Friday, December 20, 2013

Farmers & Handlers: Tell Your Stories -- Your experiences and costs with preventing GE contamination, or about being contaminated

Consumers: Tell USDA to Do the Right Thing:                    
  Contamination Prevention Now

USDA published a request for public comments [FR Vol.78, No. 213, Nov. 4, 2013] on how agricultural coexistence in the United States can be strengthened. Comments will be accepted through January 3, 2014.  [Note: NOC and many other organizations have requested an extension to this deadline.  We will notify you if there is more time, but in case not, we all need to comment!]
Why is this comment period important?
Organic and Non-GMO agriculture has shouldered the burden of GMO contamination for too long. This is our opportunity to tell USDA that it must use its authority to: 

(1) Implement mandatory contamination prevention measures to avoid the problem and protect the non-GMO sector, and 
(2) Ensure shared responsibility for the unwanted spread of GE products, including a fair compensation mechanism that does not further burden those who must avoid, and sometimes are harmed by, contamination.  
Comment ONLINE at the Federal eRulemaking portal.
Submit SNAIL MAIL comments to:  Docket No. APHIS–2013–0047, Regulatory Analysis, and Development, PPD, APHIS, Station, 3A–03.8, 4700 River Road Unit 118, Riverdale, MD 20737–1238.
Farmers & Handlers -- If you would like to send an ANONYMOUS COMMENT outlining your experiences and costs, please go to this site set up by NOC.  We will take your comment from this site, and include it as text in our comments submitted to the Docket.  If you have any questions about this process or its anonymity, please call Liana at 914-443-5759.

In 2011, following USDA’s  highly controversial approval of genetically engineered (GE) alfalfa USDA re-convened the Advisory Committee on Biotechnology and 21st Century Agriculture (AC21), which made recommendations in five major areas regarding agricultural coexistence (compensation,  stewardship, education and outreach, research, and seed quality).  

Some of these recommendations included investigating an appropriate compensation mechanism for dealing with economic harm caused by GE contamination such as  the possibility of offering crop insurance to organic and non-GMO farmers.  Other recommendations focused on identifying ways to foster communication and collaboration among those involved in all sectors of agriculture production, including conversations among neighboring farmers regarding planting dates to prevent cross-pollination.   Toaccess all AC21 documents and read the full AC21 report go HERE.

The public comment period now open is to solicit feedback on these recommendations.

What information is USDA seeking as part of this comment period?

USDA is asking for input on more than a dozen questions under the topics of education, collaboration, and outreach. The department seeks input on coexistence practices, and, specifically, how the department can support communication between farmers. See those questions HERE

Yet,  USDA is not discussing the most important question: 
How do we prevent contamination? Communication between neighboring farmers is a good thing, but communication alone is not a viable solution to the complicated contamination issues at hand. USDA’s questions miss this point. Talking about coexistence is perpetuating contamination

What should I say in my comments? Have a story to share?

If you are a farmer or handler, please consider sharing any experiences you’ve had with contamination on your farm or as a buyer. If you’ve been directly impacted by contamination, please explain the circumstances and consequences. Several AC21 members have stated that they don’t believe contamination is a problem
Even if you haven’t experienced contamination, are you spending your resources to prevent contamination (for instance:  land for buffers; choosing less profitable varieties with delayed planting dates, etc.)?  What is this costing you?

Tell the USDA your story:  

Submit your comments directly to, or submit ananonymous comment through this link.  


> USDA must establish mandatory measures to prevent contamination 

USDA is missing the point with these questions. The department wants input on “education” efforts, yet education does not prevent contamination. Voluntary solutions on this issue are insufficient – it’s what we have now and it isn’t working.

> USDA must use its authority to prevent GMO contamination and to compensate contaminated farmers and other businesses impacted.

USDA must establish a set of mandated best practices to prevent GE contamination by all farmers who use GE seed and require these farmers to institute concrete contamination prevention measures on their farms to supplement those already being used by organic and other non-GMO producers.

> USDA must establish shared responsibility

Fair farming for all should be USDA’s goal. Planting genetically engineered crops can threaten livelihoods, affect critical food supply and demand, and impose an unfair financial burden on farmers seeking to satisfy discernible markets for non-GMO products.

We know pollen can travel long distances, and we know contamination is happening, as reported by seed companies, farmers, grain buyers, and food manufacturers. We also know that these farmers and businesses are not publicly announcing problems with contamination because they don’t want to risk their reputation and markets.

The burden of preventing contamination cannot be the sole responsibility of   organic and other non-GMO farmers. Organic agriculture is especially vulnerable because it loses market value when contamination happens. USDA needs to develop mandatory rules to prevent contamination.

A key part of any education process USDA takes on must be based on full transparency and disclosure of information at every step of the supply chain. This includes labeling GE foods.

USDA should not approve promiscuous crops like alfalfa, sugar beets, canola, and corn.

> USDA should conduct more research to ensure a non-GMO seed supply

If USDA is going to educate the agricultural community, it should learn more about the impacts of GE products and monitor gene flow and contamination in the seed supply.

USDA should immediately create a GE contamination registry so it can track and eliminate known sources of GE contamination across the supply chain.

> USDA should reject Crop Insurance as a compensation mechanism

Farmers who seek to avoid GMOs must not continue to be solely responsible for contamination prevention and clean-up, or be forced to give up growing certain crops. Planting GMOs must not in any way preclude the growing of organic or conventional, non-GMO crops.

AC21 recommends that farmers buy crop insurance to protect themselves against unwanted GMO contamination. This is simply unacceptable. It would unfairly require organic and other non-GMO producers to spend even more money to protect themselves while GMO manufacturers would completely escape liability for GMO contamination prevention and compensation.

The patent holder should be responsible for segregation and traceability, from seed to plate. Those who own, promote, and profit from GMO products must be held responsible for the economic and market harm their products cause.

> Are there any good proposals in AC21’s recommendations?
AC21’s recommendations included some good proposals for research and seed quality. Tell USDA to implement these recommendations immediately: 
·         USDA should conduct research to ensure there is an adequate supply of improved non-GMO seed that meet the diverse and local needs of farmers
  • USDA should ensure the continued work of the National Genetic Resources Advisory Council (NGRAC)
  • USDA should create and implement a plan to maintain the purity of publicly held germplasm. The plan should include measures to (1) determine the presence of GE traits in publicly held germplasm stocks, (2) conduct ongoing monitoring of contamination in germplasm stocks, and (3) address contamination if it is identified in germplasm stocks.
  • USDA should also conduct research on the state of contamination in the commercial, non-GMO seed supply.
Deadline is January 3, 2014