In addition, the US Agriculture Department should create an advisory task force that could scientifically identify the extent that GMOs already unintentionally taint organic crops, on which crop-specific thresholds for acceptable GMO contamination levels could be established, OTA and other stakeholders added at the semi-annual NOSB meeting in Washington, DC, in April.
Together these suggestions could help advance the creation of a seed purity standard, which remains out of reach despite significant debate and input from two discussion documents, a report, a collection of prevention strategies to keep GMOs out and an expert panel on seed purity.
“We are constantly looking for ways to improve our ability to keep GMOs out of organic food and seed,” but it is a “tough” job considering how prolific GMOs are in some conventional crops, such as corn, soy and alfalfa, Gwendolyn Wyard, senior director of regulatory and technical affairs at OTA, told FoodNavigator-USA.
She explained that when it comes to identifying the most critical places in the supply chain for keeping GMOs out of organic food and seed, “the seed is an obvious important place because it is at the start of the supply chain. You want to start with clean seed. If you start with contaminated seed then you are going to have contamination down the line.”
OTA argues for tighter guidance on sourcing seeds & using non-organic seeds
OTA argues in written comments that one of the best ways NOSB can improve seed purity is “through strengthening the seed provisions in the regulation through the guidance process.”
Specifically, it suggests the National Organic Program tighten the use of non-organic seeds on organic farms, as these are the seeds that pose the most risk of GMO contamination.
“Organic producers and farmers are not allowed to use genetically modified seed,” and may only use non-organic (non-GMO) seed if organic versions are not commercially available in the necessary quality, quantity and form, Wyard said.
While OTA recognizes there are valid times when farmers and producers will need to use non-organic seed, it says in its written comments that the National Organic Program’s seed guidance from March 2013 does not go far enough to encourage farmers and handlers to try and find organic supply before resorting to non-organic seed.
Since the NOSB recommendations on which the guidance was based were made in 2005 and 2008, “the number of companies supplying organic seed has grown ten-fold and more educational sources and tools exist to support the sourcing and planting of organic seed,” which is why OTA believes NOP’s guidance “should be revised to more accurately reflect the current state of the organic seed industry, and it should include additional guidance specific to the use of ‘at-risk’ non-organic seed.”
Specifically, the trade group recommends NOP’s seed guidance reiterate that certified operators may only use non-GMO non-organic seed or planting stock and reiterate the existing prohibition on excluded methods. In addition, it says certified operators should be required to demonstrate to auditors the non-organic seed’s non-GMO status.
OTA says the guidance also should encourage growers to contact more than three sources for organic seed and the number of companies contacted should be “relative to the number of companies potentially supplying the organic equivalent variety.” In addition, the trade group says growers should keep proof of its search in its records.
NOP also should strengthen the current guidance, which does not require producers to establish goals for increasing organic seed usage, “to require certifiers to work with producers on gauging measurable and reasonable annual increases in organic seed usage,” OTA writes in the comments.
The seed guidance also should require certified buyers that purchase seed and planting stock for contractual growing be held accountable for determining if the variety is commercially available as organic, OTA says.
And finally, the trade group says NOP should include in the guidance explicit reference for certifiers, inspectors and producers to use the Organic Seed Finder database as a seed-sourcing tool.
Stakeholders ask for a task force to evaluate potential contamination thresholds
Parallel to strengthening the seed provisions in the regulation through guidance, USDA should appoint a seed purity advisory task force that can develop a testing framework for data collection to better understand the extent of GMO contamination in organic crops, OTA argues in its comments.
While the organic industry is constantly looking for ways to improve the purity of seeds, stakeholders acknowledge that the risk of some contamination is high given upwards of 90% of some key conventional crops are GMO.
“Given that we can no longer live in a world free of GMOs,” the organic industry needs to determine if there is an acceptable tolerance level or threshold for some contamination, Wyard said.
“In Europe they have a tolerance level, the Non-GMO Project has established a tolerance level, but in the organic regulations we don’t have a tolerance level. GMOs are just prohibited,” she added. “So, the seed purity discussion is trying to identify what is the feasibility for setting a seed purity standard and if we were to set a tolerance level or threshold, what would that look like?”
A major hurdle to answering this question is the lack of data in the public domain about the extent of GMO contamination of organic crops on which a threshold should be established.
“So, the first thing we need to do is set up a very well organized framework for collecting data,” which will include “testing protocols and methods uniformly across regions and crops and be done in a way that creates statistical data,” Wyard said.
The USDA-appointed seed purity advisory task force would take on the challenge of creating this framework and also have the expertise necessary to interpret the findings, OTA argues in materials prepared for the April meeting. It adds, “This, in turn, would inform a NOSB recommendation to NOP on appropriate crop-specific testing thresholds.”
This approach is far more effective than asking accreditors to test and gather data, OTA said, adding that accreditors use residue sampling to confirm compliance with regulations, not to collect statistically significant data sets.
Creating this task force would take several years, OTA acknowledges, but it and others see it as the best next step forward – a notion with which NOSB members indicated they agreed.
NOSB indicated at the meeting that it would push these two suggestions forward to USDA, but as an advisory board for the Secretary of Agriculture, it does not have the power to make them happen. Rather, USDA’s National Organic Program will have final say on the issues – likely after seeking additional public input.