From: Harvey Newstrom (mail@HarveyNewstrom.com)
Date: Thu Jun 28 2001 - 21:54:39 MDT
Robert J. Bradbury wrote,
> On Thu, 28 Jun 2001, Harvey Newstrom wrote:
>
> > If I mixed up a batch of rice in a vat, added beta-carotene,
> > and then sold it as "rice", I would be arrested. The
> ingredients list would
> > be lacking one of my ingredients.
>
> Actually, unless the labeling requirements actually require
> you to list beta-carotene, you would not get arrested.
Food labeling laws require beta-carotene to be counted as vitamin A in the
nutritional labeling as well as being listed in the list of ingredients if
it is added from a separate source. I am not just guessing what I think the
law might be. I actually researched this when I wrote my nutrition
reference book on food nutrient values.
> If its a substance "naturally" found in foods you can add it.
> This is the entire basis of the "nutraceutical" market.
> I suspect there is some "minimum" level (1%???) below which
> you do not have to list it.
Wrong. Please research laws before extrapolating what the "nutraceutical"
market seems to be doing or what you "suspect" might be the law.
> Just looking at a Yogurt container, it looks like you have to
> list vitamins and minerals if they are above 4% of the RDA.
The cut-off point is 2%, and you still have to note that it is present in
amounts less than 2%.
> Beta-carotene may have a "funny" position since it is converted
> to Vitamin A as needed by the body (i.e. you can't "O.D." on it).
This has nothing to do with labeling laws. You seem to be just guessing
what laws you think would make sense.
> > I don't see why GMO rice that is
> > chemically the same as rice+beta carotene should be exempt from proper
> > labeling.
>
> Because GMO "rice" will cross pollinate with "rice" it is still
> from a scientific
> viewpoint "rice", just as I believe most, if not all of the
> natural strains
> of rice (e.g. Indian rice, Japanese rice, wild rice) will
> cross-pollinate even
> though they may have quite different chemical makeups (perhaps below a 5%
> of mass/volume level).
This has nothing to do with my point. Rice does not contain beta-carotene.
Golden rice does. Not labeling the difference totally confuses and
eliminates the benefit of golden rice. It was specifically created to
contain beta-carotene to fight blindness in poor countries. It would be
ludicrous to say it should be labeled no differently than white rice so
nobody could tell the difference.
> If I create a product mixing GMO Golden rice with polar-bear liver,
> do I have to label the GMO rice as "Golden" even though the amount
> of beta carotene it is contributing to the mix may be < 1% of the
> amount being contributed by the polar-bear liver?
Labeling laws require that all ingredients be listed. There is no magical
percentage below which you don't have to report an ingredient. That's why
you still can find sodium benzoate listed at levels less than one tenth of
one percent.
> No, this is a misperception. What is added is a protein that allows the
> plant to metabolize (and therefore tolerate) round-up. There may be
> residual amounts of round-up on the plant as a result of this (but
> these will diminish with washing, cooking, etc.)
OK, I stand corrected. If roundup corn does not actually add roundup, then
it should not be listed in the ingredients. I did make a bad assumption on
this point. I still think golden rice should note its beta-carotene
content. If Roundup corn is merely more resistant to roundup, but adds no
chemical to the plant, then it cannot be listed differently as an
ingredient, because it is chemically the same.
> What will be "missing"
> is the probably more toxic other herbicides that are used by farmers
> in lieu of round-up. I believe round-up has been shown to be "generally
> accepted as safe" in that it doesn't interact with human metabolism.
> There is a debate about this back in the archives someplace where people
> explore the round-up issue in more detail.
I am not questioning the safety of Roundup. I also believe it is safer than
other herbicides.
> The toxicity of substances varies significantly with dose. By far
> and away the greatest carcinogens consumed by humans are alcohol
> and tobacco.
Labeling laws do not address toxicity. They require all ingredients to be
listed, whether they are good or bad ingredients, it just has to be
accurate. Also note that alcohol and tobacco are grandfathered in as
pre-existing products and do not have to follow the same laws that all
modern products have to follow. This was a key issue in the tobacco trials
recently, because if it was found that tobacco was modified from its
original form, it would have constituted a new product which was no longer
grandfathered in.
> Perhaps from your point morally, but not under the law. The law has
> an some "abundance level" requirements for food labeling. This
> contrasts somewhat with EPA "laws" for chemical exposure for
> workers and the public (an entirely different venue from food labeling).
> I believe there, things must be labeled (and start getting restricted)
> even at very very low exposure levels.
Again, you are wrong. Food labels must list all ingredients. There is no
level at which ingredients can be left out. Residue are not usually
considered ingredients, because they are not intentionally put into food.
They are contaminants, and are allowed at lower levels. Anything
deliberately added to food must be listed in the list of ingredients, no
matter how small the amount is.
> > (And again, I will note that this is my personal preference. I don't
trust
> > the public to be able to handle full disclosure. However, I am not
ready to
> > rescind the public's right to know either.)
Since I researched a massive tome on nutrients, I am probably more
interested in food contents than most people. I am frustrated that
corporate lawyers would choose to restrict the labeling of food contents
because it would confuse the public. This seems to be dumbing down
information to the lowest common denominator. Just at a gut level, it seems
to be anti-consumer, anti-market, anti-knowledge and anti-choice. It might
be the best public policy, but it goes against my libertarian views for
anarchy, self-determination, and fully informed self governance. But that's
just my opinion. Obviously, most people disagree.
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