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7-Business: Is GMO-free production possible? Costs and methods of crop segregation

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TITLE:  Is GMO-free production possible?
        Costs and methods of crop segregation
SOURCE: Neil Sorenson of the Institute for Agriculture and Trade Policy
        sent by Farm News from Cropchoice, USA,
DATE:   November 23, 2001

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Is GMO-free production possible?
Costs and methods of crop segregation

(Nov. 23, 2001 -- CropChoice news) -- The following is a fact sheet about 
segregation of transgenic from non-transgenic crops by Neil Sorenson of the 
Institute for Agriculture and Trade Policy.

Organic producers, who by definition must be GMO-free are taking many 
precautions to keep GMOs out of their products. Cross-pollination and 
commingling in elevators and transport systems make identity-preservation 
difficult. Customer demand, especially in export markets and corporate 
investment in varietal traits, however, are creating incentives for 

Organic growers, with their de facto ban on genetically modified organisms, 
have taken many precautions to ensure the maintenance of virtually pure 
genetic strains. Admittedly, even for organic producers, some trace amounts 
of genetic contamination have been found, despite stringent requirements.

Will industry, grain handlers and producers be able to develop the 
necessary identity preservation systems to achieve reliably GMO-free 
products on a large scale?


Obtaining high seed purity levels for corn is difficult because cross-
pollination of a seed-producing plant by the pollen of a plant of 
undesirable variety is very likely. Given the rapid contamination of 
cornfields, most conventional seed corn producers are no longer able to 
guarantee 100% seed purity. Current practices significantly underestimate 
the size of buffer zones necessary to ensure a GMO-free grain. The only 
practical way to meet very high GMO-free purity standards for corn would be 
to create very large isolation zones in which only non-genetically modified 
corn is grown for miles around. Setting up and administrating such an 
isolation zone, and enforcing compliance by neighboring farmers who may 
have economic incentives to grow GM corn, would present many organizational 

New elevators are being built with future segregation and identity 
preservation needs in mind, but the current grain handling system would 
need to be significantly modified to support identity preservation 
practices. Companies or cooperatives that own several different elevators 
may be able to clean and dedicate entire elevators exclusively to non-GM 
grains at some expense. Trucks and barges as well as manufacturing 
facilities will need to be cleaned or acquired new and kept clean to handle 
identity-preserved stock. Along every link of the food chain, separate 
pathways for distinct products will need to be maintained.


Cross-pollination can be prevented or minimized by using both physical and 
biological isolation. Physical isolation can make use of distance, as well 
as natural and man-made barriers, such as valleys or tree stands. 
Biological isolation is much more effective than physical isolation. Simply 
put, if the pollination date of an organic crop can be offset by 7-10 days 
relative to the pollination date of genetically engineered crops grown 
nearby, cross-pollination can be virtually prevented.


Assuming that farm labor can be hired during planting season for $15 
dollars per hour, it would cost no more than $15 to sufficiently clean out 
a mechanical planter between GMO and non-GMO runs. It takes approximately 
40 minutes to clean out an 8-row planter and 55 minutes for a 12-row 
planter to obtain a non-GMO purity level of 99.9%.


During harvest season, it would take two people approximately four hours to 
remove virtually every kernel of grain from a combine’s inner workings. 
Another harvesting procedure that obtains high levels of purity involves 
"flushing out" a combine by harvesting 60-70 bushels of non-GM grain after 
a simple 15 minute cleaning of the combine. The latter procedure costs .09 
cents per bushel, and the former costs .60 cents a bushel.

Transporting the grain from the farm to the elevator has no additional 
costs for GMO free producers. Grain trucks are designed to easily dump and 
easily sweep clean, and therefore pose little risk of contamination.

At the Grain Elevator

An elevator could dedicate certain bins to be permanently used for storing 
non-GM grains, but this would offer the elevator less flexibility in the 
number and types of grains it could store within its existing storage bins. 
With the arrival of GMOs, there are virtually twice as many types of corn, 
so if an existing elevator wanted to segregate GMOs from non-GMOs, then it 
would cut in half its capacity to separate grains by high and low quality.

Grain elevators are not designed to be kept "kernel clean." It would be 
prohibitively expensive to achieve this degree of cleanliness in the pits, 
boots, conveyor belts, storage bins, distributors, and especially the legs 
of an elevator. The cost-effective procedure is for grain handlers to 
dedicate separate grain paths to non-GM and GM grains. Those elevators with 
multiple grain paths of dump puts, legs, storage bins, conveyor belts, and 
spouts will be able to practice segregation and identity preservation with 
lower costs than those without separated grain paths.

Rail and Water Transport

For rail transport, hopper cars are built to receive various types of bulk 
cargo, and are cleaned after each shipment as a matter of standard 
procedure, and thus genetic contamination is of little concern. However, 
shipping identity preserved grain via river barges can be both difficult 
and costly. Currently, cleaning a barge costs around $300, and can be a 
difficult and unreliable procedure. The risk varies depending on the type 
of commodity that had previously been transported. Shipping GMO-free grain 
by sea is not costlier or riskier than for conventional commodities. 
Current regulatory requirements ensure that ship holds are cleaned between 
every shipment.


It is possible to develop verifiable methods for guaranteeing the purity of 
non-GM seed, grains and processed foods. A Polymerase Chain Reaction is a 
laboratory process in which a particular DNA segment from a mixture of DNA 
chains is rapidly replicated, producing a large, readily analyzed sample of 
a piece of DNA; the process is sometimes called DNA amplification.

Currently, there are many qualitative Polymerase Chain Reaction or "PCR 
negative" claims being marketed internationally. A PCR negative test shows 
that a particular genetic component is not present. However, GMO-free 
claims relying on this test are often misleading and sometimes openly 
false, as the tests cited are for ingredients where GMOs cannot be reliably 
tested for or detected, like oils or highly processed ingredients. Only the 
more expensive and thorough quantitative PCR test can reliably detect the 
exact presence of foreign genetic material.

In order to detect the presence of herbicide resistant traits, the ELISA 
(Enzyme Linked Immunosorbant Assay) detects a specific protein that has 
been captured by an antibody formed for the protein. GMO-free seeds show 
distinct characteristics when placed on a medium that is moistened with the 
respective herbicide.

Generally, current procedures lack both uniformity and reliability, and 
testing methodologies for the literally hundreds experimental GMO varieties 
that are planted in fields around the U.S. and elsewhere are nonexistent. 
There is a great need for new testing products and internationally applied 
testing protocols that can guarantee the integrity of non-GMO products from 
start to finish.


The StarLink debacle – in which a variety of genetically engineered corn 
not approved for human consumption in the US was nonetheless mixed with the 
food supply, both domestic and exported, costing manufacturers up to $1 
billion in economic losses – provides a glimpse of the damages that could 
accrue in the future. The traditional practice of "commingling" or mixing 
crop varieties during storage and shipment is likely to generate many more 
liability claims both in the US and internationally.

If the US Environmental Protection Agency continues to define GMOs as 
"substantially equivalent" to other crops and if open-field testing of 
unapproved varieties remains commonplace, contamination will become the 
norm. As testing methodologies advance, detection systems for new varieties 
will make compliance with international regulations and GMO-free 
certification systems increasingly more difficult.

Threshold Levels

Because of all the possible contamination points in the current grain 
handling system, agri-business is promoting "threshold levels" of 
contamination that would be considered acceptable and marketed as "GMO-
free" nonetheless. The industry contends that the costs of identity 
preservation increase exponentially with each percentage decrease in what 
would be considered a tolerable level of foreign DNA in consumer products.

The European Union, for example, has proposed a threshold of 1% 
contamination, while Japan would tolerate up to 5%. Because accuracy is 
much less important with a higher threshold, the industry is opposing the 
EU proposal and seeking a higher standard globally.

GM Contamination and Trade

Proposed European Union regulations for labeling GM foods and GMO-free 
foods would require identity preservation or "traceability" – defined as 
"the ability to trace and follow a food, feed, food producing animal, or 
substance through all stages of production and distribution." Further, the 
European Commission states that food and feed business operators "shall 
have in place systems and procedures which allow for this information to be 
made available to the competent authorities on demand."

The EU threshold of 1% for food and feed without triggering labeling 
requirements allows for some contamination, but the regulation further 
stipulates that this presence of GMOs must be the result of "adventitious" 
or technically unavoidable pollination. Responsible parties must be able to 
demonstrate that steps were taken to avoid the presence of foreign genetic 
material. Thus, simply assuming a tolerance level of 1% will not satisfy EU 

Each ingredient of any non-GMO-free product imported from the US into 
Europe, or the product itself if it consists just of one ingredient, will 
have to be labeled with the words 'genetically modified' or 'produced from 
genetically modified [name of organism] but not containing a genetically 
modified organism.'

Under the Cartagena Protocol on Biosafety, all shipments of commingled 
grains will have to indicate they "may contain" GMOs and importing nations 
may refuse shipments of GM-foods providing they follow certain procedures. 
In coming years, more detailed requirements for documenting the presence of 
GMOs will be negotiated, as well as provisions for compensating the victims 
of harm caused by GMOs.

If implemented, these regulations may force North American exporters to 
implement real-time systems to trace the origin of their products back to 
the farm in order to meet international market demand for GMO-free 
products. While threshold levels of tolerable contamination would undercut 
the degree of care required, incentives for developing and maintaining 
segregated pathways for grain varieties are growing.

Practical Experience

General Mills has pioneered identity preservation practices, undertaken 
studies to determine the effectiveness of buffer zones and is taking a 
realistic look at prospects for contamination. The company is working 
directly with farmers and breeders to learn more about identity 
preservation, but have found that technological possibilities are way ahead 
of consumer knowledge.

General Mills has found that approaching the development of non-GM product 
lines from a perspective of zero tolerance is costly and nearly impossible, 
but there is a degree of "substantial difference" between types of 
traditional varieties and that the "performance variation between varieties 
is greater than believed."

Whole Foods, a natural foods chain, decided to market their store brands as 
GMO-free. They began by randomly testing products containing corn, soy, 
canola (rapeseed) or tomatoes. They eventually eliminated the use of corn 
syrup from all recipes and reformulated many products, at great cost to the 
company. Certain products had to be discontinued because of the difficulty 
in finding a manufacturer that would guarantee product integrity.

Liability In the StarLink case, under pressure from the Attorneys General 
of 16 farm states, the company that engineered the product, Aventis 
CropScience, voluntarily accepted responsibility for compensating affected 
farmers, distributors and food manufacturers. But litigation resulting from 
other types of GMO controversies is mounting rapidly. Claims arising from 
genetic contamination, violation of technology-user agreements associated 
with patented GMOs, and regulatory liability are adding swiftly to the 
burden of the US court system. Until legislation is enacted imposing 
liability on the companies that make and sell GMOs, those farmers, 
companies and third party certification programs selling GMO-free products 
and services are bearing the burden of proof of their GMO-free claims, and 
being found liable and absorbing the economic costs for adventitious 
contamination of their products.


Genetically modified seeds, commodities and processed foods have been a 
source of controversy in international markets since their introduction. At 
present, the primary incentive for the production of identity preserved non-
GMO products is to take advantage of export markets where GMOs have been 
prohibited or otherwise regulated.

Identity preservation involves seed testing and certification; production, 
transport and storage on and from the farm; receiving and handling at the 
elevator; the establishment or use of dedicated processing and storage and 
distribution facilities; supplier certification and monitoring; development 
of recognizable and standardized labeling systems; compliance monitoring; 
GM testing throughout the supply chain; and provisions for appropriately 
allocating liability in case of errors.

Identity preservation adds costs and complexity to the food system, and 
failure at any point could result in commingling of a product or 
mislabeling and related liability claims. But the biotechnology industry 
has invested deeply in the development of new GMO products. More than 
28,000 field test sites have been authorized in the US through 2000, 
including more than 4,500 in that year alone. Of these, information about 
the genetic material being tested in two-thirds of the sites was considered 
"Confidential Business Information" not available to the public.

If the industry expects to successfully market GMO products in the future, 
investments in segregated pathways for identity preserved products seem to 
be an unavoidable cost of doing business now.

Sources Cert ID Non-GMO Certification, Program Overview Hurburgh, Charles, 
"The Economics of Non-GMO Segregation and Identity Preservation." "Knowing 
Where It's Going: Bringing Food to Market in the Age of Genetically 
Modified Crops," Minneapolis, MN, September 11, 2001. The Non-GMO Source, 
August 2001. The Organic Standard, September 2001. Prairie Grains, 
"Segregating Grain in a Post StarLink World," May 2001. St. Paul Pioneer 
Press, August 2, 2001.

By Neil Sorensen
Institute for Agriculture and Trade Policy
2105 First Avenue South
Minneapolis, Minnesota 55404
Tel: (+1-612) 870-3412
Fax: (+1-612) 870-4846

IATP is one of the founding members of the Genetically Engineered Food 
Alert Campaign, a coalition of organizations concerned with the protection 
of consumer rights, public health and the environment. For more 


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