Updated excerpt from Codex Alimentarius — The End of Health Freedom
Brandon Turbeville
Activist Post
In several of my recent articles, I have discussed the problems of using “risk assessment” methodology in the evaluation of both vitamin and mineral supplements and Genetically Modified (GM) food. I have also discussed at length the dangers of the Codex Alimentarius and U.S. Food and Drug Administration position on GM food which is known as “substantial equivalence” and, in its more extreme forms, “substantial similarity.”
However, another concern addressed by the Codex Guidelines has to deal with antibiotic resistance created through the process of genetic engineering. Yet, as is typical of any Codex Alimentarius presentation, the agency makes several misleading and unsettling statements in this regard as well. While Codex does state that methods should be used that do not result in antibiotic resistance, it qualifies that claim in its document “Foods Derived From Modern Biotechnology,” by stating that these methods should be used “where such technologies are available and demonstrated to be safe.”[1] This is certainly no mandate. It is merely a suggestion that will most likely be completely ignored by industry.
The Guidelines then go on to say that “Gene transfer from plants and their food products to gut micro-organisms or human cells is considered a rare possibility because of the many complex and unlikely events that would need to occur consecutively.”[2] This statement stands in direct contradiction to established science.[3] Indeed, the series of events that would have to transpire in order for the transfer of modified genes from a plant to human DNA or cells are neither unlikely nor rare.
In a footnote to this statement, Codex makes the claim “In cases where there are high levels of naturally occurring bacteria that are resistant to the antibiotic, the likelihood of such bacteria transferring the resistance to other bacteria will be orders of magnitude higher than the likelihood of transfer between ingested foods and bacteria.”[4] Yet while this may in fact be true the statement is still misleading. The issue being discussed in the footnoted statement is the likelihood of DNA transfer from GM plants to humans. Furthermore, if such events were so unlikely, why would it be important not to use antibiotic resistant gene technology in the future?
Another concern presented in the section of “Foods Derived From Moderin Biotechnology” dealing with GM plants is the question of potential allergens being created within the food products as well as the introduction of entirely new allergens that have never before existed in nature.
While Codex claims that “all newly expressed proteins” as well as “a protein new to the food supply” should be tested for safety, there are legitimate questions as to whether or not Codex has the ability or the desire to test for such possibilities. [5]
First, while it is quite possible to know what foods occurring naturally are allergenic, it is much more difficult to come to these conclusions about new substances or proteins. This is partly due to the fact that naturally occurring materials have so many millions of years of history and use which, in itself, tends to naturally weed out the allergenic foods from the non-allergenic ones in a population’s diet. GM products do not have this history.
Indeed, the idea that over time a population tends to form its own guidelines through natural process adds to the ease in which scientific inquiry may form knowledge of the food properties in relation to the population itself. Again, this is not the case with GM food.
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Updated excerpt from Codex Alimentarius — The End of Health Freedom
Brandon Turbeville
Activist Post
In the course of the recent article series I have written regarding Codex Alimentarius and its position on Genetically Modified (GM) food, I have criticized both the “risk assessment” method of GM food evaluation as well as the official position of Codex Alimentarius in regards to the “substantial equivalence” standards. I have also written about the very real possibility of the introduction of new allergens and antibiotic resistant bacteria into the general food supply.
However, up to this point, all of the problems with the Codex Guidelines mentioned have been in relation to the section of the Codex GM position document known as “Foods Derived From Modern Biotechnology,” which focuses on GM plants.
There are, accordingly, two more sections – one dealing with GM Micro-Organisms and the other dealing with GM animals.
However, while it may seem that the majority of criticism expressed thus far focuses more attention on the first section (GM plants), the fact is that all three sections are very similar in their language and directives, with only a few changes in the wording made to apply to the new topic.
In many of these sections the language is word for word, copied and pasted to reiterate the same purpose as the first section. Therefore, I will not repeat my criticisms of the second and third sections that have appeared in my criticism of the GM Plants section. Suffice to say that all of the problems existing in the GM Plant section exist in the GM Micro-Organism and GM Animal sections as well, namely those of questionable scientific practices, the ignoring of relevant data, and so on. This claim is easily verifiable by reading the Guidelines document cited in the footnotes.
With that said, some attention should be paid to the section entitled, “Guideline For The Conduct Of Food Safety Assessment Of Foods Produced Using Recombinant-DNA Micro-Organisms.” This section deals mainly with bacteria, yeasts, and certain types of fungi in their uses in food production.
While making many of the same admissions present in the GM plant Guidelines, one of the most startling statements made regarding GM micro-organisms is the admission that they can in fact survive digestion.
Codex says, “In some processed foods, they [GM micro-organisms] can survive processing and ingestion and can compete and, in some cases, be retained in the intestinal environment for significant periods of time.”[1]
While this statement is not revolutionary, it is quite surprising to see it uttered by Codex Alimentarius, an organization that seems to go to great lengths to approve GM products.
Nevertheless, the fact that these micro-organisms can survive digestion is extremely important to the GMO safety debate. So are the questions of rDNA retention in the intestinal tract, the potential for changing the intestinal flora of those consuming the GM product, and the subsequent effects on the immune system.
These are all concerns that Codex tacitly admits the existence of, simply by acknowledging the need to test them.[2] Yet the tendency of GM micro-organisms to survive digestion and begin to change the makeup of the human intestines is mentioned later, in a footnote, where it is stated quite openly,
Permanent life-long colonization by ingested micro-organisms is rare. Some orally administered micro-organisms have been recovered in feces or in the colonic mucosa weeks after feeding ceased. Whether the genetically modified micro-organism is established in the gastrointestinal tract or not, the possibility remains that it might influence the microflora or the mammalian host.[3]
It should be noted that the idea that “life-long colonization by ingested micro-organisms is rare”[4] is highly contested by many independent scientists.[5] Yet, even if one were to assume the truth of Codex’s statement, the fact that it is rare means that it is still possible. More importantly, the statement admits that, even without long-term residence in the intestinal tract, there is still the distinct possibility that it will still significantly affect the intestinal flora and likewise the host itself.
Still more obviously biased concerns exist in the subsection dealing with the information that should be provided on each of the DNA modifications or micro-organisms. This information is, for the most part, very basic. It contains such data as which genes are added, the number of insertion sites, etc. However, two sources of information that are required to be included cause some concern.
The first is the inclusion of the “identification of any open reading frames within inserted DNA or created by the modifications to contiguous DNA in the chromosome or in a plasmid, including those that could result in fusion proteins.”[6]
The second is the “particular reference to any sequences known to encode, or to influence the expression of, potentially harmful functions.”[7]
Yet, both of these expressions (fusion proteins and genes that express harmful functions) are considered potentially dangerous even under the weak Codex standards. These expressions refer to the ability of some proteins to fuse with other proteins of the same and other species, mutating the DNA of the species, or forcing it to produce potentially adverse effects. Neither of these characteristics should be present in food, yet Codex mandates only that they be reported, not removed, as a result of the testing. This appears to be a continual thread of Codex’s Guidelines.
Thus, Codex continues by saying that additional information should be provided
to demonstrate whether the arrangement of the modified genetic material has been conserved or whether significant rearrangements have occurred after the introduction to the cell and propagation of the recombinant strain to the extent needed for its use(s) in food production, including those that may occur during its storage according to current techniques;[8]
as well as
to demonstrate whether deliberate modifications made to the amino acid sequence of the expressed protein result in changes in its post-translational modification or affect sites critical for its structure or function;[9]
While reporting information related to the instances above might seem like a good idea (and certainly few would argue that it isn’t), simple reporting is not enough. Indeed, these issues, as well as the others mentioned in this section of the Guidelines, are related directly to the question of the stability of genetically modified organisms. This is mentioned briefly in this section of the Guidelines, most notably in a footnote where it says,
Microbial genes are more fluid than those of higher eukaryotes; that is, the organisms grow faster, adapt to changing environments, and are more prone to change. Chromosomal rearrangements are common. The general genetic plasticity of micro-organisms may affect recombinant DNA in micro-organisms and must be considered in evaluating the stability of recombinant DNA micro-organisms.[10]
It is clear that GM organisms are often dangerously unstable. Many of them carry genes that overproduce a certain characteristic, cannot be turned off, or simply begin to change even after it has been bonded to the new strain of DNA.
Yet, with all of these admissions by Codex as to the dangers that GM micro-organisms pose to those who consume them as well as the fact that GM DNA is often unpredictable, the Codex Guidelines recommendations for testing suggest that these micro-organisms should be assessed based upon tests conducted on the conventional counterpart, not the micro-organism itself.
If tests conclude that the questionable micro-organisms are removed or rendered non-toxic in their individual and natural states, then “viability and residence of micro-organisms in the alimentary system need no examination.”[11]
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Updated excerpt from Codex Alimentarius — The End of Health Freedom
Brandon Turbeville
Activist Post
In my last article entitled, “Codex Alimentarius and GM Food Guidelines Pt.8”, I detailed the Codex Alimentarius position regarding Genetically Modified (GM) Micro-Organisms. Similarly, in several of the articles I have written recently, I have also discussed the Codex position on GM plants and other GM organisms.
Yet, no analysis of the Codex Alimentarius positions on GM food and/or organisms would be complete without a discussion of the Codex position on GM animals.
Indeed, the “Guideline For The Conduct Of Food Safety Assessment Of Foods Derived From Recombinant-DNA Animals,” a subsection of the Codex document “Foods Derived From Modern Biotechnology,” is as interesting for the concerns that it does not address as for the ones that it does. Largely a copied and pasted version of the two sections before it, (“Guideline for the conduct of food safety assessment of foods derived from recombinant-dna plants” and “Guideline for the conduct of food safety assessment Of foods produced using recombinant-dna micro-organisms”) the GM animal Guidelines does not address some very key issues such as:
1.) Animal welfare
2.) Ethical, moral and socio-economic aspects
3.) Environmental risks related to the environmental release of recombinant-DNA animals used in food production
4.) The safety of recombinant-DNA animals used as feed, or the safety of animals fed with feed derived from recombinant-DNA animals, plants and micro-organisms.[1]
As can be easily seen, these issues are extremely important in their own right. Just the moral issues, in addition to the hazards of the potential of GM animals being released into the environment, are enough to fill volumes. However, Codex chooses not to deal with these issues in its Guidelines.
With that being said, because Codex treats GM animals essentially the same as GM plants, there is very little difference in the guidelines. This shows a lack of scientific zeal as animals are fundamentally different than plants.
Yet one area where Codex does address a different aspect of the GM safety question is related to veterinary drug residues. It says,
Some recombinant-DNA animals may exhibit traits that may result in the potential for altered accumulation or distribution of xenobiotics (e.g. veterinary drug residues, metals), which may affect food safety. Similarly, the potential for altered colonization by and shedding of human pathogens or new symbiosis with toxin-producing organisms in the recombinant-DNA animal could have an effect on food safety.[2]
With its implicit admission of the instability of modified genes, Codex now also admits that these genes, when changed in animals, could affect the distribution and retention of veterinary drugs and other substances which would necessarily change the content of the food product derived from that animal. As Codex states, this same situation could also apply to human pathogens as well as veterinary drugs.
As a side note, it appears that 2007-2008 was a very beneficial year for GMO food producers. Not only were the pro-GM testing Guidelines approved by Codex, but many countries, such as the European Union who had been opposed to the introduction of GM food up to this point, began changing their position to one that was slightly more open to GMO.
For instance, in 2008, Codex Alimentarius approved Guidelines that would allow low levels of GM products that have not been approved by the countries’ regulatory agencies inside products that are imported into the country. This would include products like grain, corn, and oats. Codex claims that this set of standards merely recognizes the fact that GM products will inadvertently mix with non-GM products during processing and transportation and that it means to provide guidance in this unavoidable situation.[3]
However, this presupposes that GM contamination of food shipments is unavoidable when in fact just the opposite is the case. If GM products were not used to begin with, the entire issue would not need to be addressed.
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