organic farmers pay the price for contamination

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    Until genetically engineered crops (also described as GMOs) were introduced asa production method for U.S. farmers, coexistence between different sectorsof agriculture was a fairly simple prospect. Today, the ability of organic, non-GMO oridentity-preserved production to coexist with GMO production is in question.

    GMO crops became commercially available in he Unied

    Saes in 1996 and now consiue he vas majoriy o corn,

    coton and soybean crops grown in he counry.1U.S. GMO

    culivaion grew rapidly rom only 7 percen o soybean acres

    and 1 percen o corn acres in 1996, o 93 percen o soybean

    and 90 percen o corn acres in 2013.2Ceriiableorganic crops

    canno be grown rom GMO seeds.

    The hrea and acual occurrence o conaminaion o non-

    GMO crops by GMO crops harms many paricipans in

    markes where no deecable GMO presence is required or

    expeced, including organic and non-GMO (ofen described as

    ideniy preserved).The opic o coexisence becomes even more complicaed

    because organic and non-GMO armers are aking a variey

    o precauionary measures o ry o proec hemselves rom

    conaminaion and mainain heir abiliy o sell ino speciic

    markes, while GMO growers are no speciically required o

    miigae he risk o conaminaion.

    Food & Waer Wach parnered wih he Organic Farmers

    Agency or Relaionship Markeing (OFARM) o survey or-

    ganic grain producers on prevenaive measures ha hey use

    o avoid GMO conaminaion and he inancial losses associ-

    aed wih conaminaion.

    Survey indings include:

    Nearly hal o respondens were skepical ha GMO and

    non-GMO crop producion could coexis.

    enough o proec organic and non-GMO armers rom

    conaminaion.

    ORGANIC FARMERS PAY THE PRICE FOR

    GMO CONTAMINATION

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    GMO Crops Are a MajorObstacle to CoexistenceBecause using GMO seeds is an excluded mehod under he

    USDAs organic sandards, organic armers are responsible

    or making cerain ha hey do no grow geneically engi-

    neered crops.5Wih he prolieraion o hese crops, however,

    coexisence beween organic, non-GMO and GMO armershas become more and more difficul, due o he poenial or

    gene low and commingling o crops a boh he planing and

    harvesing levels and in he disribuion chain. Ofen reerred

    o as adveniious presence, GMO crops can conaminae

    non-GMO and organic crops hrough cross-pollinaion on he

    ield or hrough seed or grain mixing pos-harves.6

    Nearly hal (48 percen) o respondens were skepical ha

    GMO growers and non-GMO growers could coexis, wih 22

    percen saying ha here was no chance a coexisence. One

    armer wroe: I eel ha he GMO conaminaion problem

    is he mos severe or organic armers. I see no soluion o

    i.11Due o he risks o GMO conaminaion, some arm-ers are eeling hopeless and even choosing o abandon heir

    organic producion alogeher.12And over wo-hirds (68

    percen) o respondens did no hink ha good sewardship

    alone could proec organic armers rom GMO conamina-

    ion, wih 37 percen saying ha hey hough i would be

    oally inadequae.

    When armers were asked abou he prospec o GMO con-

    aminaion occurring on heir arms, 5 ou o 6 (84 percen)

    respondens were concerned, wih 59 percen saying ha

    hey were exremely concerned. This concern will only grow

    as more GMO crops are pushed hrough he USDAs pipeline,

    making i harder or organic and non-GMO armers o suc-

    cessully sell heir crops wihou GMO-relaed rejecions.

    The Costs of Contamination PreventionThe USDA organic sandards require ha organic armers use

    cerain prevenaive measures ha will minimize he risk o

    conaminaion. One o he main requiremens is mainaining

    a buffer zone ha is adequae o proec crops rom chemical

    spray drif or cross-pollinaion.13Due o hese requiremens,

    organic armers end up bearing he burden o avoiding GMOpresence rom crops planed by heir neighbors.

    The necessary acreage o a buffer zone depends on he drif

    risk o he ield in quesion,14bu he median size o buffer

    zones or survey respondens was abou ive acres. Because

    he buffer akes up space on land ha oherwise could be

    culivaed and sold, such zones can represen a inancial loss.

    Grass buffers are ofen no harvesed, so armers lose all o he

    value ha could have been gained rom growing an organic

    crop on ha land. Farmers who grow convenional crops as

    buffers are able o sell he harvesed buffer o he conven-

    ional marke, bu hey lose he value o he organic premium

    or hose acres. According o respondens, he median cos obuffers due o he loss o organic premium is approximaely

    $2,500 per year, wih several armers reporing annual losses

    o over $20,000.

    Costs of Preventative Measuresto Avoid GMO Contamination

    Method Median Annual Cost

    $2,500

    $200

    $520

    Total $6,532 to $8,500

    Do you delay planting to preventcontamination from neighboring farms?

    No (31%)

    Yes (67%)Blank (2%)

    Estimated annual cost/loss associatedwith delayed planting?

    SoybeansCorn$0

    $6,000

    $12,000

    $18,000

    Average cost

    Median cost

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    usually coss arms abou $1,000 o $2,000 per rejeced load.20

    And rejecions are no necessarily a once-in-a-lieime occur-

    rence. O hose respondens who had crops rejeced, over a

    hird had been rejeced more han once.

    Along wih he economic losses associaed wih rejecion,

    here is also he difficuly and sress o inding a new marke

    and buyer or he rejeced load and resolving he siuaion. As

    more GMO crops are approved and conaminaion becomes

    more o a problem or a wider variey o armers, i is very

    likely ha he number o loads rejeced will increase and he

    inancial burden will be more han some organic producers

    can coninue o bear.

    Looming Threat of Contaminationfor GMO Alfalfa and Wheat FarmersSome o he surveyed armers indicaed ha GMO conami-

    naion would become more o an issue or hem in he uure

    depending on uure adopion o new GMO crops, such asGMO whea. We know corn pollen can ravel up o wo miles.

    There is no doub o GMO polluion. Now alala is nex, will i

    ever sop? asked one armer.21A Norh Dakoa armer wroe:

    All his is subjec o change i our neighbors grow GM alala

    or GM whea is approved or wider whea seed conaminaion

    is deeced. One can only go so ar eliminaing crops wih GM

    varieies. The loss o crop opions is no a direc cos, bu a

    real one. We canno, or example, grow organic canola as we

    are surrounded by hundreds o acres o GM canola polli-

    naed by insecs no buffer is big enough o conain cross-

    pollinaion.22A Monana armer echoed his concern, wriing,

    We grow whea and won need exra proecion unil GM

    whea is commercially available.23

    The USDA approved Roundup Ready alala in 2010, which is

    no only he mos imporan eed crop or dairy cows, bu also

    an open-pollinaed crop, meaning ha wind or insec pollina-

    orscan pollinae and readily conaminae non-GMO alala

    ields or disances as grea as 1.5 miles.24Alala conamina-

    ion is already occurring in he Unied Saes.

    In Augus 2013, a Washingon sae armer repored ha his

    alala was rejeced or expor due o he presence o a genei-

    cally engineered rai. However, he USDA decided no o ake

    any acion o invesigae ransgenic alala gene low or o ad-

    dress ways o preven conaminaion.25In addiion o alala,GMO whea which hasn been ield-esed since 2005

    was ound on an Oregon arm in May 2013, causing Japan and

    Souh Korea o suspend some U.S. whea impors. I is unclear

    how he GMO whea appeared, bu alhough one Monsano

    represenaive ried o claim ha i was he resul o poenial

    saboage, here is zero evidence supporing ha allegaion.26

    Monsano is currenly working on herbicide-oleran GMO

    whea,27which once commercialized could ollow in he pah

    o alala as a serious risk o organic and non-GMO armers.

    Strained RelationsBetween NeighborsThe survey asked armers i hey had any non-moneary coss

    rom he hrea o GMO conaminaion. Several responses

    described srain beween GMO and non-GMO armers. One

    armer wroe ha, every ime I walk ino he local co-ophey gri heir eeh.28Ohers wroe ha convenional arm-

    ing neighbors do no respec us, ha non-organic neighbors

    eel ha our arm is a horn in heir sides or a nuisance, and

    ha hey are considered o be a problem o hem because

    we are no GMO like he res o hem.29Some relaionships

    have goten so srained ha neighbors ge ben ou o shape

    when approached abou GMO issues, and some neighbors

    will no longer ell us wha hey plan.30

    Given he enrenched srucural differences in ypes o arm-

    ing ha are creaing his srain, soluions o coexisence ha

    are based on effors o improve communicaion seem unlikely

    o succeed. This ension beween neighbors cass doub on heemphasis being pu by he AC21 Commitee on communica-

    ion beween armers as a primary sraegy or coexisence.

    Compensation for GMO-related HarmBecause o he signiican economic loss associaed wih GMO

    conaminaion, our survey asked armers who should have o

    pay he premium or a heoreical insurance package ha was

    designed o cover hose coss.

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    Nearly hal (45 percen) o respondens said ha hey would

    no purchase crop insurance inended o cover coss associaed

    wih GMO conaminaion. O he 35 percen o respondens

    respondens who answered ha hey would purchase insur-

    ance or GMO conaminaion-relaed losses, more han hree-

    quarers o hem (78 percen) believed ha he added premium

    or coverage should be paid by GMO paen holders or GMO

    paen holders andGMO users. One armer said: Under no

    circumsances should an organic armer have o buy insurance

    o proec him rom inancial harm due o GMO conaminaion.

    Tha responsibiliy should be wih hose companies selling his

    echnology and hose armers using i.31

    The respondens commens made i quie clear ha hey

    believe i is unair ha hose being harmed by GMO con-

    aminaion mos are he ones ha would be responsible or

    also paying ino an insurance program. Only 9 respondens (3

    percen) said ha organic armers should be he ones o pay

    or he premium on conaminaion insurance.

    One armer noed: Monsano and allies are spending millions

    buying voes o voe agains GMO labeling in he sores! They

    should pay or insurance or GMO conaminaion on organic

    land. All he big boys care abou is heir botom line. They

    have o be held accounable i heir [GMO seed] conaminaesmy crop!32

    During he series o AC21 meeings in 2011 and 2012, here

    was almos no discussion abou he idea o a compensaion

    und paid ino by he echnology paen holder. Bu here is

    widespread agreemen in he organic communiy,33backed up

    by he resuls o his survey, ha he liable pary or conami-

    naion should be he paen holder o he gene echnology

    ha prois rom he echnology. A ime-esed oundaion o

    liabiliy has been ha users o a new echnology had o as-

    sume legal responsibiliy or is proper use and conainmen o

    is uninended consequences.

    In addiion o concerns abou who would pay premiums or

    crop insurance o compensae or conaminaion, here is

    doub ha a crop insurance mechanism is easible or or-

    ganic growers. Crop insurance always has been inended or

    proecion rom naural disasers, and by is naure i would

    need o be signiicanly redesigned o cover his kind o loss.

    Alhough he USDA has made improvemens o crop insur-

    ance coverage or organic producers in recen years, here are

    sill some organic growers who are reimbursed or losses a

    convenional prices, insead o being covered or he higher

    value associaed wih heir specialized producion.34Ohers

    may no even have access o crop insurance i sufficien risk

    daa associaed wih hese crops are no available or devel-

    oping an insurance policy.35

    ConclusionAs he organic armers surveyed made clear, peaceul coex-

    isence beween GMO crops and organic crops is unlikely,

    and conaminaion is already occurring. The burden o rying

    o proec hemselves and paying or conaminaion is res-

    ing solely on organic armers, raher han on he companies

    ha proi rom his echnology and he users who have so

    ar been able o escape responsibiliy or serious effor or

    conaining i.

    The USDAs ocus on coexisence is misplaced. Insead o an

    exended discussion o coexisence, he deparmen mus recog-

    nize he harm ha is already being done o organic and non-

    GMO armers and prioriize ways o preven conaminaion.

    Food & Waer Wach and OFARM recommend ha:

    should be held accounable or all losses associaed wih

    GMO conaminaion and pay ino a compensaion und o

    help armers recover he ull coss o heir economic hard-

    ship caused by conaminaion.

    -

    ship requiremens or GMO crop producion o ensure ha

    responsibiliy or prevening conaminaion is shared, rahe

    han resing solely on organic and non-GMO producers.

    These requiremens should include buffer zones or GMO

    crop ields ha adjoin organic and non-GMO crop ields o

    reduce GMO and chemical drif. This is especially impor-an in ligh o he pending approval o crops engineered o

    olerae herbicides such as 2,4-D ha are prone o drif.

    and analyzing incidences o conaminaion and associaed

    economic losses a all levels o he supply chain.

    service o help educae GMO, non-GMO and organic arm-

    ers abou his escalaing problem and how o bes avoid

    conaminaion problems.

    Who should pay the added crop insurancepremium for coverage for contamination?

    Both GMO patentholders and users (29%)

    GMO patent

    holders (38%)

    Blank (16%)You, the organic

    farmer (3%)

    Other (6%)

    Risk ManagementAgency (0.4%)

    GMO users, whobought the seed

    (7%)

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    1. Contamination is occurring.Several markeers

    esimaed ha GMO conaminaion is eiher he irs or

    second mos requen reason or loads being rejeced by

    buyers. They also poined ou ha conaminaion was

    a major problem in 2013 due o weaher condiions ha

    made i hard or growers o ime heir planing o avoid

    conaminaion o corn crops. One markeer esimaed

    ha 10 o 20 percen o he producion his organizaion

    handled was rejeced or GMO conaminaion in 2013,and anoher described rejecions in 2013 as an epidemic.

    2. Costs of contamination are imposed at the market-

    ing level as well as at the farm level.In addiion o

    he coss described in he survey by growers, co-ops and

    grain markeing organizaions are incurring coss as

    well. One organizaion wen so ar as o develop is own

    esing program, which coss hem over $19,000 annu-

    ally. In addiion o heir own esing effors, oher coss

    imposed a he markeing sage include:

    -

    ion during shipping. (One markeer esimaed ha eachruck washou coss $40 o $50.)

    conaminaion and can no longer be sold or he origi-

    nal inended use, bu will be acceped or animal eed

    or oher lower-premium use. One markeer esimaed

    ha each shif rom he ood marke o he animal

    eed marke cos abou $5.00 per bushel.

    a new buyer i a load is rejeced. (One co-op repored

    reigh coss ha range rom $500 o $900 per load.

    This means ha a rejeced load can add more han

    $1,000 in coss i he crop has o be shipped back o

    he arm and hen o a second buyer.)

    Some markeers have gone so ar as o limi hemselves

    o lower-premium markes, such as animal eed, o re-

    duce he coss and hassle o rying o complee sales o

    ood markes wih more rigorous GMO esing regimes.

    The cos o his limiaion on he pool o poenial buy-

    ers is hard o quaniy, bu very real.

    3. It is unrealistic to expect this issue to be resolved

    in the marketplace.Many o he markeing expers we

    spoke o expressed heir growing concern abou heir

    abiliy o be reaed airly in a sysem ha relies predomi-

    nanly on buyer esing programs. The variable naure o

    conaminaion, even wihin one load or one corn ield, as

    well as he increasing sophisicaion o esing echnology

    are major challenges o creaing a esing sysem ha

    proecs boh buyers and sellers o organic grain.

    Organic grain markeers expressed concern ha hey

    have litle recourse i a buyer misakenly inds con-

    aminaion due o sloppy esing pracices (such as no

    cleaning he sampling probe beween samples). Anoher

    gave he example o a load o corn ha was rejeced

    when a buyer esed and ound some level o conami-

    naion. The grower ook he crop back, sored i sepa-

    raely rom oher crops and six monhs laer shipped i

    o he same buyer, only o have i acceped.

    afer he growers and co-ops do heir own esing beore

    shipping he crop o he buyer, some loads are sill re-

    GMO soybean harvess or rom rucks ha had previous-

    ly hauled GMO crops and had no been properly cleaned.

    Relying on he buyer-seller relaionship o resolve his

    problem is no easible. Growers and heir markeers are

    worried ha he considerable cos and effor o aking

    back a rejeced load pus hem in a vulnerable posiion.

    This makes some more willing o lose he premium or

    an organic ood-grade crop, raher han pay o ake hecrop back and ind a new buyer. These are he ypes

    o economic burdens ha are no well suied o a crop

    insurance mechanism and indicae he urgen need or

    he USDA o ocus on prevening conaminaion.

    Costs Not Limited to Farm LevelIn addiion o he survey, we inerviewed organic grain markeing expers rom several co-ops, which marke grain rom

    armers in more han a dozen saes.

    These expers reaffirmed he opinions rom survey respondens abou conaminaion and he inappropriaeness o crop

    insurance as a remedy. And several hemes emerged rom hese inerviews abou rends seen in he markeing sage o

    he organic grain supply chain.

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    General Information

    1. Farm Location

    17 states including:

    2. Size of Farm (Acres)

    3. Production method (organic, conventional,non-GMO, GMO):

    4. Number of crops, types grown (organic, con-ventional, non-GMO, GMO):

    5. If organic, percentage organic?

    (continued on page 10

    Costs of GMO Contamination Survey Results (March 2014)

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    6. If organic, number of years organic?

    Genetically Engineered Contamination

    7. How concerned are you about GMO contami-

    (01 not concerned at all, 24 not concerned, 5 neutral,68 concerned, 910 very concerned)

    8. Do you think GMO growers and non-GMOgrowers can coexist?

    (01 being no chance at coexistence, 24 little chance,5 neutral, 68 chance, 910 high chance of coexistence)

    9. Do you think good stewardship is enough toprotect organic/non-GMO farmers from unin-tended GMO contamination?

    (01 being very inadequate, 24 inadequate, 5 neutral,68 adequate, 910 being very adequate)

    Preventative Measures

    contamination from neighboring farms?

    -

    tional crop?

    10-c. Estimated annual cost/loss associated with

    sold as organic)

    11. Do you delay planting to prevent contamina-tion from neighboring farms?

    All (268):

    Corn Growers (188): Soy Growers (153):

    (continued on page 11)

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    11-a. If yes (179 respondents), are you missing anoptimal production window?

    Corn Growers who answered yes to Q11 (141):

    Soy Growers who answered yes to Q11 (120):

    11-b. If yes, by how many days?

    11-c. Estimated yield drag associated with de-layed planting?

    Corn:

    Soybeans:

    Wheat/Other:

    11-d. Estimated annual cost/loss associated withdelayed planting?

    Corn:

    Soybeans:

    Wheat/Other:

    12. Do you test your crops for presence of GMOmaterials?

    12-a. If yes (56), which of the following tests doyou use (circle all that apply):

    (continued on page 12)

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    12-b. Estimated annual cost associated with test-ing for GMO presence?

    13. Do you keep any additional records in an ef-fort to protect yourself against GMO presence?

    13-a. If yes, what types of records do you keep?

    13-b. Estimated time and resulting cost associ-ated with record-keeping, if any?

    Hours/week:

    Cost:

    14. Do you take any other measures that either

    help to prevent contamination or lower the

    14-a. If yes, what are these measures?

    14-b. What is the amount of time spent on theseactivities and associated cost, if any?

    Hours/week:

    Contamination Incidents

    15. Have you ever found GMO presence or sus-pected it on your farm?

    All (268):

    Corn Growers (188) only:

    Soybean Growers (153) only:

    (continued on page 13)

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    up to 84)

    15-b. What percentage of GMO presence wasdetected?

    16. Have you ever been rejected by a buyer dueto GMO presence in your grain?

    Those that said yes to Q15 only (84):

    Corn Growers only (63):

    Soybean Growers only (54):

    16-a. If yes (44), was the rejection for food, feedor both?

    16-b. When, and for how many seasons, did GMOpresence occur?

    No. of years (Ranged from 19992013):

    16-c. How many bushels were rejected?

    16-d. What was the associated premium loss orcost due to this load rejection?

    17. Have you ever had any non-monetary lossesdue to GMO presence on your farm, i.e., relation-ship strain with local co-op, neighbors?

    17-a. If yes, please explain:

    18. If you have had GMO presence on your farm(84), were you approached by the company thatheld the patent on the GMO seed?

    18-a. If yes, how was the situation resolved?

    Compensation for GMO-related Financial Harm

    19. Do you have crop insurance?

    (continued on page 14

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    20. If crop insurance was redesigned to covercosts associated with unintended GMO presenceon your farm, would you purchase it?

    20-a. If not, why?

    20-b. Who should pay the added premium forcoverage?

    Of everyone:

    Of those who answered yes (94) to 20:

    Of those who answered no (120) to 20:

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    Endnotes

    Updaed July 4, 2013.

    3 USDA Advisory Commitee on Bioechnology and 21s Cenury Agriculure (AC21).

    -

    vember 19, 2012 a 3 o 4.

    4 Ibid. a 14 o 15.

    -

    6 Gealy, David R. e al. Council or Agriculural Science and Technology. Implicaions

    o Gene Flow in he Scale-up and Commercial Use o Bioechnology-derived Crops:

    7 Ibid -

    Agriculure and Is Role in Co-exisence, Washingon, D.C. Sepember 78, 2011 a 20.

    8 Gealy (2007) a 3.

    9 Greene (2011) a 21; Gealy (2007) a 11.

    10 Gealy (2007) a 3.

    11 Survey No. 35.

    12 Survey Nos. 35, 133, 176

    13 Coleman (2012) a 47.

    14 Ibid.

    15 Ibid. a 9.

    16 Food & Waer Wach esimaes aken rom inerview wih a Midwesern armer co-op

    conduced on December 20, 2013.

    17 Survey No. 144.18 Survey No. 146.

    19 Survey No. 29.

    20 Food & Waer Wach esimaes aken rom inerview wih a Midwesern armer co-o

    conduced on December 16, 2013.

    21 Survey No. 3.

    22 Survey No. 130.

    23 Survey No. 244.

    -

    men. December 2010 a V-64; Mallory-Smih, Carol and Maria Zapiola. Gene low

    rom glyphosae-resisan crops. Pest Management Science.Vol. 64. 2008 a 434.

    25 Gillam, Carey. USDA will no ake acion in case o GMO alala conaminaion.

    Reuters. Sepember 17, 2013.

    26 Kaskey, Jack. Monsano says rogue whea in Oregon may be saboage. Bloomberg.

    June 5, 2013.

    ary 8, 2014 a 7; Dupon, Veronique. Monsano esing new GM whea afer 8-year

    reeze. Agence France Presse. June 5, 2013.

    28 Survey No. 111.

    29 Survey Nos. 35, 195, 230.

    30 Survey No. 214, 229

    31 Survey No. 118.

    32 Survey No. 142.

    34 USDA. Agriculure Secreary Vilsack Unveils Vision or U.S. Organic Agriculure.

    Release No. 0096.13. May 14, 2013; USDA Risk Managemen Agency. Imporan Dae

    14-030. February 5, 2014.

    -ance and Credi or a Healhy Farm and Food Fuure. April 2012 a 3 o 4.