In the course of the recent article series I have written regarding Codex Alimentarius and its position on Genetically Modified (GM) food, I have criticized both the “risk assessment” method of GM food evaluation as well as the official position of Codex Alimentarius in regards to the “substantial equivalence” standards. I have also written about the very real possibility of the introduction of new allergens and antibiotic resistant bacteria into the general food supply.
However, up to this point, all of the problems with the Codex Guidelines mentioned have been in relation to the section of the Codex GM position document known as “Foods Derived From Modern Biotechnology,” which focuses on GM plants.
There are, accordingly, two more sections - one dealing with GM Micro-Organisms and the other dealing with GM animals.
However, while it may seem that the majority of criticism expressed thus far focuses more attention on the first section (GM plants), the fact is that all three sections are very similar in their language and directives, with only a few changes in the wording made to apply to the new topic.
In many of these sections the language is word for word, copied and pasted to reiterate the same purpose as the first section. Therefore, I will not repeat my criticisms of the second and third sections that have appeared in my criticism of the GM Plants section. Suffice to say that all of the problems existing in the GM Plant section exist in the GM Micro-Organism and GM Animal sections as well, namely those of questionable scientific practices, the ignoring of relevant data, and so on. This claim is easily verifiable by reading the Guidelines document cited in the footnotes.
With that said, some attention should be paid to the section entitled, “Guideline For The Conduct Of Food Safety Assessment Of Foods Produced Using Recombinant-DNA Micro-Organisms.” This section deals mainly with bacteria, yeasts, and certain types of fungi in their uses in food production.
While making many of the same admissions present in the GM plant Guidelines, one of the most startling statements made regarding GM micro-organisms is the admission that they can in fact survive digestion.
Codex says, “In some processed foods, they [GM micro-organisms] can survive processing and ingestion and can compete and, in some cases, be retained in the intestinal environment for significant periods of time.”
While this statement is not revolutionary, it is quite surprising to see it uttered by Codex Alimentarius, an organization that seems to go to great lengths to approve GM products.
Nevertheless, the fact that these micro-organisms can survive digestion is extremely important to the GMO safety debate. So are the questions of rDNA retention in the intestinal tract, the potential for changing the intestinal flora of those consuming the GM product, and the subsequent effects on the immune system.
These are all concerns that Codex tacitly admits the existence of, simply by acknowledging the need to test them. Yet the tendency of GM micro-organisms to survive digestion and begin to change the makeup of the human intestines is mentioned later, in a footnote, where it is stated quite openly,
Permanent life-long colonization by ingested micro-organisms is rare. Some orally administered micro-organisms have been recovered in feces or in the colonic mucosa weeks after feeding ceased. Whether the genetically modified micro-organism is established in the gastrointestinal tract or not, the possibility remains that it might influence the microflora or the mammalian host.It should be noted that the idea that “life-long colonization by ingested micro-organisms is rare” is highly contested by many independent scientists. Yet, even if one were to assume the truth of Codex’s statement, the fact that it is rare means that it is still possible. More importantly, the statement admits that, even without long-term residence in the intestinal tract, there is still the distinct possibility that it will still significantly affect the intestinal flora and likewise the host itself.
Still more obviously biased concerns exist in the subsection dealing with the information that should be provided on each of the DNA modifications or micro-organisms. This information is, for the most part, very basic. It contains such data as which genes are added, the number of insertion sites, etc. However, two sources of information that are required to be included cause some concern.
The first is the inclusion of the “identification of any open reading frames within inserted DNA or created by the modifications to contiguous DNA in the chromosome or in a plasmid, including those that could result in fusion proteins.”
The second is the “particular reference to any sequences known to encode, or to influence the expression of, potentially harmful functions.”
Yet, both of these expressions (fusion proteins and genes that express harmful functions) are considered potentially dangerous even under the weak Codex standards. These expressions refer to the ability of some proteins to fuse with other proteins of the same and other species, mutating the DNA of the species, or forcing it to produce potentially adverse effects. Neither of these characteristics should be present in food, yet Codex mandates only that they be reported, not removed, as a result of the testing. This appears to be a continual thread of Codex’s Guidelines.
Thus, Codex continues by saying that additional information should be provided
to demonstrate whether the arrangement of the modified genetic material has been conserved or whether significant rearrangements have occurred after the introduction to the cell and propagation of the recombinant strain to the extent needed for its use(s) in food production, including those that may occur during its storage according to current techniques;as well as
to demonstrate whether deliberate modifications made to the amino acid sequence of the expressed protein result in changes in its post-translational modification or affect sites critical for its structure or function;While reporting information related to the instances above might seem like a good idea (and certainly few would argue that it isn’t), simple reporting is not enough. Indeed, these issues, as well as the others mentioned in this section of the Guidelines, are related directly to the question of the stability of genetically modified organisms. This is mentioned briefly in this section of the Guidelines, most notably in a footnote where it says,
Microbial genes are more fluid than those of higher eukaryotes; that is, the organisms grow faster, adapt to changing environments, and are more prone to change. Chromosomal rearrangements are common. The general genetic plasticity of micro-organisms may affect recombinant DNA in micro-organisms and must be considered in evaluating the stability of recombinant DNA micro-organisms.It is clear that GM organisms are often dangerously unstable. Many of them carry genes that overproduce a certain characteristic, cannot be turned off, or simply begin to change even after it has been bonded to the new strain of DNA.
Yet, with all of these admissions by Codex as to the dangers that GM micro-organisms pose to those who consume them as well as the fact that GM DNA is often unpredictable, the Codex Guidelines recommendations for testing suggest that these micro-organisms should be assessed based upon tests conducted on the conventional counterpart, not the micro-organism itself.
If tests conclude that the questionable micro-organisms are removed or rendered non-toxic in their individual and natural states, then “viability and residence of micro-organisms in the alimentary system need no examination.”
Embodying the impracticality and unscientific methodology of substantial equivalence in this context, Codex does not take into account the various potential dangers that it mentioned just a few short paragraphs previous.
Even on the question of antibiotic resistance, Codex takes the position of ignoring sound science in terms of its allowance of antibiotic resistant genes to be used as recipient organisms. It says,
In general, traditional strains of micro-organisms developed for food processing uses have not been assessed for antibiotic resistance. Many micro-organisms used in food production possess intrinsic resistance to specific antibiotics. Such properties need not exclude such strains from consideration as recipients in constructing recombinant-DNA micro-organisms.Although Codex does suggest that transmissible antibiotic resistant genetic strains should not be used, it clearly states that they should not be removed from consideration for use. This does little to ease the concerns related to antibiotic resistance in general. This is because, as mentioned earlier, any gene that is inserted into another organism via genetic modification is inherently unstable. Not only that, but this process creates the potential to destabilize other genes as well. So the possibility still exists even when not using what is considered a “transmissible” gene. Codex, of course, does not address this issue. It merely suggests that these antibiotic resistant genes not be removed from consideration as potential transfers and recipients.
The final mention of Codex’s treatment of GM micro-organisms revolves around some of the testing methods used to determine the potential of allergenicity – Sequence Homology and Pepsin Resistance testing. With the exception of the specific serum tests mentioned earlier (the more reliable form of testing when adequately provided for), these are the only two methods mentioned for determining potential micro-organism allergens.
The problem with both of these methods is that they are insufficiently geared to the task. By Codex’s own admission, Sequence Homology only assesses “the extent to which a newly expressed protein is similar in structure to a known allergen,” not whether the protein actually is an allergen.
But even this limited testing ability is challenged by the fact that the test can only be conducted by using sequences of allergens that are already known and available in scientific literature and public databases. The document also says, “There are also limitations in the ability of such comparisons to detect non-contiguous epitopes capable of binding themselves specifically with IgE antibodies.”
Therefore, the Pepsin Resistance test is just as problematic as Sequence Homology because, as Codex admits, “a lack of resistance to pepsin does not exclude that the newly expressed protein can be a relevant allergen.”
Because several food allergens have demonstrated a resistance to pepsin digestion, it was conceived that this method of testing would be useful for determining potential food allergens. However, this is obviously not the case as the correlation between pepsin resistance and allergenicity has not been fully investigated in its own right.
There is also the potential for Codex to use the some to ignore the many, i.e. actually using pepsin resistance testing to claim that if a substance has no pepsin resistance, then it is not a potential allergen.
In the end, the Codex position on GM Micro-Organisms and the potential safety implications of these organisms is yet more example of Codex’s complete and intentional obfuscation of the relevant scientific data. In cases where the science supports Codex’s position, the science is touted at every available opportunity. When it does not, the science is ignored.
 Foods Derived From Modern Biotechnology,” 2nd edition. Codex Alimentarius. P.39 ftp://ftp.fao.org/docrep/fao/011/a1554e/a1554e00.pdf Accessed May 24, 2010.
 Ibid. p.42
 Ibid. p.48
 Smith, Jeffrey. “Seeds Of Deception.” YES Books, 2003.
 “Foods Derived From Modern Biotechnology,” 2nd edition. Codex Alimentarius. P. 44. ftp://ftp.fao.org/docrep/fao/011/a1554e/a1554e00.pdf Accessed May 24, 2010.
 Ibid. p.45
 Ibid. p.45
 Ibid. p.45
 Ibid p.49
 Ibid. p.49
 Ibid. p.53
 Ibid. p.54
 Ibid. p.54
 Ibid. p.54
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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