Roundup Ready sugar beets have been back in the news due to the decision by Judge White to revoke approval. As I understand it, the USDA conduced an Environmental Assessment for Roundup Ready sugar beets but did not conduct an Environmental Impact Statement. According to regulation, an EA is sufficient if potential harm is found to be minimal, but an EIS is needed for anything that is less well understood, such as a new trait (and this is hardly a new trait). After reading the EA, I agree with the USDA that the potential environmental harm is minimal, and I think the potential economic harm is minimal as well, due to some very specific characteristics of beet biology, which I’ll explain in this post, followed by a discussion of mitigation strategies that might be used to control gene flow in beets (sorry, folks, this is going to be another long one).

Beet biology

Sugar beets are biennial, which means they need two years before they reach maturity. During the 1st year, the plants produce a large root that, when dried, is 15-20% sugar. During the 2nd year, the plant uses those stored sugars to produce flowers and then seeds. Sugar beets harvested for sugar, therefore, don’t produce flowers or pollen or seeds.

Sometimes a few plants will “bolt” or flower when they aren’t supposed to, such as when there are unusual temperatures. This happens in both GM* and non-GM beets. Modern beet varieties have been bred to not bolt. Still, a small amount of beet seed has been fertilized by pollen from weed beets, resulting in weed x cultivated beet hybrids that might bolt. This results in a very low percentage of bolters in any beet field – fewer than 1 per 1000 square meters of field. Only 1/2 of the pollen from these “accidents” will have the Roundup Ready gene. Another source of pollen could be beets or pieces of beets that are can be missed during harvest. These can flower during the following year as volunteers.

Bolters must be dealt with immediately, usually by removing them by hand. In the case of Roundup Ready beets where Roundup can be used to remove bolters. They have to be removed because seed from the bolters can grow into plants that harbor disease, and cause other problems. Some discussion on bolter control can be found in the University of California Cooperative Extension Sugarbeet Notes.

When they do flower, such as when beets are grown for seed, sugar beet pollen is fairly mobile, according to the Jan 2009 Pollen dispersal in sugar beet production fields. It is carried by the wind and possibly by insects as well. They found that pollen carried up to 1200 meters (that’s about 0.75 miles). These results are fairly consistent among papers testing dispersal of beet pollen. Even though pollen can move from field to field, most of it stays put. In the 1967 Cross-pollination between fields of sugar beet, the amount of pollen falling from one 20 acre beet field onto another that is 1000 meters away is estimated to be 0.004 compared to the amount of pollen coming from the field itself. Beet pollen can remain viable for a while when stored cold and dry in a lab refrigerator, but in the field it’s only viable for about 24 hours after it is shed by the flower.

Even though there’s all of this pollen flying around, most of it falls close to the parent plants. This is a good thing for any farmer trying to grow seed, or it would be impossible to produce seed with the genetics that they want.

Pollen potential

There are 4 situations I can imagine for combinations of GM and non-GM sugar beet fields. Only one is a problem because the seeds of sugar beets grown for sugar are irrelevant. You can not both harvest the root for sugar this year and harvest the seed next year. Even if a flower from a plant was pollinated with pollen that contains a transgene, the beet from that plant will not. So, there is no risk of contamination of non-GM beets with GM beet pollen – except in the case of seed production.

1. Two fields growing beets next to each other, one GM and one not GM. In this case, the only pollen around will be from bolters. Even if flowers are produced and are pollinated with pollen that has a GM gene, the root is still not GM.
2. A field growing non-GM beet seed next to a field growing GM beets. The only GM pollen around will be from bolters. It is possible that pollen from GM bolters could fertilize the non-GM beet flowers at a very low rate. Appropriate distances must be maintained by the farmer growing the seed to ensure he will produce seed with the genetics he wants.
3. A field growing GM beet seed next to a field growing non-GM beets. As in case 1, the roots in the non-GM field will not be affected. Just like in case 2, the farmer growing seed needs to maintain appropriate distances to protect her flowers from bolters to ensure her seed will have the genetics she wants.
4. Two fields growing beet seed next to each other, one GM and one not GM. This is where things get a little more complicated, just because there’s more pollen around. Since most beet seed is grown in Willamette Valley in Oregon, the potential for cross pollination is fairly high. The problem isn’t unique to GM, though.

Sugar beets, table beets, and chard are all grown for seed in Willamette Valley, and they are all capable of cross pollination. Seed producers of any of these must keep their fields separated by distance from any other seed producers or the resulting seed could be worthless.

For example, if red table beet seeds were grown too close to sugar beet seeds, the sugar beet seed grower could end up with red sugar beet seed. Whoever bought and planted that seed would end up with a worthless crop, since all that red pigment would complicate sugar processing. Even if only a small percentage of the field had genes from table beets, the farmer would be paid less for his crop since the sugar processor would have to find a way to remove the red sugar beets. Table beets growing from the contaminated seed would likely have issues as well.

You gotta keep ‘em separated

Producing pure seed isn’t an easy job. Without GM even entering the discussion, there’s a lot to do to make sure that the seed a farmer buys is going to produce the right plants. In the case of beets, the plants are often weeded by hand to remove any plants that don’t look like the rest. The American Crystal Sugar Company has an excellent webpage that talks about sugar beet seed production, with pictures. For a non-beet centric view of how complicated it can be to produce good seed, the Seeds of Change seed company has a great article: Redefining Seed Quality. The article is about organic seed but applies equally to all seed types (there is one error in this article, see the next section of this post for details).

How do seed producers in Willamette Valley and elsewhere keep pollen from sexually compatible crops from pollinating their flowers and contaminating their seed? It all comes down to distance. The Oregon Seed Certification Service recommends different distances for stock seed and for certified seed (see the Oregon Seed Certification Service Handbook for more details on types of seed). Oregon’s sugar beet certification standards sheet (pdf) lists the following distances  for stock and certified seed production:

1. From sugar beet pollen source of different or unknown ploidy: 5000 ft, 3200 ft
2. From sugar beet pollen source of similar ploidy or between fields where male sterility is not used: 3200 ft, 2600 ft
3. From other pollinator or genus Beta that is not a sugar beet (including fodder beet, red beet, swiss chard): 10,200 ft, 8000 ft

Remember, 5,280 ft is a mile, so this standards sheet is saying that seed production fields need to be 1 to 2 miles apart (the American Crystal Sugar Company site says the distance needed might be “several miles”). If this distance works well enough to keep all the different varieites of sugar beets, table beets, and chard genetically pure, then it will work to keep GM genes out of non-GM crops. Pollen from a GM plant is no different than pollen from a non-GM plant. While I could understand if someone advocated for tests with GM pollen to determine the exact distance, I don’t think that’s necessary since we already have a lot of information on how far apart fields need to be to prevent gene flow. We just need to ask seed companies what they have found to be effective.

Don’t panic, it’s organic

The Redefining Seed Quality article has one little mistake. It says “By law organic seed can not contain genetically modified organisms (GMOs).” This is a common misconception. The law actually says that GM can not be used in organic seed, not that it can’t contain GM seed. The organic standards are processed based, not content based. As long as an organic farmer sources seed that isn’t GM and makes a reasonable effort to prevent GM materials from being in his products, organic certification will not be affected, even if the product is tested and found to have a GM gene in it. How can this be? Those reasonable efforts work the majority of the time because they are based on sound science.

The regulation isn’t completely clear on how all this works, so we can’t really blame Seeds of Change for assuming that the law says seed can’t contain GMOs. Back in 2004, USDA official Bill Hawks responded to questions about organic certification and GM by Gus Douglas of the National Association of State Departments of Agriculture. The excellent questions were met with excellent responses and really clears up what the policies are. The letter isn’t long, I recommend reading it in full.

This point of GM content is very important in the case we’re discussing here. If an organic beet or beet relative seed farmer (or any organic seed farmer) takes reasonable precautions, such as the appropriate distances as discussed above, it is still possible for cross pollination to occur at some low level. What level is acceptable? The regulation doesn’t say, because content isn’t the issue.

Of course, even though content isn’t the issue for organic certification, some people want to add extra levels of testing and certification beyond organic standards. The Non-GMO Project is a private labeling program that has established its own guidelines for what level of GM content is too high to allow use of their proprietary label. The Non-GMO Project Working Standard sets the following levels as the maximum allowable GM content: 0.1% for seed and other plant propagation materials, 0.5% for ingredients of human food, supplements, or hygiene products, and 0.9% for animal feed and supplements. These levels may or may not be met by the precautions required for organic certification, so farmers looking for a Non-GMO or similar label may need to take additional precautions.

Distance as mitigation strategy

As labels like Non-GMO become more widely used, more farmers will be testing their crops, so there is potential for economic harm due to even low levels of cross pollination. Still, none of this justifies a nationwide ban on GM sugar beet seed production. There are other options. Some would put the onus on the sugar industry and farmers who want to grow GM beet seeds, others put the onus on farmers who want more strict pollen control. Unfortunately, all options will make things difficult to varying degrees for one or the other, which I suppose is why the issue ended up in court instead of peacefully decided.

Judge White may not have known about distance as a mitigation strategy. If he had, perhaps he could have ruled that GM seed production could only take place a certain distance away from the fields of farmers who don’t want even the potential of GM pollen. I’d imagine there could be a legal argument that farmers using existing methods have certain rights when faced with a new method that could potentially affect their livelihoods. Setting such a distance may well effectively ban the growing of GM sugar beet seed in Willamette Valley.

Another option that was available to Judge White was to just prohibit GM beet seeds from being grown in Willamette Valley. There’s already a ban in all of Oregon against growing any canola (GM or not) because of concerns that the canola will pollinate other brassica crops grown for seed, like broccoli, although that concern might not be warranted, according to farmer Dean Freeborn in Farmer pushes for relaxation on canola rules. This could be used as precedent to justify a ban on GM sugar beet seed production in Willamette Valley, or even in all of Oregon.

Since Willamette Valley is apparently the best place to grow beet seed, a true ban or effective ban would likely harm the sugar industry and even farmers who don’t currently supply niche markets if the GM beet seed has to be grown elsewhere. I’m not sure what the law says about preferring one industry over another, but I think an argument can be made here.

Aside from the negative effects on the non-specialty seed market, there is another problem with distance. It requires, in any way I can think of it, that exact locations of fields be made public, at least to other seed farmers. From there I bet it wouldn’t be too hard for destructive activists to start pulling up plants or setting fields on fire. It’s an unfortunate reality that has to be dealt with.

Other mitigation strategies

If not distance, seed producers always have the option to use mobile, temporary tents over the plants while they are receptive to pollen. According to Seeds of Change, tents or field covers have a lot of advantages, including protecting the plants from insects and other pests. Here in Ames, Iowa researchers from USDA APHIS use tents made of fine mesh so the wind and sun can pass through while isolating the plants from undesired pollen. Of course, this would be a hassle for growers that don’t currently need to use them.

Another option is to use varieties that aren’t sexually compatible with your neighbor’s crops. Without going too much into detail, some varieties of beets have genes that only allow pollination with pollen that has a compatible gene. All the pollen in the world could be flying around, but only sexually compatible pollen would successfully fertilize flowers.

Another solution was suggested, briefly, by the (former?) Board President of the Organic Seed Growers and Trade Association Frank Morton in a post titled GMOs at the Door:

Some [mitigation strategies] are so obvious that it seems negligent to have not employed them, like using male-sterile maternal lines to carry the RR-genes (so no RR-pollen is created) in the hybrid seed production process (all GM-sugar beets are F1 hybrids).

This idea isn’t new, and works for many more crops than just beets. As described in The use of cytoplasmic male sterility for seed production (paraphrased from pdf, page 630):

CMS is used to produce hybrids of both table and sugar beets. Sugar beets are almost exclusively hybrids in the US and Europe, with some open-pollinated cultivars grown in regions of the world with lower inputs such as Morocco and Egypt. Approximately 50% of table-beet cultivars are hybrid; OP cultivars are still produced with the advantage of cheaper seed. CMS and its potential to be used to create hybrids was described in 1945.

Since hybrids are already used, it wouldn’t take much more effort to develop male sterile lines that carry the transgene. It does take a little breeding work, but that should be child’s play for Monsanto’s plant breeders. Male sterile plants make a lot of sense for hybrid production in general, doubly so when dominant transgenes like Roundup Ready are involved.

To be honest, I don’t know why this strategy isn’t used with sugar beets. It seems like a win-win. Farmers of non-GM seed avoid any additional problems with cross pollination, all seed farmers keep using distances for isolation just as they always have, the sugar industry and sugar beet farmers get all the GM sugar beet seed they want… Once this economic cross pollination issue for seed production is resolved, there’s no reason to stop the deregulation of GM sugar beets.

A history of beets

Sugar beets don’t appear in nature, nor table beets. Ancestors of beets were domesticated from a seashore living species that distributed its seeds in corky fruits that floated in the water, called sea beets or sea spinach today. By ancient times, the plants were bred into something like Swiss chard, widely grown in gardens and considered to be a very healthy addition to the diet. The plants even appeared in ancient literature, such as in this culinary quote from The Acharnians by Aristophanes circa 425BC:

Beets and beet greens remained popular throughout the centuries. In 812, Charlemagne issued a decree that imperial estates include beets in their gardens, referring to a plant similar to table beets in that both leaves and roots can be eaten. In 1538, several varieties of beets were described by Andrea Cesalpino, an Italian botanist, in De Plantus. In 1600, the sweetness of beets was praised by Oliver De Serres, a French agronomist, in Théatre d’agriculture.

Finally, in 1747 Andreas Sigsmund Marggraf reported to the Prussian Academy of Sciences that he had extracted pure sugar from beets! However, the sugar was only about 1.6% of the total beet weight, which seemed too low to bother with. His student, Franz Carl Archard, working with white beets used for animal feed, developed the highly sweet White Silesian beet. Franz went on to open the first sugar beet extraction plant, and the rest is history.

Historical information is paraphrased from Sugar Beet by A. Philip Draycott.

.

*GM stands for genetically modified or genetic modification.

Note: Much of this post originally appeared as No risk assessment for sugar beets? but has been edited to be a broader discussion of sugar beet biology, with additional discussion of seed production. The historical part was just incidental, I found all of this cool information and just had to include it. I hope you’ll think it’s cool too!

We’ve talked about high fructose corn syrup many times here at Biofortified. There’s a lot of subjects to be considered, including whether we should be growing so much corn in the first place. The biggest concern about HFCS, though, judging by popular magazines and websites, is health. People are worried that corn syrup is worse for us than other sugar sources, which has resulted in the latest marketing scheme of switching corn syrup for other sugars so products can be labeled “HFCS Free”.

Does changing the sugar actually make the product healthier? Unfortunately, no. Because HFCS is sweeter than cane or beet sugar, more calories of sugar have to be added to achieve the same level of sweetness. The only thing that would make a product healthier is to reduce overall sugar content. This is especially true because cane and beet sugar as well as other caloric sweeteners all contain fructose, which has been correlated with or directly connected with a variety of health problems.

Over at Science-Based Medicine, Dr. Jim Laidler (an accomplished physician turned researcher) has written High Fructose Corn Syrup: Tasty Toxin or Slandered Sweetener? It’s a very informative post, one that anyone with concerns about HFCS should read and share! He concludes that fructose is something to be concerned about, but that’s only part of the story:

For people who are worried about their health or their children’s health — and who isn’t, these days — the data suggest that the best choice is to reduce intake of all sweeteners containing fructose. That includes not only the evil HFCS, but also natural cane sugar, molasses (which is just impure cane sugar), brown sugar (ditto) and honey. Even “unsweetened” (no added sugar) fruit juices need to be considered when limiting your family’s fructose intake.

Finally, the best nutritional advice is to eat everything in moderation — and that includes sweets. While a diet high in fructose may increase your risk of obesity, diabetes and heart disease — maybe — a fructose-free diet is not guaranteed toprevent those diseases. Eat a variety of foods, including a small amount of sweets, get enough exercise, watch your (and your children’s) weight and see your doctor for regular health check-ups.

And stop worrying that HFCS is poisoning you and your children.

We’ve discussed labeling many times at Biofortified, usually looking at things from a practical perspective, such as in the posts What’s in a label? and Labeling GMOs. I argue that anything that is scientifically proven to be a hazard should be a mandatory label. For example, a label that a product contains nuts is justified by severe allergic reactions, even though the additional label may add to the cost of a product for people who don’t have allergies. Any label that doesn’t have a proven hazard is simply a label of preference, so should not be mandatory. Instead, voluntary labels are appropriate. For example, producers may choose to label products as free from animal products if they think the cost of sourcing non-animal ingredients, testing, and labeling will be rewarded by additional purchases of their products by vegetarians and vegans. Non-vegetarians shouldn’t have to pay for a label is based on preference, not science.

Practical concerns are not the only reason to label or not label foods, however. Ethics definitely comes into play. Do people have a right to labels, such as labels that indicate a product contains ingredients derived from genetically modified organisms?

Chris MacDonald, Associate Professor in the Philosophy Department at Saint Mary’s University, has written about the ethics of labeling GMOs at The Food Ethics Blog: Should Companies Label Genetically Modified Foods? and in a peer-revied paper Corporate Decisions about Labelling Genetically Modified Foods in the Journal of Business Ethics. The full paper is well worth reading, as is the blog post, but I’ll summarize (and editorialize) a bit here.

Chris argues that corporations should only be compelled to label if the product meets any of the following criteria:

1. A law requiring it;
2. A serious threat to human health;
3. Recognition within the industry that labelling made sense as a shared way of doing business; or
4. A consumer right to the information.

Of course, a law is not warranted unless one of the three other criteria is met, but based on our standards of ethics, individuals and companies are ethically bound to follow the law.

As Chris his co-author Melissa Whellams describe, the Canadian government passed the Standard for Voluntary labelling and Advertising of Foods that are and are not Products of Genetic Engineering in April 2004 in response to consumer requests for labeling.

The voluntary nature of the Standard essentially puts the onus of labelling back onto food producers and manufacturers. Current legislation under the Canadian Food and Drugs Act requires that all foods, including GM products, be labeled where potential health and safety risks (e.g., allergens) have been identified, or where foods have undergone significant nutritional, or compositional changes. Since Health Canada has deemed GM foods to be safe, companies are not required to label products as genetically modified, but under the new Standard, companies may voluntarily label their foods as products of genetic engineering.

While the Standard was being drafted, some stakeholders argued that GMOs are a “like to know” issue and that a “Contains GMOs” type label would simply be confusing to consumers, possibly mistaken as a warning. Other stakeholders argued that GMOs are a “right to know” issue, which is where ethics comes in. Do consumers who want to know if products contain products of genetic engineering have rights that trump the rights of consumers who don’t care? What about farmers, distributors, grocers?

Chris and Melissa argue “that although unilateral action in this regard might be admirable, an agri- food company has no ethical obligation to label its GM foods, given the current social, legal, scientific, and economic context.” This includes no ethical obligation to the consumer.

How can this be, when arguments for labeling of GMOs are often rooted in rights, including the important idea of autonomy? Chris and Melissa explain autonomy ”as involving morally important kinds of control over one’s life.”

We might then say that a person has a right to X (some bit of information, in the case at hand) where X is a prerequisite for effective exercise of autonomy, i.e., for effective decision-making regarding matters about which it is morally good that I be able to make decisions.

For example, most of us agree that we have a right to know information about a diagnosis that would help us to make informed decisions about medical treatment options. This is in contrast to the way healthcare was done in decades past, where patients assumed the doctor knew best.

Despite the arguments of labeling advocates, there is no such agreement about right to know for non-health related information when it comes to food. For example, despite the importance of freedom of religion in the US and Canada, no one is arguing for mandatory labeling for non-health religious reasons. We expect people who want to keep Kosher to seek out Kosher foods themselves. If religious or spiritual food needs aren’t considered a right, why would any other “desire to know” be a right? Perhaps this will change in the future, as “desire to know” became “right to know” in health care, but until then, governments and corporations are under no ethical obligation to label.

In another post, Chris argues that in the case of Trans-fats, there does seem to be sufficient threat to human health to warrant mandatory labeling, in contrast to the lack of harm shown by genetically engineered crops. In another post, Chris addresses the idea that environmental concerns are enough to warrant labeling, arguing that the concerns aren’t science based and that labels wouldn’t actually decrease environmental harm anyway. Besides, we know that genetic engineering is less harmful to the environment than other agricultural practices that aren’t labeled.

*Chris is also the Coordinator of SMU’s M.A. Programme in Philosophy and a Nonresident Senior Fellow at Duke University’s Kenan Institute for Ethics. He serves on the Editorial Board of the Journal of Business Ethics and has been named one of the 100 Most Influential People in Business Ethics two years in a row by Ethisphere magazine.

MacDonald, C., & Whellams, M. (2007). Corporate Decisions about Labelling Genetically Modified Foods Journal of Business Ethics, 75 (2), 181-189 DOI: 10.1007/s10551-006-9245-8

A recent paper in PLoS concluded:

we reject the organic-conventional dichotomy and emphasize that, in order to optimize environmental sustainability, individual tactics must be evaluated for their environmental impact in the context of an integrated approach, and that policy decisions must be based on empirical data and objective risk-benefit analysis, not arbitrary classifications.

The paper was Choosing Organic Pesticides over Synthetic Pesticides May Not Effectively Mitigate Environmental Risk in Soybeans (full text) by Christine Bahlai et al. Long story short, the research showed that some synthetic pesticides were more environmentally benign than some organic pesticides, showing that it’s inaccurate to say that organic pesticides are better for the environment. Sometimes they are, and sometimes they are not.

The paper itself is really great, deserving of its own post (see Organic pesticides aren’t necessarily more sustainable than synthetic by Colby Vorland), but I’d like to talk about the organic-conventional divide. Normally I don’t approve of thoughts in scientific journal articles that aren’t immediately related to the research, too often authors stray into questionable territory. But Christine’s thoughts here are immediately related to her findings, and her results may indicate that big changes are necessary in the way we think about farming.

Separating out “organic” as defined by the USDA may be beneficial in the short term for farmers that have transitioned to certified organic methods who can then charge a premium, but in the long term, the divide is a detriment to farmers, consumers, and the environment. If we really care about farming in a more environmentally friendly fashion, we need an entirely new system.

We all want the same things*:

1. healthy food that is accessible to everyone regardless of location or income
2. farmers that can afford to farm and to pay fair wages to their employees
3. conservation of resources (especially soil!) and protection of ecosystems

We can get those things through three complimentary and often intertwined avenues:

1. demand
2. policy
3. research

Demand driven change seems to be moving along. We see lots about healthy food in popular media, increasing popularity of farmers’ markets, talk of adding cooking classes to public schools, and a push to make school lunches healthier, just to name a few. More could be done, but it is happening. We might have different ideas of what exactly constitutes healthy food, but I don’t think anyone’s arguing that more fruits and veggies is a bad idea. Ok, probably someone is, but let’s just agree to ignore them.

Policy driven change seems to be moving along as well. Michelle Obama is leading the charge with her Let’s Move program that touches many government programs. Kathleen Merrigan is pushing for help for local food systems, even while Tom Vilsack works mostly within the status quo. As demand for healthier food increases, senators and congressmen will be more likely to support policy changes at the federal level, especially if we somehow start electing people with backgrounds other than business. Yes, it would be nice if everything changed faster, but it’s going to take a while to change a system that’s been in place for 40+ years.

With both demand and policy, the important thing is to keep pushing for changes, and over time things will change. Optimistic, simplistic, yes, but true. The alternative is revolution, which would probably suit some people, but is more than a little extreme.

That leaves us with research. Research is what informs both demand and policy – or at least it should be. Research can provide us with information about which methods are preferable to others, such as which pesticides would have the least impact on farm and off farm ecosystems. Research, if properly applied, can help guide demand and policy to improve human and environmental health, among other things.

Here’s the problem, to borrow from the pesticide comparison paper: not enough “empirical data and objective risk-benefit analysis” and too much “arbitrary classification”. When demand and policy are based on arbitrary classifications like “natural is better” without research to back it up, we end up with demand and policy that are ineffective at best. We also end up with unnecessary divisions that cause efforts to be split, even though we all really want the same thing.

Let’s look at organics as defined by the USDA:

…an ecological production management system that promotes and enhances biodiversity, biological cycles and soil biological activity… The primary goal of organic agriculture is to optimize the health and productivity of interdependent communities of soil life, plants, animals and people. (USDA National Organic Standards Board definition, April 1995)

or agriculture that does

…respond to site-specific conditions by integrating cultural, biological, and mechanical practices that foster cycling of resources, promote ecological balance, and conserve biodiversity. (CFR Regulatory Text, 7 CFR Part 205, Subpart A — Definitions. § 205.2)

Sounds great, right? Except that by separating organic out from the rest of agriculture, we’re implying two things:

1. that non-organic-certified farmers don’t have these goals in mind
2. that they don’t have to.

It probably is true that some conventional** farmers don’t care about their soil, don’t conserve resources, etc. But those aren’t going to be very sucessful farmers if their soil is poor and they have to buy way more fertilizer than their neighbors, for example. If you lined up all of the farmers in the US according to their soil quality, I bet you’d find a bell curve. In each category from bad to great soil, you’d find some conventional and some organic farmers. According to the research, organic methods can be better for soils than conventional methods***, but there is so much variation in how farmers actually apply the methods that a one farm to one farm comparison really doesn’t tell the whole story.

There are many conventional farmers that apply integrated pest management, that use rotations to reduce crop-specific pests, that use legume rotations to help reduce the amount of nitrogen that needs to be applied, that use planting methods that decrease soil compaction, and so on. And there are organic farmers that just do the minimum to keep certified. And a whole range between.

Even if we assume that, on average, organically farmed soils are superior in organic matter, microbial activity, etc, we’re still not saying much. “Certified organic cropland and pasture accounted for about 0.6 percent of U.S. total farmland in 2008″, according to the USDA. When we make regulations for such a very small portion of farms, we’re not actually doing anything at all. Consumers should demand environmentally friendly methods from the other 99.4% of farms and policy should be made that includes all of those farms – and all of it needs to be based on sound research.

Ideally, demand and policy would be based on those methods that have been shown to work. If additional research confirmed that using mineral oil was more harmful to farm ecosystems than one or more synthetic pesticides, then one would hope to see demand and policy encourage use of the insect control strategy that had the least impact instead of arbitrarily choosing the “natural” method over a synthetic. Right now, there’s little if any research driving demand or policy. Instead, we have ideology.

Infighting over whether organic or not-organic is better, can feed the world, blah blah blah, isn’t actually helping anyone. The reality is that some methods used by some organic farmers are superb and some might not be. Some should be widely adopted, and some might even be more harmful their conventional counterparts (see the study I started this post with). Complicate that with the fact that not all farmers use the same methods and trying to decide whether organic is better becomes completely futile.

The research looks at individual methods, not arbitrary classifications – which is  really the only effective way to look at things. What we really need is a system that rewards farmers for environmentally friendly farming practices****. A farmer that uses legume rotations for nitrogen but still needs to use some synthetic N, P, and K  to maintain good soil nutrients should be rewarded or recognized somehow if he uses application methods that have been shown to reduce runoff. A farmer that uses integrated pest management to reduce chemical pesticide application that farmer should be recognized.

Perhaps there could be a scoring system where environmentally friendly methods are given a number value and farmers with higher values can seek a higher price from buyers that are interested in such things. I can easily imagine a box of corn flakes labeled “made from corn with E-values of 100 or higher!” Another option might be to revamp the whole subsidy system to focus on farming practices, where farmers could have a financial incentive to choose environmentally friendly practices, epecially in cases where a change from one method to another would have an initial capital cost (like new tilling equipment) or when the change might reduce yields or income.
.

Let’s put aside the petty squabbling and focus on the research that has the potential to guide 100% of farms toward more sustainable methods. Not enough research? Let’s demand better federal funding for relevant projects. Let’s demand policy that helps all farmers and all land, not just some.

So, farmers organic and conventional, advocates of various farming methods, consumers, economists, policy analysts, everyone… What sorts of incentive systems might work? Would you spend a little more for a product that you knew was made with ingredients that were sustainable grown? Would this whole crazy idea be just too expensive to implement? Would the cost be mitigated by the benefits?

Bahlai CA, Xue Y, McCreary CM, Schaafsma AW, & Hallett RH (2010). Choosing organic pesticides over synthetic pesticides may not effectively mitigate environmental risk in soybeans. PloS one, 5 (6) PMID: 20582315

.

* Yes, agribusiness wants something else – money. But I’m talking about people, not corporations here. And if you think organic agribusiness cares any less about money than other companies, you are simply naive.

** I really don’t like the word conventional, but it’s better than saying “non-organic-certified” every time I want to mention farmers that aren’t organic certified.

*** To name one recent study that shows healthier soil under organic methods:  Moeskops B, et al. 2010. Soil microbial communities and activities under intensive organic and conventional vegetable farming in West Java, Indonesia. Applied soil ecology 45(2)112-120. Within the confines of this particular study, organic soils are closer to local forest soils, but I bet there are farms which would show the opposite to be true. As with all studies, we have to be careful to remember that the findings apply within the conditions of the study and may or may not apply elsewhere.

****I’m not advocating a dissolution of the certified organic system. It’s not perfect, but it’s all we’ve got at the moment. I’m just saying we can have a system that actually works to improve all farms, and organic can keep doing whatever its adherents want.

My post Details on the Dirty Dozen on EWG’s Shopper’s Guide to Pesticides™ led me to dive into the 2008 USDA data to see just how contaminated (or not) our produce really is. There’s so much information that it’s a little difficult to work with, but with perseverance and the right software (JMP is the best!*), I was able to re-do the EWG analysis but with the newest available data.

Below you can find my results with a through explanation of what I’ve done and why. The results are posted without all the commentary at Produce Pesticide Rankings which has all of the results and Pesticide Produce Rankings Tables which has comparisons of my results to the EWG results. You can download the original USDA data yourself or check out the Latest PDP Findings of Interest to Consumers.

See Produce Pesticide Rankings Part 2 for the real scoop on which produce is the most and least safe.

Concentration and LOD

My first step was to compare the detected Concentration to the Limit of Detection. The LOD seems to have been ignored by EWG. The LOD is the smallest concentration of the chemical you are looking for that will give a positive signal with the method used. Every method/chemical combination has a different LOD that can be found by comparing a blank (no chemical) to smaller and smaller concentrations of the chemical. If the detected concentration is at or below the limit of detection, it does not indicate the chemical is present – which is not the same as saying the chemical is not present. The chemical could be there, but the amount is so small that it can not be detected with the method being used.

Let’s put some numbers on it. There were 1,780,365 tests conducted on 13,381 samples (including fruits, vegetables, fish, nuts, and water), with 33,426 of those tests having a concentration listed (1.88%). Of those, 273 were equal to the LOD leaving 33,153 positive concentrations (1.86%). Not a big difference, but still, it would be incorrect to include the concentrations that are below the LOD. In a lot of experiments a blank is subtracted from the results and I can’t think of a reason why that wouldn’t be appropriate here. So, I created a column of Concentration minus LOD and used these numbers for my calculations.

Units

Most of the tests have a unit of ppm (parts per million), but some are ppb (parts per billion) or ppt (parts per thousand). I converted ppb to ppm (ppb/1000=ppm) and ppt to ppm (ppt*1000=ppm) so all of the average residue values would be in the correct units.

It would be inappropriate to average values with different units. As illustrated by the Alaska Department of Environmental Conservation, ppm is drops per bathtub while ppb is drops per swimming pool!

Comparing the 2008 data with EWG

Because this investigation was inspired by EWG, let’s go through their Spreadsheet column by column to compare the top five values of each. You can find this information in Pesticide Produce Rankings Tables. The 3 types of water tested by USDA top most of the lists in the 2008 data, but since this discussion is on produce, they aren’t included here.

Percent of samples tested with detectable pesticides

This isn’t really a good metric because it doesn’t take into account which of the detected residues are above or below the EPA tolerance level and the EWG numbers don’t take the LOD into account (the numbers I report are all Concentration – LOD), but nonetheless here’s how they stack up.

• % of samples with 1 or more residues: 95.78 Peaches, 95.55 Celery, 95.24 Nectarines, 94.06 Strawberries, 92.75 Catfish.
• % of samples with 2 or more residues: 89.74 Celery, 88.66 Strawberries, 86.04 Peaches, 80.65 Nectarines, 72.22 Blueberries.
• EWG % of samples tested with detectable pesticides:  97.20 Plums, 96.20 Peaches, 95.10 Bell Peppers, 95.00 Celery, 93.60 Apples.
• EWG % of samples with two or more pesticides: 85.70 Peaches, 84.70 Celery, 82.30 Blueberries, 80.60 Bell Peppers, 74.40 Apples.

As you can see, the percentages don’t vary much from the collection of data used by EWG to the 2008 only data. Some of the foods tested in previous years weren’t tested in 2008 (apples, bell peppers).

A lot of the samples for each commodity have 1 residue, fewer have 2, fewer have 3, and so on. For some perspective, consider the percentage of all tests done on all samples for each commodity that had one or more residue.

• % of tests with 1 or more residues: 1.18 Nectarines, 0.92 Collard Greens, 0.90 Summer Squash, 0.83 Kale, 0.79 Almonds.

Average number of pesticides found on a single sample

This is a little more useful than the percent of samples with one or more residues, but not by much, since we’re still leaving out consideration of the EPA tolerance.

• Mean residues detected per sample: 5.15 Celery, 4.94 Strawberries, 3.61 Blueberries, 3.50 Peaches, 2.46 Spinach.
• EWG Average number of pesticides found on a single sample: 3.79 Celery, 3.08 Peaches, 3.00 Blueberries, 2.90 Strawberries, 2.75 Apples.

The USDA lets us know in their Latest PDP Findings of Interest to Consumers that the number of samples with pesticides and number of pesticides per sample doesn’t correlate to pesticides per serving size because the sample sizes were a lot more than a serving. “Sample size ranges from 16 ounces to 5 pounds depending on food tested. For example, for peaches and celery, the sample size is 5 pounds; for strawberries and blueberries is 3 pounds and 1 pound respectively.”

In regards to number of pesticides per sample, the USDA states: “There may be many more pesticides available for use by food producers, but 20 years of testing show that no food has ever been treated with all available pesticides.”

Average amount of pesticides found in ppm

This might be the worst metric of all because it averages pesticides that have very different toxicity levels. One ppm of one pesticide can be very different from one ppm of another pesticide! Still, here’s where we start to see some real differences!

• Mean ppm residue by commodity: 0.8 Potatoes, 0.61 Spinach, 0.37 Rice, 0.35 Nectarines, 0.33 Sweet Potatoes.
• EWG Average ppm of all pesticides found: 1.602 Potatoes, 1.373 Spinach, 1.200 Plums, 1.066 Peaches, 0.906 Red Raspberries.

The EWG shows average ppm of pesticides that are twice what I’ve got from the 2008 data! What’s happening here? One possibility is that EWG didn’t convert the ppt to ppm, but surely they’d notice the different units in the data, so it must be something else. We could have done the averages differently, but that’s unlikely too, it’s just averaging.

The only other thing I can think of is that there were high levels of residues in the past, high enough to skew the overall averages. If this is true, then we have something to celebrate – there have been great reductions in pesticide residues over the years!

Still, this brings up a question: why would the EWG tell people that produce has such high amounts of pesticide residues when produce today actually has much less? If the goal is to tell people what are the safest foods to buy for their families today, why include old data?

The USDA states specifically in their Latest PDP Findings of Interest to Consumers that there have been significant changes over the years, with reduced number of samples with pesticides and reduced ppm of pesticides. Specifically, there have been reductions in the most harmful pesticides as safer alternatives have been approved for use.

Maximum number of pesticides found on a single sample

Again, this metric does not take the EPA tolerances into consideration, and the results are about the same..

• Maximum residues detected per sample: 14 each Strawberries and Celery, 12 Blueberries, 11 Catfish, 10 each Spinach, Collard Greens, and Peaches.
• EWG Maximum number of pesticides found on a single sample: 13 each Blueberries, Strawberries, and Celery, 11 Bell Peppers, and 10 Kale.

Considering the EPA tolerance levels

Now that we have those comparisons out of the way, let’s look at the pesticide residues that the USDA finds to be of concern: Pesticide Produce Rankings Part 2.

.

*Thanks to my husband for explaining that it makes a lot more sense to keep the test data and the sample data in two separate tables that you join when needed based on the sample number. Having all the data in one JMP file is about 8mB which doesn’t work all that well even on a good computer.