Final Kleinman Testimony

A Pediatrician’s Viewpoint on HB 6798 – An Act Requiring Labeling of Baby Food and Infant Formula Containing Genetically Engineered Organisms

My name is Dr. Ronald Kleinman, and I am the Physician in Chief of the Massachusetts General Hospital for Children, Chair of the Department of Pediatrics at the Massachusetts General Hospital and the Charles Wilder Professor of Pediatrics at Harvard Medical School. My research and clinical work focuses on gastrointestinal immunology, nutrition support of infants and children, and nutrition and public health policy. I have also served on the Medical Advisory Group on Diet and Nutrition Guidelines in Cancer for the American Cancer Society and as Chair of the Committee on Nutrition for the American Academy of Pediatrics (AAP). In my work with the AAP, I have served as editor of the fourth, fifth, and sixth and the current seventh edition of the Academy’s Pediatric Nutrition Handbook.

Beyond my professional interest in the subject of infant nutrition, I grew up in Connecticut and attended Trinity College before pursuing my medical training out of state. Given my professional background and ties to Connecticut, I felt compelled to submit this testimony for your consideration as your committee evaluates the merits of HB 6798, An Act Requiring Labeling of Baby Food and Infant Formula Containing Genetically Engineered Organisms.
At the outset, I have to express my objection to this legislation as a pediatrician and nutrition scientist. I know the weight new parents and caregivers place on every decision affecting their children, and I have made it my life’s work to help guide parents through these challenges. In today’s world, my efforts are often complicated as a result of the conflicting messages, information and misinformation about genetically engineered (GE) foods. In counseling caregivers, what is most important is to help them separate myth from fact, and recognize when emotion has trumped hard science.

HB 6798 is based on emotion, not science. There is no scientific evidence to support the proposed labeling requirement and, even worse, the label has the potential to lead to unintended consequences that could prove serious. As a medical professional, I have personally reviewed the scientific data and safety information related to GE foods. I can tell you that there is no credible evidence that GE foods pose any risk to infants or people from any other age groups. Consuming foods produced through biotechnology is safe for all populations, including infants, children and women who are pregnant or nursing. The idea that special labels are needed for certain populations is not supported by science and has no basis other than emotion.
Putting my personal observations aside, a vast body of scientific evidence supports the safety of GE foods and ingredients whether they are consumed by adults or infants and young children. More than 2,000 studies have been conducted on these foods and have consistently found that GE foods and ingredients present no unique risks or dangers to human health. While you may hear testimony from supporters of this bill that there has been limited testing of safety, that is simply false. Agricultural biotechnology is one of the most well researched technologies of our time and the scientific consensus is clear, these foods are safe.

Despite the lack of any credible science demonstrating harm or risk from these products, some will try to convince you that there are safety concerns by citing research like the 2012 study by Gilles-Eric Séralini “Long term toxicity of a Roundup herbicide and a Roundup-tolerant genetically modified maize.” Let me be clear, the findings of this study have been overwhelmingly discredited, and it was even retracted by the journal that published it when the authors refused to withdraw it. I have also personally reviewed all of the scientific literature regarding glyphosate, the active ingredient in Roundup, and found it to be of no consequence to the health or safety of infants. I have provided some more information on this topic below.
It also deserves mentioning that the scientific consensus of safety of these foods and ingredients derived from them is reflected in the position of the U.S. Food and Drug Administration (FDA), which has concluded that these foods and ingredients are equivalent in composition, nutritional value and quality as conventionally produced foods and ingredients. The FDA is the federal agency with jurisdiction over infant formula and baby food and, in the case of infant formula, is required by law (the Infant Formula Act) to review all ingredients before they are used in infant formula. Infant formula ingredients are only approved after they have been found to be safe and suitable. Current infant formulas produced in the United States are the most heavily regulated and tested foods available in the world and their ingredients are unequivocally safe.

Because the FDA has concluded GE foods to be safe and equivalent to their conventional counterparts, whether used in infant formula, baby food or food for other age groups, the Agency continues to uphold the position that mandatory labeling of GE foods as a class is not required. However, if, for example, the Agency were to determine that a new genetic trait was likely to introduce potential allergens, labeling would be required. And, if FDA or any of the other Federal agencies involved in the review of new GE crops or the foods derived from them were to determine that a new trait was unsafe, the product would not be permitted on the market.

I recognize that many supporters of mandatory GE labeling bills like HB 6798 claim that this legislation is about “right to know.” While a compelling argument on the surface, “right to know,” and HB 6798 specifically, has the potential for significant unintended consequences. First, the proposed labels are fundamentally unnecessary because they do not provide useful information. If scientific data shows that GE foods and the ingredients derived from them are safe and nutritionally equivalent to conventional foods, then the only thing that these labels do is serve to satisfy consumer curiosity. In my opinion, curiosity is best addressed through voluntary labeling, and I point to certified organic infant formulas available in Connecticut, as well as organic baby food and baby food that has been certified GE free by third-party programs like the Non-GMO Project. Because these products already exist in the marketplace, anyone wishing to avoid GE ingredients is free to do so.
Furthermore, given the misinformation about GE foods, particularly questions about safety that will be raised by proponents of HB 6798 despite overwhelming peer reviewed published scientific evidence from independent researchers opposing their position, these labels will confuse and will clearly alarm parents and caregivers about the products they are feeding infants and young children. Not only does this confusion and alarm lead to unnecessary angst for Connecticut parents and cause them to needlessly question the safety of what they are feeding their infants, it may also lead to the use of inappropriate infant feeding methods that are not recommended by any reputable medical authority and may be extremely dangerous to infant health. An example is homemade infant formula. A quick search of the internet shows that some anti-GE food groups, natural food proponents and some parents are promoting homemade infant formula recipes and recommending that caregivers use homemade infant formula to avoid GE ingredients.

As a pediatrician, I would never recommend that a family use homemade infant formula. There is often no evidence provided that these recipes contain adequate nutrients needed for developing infants and home preparation has a very real possibility of introducing germs and toxins from the environment that could harm the infant. Recommendations to use raw milk are also extremely problematic and not recommended by the AAP or other medical authorities, yet some recipes advocate the use of raw milk. I’ve also seen instances where parents choose to feed unfortified animal milks, like goats milk, which lacks the necessary nutrients for a developing infant even if it is pasteurized and stored and administered safely. The bottom line is that the labeling requirement proposed in HB 6798 will confuse and scare parents without any benefit to public health or safety, and may even lead some to use unsafe alternative feeding methods that could put the health of infants at risk. This is a return to the days before the Infant Formula Act was passed by the Congress and similar to the situation that existed in the 19th and early 20th century. Do we really want to return to those days where every infant was at risk for serious illness from being fed an infant formula?

Another point that I touched on above, but want to provide some more information about here concerns the issues that have been raised by many supporters of HB 6798 about glyphosate, the active ingredient in Roundup. Roundup is a product widely used for over 30 years for weed control. It has an exceptionally well documented safety record for humans of all ages as well as the environment. Glyphosate is often cited by those opposed to GE foods because some GE crops have been engineered to withstand applications of glyphosate. These individuals often fuel fears and raise safety concerns about GE crops, claiming that they are vectors that expose adults and children to harmful glyphosate. As I suspect some will testify to the dangers of glyphosate at the February 24 hearing, I want to be sure the Committee considers the following information.

  1. 1. Glyphosate controls weed growth by interfering with the metabolism of plants; it has no effect on the metabolism of humans and animals and therefore has a very strong safety profile, documented over the past 40 years and confirmed by multiple independent international agencies.
  2. Human exposure to glyphosate most often occurs from the very minute amounts that remain on food that is consumed. Because it is among the safest agents used to control weed growth the US Environmental Protection Agency has set an Allowable Daily Intake (ADI) of 1750 micrograms (ug) of glyphosate for every kilogram (kg) of body weight.
  3. The current daily intake of glyphosate by individuals in the US is estimated, based on food intake data and assuming all foods carry maximal allowable residues, at about 13% of the ADI (or 230 ug per kg of body weight) from residues in or on foods. This is a maximum-case estimate. Tests for glyphosate in samples of urine suggest the typical dietary intake is well below 1% of the ADI or less than 17.5 ug per kg of body weight.
  4. Glyphosate that is ingested is mostly passed unchanged in the stool. About one third is absorbed into the body and is promptly removed into the urine.
    • Glyphosate does not accumulate in the body or in breast milk based on its chemical properties.
    • No harm has been associated with the typical amount of glyphosate that passes into the body and then out in the urine.
  5. In the recent report from Moms Across America, the levels of glyphosate detected in 3 of 10 samples of breast milk, if accurate (they still must be confirmed by using an assay validated for breast milk), suggest that a breastfeeding infant might be exposed to about 1/50th of the Allowable Daily Intake and do not support any risk, either to the mother or infant.
  6. There is no significant risk to infant health from glyphosate based on current use levels.

If you wish to learn more about glyphosate, I am enclosing with this testimony an article I wrote for the Genetic Literacy Project on glyphosate and infant health for your consideration.
In closing, I want to underscore my opposition to HB 6798. This legislation is not based on science and is likely to lead to unintended consequences ranging from parental confusion and concern to potential use of unrecommended and potentially dangerous infant feeding methods. I applaud the Committee for your attention and service to Connecticut’s children. We share a commitment to keeping children and their families safe, healthy and happy. Unfortunately, HB 6798 will not advance these goals.

I call on you to take the tough position of rejecting the unfounded claims on which this bill is ultimately based—namely, that GE foods are unsafe and special labeling of infant formula and baby food is needed to help parents and caregivers avoid them. This scientific evidence of safety is clear and options already exist through organic certification and voluntary claims for parents who wish to avoid GE foods. This legislation will not protect children, but it will have unintended consequences that will needless worry families and could harm children. In the end, forced labeling will only serve to give false credibility to misinformation and discourage people from eating foods that are perfectly safe. My charge to the Committee is to stand up against the scare tactics and vote against HB 6798.

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