In several of my recent articles, I have discussed the problems of using “risk assessment” methodology in the evaluation of both vitamin and mineral supplements and Genetically Modified (GM) food. I have also discussed at length the dangers of the Codex Alimentarius and U.S. Food and Drug Administration position on GM food which is known as “substantial equivalence” and, in its more extreme forms, “substantial similarity.”
However, another concern addressed by the Codex Guidelines has to deal with antibiotic resistance created through the process of genetic engineering. Yet, as is typical of any Codex Alimentarius presentation, the agency makes several misleading and unsettling statements in this regard as well. While Codex does state that methods should be used that do not result in antibiotic resistance, it qualifies that claim in its document “Foods Derived From Modern Biotechnology,” by stating that these methods should be used “where such technologies are available and demonstrated to be safe.” This is certainly no mandate. It is merely a suggestion that will most likely be completely ignored by industry.
The Guidelines then go on to say that “Gene transfer from plants and their food products to gut micro-organisms or human cells is considered a rare possibility because of the many complex and unlikely events that would need to occur consecutively.” This statement stands in direct contradiction to established science. Indeed, the series of events that would have to transpire in order for the transfer of modified genes from a plant to human DNA or cells are neither unlikely nor rare.
In a footnote to this statement, Codex makes the claim “In cases where there are high levels of naturally occurring bacteria that are resistant to the antibiotic, the likelihood of such bacteria transferring the resistance to other bacteria will be orders of magnitude higher than the likelihood of transfer between ingested foods and bacteria.” Yet while this may in fact be true the statement is still misleading. The issue being discussed in the footnoted statement is the likelihood of DNA transfer from GM plants to humans. Furthermore, if such events were so unlikely, why would it be important not to use antibiotic resistant gene technology in the future?
Another concern presented in the section of “Foods Derived From Moderin Biotechnology” dealing with GM plants is the question of potential allergens being created within the food products as well as the introduction of entirely new allergens that have never before existed in nature.
While Codex claims that “all newly expressed proteins” as well as “a protein new to the food supply” should be tested for safety, there are legitimate questions as to whether or not Codex has the ability or the desire to test for such possibilities. 
First, while it is quite possible to know what foods occurring naturally are allergenic, it is much more difficult to come to these conclusions about new substances or proteins. This is partly due to the fact that naturally occurring materials have so many millions of years of history and use which, in itself, tends to naturally weed out the allergenic foods from the non-allergenic ones in a population’s diet. GM products do not have this history.
Indeed, the idea that over time a population tends to form its own guidelines through natural process adds to the ease in which scientific inquiry may form knowledge of the food properties in relation to the population itself. Again, this is not the case with GM food.
Therefore, another problem with the Codex Guidelines is made manifest. Because Codex works on a global scale, the potential allergens are listed globally and may not take into consideration (in future labeling) the geographic concerns of individual populations. When one considers the fact that allergens differ across geographic boundaries, with some foods being allergenic in one culture but not in others, he/she is confronted with the task that, in order to introduce a new substance into the food supply with new proteins, all of these populations must be tested separately. The tests of course should also be conducted over a longer period of time to investigate prolonged exposure.
However, Codex makes no mention of this problem and, likewise, mentions no remedy for it. Are we really supposed to believe that, hidden deep within the Guidelines, Codex plans to organize representative samples of every culture across the globe for every new protein added to the food supply? This is not likely even if one believed the organization was working truly promoting food safety.
Secondly, Codex itself admits tremendous flaws in its ability to test for new allergens. It says quite plainly that “there is no definitive test that can be relied upon to predict allergic response in humans to a newly expressed protein.” Because of this lack of a standardized and easily deciphered test, it goes on to say “A critical issue for testing will be the availability of human sera from sufficient numbers of individuals.”
This, however, is a major problem due to the fact that in order to test for just one allergy a minimum of eight sera is required for a major allergy, and a minimum of twenty-four sera for a minor allergy.
This is a rather large amount of material for testing purposes. It should be noted that this is the required sera for just one test subject. This test would have to be repeated hundreds and perhaps even thousands of times per geographic region or culture. It would then have to be replicated hundreds or thousands of times more on a global scale to account for these regions and cultures.
Even Codex admits, albeit in a footnote, that “It is recognized that these quantities of sera may not be available for testing purposes.”
With this in mind, it is clear that testing for allergens in GM products would prove extremely difficult to organize and conduct, even if Codex were truly committed to its professed goal of food safety.
 “Foods Derived From Modern Biotechnology,” 2nd edition. Codex Alimentarius. P.18 ftp://ftp.fao.org/docrep/fao/011/a1554e/a1554e00.pdf Accessed May 24, 2010.
 Ibid. p.18
 Ho, Mae-Wan; Ryan, Angela; Cummins, Joe; “Cauliflower Mosiac Viral Promoter- A Recipe For Disaster?” Institute of Science in Society. http://www.i-sis.org.uk/camvrecdis.php
 Foods Derived From Modern Biotechnology,” 2nd edition. Codex Alimentarius. P.18 ftp://ftp.fao.org/docrep/fao/011/a1554e/a1554e00.pdf Accessed May 24, 2010.
 Ibid. p. 27
 Ibid. P.20
 Ibid. p.22
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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