In my last article, “Codex Alimentarius and GM Food Guidelines Pt.4,” I discussed a tangible, real-world example of the results of using “substantial equivalence” or “substantial similarity” when assessing the dangers of Genetically Modified (GM) food and/or approving that food for the market.
Returning to the defining Codex document in relation to GM food, “Food Derived From Modern Biotechnology,” it should be noted that the risks associated with GMOs are dealt with in a rather curious manner. Indeed, the monitoring and management of risks from GM food after their approval is mentioned rather blandly in the introductory section of the Guidelines. It says,
Post market-monitoring may be undertaken for the purpose of:
A.) Verifying conclusions about the absence or the possible occurrence, impact and significance of potential consumer health effects; and
B.) Monitoring changes in nutrient intake levels, associated with the introduction of foods likely to alter nutritional status significantly, to determine their human health impact. It should be noted that these are issues which should be resolved in a scientific setting prior to market. Yet Codex is obviously content to allow the public to act as lab rats in the real world rather than force these side effects to be addressed in an actual lab. Absolute disregard for the global population is evident here.
As will be discussed in future articles, when one understands the ultimate purpose of Codex Alimentarius, it becomes clear as to why policies like this emanate from the organization. Such is also the case when Codex mentions the management of risks finding their way into the market and the need for post-market tracing for the purpose of recall. It is important to note that tracing food materials is a difficult task, especially if those products have already found their way into the environment and have begun to reproduce.
Regardless, the second chapter of Codex’s “Foods Derived From Modern Biotechnology” makes what should be considered a revelatory admission. It says,
The Codex principles of risk analysis, particularly those for risk assessment, are primarily intended to apply to discrete chemical entities, such as food additives and pesticide residues, or a specific chemical or microbial contaminant that have identifiable hazards and risks; they are not intended to apply to whole foods as such.Essentially, this is an admission that risk assessment methodology is absolutely incapable and inappropriate when dealing with the safety of a whole food. As Codex makes clear, the principles for risk assessment were never intended to address anything other than chemicals and additives.
However, one should remember that risk assessment is indeed the method used to determine the safety of vitamins, nutrients, and minerals by Codex Alimentarius in order to label them unsafe at unreasonably low levels.
But Codex continues with even further admission that the testing methods used are not nearly as intense as one might think. The document reads,
Traditionally, new varieties of food plants have not been systematically subjected to extensive chemical, toxicological or nutritional evaluation prior to marketing, with the exception of foods for specific groups, such as infants, where the food may constitute a substantial portion of the diet. Thus, new varieties of corn, soybean, potatoes and other common food plants are evaluated by breeders for agronomic and phenotypic characteristics, but generally, foods derived from such new plant varieties are not subjected to the rigorous and extensive food safety testing procedures, including studies in animals, that are typical of chemicals, such as food additives or pesticide residues, that may be present in food.Simply put, Codex is admitting, albeit cleverly, that the testing method for whole foods is inadequate, and that the testing itself is not nearly as extensive as it would be for evaluating a known toxin like a chemical, pesticide, or apparently, vitamins and minerals.
As related to Codex’s position on vitamins and minerals, Codex considers genetically modified foods that have been engineered to produce a deadly chemical or pesticide to be a whole food, but vitamin C is considered a toxin.
Yet Codex does not stop here with the prefacing of their intended deceit and the admission of flawed and manipulated science. It says,
Animal studies cannot be readily applied to testing the risks associated with whole foods, which are complex mixtures of compounds, often characterized by a wide variation in composition and nutritional value. Owing to their bulk and effect on satiety, they can usually only be fed to animals at low multiples of the amounts that might be present in the human diet. In addition, a key factor to consider in conducting animal studies on foods is the nutritional value and balance of the diets used; this is in order to avoid the induction of adverse effects that are not related directly to the material itself. Detecting any potential adverse effects and relating these conclusively to an individual characteristic of the food can, therefore, be extremely difficult. If the characterization of the food indicates that the available data are insufficient for a thorough safety assessment, properly designed animal studies could be requested on the whole foods. Another consideration in deciding the need for animal studies is whether it is appropriate to subject experimental animals to such a study if it is unlikely to give rise to meaningful information.But there are several problems with this statement.
First, let it be made clear that this writer does not support the use of animals for laboratory testing for any reason.
However, this issue is not the focus of this article and it will be repeatedly referred to in its proper context in terms of scientific debate.
That being said, what Codex has admitted to in this statement, albeit subtly, is that test subjects will actually be fed significantly less of the GM food in question than exists in the standard human diet. Nowhere does Codex mention that the amount fed to the test subjects can be adjusted per capita, but simply that the amount fed to them will be “at low multiples of the amounts that might be present in the human diet.”
Furthermore, Codex attempts to convince the reader that because of differences in nutritional values and diet balance in the animals being tested it is extremely difficult to determine if there are any adverse effects resulting from the material being tested or another material/condition. Hence, Codex would have the reader believe that this problem could not be solved by the addition of a control group.
In the end, the overall conclusion of Codex is that testing GM foods is largely unproductive and that, for the most part, it should only be conducted in very special circumstances. Mere post-market tracking is looked upon as the most favorable route. This, however, leaves the consumer as the test subject, and corrective action can only be taken after it is too late for hundreds, thousands, or even millions of people.
Codex furthers this claim with an admission of its acceptance of “substantial equivalence” as a testing standard. Because of the problems associated with using risk assessment to address dangers in whole foods (but evidently not nutrients and vitamins), Codex claims it must rely on substantial equivalence to address intended and unintended changes in the food. Hence, Codex officially accepts the concept. 
In subsequent sections, Codex claims that even weak standards like substantial equivalence may not be required. The guidelines state, “For the reasons described in Section 3, conventional toxicology studies may not be considered necessary where the substance or a closely related substance has, taking into account its function and exposure, been consumed safely in food.”
However, there is no discussion of exactly how it will be determined that these substances have been consumed safely in food to begin with. Considering the fact that toxic substances like fluoride and rBGH have been consumed “safely” in food for many years, it is certainly frightening to think that even more substances may be created and added to the food supply under the guise of a history of safe consumption. Nevertheless, this process (or lack thereof) is not only unscientific, it is very dangerous.
Although Codex clearly maintains a double standard in regards to GM food versus vitamins and nutrients, there are some similarities in the risk assessment procedure applied to them. One of the few instances in which Codex applies the same standards for GM food as for dietary supplements is the area of nutritional properties of the food.
In fact, this procedure is in direct correlation to the Guidelines for Vitamin and Mineral Food Supplements and works in tandem with them in order to create a lower acceptable level of nutrients in the food itself.
In relation to this situation, it is important to pay close attention to several statements made within the guidelines. For instance,
Information about the known patterns of use and consumption of a food, and its derivatives should be used to estimate the likely intake of the food derived from the recombinant-DNA plant. The expected intake of the food should be used to assess the nutritional implications of the altered nutrient profile both at customary and maximal levels of consumption. Basing the estimate on the highest likely consumption provides assurance that the potential for any undesirable nutritional effects will be detected. While this language is carefully crafted to appear benign and concerned only with the welfare of different cultures consuming the GM food, what is actually being presented is the idea of a Global Expectable Average Daily Diet for purposes of creating an Upper Limit not on GM food, but on the nutrients existing within the food itself - all this, while, at the same time, allowing genetically engineered food to remain virtually unregulated.
As mentioned in the chapter dealing with vitamin and mineral supplements, the Global Average Daily Diet is simply taking the “average” level of consumption of a food or nutrient across the world and using that level as a base level standard for what will be considered the average intake of the product by all populations. The highest or lowest levels are usually chosen based on the needs of the scientist, particularly in situations like these where researchers have ulterior motives.
Remember, in the case of vitamin and mineral food supplements where the highest level of intake was used instead of the real average. This was because third world countries were not included properly in the average.
Like the GADD for vitamins and nutrients, the highest level of consumption will be used to examine GM food. However, using the highest level of consumption, in this case, will have an entirely different effect than it did upon vitamins and minerals.
Using the highest level of consumption estimation in concert with the concept of substantial equivalence, Codex creates an environment where it would be difficult for GM food not to be approved.
With the concept of substantial equivalence and the GADD taken in concert with one another, we could easily imagine a hypothetical scenario such as the following:
We might imagine that potatoes have a higher consumption rate in North America and Europe than in other regions of the world. So researchers would determine, based on the rate of potato consumption of Europe and North America, the Global Expectable Average Daily Diet. This average consumption rate would be applied worldwide regardless of other cultures’ consumption of potatoes. Likewise, using the concept of substantial equivalence, GM potatoes would be approved with an Upper Limit of the highest rate of consumption worldwide.
Thus, substantial equivalence and the GADD are two pieces of the puzzle used to craft a system of regulations in which vitamins and mineral supplements are severely restricted in terms of levels of nutrition, while GM food remains virtually unregulated at all.
In future articles, I intend to expand upon the possibilities of these concepts to be used to form a regulatory structure in which nutrition itself is regulated even out of food and where the genetically modified version is the only acceptable product.
 “Foods Derived From Modern Biotechnology,” 2nd edition. Codex Alimentarius. P. 4 ftp://ftp.fao.org/docrep/fao/011/a1554e/a1554e00.pdf Accessed May 24, 2010.
 Ibid. p.4
 Ibid P. 7
 Ibid. p.8
 Ibid. p.9
 Ibid. p.9
 Ibid. p.9
 Ibid. p. 14
 Ibid. p.17
Read other articles by Brandon Turbeville here.
Brandon Turbeville is an author out of Florence, South Carolina. He has a Bachelor's Degree from Francis Marion University and is the author of three books, Codex Alimentarius -- The End of Health Freedom, 7 Real Conspiracies, and Five Sense Solutions and Dispatches From a Dissident. Turbeville has published over 190 articles dealing on a wide variety of subjects including health, economics, government corruption, and civil liberties. Brandon Turbeville's podcast Truth on The Tracks can be found every Monday night 9 pm EST at UCYTV. He is available for radio and TV interviews. Please contact activistpost (at) gmail.com.
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