Measure 92, GMO Labeling

On the ballot in Oregon this year is a measure that is of particular interest to me.  Not just because I’m a farmer, not just because I’m a mom, and not just because I’m a consumer who buys food here, but a mix of all of these things that make me who I am creates an interest in the GMO labeling issue.  Let me start by saying that I am against labeling here in Oregon.  And it’s not because Monsanto is paying me to say that, it’s not because I’m a GMO farmer, and please don’t comment on here saying exactly those things.  I’ve been called too many horrible things from people who have a different opinion than mine because of the public stand that I’ve taken on this issue and here is not the place to bring on useless insults.

I’m against labeling because it truly doesn’t make sense for our state.  The yes side claims that 64 other countries label their food, and their food prices didn’t rise because of it.  Well I have tried to find the study and I haven’t been able to, but I question what they looked at when they did this study.  First of all it was done of the “countries” where labeling has become law, but did they look at the impact it would have if just one state in that country would have tried to do it?  Did they take into account the cost of food to begin with?  In the US we have one of the cheapest and safest food supplies in the world, maybe other countries have more favorable margins that allow them to add a label and not cause the end result to be a higher food price for others.  I also would question how many of these countries have actually put these labeling laws into effect and actually monitor them?  I know for a fact that not all of them do.  I would also question how their labeling laws look in comparison to the one on the ballot, which to me makes no real sense at all.  Too many questions with the country argument, to me, it’s moot.

Then there is the argument that it includes all foods and the No side is lying when they say it doesn’t.  Well, we are saying that because, it doesn’t.  It doesn’t include animal products because they say that when animals eat the GMO’s it doesn’t become part of the animal (why then are they so scared that they are going to become part of us when we eat them?).  But then they include things that are made with sugar, a product that while grown in a GMO sugar beat, in the end has no DNA when added to food, so how could it still contain the GMO that was inserted into the DNA?  Same situation with soybean oil and GMO soybeans.  Even better is the pop that you buy at the grocery store that will have to be labeled, but then if you walk across the street to the 7-11 to buy it, it wouldn’t need a label…hmmm, yes this is getting confusing…I agree!

So what if you do want to know what is in your food?  Well as someone who does want to know, I understand, and I have the answer for you!  All you have to do is buy products that are already labeled through a national labeling system that we already have in place.  If you buy organic or non-GMO project verified, those are both guarantees that the product you’re buying doesn’t have GMO’s.  It is true that yes, these products cost more, because they have this label on them and people who are concerned for whatever reason about eating anything other than organic can pay the higher price for it.  For the rest of us, the rest of us who understand the safety of food that is conventionally grown, let us keep our lower cost of safe and reliable food.  Why would you want to increase our costs for a label that study after study has confirmed that GMOs are safe to consume?

My last reason is one that has just come about in the last couple of weeks, with the addition of the new commercial from the yes side.  We’ve all seen it, where the EPA guy is holding up blue corn and regular colored corn.  And those of us in the agriculture industry know exactly what he’s holding up, it’s corn that has been treated so that it can be planted and fend off any pests while it sits in the ground waiting to sprout.  So as a farmer I’m sitting there wondering where he is going with this, because blue seed has absolutely nothing to do with whether the seed is GMO or not!  Not to mention the fact that it’s seed, seed that is planted to then produce the food.  You don’t eat the seeds folks.  But then of course he starts to talk and confirms my fear, he thinks somehow that no one will ask the question, that we will just trust him, that those blue corn chips you’re eating, yup you guessed it…they are covered with 5 toxic chemicals…but wait they aren’t!! Like I said, seed treatments have nothing to do with GMO at all, they have nothing to do with the food you eat at all!! So if you’re making your decision on that commercial in any sort of way please don’t.  This is a gross use of media to spread fear about our food in a completely misleading way and it’s quite frankly infuriating to me as a farmer and insulting to me as an intelligent person. (By intelligent I am referring to the fact that I understand how food is grown…this is not rocket science here folks)

I think that it’s safe to say this campaign in Oregon isn’t just about Oregon.  You can see from who has contributed to both sides that this issue is of national concern.  And whether people here pay more for their food or not is really of no concern to those who are pushing the issue.  Those who want to use fear and blue seeds to scare you into making a decision that we will regret.  The end game for the yes folks is to get GMO technology banned and to take away tools that make modern day agriculture look like the villain. When really 98% of us are just family farmers who are growing safe food that we too feed to markets as big as world markets and as small as our own dinner tables with our own families.  So when you sit down to fill out your ballot take a moment to really think about what the costs might be.  Maybe you can afford higher food prices, and because of that maybe you do buy organic and maybe that is your way to continue to have GMO free food.  But maybe there is also room for the rest of us to have the freedom to buy inexpensive food that we too enjoy.  There is room for different markets here in Oregon, conventional farmers, organic farmers, local farmers, etc; and I think that we need to encourage that balance to continue to be a strong state in this great nation.

Below is my commercial that you may have seen, I hope that maybe watching it again will make you realize that I am sincere, I do care, and what I say in this short commercial and in this long blog post means a lot to me and my legacy of farming here in Oregon.

You can see other responses to this bill that add more information by clicking on any of the following links:
Oregon Green – Farmers Against Measure 92Kathy Hadley – This Farmers Take on Measure 92
NuttyGrass – GMO Labeling in Oregon (Past post on similar issue)

 

Author: Nuttygrass

I'm a nut and grass farmer, EMT, Firefighter, and world traveler. I love a good laugh and a great adventure!

13 thoughts on “Measure 92, GMO Labeling”

  1. I still think the increase in food prices if labeling is required is a scare tactic. I’ve never seen the Wheaties box cost more just because they’ve changed the sports star on the front. The real issue is the GE community doesn’t want the fearful average consumer not buying their food because of labeled ingredients, at the same time as they’re saying that GE foods are equivalent and as healthy as others. If we believed in people’s intelligence to decide for themselves and educate themselves then let’s level the playing field between organic, conventional and GE, and label all products.

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    1. I agree that marketing is a huge issue here with labeling Janet. However I disagree that a cost increase is just a scare tactic. The difference with labeling in the sense of measure 92 and the increase in cost isn’t just about ink on a piece of cardboard. It’s more about the infrastructure changes that would have to take place from the farmer, processors, and then finally to the packaging changes. The cost would increase on many levels and that price would be passed on to the consumers I’m afraid.

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  2. So as an environmental chemist I thought I would offer a quick correction on your point about animals and food.

    It’s not the DNA of GMO food that anyone is worried about. Our bodies are very very good a destroying foreign DNA. It is the metabolites that are synthesized by the plant through the expression of this DNA that may not be fit for human consumption. They may be carcinogenic (cause cancer) or mutagenic (cause mutations) or cytotoxic (kill cells), but since animals don’t really live long enough to develop cancer, and we don’t really care all the much if the animals do develop cancer, we don’t worry too much about what metabolites (chemicals that are biosynthesized by the plant) that we feed them. So basically your argument that GMO’s are safe for human consumption because we feed them to animals doesn’t really fly.

    However, on a broader point there is no reason to really suspect that GMO’s will be more harmful to humans than any other food source. That’s why we study the chemical profiles of food, and there is no reason to treat GMO food differently.

    The reasons that one might consider voting for GMO labeling are the secondary impacts of growing genetically modified food. (1) Increased organophosphate pollution, and (2) economics that favor large agricultural corporations over smaller farmers.

    (1) Organophosphates and other chemicals used to treat GMO crops are damaging to ecosystem sand they do get into our water and cause health problems.

    (2) Labeling GMO’s is a good way to support smaller famers over corporate agriculture. Large corporate agriculture has a pretty solid monopoly over farming in the United States and takes a pretty large cut from smaller farmers in order to provide them with seed. Labeling is one small step towards leveling this playing field in support of smaller farms.

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    1. Thank you for your comment Tucker! I wasn’t trying to say that GMOs are safe because animals consume them, sorry I was being sarcastic in my comment there on my blog. I understand what you are saying, and I agree that continuing to study GMOs and the effect that they have on humans is important. However I also feel very safe in the fact that there has never been a study done where they have shown to have adverse effects on humans, not one time. Hopefully that will continue, but continual studying is key here.

      As to your other points, GMOs have been shown to decrease the use of pesticides on crops. I know many farmers who spray a lot less because of the availability of GMO seeds that they plant already have the insecticide inside of them. Or they are able to use round-up to keep the field clean, instead of using spray after spray to keep weeds and pests down. While there are resistances coming along, which is to be expected because that is the natural progression of nature, there is also a lot of studying and research done on how to combat these to resistances and how to correctly utilize all tools available to the farmer to help with this issue.

      And as far as supporting smaller farmers with this bill, I think that is pretty far fetched considering that 98% of farms in the US are family owned and operated. While many of us are incorporated and we therefore fall under the “corporate farm” umbrella, we are still family operations and not big corporate farms that you think are out there controlling the food supply. I don’t see this measure as a way to level the playing field for smaller farmers at all. I see it as a way for big organic ag to gain more market share by pushing conventional family farmers out of the industry with costly new regulations in this state.

      Thanks for your comment!

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      1. I agree with you regarding GMO safety, there are actually a couple of studies that show GMO’s to have an adverse affect on humans (mostly out of France), but they are not credible and there are many more studies that show GMO’s to be safe. Furthermore, even if there were to be a credible study, which showed that a GMO crop was unsafe for human consumption, it would be relevant only to that crop not to GMO’s in general since each crop has a complete unique and independent metabolite profile.

        However, the issue of pesticides is not one of quantity… The fact that farmers are spraying with Roundup, even if it’s only once, is a problem! Roundup is a brand name for Glyphosate. Glyphosate is a herbicide that can only be used on GMO plants, because it would normally kill most plants. The chemical composition of Glyphosate if very similar to a nerve-agent/chemical weapon… Glyphosate is easily transported in the environment and into ground water/drinking water. There are multiple studies showing that Glyphosate is highly toxic to humans.

        Here is one from the Journal of Toxicology -http://www.ncbi.nlm.nih.gov/pubmed/19539684.

        So while GMO may reduce the total quantity to pesticides used, they significantly increase the use of Glyphosate (ie. Roundup).

        That being said, a labeling measure like 92 is not the best way to reduce organophosphate use, it would be much better if for the EPA to more tightly regulate the use of such chemicals. But I voted for measure 92, because I’m curious to see if Labeling in Oregon = A reduction GMOs (that are designed to be used with roundup) = a reduction in Glyphosate pollution = a reduction in Cancer rates.

        This of course is assuming that people will figure out which GMO foods actually increase Glyphosate pollution and only stop buying those crops, rather then stop buy GMO’s in general.

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    1. Hi Ally,
      Thanks for the link, I’ve already seen the report that you have shared. The reason that I didn’t link was because there are so many back and forths going on with websites and information. I will leave you with this study that claims that the cost will increase, a study done in Washington state. http://l.facebook.com/lsr.php?u=http%3A%2F%2Fwww.washacad.org%2Finitiatives%2FWSAS_i522_WHITEPAPER_100913.pdf&ext=1414599959&hash=AcnGU2CgzWTjgqgTLqGbVKLcRbexgPf7FdtR_6lKNuZ5Jw

      My main question on this blog wasn’t about the cost studies done for Oregon, it was about the comparison that they have done with other countries and their costs not going up, because their food supply already costs so much more than ours here in the US. Plus if they took into account the fact that we are a state and how a piece meal labeling scheme would economically hurt everyone involved. Here is another graphic that shows what I mean: http://coalitionforsafeaffordablefood.org/sites/default/files/cfsaf-gmo-labeling-final.png

      Thank you for your comment.

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  3. Lots of things to take issue with, with this article aside from your clear biases… However the thing that discredits you the most is your refuting the yes side claims because you can’t find study’s to back them up, yet of all your claims there are no studies referneced or mentioned to support them.

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    1. Nope, I didn’t use the lack of finding the study as a reason to refute the yes side, I just brought up a lot of questions that, if I had found the study possibly could have been answered. Questions that change the whole picture when you really look into the issue at hand. I didn’t add any links to my argument because most of my reasons were from personal experience. For instance I have traveled abroad and have seen the cost of food in other countries. As for the increase in the cost of food you can find plenty of links that back me up on the Votenoon92.com website. And finally the seed treatment reason, and deceptive use of that technology that has nothing to do with GMO, I know that because I’m a farmer and I’ve used seeds that are treated before. If you want to see tit for tat website throwing back and forth as far as whose study refutes whose, I’ll let you go to facebook for that. This is my personal blog, which is yes biased in the fact that I am asking people to Vote No on 92. Thanks for stopping in.

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  4. You are certainly entitled to your opinion, but unfortunately, the commercials on the ‘no’ side have their fair share of misleading claims as well.

    For example, is there currently mandatory labeling of restaurant food for anything? Or mandatory labeling of the ingredients in alcohol products, or mandatory labeling of the food eaten by the cows who produced the milk you drink or meat you eat? No, there isn’t, because those are the federal standards.

    And yet the ‘no’ campaign with a straight face claims that because Measure 92 complies with existing federal rules around not labeling each ingredient in alcohol, restaurant food, and feed consumed by meat meat/dairy on packages of meat and milk, its an unacceptable ‘exemption.’ To the contrary, its actually evidence of how reasonable Measure 92 is. The funny part is, if Measure 92 did have this kind of overreach into foods that don’t currently require federal ingredient labels, the cost claims you assert may actually be closer to being true.

    And the notion that because GMO beet sugar or soy oil is so processed that it no longer contains the exact gene sequence and therefore should not be identified as genetically engineered, ignores the fact that GMO seeds were planted to produce those processed products. Think of GMO labeling like already-mandatory Country of Origin labeling for meat and produce rather than a statement on nutrition and the basic concept makes more sense.

    But some claims the ‘no’ campaign is making are more than just spin, they are just wrong. For example, the claim you make in your commercial about Measure 92 conflicting with USDA organic and ‘non-GMO verified’ labels. Section 6(4) explicitly says that foods certified USDA organic, or that are certified GMO-free by a third party organization, are automatically considered to be compliant with Measure 92’s provisions. Where’s the conflict?

    As you know well, most Oregon farmers don’t grow GMO food products that would be subject to labeling under Measure 92. The issue at stake is primarily about processed foods, like whether the baby formula you buy, even if labeled ‘natural,’ has RoundUp Ready soy in it, for example, or whether the corn in your Doritos may be that new Enlist kind that allows them to spray 2,4-d on it closer to harvest. That’s why the biggest opponents of labeling are junk food companies and pesticide/GMO seed manufacturers.

    Because farmers are exempted from lawsuits under Measure 92, and because so few farmers in Oregon grow crops that would be subject to labeling under Measure 92, and because if if they did, its just a label and not a requirement to change what you grow, many farmers in Oregon actually support the measure and don’t see it in the ‘sky is falling’ way that the ‘no’ commercials make it out to be.

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    1. “Truth,”

      I believe that the reason why the NO campaign brings up the exemption of restaurant food is the perceived inconsistency of their campaign slogan, “Right to Know.” If my “right to know” is so important, then why is this standard not equally applied regardless of how I eat? For example, a frozen pizza bought in a supermarket would have to be labeled but one at a Pizza Hut does not. A soda from the cooler at a convenience store must be labeled but one out of the fountain machine does not. The right to know should be universal, not up to the discretion of the ballot measure writer. The proponents had the opportunity to draft a ballot measure that included these foods, but did not. I assume they made a political calculation that it would be easier to pass if these exemptions were made. Bringing this fact to light is not misleading voters by the NO side, but rather explaining what the measure does and does not do. You don’t get reliable and accurate information from THIS ballot measure. Also, directly to your question about, “mandatory labeling of the food eaten by the cows who produced the milk you drink or meat you eat.” Yes, there is a national standard, two in fact, that says you must label dairy, meat and eggs that have been produced by animals that eat GE feed. They are USDA Organic and the non-GMO project. Since BM 92 leaves those foods out, it is in direct contradiction to a national standard that we all use.

      Now, on to “GMO” sugar beet. Genetically engineering happens in a plants protein. There is no protein in the final sugar product. However, GE sugar would have a label that would suggest that there is “GMO” IN THE PRODUCT. That is a false claim. This is why that European labels list the ingredients and percentage of the amount of genetically engineered material in a product. This is another way that BM 92 differs from other labeling laws out there. Also, listing a production method on a food item does not give the consumer more information about nutritional value.

      Furthermore, there are many Oregon farmers that grow GE alfalfa and sugar beet. There are many more farmers who may want to use the technology but measures like this only serves to discourage research and development needed to benefit all farmers. I would submit to you that this measure hurts farmers that sell products such as jam or jellies at a farmers market. “No action may be brought against any farmer for any violation of any provision of this Act unless such farmer is also a retailer or manufacturer…” (Sec 6, sub 6) A farmer would be acting as a retailer or manufacturer at a farmers market and if they do not label their product and use GE sugar, for example.

      Let’s take a look at the YES campaign. Perhaps you have seen the misleading commercial about blue GMO corn seeds or the GMO soy in baby formula. Both completely misleading and shameful campaign tactics to scare people to vote yes. Conventional, GMO, and organic (yes, I said organic) use food coloring to differentiate treated seeds. The tactic of saying there is GMO soy in baby formula made to withstand pesticides is fear mongering. That is like saying a can of soda was tested and found to have GMO corn in it. Duh. But that is very different than suggest that mothers are feeding their babies “poison.” This sows to me that the YES campaign is getting desperate to get votes. Nothing is factual about their claims.

      Finally, there are 1738 studies from around the world that confirm GE cops are safe for human and animal consumption. This is the fastest growing technology ever adopted by farmers worldwide. None of the proponents’ claims of GMO’s can be backed up by science. We need all the tools in the agricultural tool belt (organic, conventional, GMO) if we are going to feed a growing population with a shrinking land base. These are the most regulated crops ever grown. These crops have the ability to put vitamin A into the diet of children in third worlds to prevent blindness. However, this “golden rice” is not available because of fear mongering by the anti-GMO crowd. What this measure really boils down to is an attempt by some in the organic industry to paint their competitors with a harmful brush. There is poison in baby formula; these foods are unsafe, blah, blah, blah. All you need to do is go into a grocery store and compare the price of organic products to non organic products. Notice anything? Prices are much higher. “Antis” are going after market share. It is not that difficult to see. This is nothing new in the buying and selling of goods worldwide, just the latest attempt. Vote NO on ballot measure 92.

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      1. “All”

        I can never tell if the anti-labeling side is anti-organic or truly committed to supporting ‘all’ agriculture. When push comes to shove, you often sound anti-organic. Whenever you start talking about organic industry conspiracy theories, it reveals your true colors. In reality, the markets for Oregon conventional farmers have been put at far more risk than organic farmers from GE crops (wheat, alfalfa, grass seed, specialty seed).

        However, you have revealed how truly elitist one of the ‘no’ arguments is: on the one hand you say that people should ‘just go buy organic’ if they want to avoid GMOs, while expressing concern for poor people. But in your words: ‘All you need to do is go into a grocery store and compare the price of organic products to non organic products….prices are much higher.’ So, when you tell people they should ‘just go buy organic’ if they want to know whether their food is GE or not, you are basically telling them they to pay more and suck it up. Meanwhile, in your defense of Doritos, you fail to mention that there are tons of products in our stores that are conventional and non-GE (a lot of them Oregon grown), and right now the only way to know for certain is if the non-GE product goes through an expensive certification process, which people have to pay more to ‘choose’ to access.

        On restaurants, lets be realistic, if the measure included them you’d be crowing about how much more the costs would be, not urging a ‘yes’ vote. At least be honest about that. Also, the benefit of Measure 92 WILL be felt at restaurants. For example, when you ask the pimply faced kid at Pizza Hut whether their tomato sauce has GE ingredients now, they’ll have no idea. Under Measure 92, they’ll be able to go look at the can of tomato sauce in the back room and tell you it is in fact GE. Some restaurants, probably not Pizza Hut, may actually source some different ingredients (maybe creating new economic opportunities for Oregon farmers) as they know they’ll get questions from customers about some of their foods and will now actually be able to answer them, even if they aren’t displayed on the menu as you seem to prefer.

        Separately, nothing in Measure 92 stops companies from doing ingredient specific labeling, or to talk about what the traits do (ie ‘higher in Vitamin A!’ ‘RoundUp Ready!’). Its sets a standard requirement for labeling, but doesn’t prohibit companies from adding more information.

        Regarding your sugar beet example, the label says ‘produced with genetic engineering’ so it would not be a false claim, because its about the production, not just what traces are left in the final product.

        Regarding farmers markets, there are non-GE sugars available for jams and jellies. The measure goes into effect in January, 2016 so that provides a lot time to sell existing inventory and identify alternative sweeteners, or slap on a different label. Is this really the biggest potential economic impact you can come up with for Oregon farmers? The ‘no’ ads claim farmers will have to pay ‘millions.’ If you’ve got a million dollar sugar budget for your jams and jellies, you’ve likely moved well beyond ‘mom and pop’ farmers market status.

        Regarding your desire for a requirement in Measure 92 indicating the diet of animals raised dairy, eggs, meat etc, you are correct that organic and non-GMO have a higher standard on this. But that’s not the same as being ‘in conflict with’ or ‘in contradiction’ with those standards. The only way it could be if is if it nullified them, which it doesn’t. What a flimsy claim.

        And you know alfalfa hay isn’t fed to humans right? Measure 92 has nothing to do with livestock feed. Now, if you had your way and it did, it would impact Oregon alfalfa growers. But it doesn’t, so that’s a terrible example, because now you are arguing that the measure should be more onerous and far-reaching than it actually is.

        The doublespeak from you guys is incredible!

        Look, GE crops have been available for decades in the US without labeling or significant restrictions, but companies by and large aren’t producing crops more typical to Oregon agriculture (ie hazelnuts, berries, etc). They are focused on major commodities like corn, soy, canola, cotton, and herbicide/insecticide traits specifically because that’s where the big money is. Labeling will not change this dynamic. For Oregon commodities, like wheat, its our trading partners, not Oregon consumers that are primarily impacting what is grown here.

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  5. Thank you for your advocacy for this measure, a task that I am sure has been both a lesson in strength and sheer will-power in the face of those you say attack you in the most tactless ways possible. The misinformation from the “Yes on 92” side is absolutely based on scare tactics that cause the less informed voters to be afraid, something I consider to be completely unethical. They’re capitalizing on the fact that we, as a society, are more removed from the farming industries in our country than ever before. And due to that fact, they can easily mislead the average consumer into thinking farmers and Monsanto are out for blood. Because food is so readily available at the store whenever we want, people have forgotten what it actually means to get it there to begin with.

    And, more chilling, I don’t think the average voter even understands what a GMO is or what this bill is really about. I have read comments on many forums (Oregon Live, TV news stories, etc) where people state that they are outraged by unhealthy additives in food products, and they seem to think this bill will mean these things will no longer be present in food. Sorry, but preservatives will still be there, and they are NOT the GMOs that are in conversation right now.

    I have heard many replies from proponents to the Measure 92 issue, including that if farmers want to make sure their needs are covered and protected in this kind of bill, they should get to writing one they like. Almost a “covering one’s you-know-what” type of proactive measure. But why would that make sense, when today’s conventional farmers find there’s no actual threat to the public with the safe technology they have been using? What use is there to proactively petition a bill of this sort when there’s no reason to justify it? I tried to research whether the Yes on 92 folks actually consulted with a farmer using modern, conventional means when petitioning for the bill, and I can find no such reference to anything. If someone begs to differ and has a source that confirms this point, I would be interested in knowing.

    There is a certain sub-sect of the population hell-bent on punishing Monsanto for what they claim as “crimes against food safety,” and they don’t care who they crush in the process. It’s disturbing to say the least.

    Also, they (proponents of this bill) abhor the use of genetic engineering in food, yet would proclaim the wonderful use of stem cell technology that saves lives from previously incurable diseases. Is that not a form of genetic engineering? What if GMOs had the ability to save lives from starvation in developing nations? Or, shall we continue to allow the poorest nations of the world to falter and fall behind the rest of the world in agricultural technology because of our moral obligation to “protect” them from unsubstantiated claims that GMOs lead to cancer and other ills?

    Everyone should have the chance to have their voice heard, but non-farmers or those who have no understanding of conventional agriculture should not be able to completely change the agricultural landscape as we know it today.

    The passage of this bill invites much broader brush-strokes to this agenda that would mean many unnecessary challenges and regulations for our farmers. It could mean that many farmers decide it’s no longer worth it and sell out, losing family legacies in the process. And if people don’t like Monsanto, it is most likely they or corporate farms of that sort that will pick up the slack, as they have the deep pockets and technology. Which would “they” rather have? A proverbial “making of one’s own bed,” if you will.

    At the end of the day, these efforts (especially the vast expenditures) could have been very well spent by a massive educational campaign to inform consumers about what choices they already have. Or, how about an incentive to bring more farmers to the conversation about what food labeling means rather than strong-arm legislation? We don’t need another law that will add another layer of complexity to what is already a challenging business.

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