Gilles-Éric Séralini
• New Study on Goats fed GMO soy: Mothers had less protein in milk and kids were smaller.
• GMO fed Rats 30, 60 and 90 days from Turkish Journal of Biology - "Biological impact of feeding rats with a genetically modified-based diet
• University of Washington-Protein and Gene Double Meaning Study
• Dr.Judy Carman’s and Farmer  Howard Vlieger’s Pig Study on GMO Feed
• Scientist Turns Anti GMO
• Dr. Huber 50 Year Plant Pathologist on GMOs and Glyphosate
• COVVHA 100 Scientific Study Links on the Health Risks of GMOs
• Rodale Institute -GMO Myths Busted
• Compositional Differences of GMO Soybeans and Non GMO Soybeans
• Morphological Changes of The Liver, Kidneys, And Adrenal Glands Of Experimental Animals After Long Term Feeding With Roundup Ready Genetically Modified Soya

Gene Editing - "GMOs 2.0"

• "New" GMOs Make Cells Vulnerable to Tumors and Mutations
• CRISPR Cas9 Has Potential to Increase Off-Target Mutations and Cancer Risk
• Unintended effects of "on target" edits with CRISPR
• CRISPR Cas9 GMOs shown to cause thousands of off target mutations
• DowDupont Scientists Use CRISPR to Try to Develop Glyphosate Resistance Plants
• CRISPR and the three myths of precise genome editing
• God’s Red Pencil? CRISPR and The Three Myths of Precise Genome Editing
• RNAi-Based Insecticidal Crops: Potential Effects on Nontarget Species
• Cisgenesis and genome editing: combining concepts and efforts for a smarter use of genetic resources in crop breeding