Consensus on GM Foods Should be Based on Systematic Reviews

Background:

Genetically modified (GM) food safety is a controversial subject. Some claim that all GM foods currently on the market have been shown to be as safe as their conventional counterparts. Systematic reviews of the scientific evidence and opinions of health experts, however, overwhelmingly indicate GM foods currently on the market cannot presently be considered as safe as their conventional counterparts. This is either due to a lack of evidence of safety, or because of the weight of the scientific evidence from animal studies that indicates at least some GM foods currently on the market may be unsafe compared to their conventional counterparts.

Purpose:

To compare the consensus observed in our systematic reviews to the consensus on climate change. To discuss why the claim of a worldwide consensus in the medical and public health communities that GM foods currently on the market are as safe or healthy as their conventional counterparts should never have been made in the absence of systematic reviews on the subject. To present evidence that a precautionary approach should be taken with GM foods.

Results:

Health professionals generally agree with climatologists on climate change.

Farmers and agriculture experts in the United States appear far less likely to agree with climatologists on climate change when compared to health experts.

Environmental groups often agree with climatologists on climate change and health professionals on GM food safety.

Proponents of GM foods have largely engaged in various types of science denial. These include: reliance on fake experts, cherry-picked supportive facts, belief in conspiracy theories, impossible expectations of what research can deliver and attacks on science and scientists.

Large sums of money have been spent by GM food and seed companies to promote the inaccurate claim of a consensus that GM foods are as safe as their conventional counterparts. This appears to have perpetuated the idea of such a consensus despite overwhelming evidence to the contrary.

A precautionary approach should be taken with GM foods.

Conclusion:

Systematic reviews indicate an overwhelming consensus among health groups and individual health professionals on GM foods. The consensus among these health experts is that GM foods currently on the market cannot presently be considered as safe as their conventional counterparts. This is either due to lack of evidence of safety, or because of a consensus in the scientific literature that at least some GM foods currently on the market may be unsafe compared to their conventional counterparts. Despite the overwhelming consensus, various types of science denial have been used by agrochemical companies to deny this consensus. The evidence also indicates that those who deny the GM food consensus, such as agricultural experts and corn belt farmers who have largely adopted GM crops, are also likely to deny the consensus on climate change. In comparison, health professionals and environmental groups are more likely to accept the consensus on GM foods and climate change.

Therefore, we call upon the health community, who are the experts on health, to continue to inform the public of the potential harms from GM foods and to choose non-GMO and organic foods to avoid those potential harms. We urge the governments of the world to place a moratorium on all GM foods until each GM food has been demonstrated as safe in independent long-term and multigenerational chronic toxicity/carcinogenicity studies using both rodents and non-rodents comparable to humans. We also call upon all who have published papers claiming that there is a consensus that all GM foods on the market are safe to provide corrections, or formally retract their papers if necessary. Our systematic reviews indicate this claim is not supported by the consensus, nor does it appear this claim was ever supported by the consensus.

A precautionary approach should be taken especially since there is now a consensus among health groups and individual health professionals that GM foods currently on the market cannot be considered as safe as their conventional counterparts at this present time, and a consensus in the scientific literature that some GM foods currently on the market may be unsafe compared to their conventional counterparts.

Disclaimer: Neither GMO Free Florida, our fiscal sponsor GMO Free USA, nor any person acting on behalf of GMO Free Florida or GMO Free USA are responsible for the use, actions or decisions taken as a result of the information in this report. The views expressed in this report are those of the unpaid volunteers who authored this report and are not necessarily the views of GMO Free Florida or GMO Free USA. The authors declare no conflicts of interest.

Systematic reviews vs. Illusory Truth Effect

There are several research papers using a systematic approach to determine the consensus of individual climate scientists on climate change, and the consensus of study results on climate change (Cook 2016, Anderegg 2010). Until now, no systematic approach has been taken to determine the consensus among health experts and the scientific studies on GM soy GTS 40-3-2 safety. Yet, in the absence of a systematic approach claims have been made of a consensus among health professionals and the scientific literature that all GM foods currently on the market are as safe as their conventional counterparts (Gostin 2016, Leshner 2015). The American Enterprise Institute, a global warming skeptic organization, has even claimed that the consensus on GM food safety is even stronger than the consensus on climate change based on a single survey of some members of a single group, many of which were not even climate or health experts (Entine 2015, Union of Concerned Scientists 2013).

The results of our systematic reviews clearly indicate a consensus of questioning the safety of GM food among health groups and individual health professionals. Only a very small number of health groups and health professionals, identified in our systematic reviews, believe GM foods on the market are as safe as their conventional counterparts (GMO Free Florida 2022, GMO Free Florida 2022a) Also, most studies using the GM soy GTS 40-3-2, the most tested GM food, indicate adverse effects or biomarkers indicative of adverse effects in the animals consuming it (GMO Free Florida 2022b). Therefore, the claim of a consensus that GM foods are as safe as their conventional counterparts appears to be based on the illusory truth effect.

The illusory truth effect occurs when a false claim is believed to be true after continuous repetition of the claim (Fazio 2015). The claim of a consensus that GM foods are safe stems from only a small number of health groups and a single survey, while ignoring the totality of the evidence that indicates the vast majority of health groups and surveys of health professionals suggest there is not enough evidence to conclude GM foods are safe (GMO Free Florida 2022, GMO Free Florida 2022a). The continuous reference to these small numbers of health groups and a single survey increases the degree of belief in the false claim that these groups represent the consensus.

Consensus on GMO compared to consensus on climate change

Some have used a 2014 survey of only some American Association for the Advancement of Science members (Funk 2015) to argue that refusing to accept that GM food is safe is equivalent to denying climate change caused by human activity (Lynas 2015, Moench 2015). Blame for this has been placed on environmental groups such as Greenpeace, who do not deny climate change but question the safety of GM foods (Lynas 2015). However, others have argued that a consensus exists on human caused climate change, but does not exist for GM food safety (Silverman 2017). There are several papers using a systematic approach to determine the consensus of individual climate scientists on climate change and the consensus of study results on climate change (Cook 2016, Anderegg 2010). Different approaches have been taken to determine the consensus on climate, such as position statements of climate science groups, relevant climate scientist surveys, careful full literature investigations of relevant climate studies and abstract ratings of such studies. As far as we are aware, no systematic approach has been undertaken to determine the consensus of health experts and studies on GM food GTS 40-3-2 safety until now. We chose to systematically review position statements and surveys of the medical and public health community as well as full literature investigations of relevant studies, as abstract ratings are considered suboptimal (Jankó 2020, Antoniou 2017).

Despite a lack of systematic reviews to determine the consensus on GM foods, claims have been made that there is a consensus among health professionals and the scientific literature that all GM foods currently on the market are as safe as their conventional counterparts (Gostin 2016, Leshner 2015). The results of our systematic reviews, however, indicate that there is a consensus among health groups and individual health professionals that GM foods cannot currently be considered as safe as their conventional counterparts (GMO Free Florida 2022, GMO Free Florida 2022a).

Despite these results some may, however, try to argue that health professionals might be more inclined to disagree with an established consensus in general. That could explain why the consensus among health groups and individual health professionals is that GM foods currently on the market cannot currently be considered as safe as their conventional counterparts. To determine if health professionals are more likely to disagree with an established consensus we set out to see if health groups and health professionals disagree with the consensus on climate change. To do this we reviewed climate change related surveys of individual health professionals. We also reviewed climate change related position statements, reports and other documents from health groups that also had statements questioning the safety of GM foods.

Statements for several medical and public health groups mentioned in our systematic review (GMO Free Florida 2022) appear to demonstrate a consensus that climate change is happening and human activity is contributing to it (Crowley 2016, Australian Medical Association 2015, Bundesärztekammer Undated, California Medical Association 2020, Physicians for Social Responsibility Undated, American Public Health Association 2015, Public Health Association of Australia 2014, Vermont Public Health Association Undated, American Nursing Association 2008a, American Medical Student Association 2001, Canadian Association of Physicians for the Environment Undated, British Medical Association 2021). Surveys of individual health professionals also reveal a consensus that humans contribute to climate change equally or greater than nature (Safaty 2014, Safaty 2015a, Safaty 2015b, Polivka 2012, Laan 2014, Safaty 2016, Thiel 2017). The opinion of medical and public health groups and individual health professionals surveyed is consistent with the opinion of climatologists, the experts on climate (Prokopy 2015b, Cook 2016, Silverman 2017).

On the other hand, surveys of agricultural extension specialists and advisors in the United States (U.S.) show a large division over whether or not humans contribute to climate change equally or greater than nature (Prokopy 2015a, Prokopy 2015b, Useful to Usable 2016). Also, surveys of farmers in the Corn Belt of the U.S., who have overwhelmingly adopted GM crops, have consistently indicated that they largely do not believe that humans contribute to climate change equally or greater than nature (Arbuckle 2013, Arbuckle 2015, Gramig 2013, Prokopy 2015b).

Interestingly, some evidence suggests that farmers who trust environmental groups are also more likely to believe climate change is occurring and is largely caused by human activity compared to those who trust agricultural groups (Arbuckle 2015). Therefore, we also set out to review the positions of environmental groups on climate change such as Greenpeace, Friends of the Earth, Food and Water Watch, National Research Defense Council, Center for Food Safety and Union of Concerned Scientists. (Greenpeace International Undated, Friends of the Earth Undated, Food & Water Watch Undated a, National Research Defense Council 2020, Center for Food Safety 2015, Union of Concerned Scientists Undated). The results demonstrate that these environmental groups all have positions on climate change consistent with the majority of climatologists. We chose these groups because they also have positions questioning the long-term safety of GM foods (Greenpeace International Undated, Friends of the Earth Undated, Food & Water Watch Undated a, National Research Defense Council 2020, Center for Food Safety 2015, Union of Concerned Scientists Undated). These positions are consistent with the statements from the majority of health groups (GMO Free Florida 2022) and individual health professionals surveyed (GMO Free Florida 2022b).

Based on these results, attempts to argue that health professionals generally disagree with an established consensus are not supported by the evidence. Also, the claim that refusing to accept that GM food is safe is equivalent to denying climate change caused by human activity is not consistent with the evidence. Instead, the evidence indicates that refusing to accept that there is not enough evidence to conclude that GM food is safe can be considered equivalent to denying anthropogenic climate change.

Science Denial

Despite a clear consensus on climate change, those with conflicts of interest often engage in science denial. Science denial, with regards to climate change, generally leads science deniers to conclude: 1. Climate change is not happening, 2. Humans are not a cause of climate change, or 3. Climate change is not a serious problem. The groups that engage in this science denial tend to be think-tanks and the fossil fuel industry (Cook 2020). Some of these think-tanks include: Competitive Enterprise Institute, the Cato Institute, the Heartland Institute, the Heritage Foundation and American Enterprise Institute (Lawrence 2019, Union of Concerned Scientists 2013). Interestingly, all of these think-tanks listed are also science deniers when it comes to the clear consensus that there is not enough evidence to conclude GM foods on the market are as safe as their conventional counterparts (Conko 2011, Fristoe 2018, Stier 2015, Bakst 2016, Entine 2015).

The characteristics of chemicals denial, a type of science denial, (Karlsson 2019) also appear to exist for the GM foods issue as well. This is not surprising since many of the GM seed companies are also chemical companies and often manufacture the herbicides applied to many GM crops (ETC group 2008). Science denialists on climate change, GM foods and chemicals all share the following techniques of denial which include: fake experts, impossible expectations, cherry picking, attacks on science and scientists and conspiracy theories (Cook 2020, Karlsson 2019).

Science denial – Cherry-picking

Using cherry-picked supportive facts, such as only including groups with statements that support their claim, and neglect of refuting information, such as statements from groups not supporting their claim, is a type of science denial (Cook 2020, Karlsson 2019). The large majority of health groups and surveys of health professionals identified in our systematic review have been overlooked by the popular press (GMO Free Florida 2022, GMO Free Florida 2022a). This is likely due to the large amount of money spent by the manufacturers and users of GM seeds and foods to repeat the inaccurate claim of a consensus that GM foods on the market are as safe as their conventional counterparts (e.g. Ballotopedia 2012, Ballotopedia 2013). This perpetuates this false belief as such claims are based only on statements from a select few groups and a single survey (GMO Free Florida 2022, GMO Free Florida 2022a).

In fact, many news articles had statements that were nearly identical to the statements by industry funded websites such as GMOAnswers and ISAAA (GMOAnswers Undated, ISAAA 2009). These articles claim there is near unanimity among experts, but list only a few handpicked groups which they claim believe GM foods were safe (e.g. Brody 2018, Saletan 2015, Burnett 2015, Ferdman 2015). The same type of cherry-picking can be seen with relevant animal feeding studies using GTS 40-3-2 (GMO Free Florida 2022b). Our review, however, found the overwhelming majority of such studies reported adverse effects or biomarkers indicative of adverse effects. Yet, most of these studies are ignored and the few studies, with severe limitations, reporting no adverse effects are cherry-picked as evidence of safety (GMO Free Florida 2022b).

Science Denial- Conspiracy Theories   

Belief in conspiracy theories is another science denial characteristic used by the fossil-fuel industry, chemical companies and GM food companies as well as the think-tanks and scientists affiliated with them (Cook 2020, Karlsson 2019). According to the Heartland Institute, a global warming skeptic organization, the Russian government has manipulated the American people into believing climate change is real and fossil fuels are a major cause of it, and to question the safety of GM foods. (Driessen 2018). However, there is a consensus among the experts and the scientific literature that climate change is real and fossil fuels are a major cause of it, and the safety of GM foods is questionable (Cook 2016, Anderegg 2010, GMO Free Florida 2022, GMO Free Florida 2022a, GMO Free Florida 2022b). It is also often the same American groups funding those who promote climate change denial, fossil fuels, GM foods and related pesticides in the United States (Malkan 2017).

In another example, a DuPont executive stated criticism of chlorofluorocarbons (CFCs) was “orchestrated by the ministry of disinformation of the K.G.B.” (Karlsson 2019). These types of claims were made by the chemical industry despite a scientific consensus of an impending environmental crisis if CFCs were not restricted (Hornsey 2018). Similar statements have been made with regards to GM foods. For example, the Vice President of Scientific Communications for the The American Council on Science and Health, a pro-industry advocacy group which has received funding from GM seed companies including DuPont (Mother Jones 2013, American Council on Science and Health 1985), called people who want GM foods labeled, “Puppets for Putin” (Berezow 2017). Even though the overwhelming majority of health groups and health professionals around the world support the mandatory labeling of GM ingredients in food (GMO Free Florida 2022, GMO Free Florida 2022a).

In one article the authors reported that more GMO related news articles were found on Russian news outlets, with most having an anti-GMO sentiment (Dorius 2018). The authors suggest this may be a conspiracy by the Russian government to indoctrinate Americans (Dorius 2018). Our review indicates that most medium and long-term animal health research on the safety of GM soy GTS 40-3-2 were conducted in Europe or Asia (GMO Free Florida 2021b). In fact, none of this research was conducted in the United States. A more plausible explanation, therefore, is that Russian and other Eurasian news outlets are likely more aware of the research indicating potential adverse effects from GM foods than their American counterparts. However, the results of the Dorius et al. article also indicated that the American news outlets HuffingtonPost and CNN ran news articles with mostly an anti-GM sentiment. Their results also indicated that Fox News ran mostly articles with a mixed or neutral sentiment, but still ran more anti-GM sentiment articles than pro-GM articles. Of all the news outlets in the Dorius et al. study, only Breitbart ran a nearly equal amount of pro and anti-GM sentiment articles, but still ran mostly mixed or neutral sentiment articles.

Our systematic reviews indicated that most health groups and health professionals either questioned the safety of GM foods currently on the market or believed they were unsafe (GMO Free Florida 2022, GMO Free Florida 2022a). This coincides with our other systematic review which found most animal health studies using the commonly consumed GM food GTS 40-3-2 indicated potential adverse effects according to the researchers in those studies (GMO Free Florida 2022b). This suggests that both the Eurasian and American media outlets examined by Dorius et al. largely reflect the opinions of the health community and the scientific evidence which are more anti or mixed/neutral sentiment than pro.

Although the results of our systematic review did not include statements by health groups or surveys of individual health practitioners located in Russia, we did find one paper where the authors interviewed several physicians in Russia. The physicians interviewed generally agreed that there is not enough evidence to conclude that GM foods currently on the market are safe for long-term consumption. They also believed that consumers should be made aware of which foods contain genetically modified ingredients (Karaeva 2011). In a 2021 survey of Russian medical students, not included in our systematic review, the majority surveyed believed GM foods currently on the market were definitely unsafe or likely unsafe and the rest gave a neutral response (Shchekotikhin 2021). This is consistent with the statements from health groups from around the world, surveys of individual health practitioners from around the world and the animal feeding studies using GTS 40-3-2 (GMO Free Florida 2022, GMO Free Florida 2022a, GMO Free Florida 2022b).

Science denial – Attacks on Science and Scientists

Attacks on science are another form of science denial (Cook 2020, Karlsson 2019). Such attacks have been made against climate scientists by the fossil-fuel industry (Hudson 2020). Pesticide companies, which make GM seeds as well, have also used this type of science denial against those who find problems with their pesticides (Charles 2017, Levin 2018). GM seed companies, and those affiliated with these companies, have also engaged in attacks on scientists that have published results that are unfavorable to GM crops or food and made attempts to suppress such research before it was ever published (Lotter 2009, Glenna 2015, Seralini 2014, Eubanks 2015). In many ways this is similar to attacks on climate scientists by the fossil fuel industry (Hudson 2020) and think-tanks affiliated with the fossil fuel industry (Lawrence 2019). According to environmental groups such as Greenpeace and Union of Concerned Scientists these attacks have largely stopped urgent action against climate change (Lawrence 2019, Union of Concerned Scientists 2013).

There are some glaring differences between climate change research and GM crop and food research, however, since any scientist can study the climate without needing permission from the fossil fuel industry. In the United States, however, scientists were required to get permission from the GM seed companies to study these crops and foods (Gurian-Sherman 2011). GM seed companies were able to control which scientists had access to research materials and some scientists stated that they were “blacklisted” by GM seed companies from conducting any further research on GM crops. One government scientist stated about a variety of GM corn, “We discovered a non-target effect of Bt pollen on a non-target [insect]. [Insects] fed the pollen experienced nearly 100% mortality. The industry partner suppressed the research and prohibited us from publicizing the results”(Glenna 2015). Instances like this prompted 26 public sector scientists to write a letter to the EPA in 2009 complaining about not being able to study GM crops and foods (Waltz 2009).

While Monsanto, the maker of GM soy GTS 40-3-2, had granted a select few universities certain permissions to study “agronomic” aspects of GM crops, it was not until 2010, when GTS 40-3-2 had been in the food supply for almost 15 years, that the Agricultural Research Service (ARS), an agency within the US Department of Agriculture, was finally given the freedom to study Monsanto’s commercial seeds without asking for permission on each project (Waltz 2010). This research, however, was again limited to “agronomic” aspects, and research such as feeding studies with rodents required special permission (Gurian-Sherman 2011). This may explain why in our review of relevant animal feeding studies using GTS-40-3-2 or an unnamed glyphosate tolerant soy, from 1993-2014, only 1 was conducted by U.S. researchers (GMO Free Florida 2022b).

Even if researchers were able to get special permission to conduct feeding studies in the U.S., such studies would still be rare due to lack of funding. For example, between 1992 and 2002 the USDA allocated $1.8 billion for biotechnology research, yet only about 1%, or $18 million, of this went to risk-related research (Lotter 2009). If such research were to report adverse effects, it is possible the GM seed companies would prohibit it from being published anyway (Glenna 2015). Similarly in the European Union, member states spent 356 million euros on new genomic techniques over 5 years, yet only 1.6% of that was spent on detection methods, risk assessment and monitoring (Members of the European Parliament Undated). On the other hand, in the U.S. $2.4 billion in Federal funding for climate change research, technology, international assistance, and adaptation was distributed in 1993 alone, with about half of that money going to science to better understand climate change (United States Government Accountability Office 2005).

Another major difference between climate research and GM crop and food research is who benefits financially. As fossil fuel extraction tends to be expensive, this limits who can profit from fossil fuels. Therefore, it is mainly scientists who work for, or are funded by, fossil fuel companies who will attack climate scientists for finding inconvenient evidence that fossil fuels contribute to climate change. On the other hand, genetic modification can be done in laboratories at most universities. In 1980 in the United States, the Bayh–Dole Act allowed public funded research to be patented at universities (Council on Governmental Regulations 2021). During that same time Diamond v. Chakrabarty allowed genetically modified organisms to be patented (H2O Case Admin 2013). Many universities and university scientists can, therefore, financially benefit from genetically modifying organisms or developing new ways to genetically modify organisms.

Universities, university-based startups and individual researchers at universities have the potential to make millions (Oxford University Innovation 2015) or even billions of dollars from their university-based GM research (Mullin Undated). Hundreds of millions of dollars in GM seed or food company funding also goes to land grant agricultural research, university buildings and departments and private grants for agriculture and plant scientists (Food and Water Watch 2012). GM seed company representatives also often hold positions on university boards (Food and Water Watch 2012). In this way many agriculture and plant scientists as well as genetic engineers have a significant financial motivation to deny the health consensus on GM foods, attack scientists finding inconvenient evidence of harm from a GM food or crop (Lotter 2009, Seralini 2014) and call for less regulations on GM foods and crops which can threaten public health. On the other hand, most scientists not involved with the fossil fuel industry have little, if any, financial motivation to deny the evidence for climate change.

Science Denial – Reliance on Fake Experts

Those claiming that GM foods currently on the market are as safe or healthy as their conventional counterparts have used types of science denial such as reliance on fake experts (Karlsson 2019). This includes referencing groups that are not experts in health as being part of their claimed consensus on the health safety of GM foods. For example, on GMOAnswers, a website funded by companies that make GM seeds, they list 23 documents by groups which they claim represents the consensus (GMOAnswers Undated 2). Yet, more than 80% of the documents listed by GMOAnswers are by groups or authors affiliated with the GM seed companies that fund GMOAnswers. Of the 23 groups listed only 4 are non-regulatory groups specializing in human health (GMOAnswers Undated 2). Of those 4 there is a group that protested against the use of the statement made by GMOAnswers saying it is, “untruthful” and gives, “a false impression of registered dietitians and the Academy” (Academy of Nutrition and Dietetics 2012). The reports for another 2 of the 4 health groups listed by GMOAnswers include authors who have a conflict of interest (Krimsky 2017, Food Safety Department World Health Organization 2005).

For the remaining groups which are not medical or public health groups, a variety of conflicts of interest exist for most of them. There are statements which include authors who are involved with companies or organizations that have GM seed producers, who fund GMOAnswers, as clients: American Association for the Advancement of Science, Nina Federoff (Malkan 2019), Society of Toxicology, Michael Bolger works for Exponent (Exponent Undated, Hardell 2007).

There are statements by groups who are sponsored by GM seed producers who fund GMOAnswers: American Phytopathological Society (American Phytopathological Society 2016), Society of Toxicology: “Monsanto Award” given out at their annual meeting (Society of Toxicology 2002) and the “Syngenta Fellowship Award” (Society of Toxicology Undated). Council for Agricultural Science and Technology (Council for Agricultural Science and Technology Undated). There are statements by authors who have collaborated with GM seed producers who fund GMOAnswers. American Society for Microbiology: David Pramer (Klein 1962), Federation of Animal Science Societies (Federation of Animal Science Societies Undated, Beermann Undated), French academy of Sciences: Ronald Douce (Picciocchi 2003), Marcel Kuntz (Kuntz 1986).

There are statements by groups who are funded by GM seed producers who fund GMOAnswers. American Society of Plant Biologists: Dennis Robert Hoagland Award funded by the Monsanto Agricultural Products Company (American Society of Plant Biologists 2021), U.S. National Academy of Sciences (Krimsky 2019). There are statements by authors who work for GM seed producers who fund GMOAnswers. Society of Toxicology: Ian Kimber (Hollingworth 2003). Union of German Academics of Sciences and Humanities: Ivo Feußner (Justia Undated a), Alfred Pühler (Justia Undated b), Heinz Saedler (Justia Undated c), Uwe Sonnewald (Justia Undated d).

There are statements by authors who work for groups which are funded by GM seed producers who fund GMOAnswers. Society of Toxicology: Steve L. Taylor, FARRP (Taylor Undated), International Council for Science: Gabrielle J. Persley, International Service for the Acquisition of Agri-biotech Applications (ISAAA) (Zoominfo 2017, International Service for the Acquisition of Agri-biotech Applications Undated), U.S. National Academy of Sciences: Peter H. Raven, Missouri Botanical Garden (Missouri Botanical Garden 2012), FDA: Robert E. Brackett, Grocery Manufacturers Association (Food and Drug Administration 2017, Grocery Manufacturers Association Undated), Society of Toxicology: Kendall B. Wallace, ILSI (ILSI 2014, International Life Sciences Institute 2016).

There are statements by groups who have GM seed producers, who fund GMOAnswers, as affiliate members. International Seed Foundation (International Seed Foundation Undated),

Council for Agricultural Science and Technology (Council for Agricultural Science and Technology Undated). There are statements by groups who have members of their board of directors who work for GM seed producers which fund GMOAnswers. Society for In Vitro Biology (Society for In Vitro Biology 2004), International Society of African Scientists (International Society of African Scientists 2000, AIChE 2021, Technically Media Inc. 2021, Thanni Holding Corporation Undated, ESA Historical Records Committee 2016).

There is also a statement by groups involved in events sponsored by GM seed producers who fund GMOAnswers. Accademia Nazionale delle Scienze, Detta Dei XL, Associazione Nazionale Dei Biotecnologi Italiani, Associazione Ricercatori Nutrizione Alimenti, Federazione Italiana Scienze della vita, Società Italiana di Genetica Agraria, Società Italiana di Fisiologia Vegetale (University of Bologna Faculty of Agriculture Dept. 2003).

Another example is a website that claims, “More than 280 scientific and technical institutions support the safety of GM crops” (Norero 2017). This is an expanded list originally created by Chiliebio which is funded by GM seed companies (Sanchez 2017). The bulk of the groups on this list come from a claim that 101 science academies and 27 scientific unions signed on to a 2003 document by the International Council for Science (ICSU). However, the references provided for this claim make no mention of these groups signing on to this document, only stating that they are members or associates of ICSU. We, therefore, consider this claim unsubstantiated. Even if this claim were true, as we previously mentioned, the ICSU report was written by Gabrielle J. Persley who is also a board member for ISAAA (Zoominfo 2017) which is funded by GM seed companies. It should also be noted that some links for groups were broken, were not archived in Internet Archive and could not be found with a Google search making them unsubstantiated as well.

Besides unsubstantiated claims, inaccurate claims were also made. For example, it is stated that the Pontifical Academy of Sciences support a claim that GM foods are safe, yet Bishop Marcelo Sanchez Sorondo, the academy’s chancellor, said this is not a statement of the Pontifical Academy of Sciences (Glatz 2010). Norero 2017 also lists the European Commission, which is not a scientific organization, yet the reference used specifically states, “The views expressed in this publication are the sole responsibility of the authors and do not necessarily reflect the views of the European Commission.” This reference also contains statements which question the safety of GM foods, such as, “Currently, there is little known about predictability of adverse effects following market release of GM foods” (European Commission 2010)

The Royal Society of Medicine is listed, but the reference is to an article in the Journal of the Royal Society of Medicine and not the position of the Royal Society of Medicine. In the same journal there is a response from a medical researcher which points out numerous errors in this article and states, “’GM crops consumed… with no reported ill effects’ – therefore they are safe. This statement is illogical and the conclusion is not valid. There is no assay and there is no epidemiology. If any GM food product did cause harm it would be impossible to pick up within the constant background of disease, particularly since in the USA, the biggest consumer, there are no labelling requirements” (Schubert 2008). It does not appear that the Royal Society of Medicine has a position on GM foods (Food Evolution Undated).

Norero 2017 lists the British Medical Association (BMA), but the BMA reference used instead questions the long term safety of GE foods and states “Many unanswered questions remain, particularly with regard to the potential long-term impact of GM foods on human health and on the environment. There is a lack of evidence-based research with regard to medium and long-term effects on health and the environment” (Jarman 2004). The American Cancer Society, the Royal Society of Canada, and International Union of Nutritional Sciences are also listed, but none of the references provided for these groups state that GM foods are safe (GMO Free Florida 2022, Royal Society of Canada 2001).

All of the groups with conflicts of interest listed on the GMOAnswers website are also listed on Norero 2017, along with several other groups with conflicts of interest. For example: AfricaBio, Ms. Kelebohile Lekoape (AfricaBio Undated), Spanish Bioindustry Association (ASEBIO Undated), Asociación Nacional de Obtentores Vegetales (ANOVE Undated), International Life Sciences Institute (ILSI 2015), Perubiotech, member of ISAAA (Perubiotech Undated), Crop Science Society of America (Crop Science Society of America Undated), American Council on Science and Health (Mother Jones 2013, American Council on Science and Health 1985), Commonwealth Scientific and Industrial Research Organisation (Public Interest Investigations 2009), Agbioworld, Greg Concko of Competitive Enterprise Institute (Eilperin 2013), Nutrition Foundation of Italy, president and author, Rodolfo Paoletti is also president of the International Atherosclerosis Society which is sponsored by Bayer (International Atherosclerosis Society 1999).

As with the GMOAnswers website, the large majority of the groups listed for Norero 2017 were not medical or public health groups. Of the groups with substantiated statements, only 10 were non-regulatory health groups that indicated GM foods are safe. At least 90% of the statements by these 10 groups (1. American Medical Association, 2. Associação Brasileira de Nutrologia, 3. National Academy of Medicine, 4.Società Italiana di Fisiologia, 5. World Health Organization, 6.Associazione Ricercatori Nutrizione Alimenti, 7. International Union of Food Science and Technology, 8. Sociedad Argentina de Nutrición, 9. Canadian Cancer Society, 10. Nutrition Foundation of Italy) include a conflict of interest. These groups were included in our systematic review (GMO Free Florida 2022). Our systematic review, however, indicates that the vast majority of medical and public health groups questioned the safety of GM foods. This supports the idea that those claiming there is a consensus that GM foods are safe are largely relying on fake experts and the few they list who are actual experts are mostly those with conflicts of interest.

Unlike with climate change, where there is ample evidence of a consensus among experts, researchers often manufacture fictitious claims about a GM food safety consensus to try to manipulate the beliefs of consumers and have been somewhat successful at doing so (Kerr 2018, Kobayashi 2021). Now that there is a clear consensus among health experts about GM food safety (GMO Free Florida 2022, GMO Free Florida 2022a) and a clear consensus in the scientific literature about GTS 40-3-2 safety (GMO Free Florida 2022b) it is not ethical to continue to make fictitious claims to manipulate consumers beliefs about the safety of GM foods. Instead researchers should inform consumers about the actual consensus among health experts on GM food safety.

Experts vs, Non-experts Review Conclusions and Lead Author’s Background

Another reliance on fake experts is using literature reviews not conducted by health experts as evidence of a consensus on the safety of GM foods as it relates to health. For example, this is also used on the GMOAnswers website (GMOAnswers Undated 2). We examined review articles to determine if different opinions were correlated with the background of the lead author. As previously stated in Report 3, Sanchez et al. and Nicolia et al. are some of the most cited literature reviews for claiming a consensus on GM food safety (GMO Free Florida 2022b). For Sanchez 2015 and 2017 the lead author of this review is Miguel Sanchez who is employed by Chilebio which is funded by companies that develop GM crops (Sanchez 2017). The other author, Wayne Parrot, is also affiliated with the groups International Life Sciences Institute and CropLife International which are directly involved with companies that make GM crops (International Life Sciences Institute 2016, CropLife International Undated).

Evidence suggests conflicts of interest are often associated with outcomes favorable to the interests of GM crop companies (Guillemaud 2016). A survey also indicated that scientists that received some or all funding from GM crop companies had a positive attitude to GM crops compared to those not involved with GM crop companies (Kvakkestad 2007). This is also reflected in the published peer reviewed journal articles where a review found research funded by private corporations was 6 times more likely to have a positive stance on GM crops (Stevens 2021). This may explain why these authors dismissed evidence suggesting adverse effects using GTS 40-3-2 even though studies suggesting adverse effects represented most of the relevant animal health studies using the most analyzed event (GMO Free Florida 2022b). Other authors with a conflict of interest such as former Monsanto employee Alison Van Eenennaam (Van Eenennaam 2014), and Pamela Ronald, who is a paid speaker for Bayer (Industry Documents Library 2014), have also conducted reviews with outcomes favorable to GM seed and agrochemical companies (Van Eenennaam 2014a, Ronald 2011).

Although Nicolia et al. believe there is a need for more studies on GM food, it is unclear why these authors disregarded the large majority of relevant studies using GTS 40-3-2 which report adverse effects or biomarkers indicative of adverse effects (GMO Free Florida 2022b). One possibility, however, may be a professional conflict of interest. The authors involved in this review are themselves genetic engineers specializing in plants. One of the authors, Fabio Veronesi, is former president of the European Association of Research on Plant Breeding (Eucarpia). He is also the vice president of the Italian Society of Agricultural Genetics (Società Italiana di Genetica Agraria) or SIGA (International Journalism Festival Undated). Eucarpia’s partners include GM seed companies such as Bayer, Pioneer and Syngenta (Eucarpia Undated). SIGA is also referenced on Monsanto’s website (Monsanto Italia Undated) and has also been involved in supporting events sponsored by Monsanto (Fresh Plaza 2012).

Another author is Alberto Manzo who is also a member of SIGA (Italian Society of Agricultural Genetics Undated). Daniele Rosellini, is another author of the Nicolia et al. review, and is also involved with Eucarpia (Eucarpia Undated 2) and also a member of SIGA (Italian Society of Agricultural Genetics Undated 2). He has also worked in the laboratory of Wayne Parrot (Parrotlab 2018). In 2009 Rosellini wrote an article which echoes the Nicolia et al. review results, before the review was conducted, suggesting possible confirmation bias. In the article he writes via translation, “the scientific literature is largely in agreement on harmlessness for human and animal health” (Rosellini 2009). Yet, our review of Nicolia et al. clearly indicates most of the scientific literature for GTS 40-3-2, one of the most used GM foods, is not in agreement on harmlessness for animal health (GMO Free Florida 2022b). The lead author, Nicolia, has a Ph.D. in Plant Biotechnology. This by itself may not be a conflict of interest, but it would not qualify one as a health expert. However, if a plant biotechnologist publishes a negative review of GM crops this could hurt their chances of working for a biotech company or even advancing at a university which receives funding from biotech companies (Lotter 2009).

In another review, the lead author Chelsea Snell was a Ph.D. student in plant science at the time of the review. Snell later went on to work for the biotech company Syngenta that makes GM seeds (Linked In). Had Snell published a negative review of GM crops it is unlikely she would have been employed by such a company. In fact, publishing a positive review of GM crops may increase the chances of an author being employed by a biotech company in the future (Lotter 2009). Snell et al. concluded, ”a 90-day feeding study performed in rodents, according to the OECD Test Guideline, is generally considered sufficient in order to evaluate the health effects of GM feed”.

On the other hand, a review by Dona et al. concluded, “The results of most studies with GM foods indicate that they may cause some common toxic effects such as hepatic, pancreatic, renal, or reproductive effects and may alter the hematological, biochemical, and immunologic parameters. However, many years of research with animals and clinical trials are required for this assessment.” In this case the lead author is a Ph.D. in the Department of Forensic Medicine and Toxicology at the University of Athens Medical School (Dona 2009).

In a review by Tsatsakis et al. it was stated that toxicological tests that are only using one mammal and only lasting 90 days are insufficient. They believed toxicology studies should be extended for the full life span of the test organism and more than one mammal should be used (Tsatsakis 2017). The lead author in this review has a D.Sc. in Toxicology and is a professor in the Department of Toxicology and Forensics at the School of Medicine, University of Crete. Many other reviews from various countries with lead authors having a food science or health background disagree with Snell et al. and support long-term safety testing (Gomez-Camponovo 2016, Ajami 2016, Gomez 2015, Zdziarski 2014, Taylor 2014, Ergin 2013, Girija 2013, Lisowska 2013). This lends support to the idea that plant scientists and those involved with GM crop companies may have different opinions than those in health science (Bray 2017).

We did, however, identify at least 1 other review in favor of GM foods in which the lead author was a medical student at the time (Key 2008). Although, it should be noted that the 2 other authors involved in that review were both involved in the genetic engineering of plants for product development (Drake 2002). This review was also criticized by a medical researcher arguing that it contained several errors (Schubert 2008).

It should also be noted that as plant scientists or genetic engineers learn more about the risks of GM foods and crops they may change their opinions. For example, as Belinda Martineau, the co-developer of Calgene’s Flavr Savr™ tomato, learned more during the development of this GM food, she became wary of the uncertainties involved (Biotech Salon Undated). In another example, Caius Rommens, the developer of several GM potatoes currently on the market, has called for the withdrawal of the GM foods he has developed after learning more about the risks of those GM foods (Rommens 2018, Frisch 2019). This may indicate that new information such as the majority of studies reporting harm from GTS 40-3-2 (GMO Free Florida 2022b) or the consensus in the medical and public health community on the lack of safety for GM foods (GMO Free Florida 2022, GMO Free Florida 2022a) may lead plant scientists and genetic engineers to change their opinion on the safety of GM foods.

Our search of review papers was not exhaustive, however, and therefore a more thorough search is needed to determine if either author affiliation with industry or the scientific field of the lead author correlates with the conclusions of the review.

Science Denial – Impossible Expectations: Sound Science (SCAMs) vs. Precautionary Principle

Another characteristic of science denial, for both climate change and GM foods, is impossible expectations of what research can deliver (Cook 2020, Karlsson 2019). Deniers of the consensus on climate change by climate experts, the consensus on GM food safety by health experts and the consensus on other issues label themselves as “skeptics” and call the weight of the scientific evidence on these issues “junk science” (Weart 2011, Jacques 2008, Entine 2013). They instead invoke a concept they refer to as “sound science” or “solid science”, adopted by the tobacco industry and used to question the evidence linking secondhand smoke to cancer (Ong 2001, Rudén 2008, Mooney 2004). Sound science applies the concept that a product should be considered safe until proven otherwise (Levidow 2000, Rudén 2008). For example, Phil Angell, Monsanto’s director of corporate communications at the time, expressed that the companies “should not have to vouchsafe the safety of biotech food” (Pollan 1998). This concept of not having to provide evidence for safety, but instead claiming that proof of harm is necessary before regulatory action, has been referred to in the scientific literature as “Scientific Certainty Argumentation Methods”, or “SCAMs” (Freudenburg 2008).

Based on the available evidence indicating potential health and other risks for GM foods and crops, many instead have called for the application of the precautionary principle. The precautionary principle mainly states that those claiming that a product is safe, especially in the absence of direct health benefit, are making an extraordinary claim. Such an extraordinary claim would require extraordinary evidence regarding the absence of harm for GM crops and food, especially when there is already evidence of adverse effects in peer reviewed studies (Taleb 2014, Hilbeck 2015, Gómez 2015, Nodari 2009, Ergin 2011, Lisowska 2010). For example, experts in complex systems had called for the precautionary principle to be used for the coronavirus CoV-2 (Norman 2020). Had this precautionary approach been used it may have saved hundreds, or even thousands, of lives (Taleb 2020). These same experts have called for the precautionary principle to be used for climate change and GM foods and crops (Taleb 2014, Bar-Yam Undated, Norman 2015).

This same type of situation occurred with artificial trans fat. In 1957, researchers including Fred Kummerow, presented evidence of harm from artificial trans fat in the journal Science (Johnston 1957). Kummerow continued his research on trans fats into the 1970’s (e.g. Yeh 1974, Jackson 1977). Yet in 1976 the FDA considered artificial trans fats, “generally recognized as safe for human consumption” (Belluz 2015). It was not until 2015, almost 40 years later, and after Kummerow sued the FDA, that the FDA determined artificial trans fats are not “generally recognized as safe”. At that time, FDA’s Acting Commissioner Stephen Ostroff said, “This action is expected to reduce coronary heart disease and prevent thousands of fatal heart attacks every year” (FDA 2015). Had the FDA used a precautionary approach, and placed a moratorium on artificial trans fats based on the animal evidence from the 1950’s-70’s, thousands of lives could have been saved by this action by their own admission.

The FDA has also been criticized in recent years for a number of regulatory mistakes such as failing to properly regulate opioids making the FDA partially responsible for the opioid crisis in the United States (Kolodny 2020). Other criticism includes 32% of novel therapeutics approved by the FDA from 2001 through 2010 having a postmarket safety event (Downing 2017). The FDA has also been criticized for a failure on food chemical safety that leaves consumers at risk of chronic diseases as the FDA did not properly consider the cumulative effect requirement for these products (Neltner 2020).

While the public expects the regulatory agencies, such as the EPA, FDA, etc., to take action against climate change or harmful products such as artificial trans fats, this is often not the case as regulatory agencies can be captured (Climate Zone Undated, Hobbs 2020). Regulatory capture is when regulators create policies in favor of businesses instead of public health or public interest, and this often occurs when there is a “revolving door” of employees that previously worked for a business being regulated that are then appointed to regulatory positions, or vice versa (Climate Zone Undated, Hobbs 2020). Sometimes large portions of these regulations are written by the business, trade groups or lobbyists for the business, and in this way the businesses self-regulate (Climate Zone Undated).

A variety of employees or associates of GM seed companies have gone on to work in regulatory positions or vice versa. For example, between 1989 and 1994 Henry I. Miller was serving as the first director of FDA’s Office of Biotechnology (Competitive Enterprise Institute Undated). Henry I. Miller is an Adjunct Fellow at the Competitive Enterprise Institute (Competitive Enterprise Institute Undated) which is a climate change skeptic organization ( Union of Concerned Scientists 2013). Miller also had an article retracted by Forbes magazine after it was discovered the article had been largely ghostwritten by an employee of the GM seed company Monsanto (Ruskin 2017). Between 1991 and 1994 Michael R. Taylor was the Deputy Commissioner for Policy at the FDA. Taylor then went to work at Monsanto, and then returned to the FDA as Deputy Commissioner for Foods and is currently Senior Advisor to the FDA Commissioner (OpenSecrets Undated). This situation is not unique to the FDA, however, as other regulatory agencies responsible for GM foods, such as the European Food Safety Authority (EFSA), have had a “revolving door” problem when it comes to GM foods. Like the FDA, EFSA has been criticized for not even meeting certain basic scientific standards when it comes to evaluating GM foods, perhaps because of such conflicts of interest (Chvátalová 2019).

In 1992 the FDA established their policy on GM foods which created a voluntary consultation process where companies can inform the FDA if they’ve conducted feeding trials. If feeding studies had been done, they were most often 28 to 90 day laboratory studies on rodents which were biochemically assessed, and conducted or paid for by the company that made the GM seeds (De Vendômois 2010). This caused even Belinda Martineau the co-developer of the first GM food approved by the FDA, Calgene’s Flavr Savr™ tomato, to write, “FDA had not completed evaluation of Calgene’s—or any other developer’s—safety-related data prior to publishing its policy for “regulating” GE foods, how could that policy be based on science?”(Martineau 2017).

In the case of GM foods and crops, the U.S. government has political motives to poorly regulate GM foods. According to the former biotechnology coordinator for FDA’s Center for Food Safety and Applied Nutrition, James Maryanski, “Basically, the government had taken a decision that it would not create new laws….Yes, it was a political decision. It was a very broad decision that didn’t apply to just foods. It applied to all products of biotechnology” (Ruskin Undated). The political decisions of the U.S. government with regards to GM foods and organisms are related to their transitioning to a bioeconomy (Ruskin Undated, Martin 2017, White House 2012, White House 2019). A bioeconomy is an economic system that relies heavily on GM foods and crops (White House 2012, White House 2019).

The U.S., and other countries that have created a system that relies heavily on GM foods and crops, therefore, attempt to apply political and economic pressure against countries that reject GM foods or crops. For example, when the European Commission applied a moratorium on GM crops and foods as well as restricted imports of GM foods, action was taken against them through the World Trade Organization (WTO) by the United States (World Trade Organization Undated). In another example, the U.S. applied pressure to Serbia to force them to accept GM foods and crops or else not be allowed in the WTO (USDA Foreign Agricultural Service 2015). In this way, political and economic pressures are placed on countries who want to accept the consensus among health groups, individual health professionals and the scientific literature that GM foods currently on the market cannot be considered as safe as their conventional counterparts and put in place a moratorium on such foods or crops.

While the public might expect that GM foods would have been thoroughly tested in long-term feeding studies before being allowed on the market, this was not the case and the FDA still has no such requirement (De Vendômois 2010). Despite this, the FDA claims, “Years of research in the U.S. and around the world shows GMO foods are just as safe to eat as non-GMO foods. And any long-term health effects from GMO foods are no different than non-GMO foods” (U.S. Food and Drug Administration Undated). This claim conflicts with the results of our review where 100% of the medium and long-term studies, of 6 months feeding duration or longer, suggest adverse effects or biomarkers indicative of adverse effects from the GM soy GTS 40-3-2 diet, and 80% of such studies where the glyphosate tolerant GM soy was not specified (GMO Free Florida 2022b).

The FDA does not supply any references for their claim, but provides 3 references in a pdf titled, GMOs And Your Health. In this pdf they reference the FDA website where the only mention of long-term effects is in regards to the 2016 National Academies of Sciences, Engineering, and Medicine (NASEM) report. The second reference in the GMOs And Your Health pdf is also the NASEM report. As we mentioned in our previous report, the NASEM report relied primarily on secondary sources in their section dedicated to long-term studies (GMO Free Florida 2022). Even when primary literature was mentioned the studies were mostly of a shorter duration than what the NASEM report itself considers adequate for chronic toxicity studies (National Academies of Sciences 2016).

We identified many medium or long-term studies, of a longer duration than most used in the NASEM report, reporting adverse effects or biomarkers indicative of adverse effects. These studies would have been available to the authors, but are missing from the section dedicated to long-term studies in the NASEM report (GMO Free Florida 2022, GMO Free Florida 2022c). Since the NASEM report does not mention the vast majority of studies we reviewed, it would appear that the NASEM conclusions are unreliable with regards to long-term studies. It should also be mentioned that some of the authors of the NASEM report had conflicts of interest (Krimsky 2017), and the NASEM report conclusions on GM food safety disagree with the majority of medical and public health groups, the majority of surveys of individual health professionals, and the majority of relevant long-term studies on GTS 40-3-2 and unnamed glyphosate tolerant GM soy (GMO Free Florida 2022, GMO Free Florida 2022a, GMO Free Florida 2022b).

The third reference in the FDA pdf is to a Medline article on GMOs which is nearly identical to a previous Medline article published in December of 2017 (U.S. National Library of Medicine 2017). In both the 2017 and 2021 versions of the Medline article it states, “The US Food and Drug Administration (FDA) assesses all GE foods to make sure they are safe before allowing them to be sold.” The statements made in these articles are different from the statements made in the same Medline article accessed in July 2016. In this 2016 article it states, “Genetically engineered foods are generally regarded as safe. There has not been enough testing, however, to ensure complete safety” (U.S. National Library of Medicine 2016). The statement that there is not enough testing to ensure complete safety is more consistent with the majority of medical and public health groups and individual health professionals (GMO Free Florida 2022, GMO Free Florida 2022a). The claims that the FDA makes sure GM foods are safe appear unsubstantiated as the FDA does not require long-term testing.

To try to determine the differences between the 2016 and 2017 Medline articles we looked for references from 2016 or 2017 in the 2017 Medline article. Only 2 such references were in the 2017 article, one of these was again the 2016 NASEM report, the second reference was an article by Hielscher et al (Hielscher 2016). The only mention of long-term studies in Hielscher et al. is the following sentence, “Until now, the available long-term studies could not find any “validated evidence that genetically modified (GM) crops have greater adverse impact on health and the environment than any other technology used in plant breeding”. The reference for this quote is page 2 in a 2013 European Academies Science Advisory Council report (European Academies Science Advisory Council 2013). While this quote does appear on page 2, there are no references provided for that statement. Therefore, it is an unsubstantiated claim.

As the FDA does not require long-term testing and the NASEM report omitted numerous long-term studies, it can only be concluded that the FDA claims about the safety of GM foods are unsubstantiated and are contradicted by the evidence from our systematic review (GMO Free Florida 2022b). This suggests that the FDA, like some other regulatory agencies, have not adequately regulated GM foods as most medical and public health groups and surveys of health professionals indicate (GMO Free Florida 2022, GMO Free Florida 2022a). This may explain why hundreds of scientists have called for regulatory agencies, such as the FDA, to apply the precautionary principle with regards to GM crops and foods (ESSNER 2015).

Call to Action

Although our review is limited to GM soy GTS 40-3-2 it is one of the most grown GM foods internationally (Soga 2020), the most analyzed (Sanchez 2015), and approved for consumption by the second most number of countries (ISAAA 2017). It would, therefore, be expected that GTS 40-3-2 would yield the best evidence for the safety, or lack thereof, of GM foods. Our systematic review, however, finds that the vast majority of relevant animal health studies reported likely adverse effects in the groups fed GTS 40-3-2 compared to the control groups (GMO Free Florida 2022b). This would explain why the safety of GM ingredients in food remains controversial throughout the global scientific community (Hilbeck 2015, Ajami 2016, Krimsky 2015, Dona 2009, Taylor 2014) and why the majority of health groups and health practitioners question the safety of GM foods currently on the market (GMO Free Florida 2022, GMO Free Florida 2022a).

Health professionals follow the concept of “Primum non nocere” or “First do no harm” (Aronson 2021).  The evidence provided in our systematic review indicates that most studies using the GM soy GTS 40-3-2 report likely adverse effects in the animals consuming it (GMO Free Florida 2022b). This indicates risks and burdens without a reasonable likelihood that the populations consuming GTS 40-3-2 stand to benefit. The World Medical Association’s Declaration of Helsinki states,”Medical research involving human subjects should only be conducted if the importance of the objective outweighs the inherent risks and burdens to the subject. This is especially important when the human subjects are healthy volunteers. Medical research is only justified if there is a reasonable likelihood that the populations in which the research is carried out stand to benefit from the results of the research” (World Medical Association 2018).

Since those consuming GTS 40-3-2 soy would not benefit directly from that consumption any more than consuming conventional soy, and would have additional health risks, it is therefore unethical to market GTS 40-3-2 as being as safe as conventional soy. Some may attempt to argue that the use of GTS 40-3-2 increases crop yields and thus has a benefit by providing food for those who would otherwise go hungry. This claim, however, does not stand up to scrutiny as the scientific evidence indicates that GM soy GTS 40-3-2 has equal or even lower yields compared to non-GMO soy (Elmore 2001, Gordon 2007, Quarles 2017) and, therefore, would not provide more food. While some GM soy is used in human foods such as the Impossible™ Burger (Robinson 2019), the argument that one must consume GM soy or otherwise go hungry also would not stand up to scrutiny as: 1. GM soy is mostly used for animal feed and making soybean oil (U.S. Food and Drug Administration Undated a), 2. the world already produces enough food to feed at least 14 billion people (World Bank 2011), and 3. It is estimated that if all foods humans can consume, such as soy, which are currently fed to livestock were instead used directly as human food it would provide enough calories for an additional 3.5 billion people annually (De Schutter 2010). Therefore, if GM soy use were really related to reducing hunger it would be used in ways to more efficiently produce food for humans.

Some have claimed that GM soy GTS 40-3-2 would lower herbicide use potentially benefiting human health (Almeida 2017). The opposite has occurred, however, and since the introduction of GM soy GTS 40-3-2, herbicide use has gone up in the countries growing this crop (Bøhn 2019, Almeida 2017, Benbrook 2016, Quarles 2017). The harms from glyphosate-based herbicides, used on GTS 40-3-2, are also well documented (Gill 2018, GMO Free USA Undated). The San Francisco Department of the Environment’s Hazard Tier for pesticides, including insecticides, herbicides and fungicides, includes a hazard assessment of both the active ingredients and the formulated product. It considers: Acute toxicity, cancer, reproductive or developmental toxicity, endocrine disruption, water pollution potential, hazard to birds, hazard to aquatic life, hazard to bees, hazard to wildlife, soil mobility and persistent, bioaccumulative, toxic substances. The San Francisco Department of the Environment’s Hazard Tier lists glyphosate-based formulations as some of the most hazardous herbicides (SF Environment 2013, 2020).

Along with an increase in herbicides comes an increase in energy and resource use as well as pollution associated with the manufacturing and production, processing, packaging and distribution of these additional quantities of herbicides. Glyphosate-based herbicides, also, have historically been one of the most energy intensive herbicides to produce (Green 1987). Glyphosate production also causes pollution and is responsible for radioactive materials and heavy metals which have resulted in superfund sites (Elmore 2017, Wozniacka 2019). Glyphosate residues on GM soy are consistently higher than on non-GMO soy (Bøhn 2019) and glyphosate and other pesticides used on GM soy are increasing as farmers continue to use higher concentrations of pesticides to combat glyphosate tolerant weeds and other problems in the average GM soybean chain (Quarles 2017, Gaitán-Cremaschi 2015). Therefore, there is almost no likelihood of benefit for the population of humans consuming GM soy GTS 40-3-2 and there is risk of harm based on empirical evidence in animal feeding studies.

It is unethical and immoral to continue to allow GM foods on the market in light of the evidence from these systematic reviews. The results of which indicate an overwhelming consensus among health experts stating that there is not enough evidence to claim GM foods are as safe as their conventional counterparts. As well as the overwhelming evidence indicating animals fed the most tested GM food have deleterious effects or biomarkers indicative of deleterious effects. The FDA is responsible for promoting and protecting public health by assuring the safety of our nation’s food supply (U.S. Food and Drug Administration 2017). The FDA must now protect public health by following the overwhelming evidence, prohibiting all soy with the event 40-3-2 from the food supply and prohibiting all other GM foods until they have been thoroughly tested in independent lifetime and multigenerational chronic toxicity/carcinogenicity studies with rodent and non-rodent animals comparable to humans.

Conclusion:

Based on the results of systematic reviews a clear consensus among health groups and individual health professionals has emerged. The consensus among health experts is that GM foods currently on the market cannot presently be considered as safe as their conventional counterparts. This is either due to lack of evidence of safety, or because of evidence that at least some GM foods currently on the market may be unsafe compared to their conventional counterparts. Despite the overwhelming consensus, characteristics of science denial have been used by agrochemical companies to deny this consensus. The evidence also indicates that many agricultural experts and corn belt farmers, who have largely adopted GM crops, who deny the GM food safety consensus are also likely to deny the consensus on climate change. On the other hand, health professionals and environmental groups are more likely to accept the consensus on GM foods and climate change.

Therefore, we call upon the health community, who are the experts on health, to continue to inform the public of the potential harms from GM foods and to choose non-GMO and organic foods to avoid those potential harms. We also urge the governments of the world to impose a moratorium on all GM foods until each GM food has been demonstrated as safe in independent long-term and multigenerational chronic toxicity/carcinogenicity studies using both rodents and non-rodents comparable to humans. We also call upon all who have published papers claiming that there is a consensus that all GM foods on the market are safe to provide corrections, or formally retract their papers if necessary. Our systematic reviews indicate this claim is not supported by the consensus, nor does it appear this claim was ever supported by the consensus.

A precautionary approach should be taken especially since there is now a consensus among health groups and individual health professionals that GM foods currently on the market cannot be considered as safe as their conventional counterparts at this present time, and a consensus in the scientific literature that some GM foods currently on the market may be unsafe compared to their conventional counterparts.

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