by Nicole Johnson
December 2, 2009
Nicole Johnson is a researcher
and activist living in Ventura county, California. Her kids wish she
would go back to painting and stop worrying so much about the world.
“I think it’s time to de-professionalize the public debate on
matters that vitally affect the lives of ordinary people. It’s
time to snatch our futures back from the 'experts.' Time to
ask, in ordinary language, the public question and to demand, in
ordinary language, the public answer.”
It’s enough to make you so queasy you lose your
HR 875, the “Food Safety Modernization Act of
2009,” is a head-spinning piece of legislation that would radically change
the structure of the US government’s regulatory agencies, usurping states
rights to federalize food inspection and determine what agricultural
practices are permissible.
Considerable concern has been voiced about what
this bill would mean for small and medium sized farmers, organic farming,
the future of conventional and organic seeds, the food localization
movement, and even home gardens. HR 875 would give regulators the power to
enter private property, which is conveniently redefined as “premises,” and
impose enormous fines for noncompliance.
Though not discussed in the corporate media,
numerous articles about it appear on the internet, launching a debate about
whether or not Monsanto is behind the bill.
In response to these articles, Brad Mitchell, a member of Monsanto’s public
relations staff who writes for the company’s new blog - a less-than-stealth
effort to counter the public’s deep distrust of the predatory corporation -
has gone on record stating that
Monsanto has absolutely nothing at all to do
with the bill.
Brad’s assurances aside, experience dictates that taking Monsanto at its
word is patently foolish.
But for those who need a bit more proof,
Organic Consumers Association and
Food and Water Watch, let’s
settle the issue, once and for all:
Who crafted the legislation and what do
they hope to gain by it?
Would it really make our food safer as
it claims, or would it make mandatory the industrial agricultural
practices that are the root cause of the food-borne illnesses it
claims to vanquish?
And what else might be at stake?
After a series of well-publicized cases of food
contamination E. coli-tainted meat, melamine-adulterated pet food and baby
formula, salmonella-infected peanut butter the public has been well primed
to look toward Congress to fix a poorly funded and insufficiently staffed
food safety inspection system.
And, right on cue, a crop of “food safety” bills
gets dumped our way.
The most controversial and transformational of these
pieces of legislation, Congresswoman Rosa DeLauro’s
HR 875, can be
traced directly to recommendations made by the
Trust for America’s Health, a
non-profit organization sponsored by the Robert Wood Johnson Foundation.
The Trust for America’s Health has produced reports that serve as blueprints
for a major restructuring of the agencies involved in overseeing food safety
policy as well as eye-popping changes to the public health system.
Its recommendations also have also made their
way into the other food safety bills that have been recently introduced in
SB 425, the “Food Safety and Tracking
HR 814, the “Trace Act of 2009”
HR 759, the “Food and Drug
Administration Globalization Act of 2009”
While the vaguely worded HR 875 gives the
appearance of being a reasonable attempt to fix the problems outlined, a
close inspection of the blueprints on which they are based - and a bit of
knowledge about the industry players who crafted them - reveals critical
clues about how the public health system would be transformed for the
benefit of biotech, pharmaceutical and agribusiness giants.
Non-profit foundations have long served as
effective tools for corporate wealth to influence public policy, providing
the means to guarantee outcomes that enrich corporations at the public’s
The global pharmaceutical and consumer product
company Johnson & Johnson’s tax-exempt foundation is no different.
Tayloring the Message
- The Trust for America’s Health
The public should familiarize itself with three key reports produced by The
Trust for America’s Health:
“Keeping America’s Food Safe - A
Blueprint for Fixing the Food and Safety System at the US Department
of Health and Human Services” (1)
“Fixing Food Safety - Protecting
America’s Food Supply from Farm-to-Fork” (2)
the “Blueprint for a Healthier America:
Modernizing the Federal Public Health System to Focus on Prevention
and Preparedness” (3)
President Obama’s nominee for Commissioner of
the Food and Drug Administration Margaret Hamburg, MD, sits on the
board of directors at the Trust for America’s Health.
Hamburg, a well-connected player in the public
health field, also serves on the board of directors of the Rockefeller
Foundation. Among other things, the
Rockefeller’s vast fortune is
responsible for funding foundations and institutes that spread unsafe
genetically-engineered food crops around the world.(4)
Sadly, those who hoped that
would herald positive changes have repeatedly found themselves duped:
deep corporate ties of his appointees guarantee a continuation of corporate
control over the US government, a veritable concierge service on steroids
for private interests.
A notable craftsman at the Trust for America’s Health is none other than the
Michael R. Taylor, JD.
Taylor penned a paper included as an appendix of
“Keeping America Safe: A Blueprint for
Fixing the Food Safety System at the Department of Health and Human
Services” called “Restructuring Food Safety at HHS: Design and
In it, Taylor prescribes the creation of a new
Food Safety Administration that consolidates all safety functions formerly
performed by a host of other government regulatory agencies and institutes
on a federal level the use of industry-friendly “risk assessment” methods.
Monsanto’s Jack of All
Most people who know Michael Taylor’s name recall that he worked as
Monsanto’s lawyer at King & Spalding for years before being appointed to the
FDA to oversee the swift introduction into the marketplace of GMOs.
He did so by ramming through a faux scientific
regulatory conceit called “substantial equivalence.”
Industry-independent scientists have rightly criticized the concept of
substantial equivalence as an inappropriate method for determining safety,
“a pseudo-scientific concept because it is a
commercial and political judgment masquerading as it if were scientific.
It is, moreover, inherently anti-scientific because it was created
primarily to provide an excuse for not requiring biochemical or
toxicological tests. It therefore serves to discourage and inhibit
potentially informative scientific research.” (5)
FDA scientists at the Division of Food Chemistry
and Technology wanted to see testing performed to ensure that GMO foods
didn’t increase levels of naturally occurring toxins, create new, previously
unidentified toxins, increase the tendency to gather toxic substances from
the environment such as pesticides or heavy metals, and alter the level
Ignoring their scientific objections, the
politically-appointed Taylor let loose GMO technology on the nation of
guinea pigs without requiring any legitimate safety and toxicology
investigations to protect public health.
He also ensured that the public
would remain ignorant of GMOs in their food by instituting a no-labeling
policy. Now, almost 80% of the food sold in grocery stores contains GMOs. Monsanto subsequently rewarded Taylor for his government work by
making him its Vice President of Public Policy.
These days, we find that Taylor has morphed from Monsanto’s VP into a
“research professor” at George Washington University School of Public Heath
and Health Services.
He also spends his time writing policy at a
number of industry-funded think tanks, including Resources for the Future,
Resolve Inc, the Food Safety Research Consortium, and the Alliance to End
Those who are concerned about what the
Organic Consumers Association calls the real Monsanto bill, The Global
Food Security Act (SB 384), can see Taylor’s contribution to that piece
of legislation by reviewing a report he wrote for a think tank called
the Partnership to Cut Hunger and Poverty in Africa. The report,
“Beating Africa’s Poverty By Investing in Africa’s Infrastructure,”(7)
supports the expansive agenda of biotech firms.
The organization is funded in part by the
Rockefeller and Gates foundations, and Taylor’s work product provides the
rational for SB 384.(8)
According the organization’s website, it aims to
“implement Partnership activities to strengthen agricultural and rural
enterprises and to facilitate their integration into regional, national and
global markets” by bringing together,
“core representatives from U.S. and
Africa-based private and public organizations who have experience with
Africa’s agriculture and trade-related issues.”
To give him credit, Taylor is relentless and
prolific. If only his work sought to empower rather than enslave.
Since shedding the title of Vice President of Monsanto, Taylor has been busy
promoting the concept of “risk assessment” as a means to deal with
food-borne illness as an alternative to urging regulatory agencies to
actually enforce laws already on the books and to adequately fund them so
they could do so.
Like “substantial equivalence,” the risk assessment
conceit offers a great opportunity to change the system to benefit corporate
Taylor has spent years churning out the
necessary conceptual building blocks in cross-pollinating think tanks and
foundations to create the intellectual framework for legislative proposals
like these food “safety” bills.
The reports produced by the Trust of America’s Health rely heavily on “risk
assessment, management and communication,” a form of message control hatched
at the Harvard Center for Risk Analysis, a corporate-funded affair that
provides “scientific” justification for a wide range of policies
corporations want to see implemented.
Using this method of risk analysis, the
necessary justification can be produced for just about whatever outcome is
wished by the underwriters.
It’s no real surprise that Taylor’s think-tank-funded policy on risk
assessment, like his report “Food Safety Updated: Developing Tools for a
More Science and Risk-Based Approach,” (9) underwritten by the
Milbank Memorial Fund and Resources for the Future, has been embraced and
institutionalized by the
Codex Alimentarius Commission.
Codex A Tool of Global
Governance by Corporate Command
If some variation of this batch of bad bills is passed into legislation, US
citizens will find their laws considerably closer to becoming harmonized
Codex Alimentarius, a set of international food codes crafted by
unaccountable and unelected bureaucrats in conjunction with vested industry
and trade interests.
It’s important that the public learns more about
Codex, because its “standards” will be enforced by the World Trade
Organization to govern global trade practices of all its member nations.
Furthermore, this body of food codes will take
legal precedence over national laws, like the 1994 Dietary Supplement Health
and Education Act (DSHEA).
The US media are assiduously silent on the matter of Codex. Under the
helpful cover of the media’s information blackout, Codex Alimentarius
Commission meetings are regularly attended by officials from,
Health and Human Services, State, Commerce
Environmental Protection Agency
the Office of US Trade Representative
the US Codex Office
Non-governmental agencies in attendance at the
meetings include the,
49th Parallel Biotechnology
the Biotechnology Industry Organization
Crop Life International
the European Association of
the Grain and Feed Trade Association
the International Cooperative Alliance
the International Council of Beverages
the International Council of Grocery
the Institute of Food Technologists
the International Glutamate Technical
Committee and the International Life Sciences Institute
...among others with the exception, that is, of
any democratically elected and accountable representatives of citizens these
food codes will affect.
The standards created by the Codex Alimentarius Commission are set to enable
industry interests to dictate and control rules covering vitamins, minerals
and nutrients, genetically modified plants and livestock, toxic residues,
antibiotics, drugs, growth stimulants and other hormones in food and
animals, organic foods, the irradiation of plants and animal food and
Scott Tips, President of the National
Health Federation, the only accredited health freedom organization allowed
to participate at Codex meetings, projects that these standards are on tract
to be implemented sometime between 2011 and 2013.
Codex committees, such as,
the Codex Committees on Food Additives
and Contaminants (CCFAC)
Pesticide Residues (CCPR)
Residues of Veterinary Drugs in Foods (CCRVDF)
Food Hygiene (CCFH)
General Principles (CCGP)
Food Labeling (CCFL)
Nutrition and Food for Dietary Uses (CCNFDU)
Import and Export Inspection and
Certification Systems (CCFICS)
Methods of Analysis an Sampling (CCMAS),
...all employ the concept of risk management to
determine the rules they recommend to the Codex Alimentarius Commission (CAC).
Codex standards are of critical importance to agribusiness, because they are
acknowledged as the appropriate guidelines in the Sanitary and Phytosanitary
(SPS) and Technical Barriers to Trade (TBT) Agreements of the WTO Agreement.
While the WTO had provisions that allowed member
states to create barriers to trade by citing national legislation to ensure
food safety, those provisions would become void, thanks to the SPS and TBT
agreements, if an international safety standard created by Codex determined
So, thanks to the unelected and unaccountable
private deal-makers who wrote these trade agreements, Codex rules will trump
Meet the Missus -
Christine Lewis Taylor
Undermining US law for the benefit of multinational corporations is a family
affair in the Taylor household. To see how the concept of “risk assessment”
can be usefully abused, let’s look at how Mrs. Michael Taylor adopts
the conceit to her purposes.
Christine Lewis Taylor, a veteran FDA employee, has been busy working up the
“scientific” justification for placing a cap on the level of nutrients
people should be allowed to consume.
To do so, she pushes a perverse concept that
defines nutrients as toxins. In other words, Mrs. Taylor would like us all
to believe that the vitamins and minerals needed by cells throughout the
body in order to function and detoxify should be considered hazardous,
requiring governmental oversight that would limit people’s exposure to them
After a stint heading up the Codex delegation on the Committee on Food
Labeling and another as a delegate to Codex’s Committee on Nutrition and
Foods for Special Dietary Uses, Christine Lewis Taylor was farmed out by the
Institute of Medicine to the World Health Organization, where she played an
instrumental role as Project Director in applying the risk assessment model
to redefine nutrition as we know it.
To develop the framework whereby an “upper
safe limit” would be set, defining the amount supplements the public
should be allowed to purchase except by prescription.
In her WHO capacity, she organized a seminar,
selected the scientists who would be allowed to participate in it, and
oversaw the group’s published conclusion.(10)
US law regulates supplements as food. But the pharmaceutical industry wants
to change that and have supplements regulated as drugs, and bureaucrats like
Mrs. Taylor are doing what they can to comply.
Taylor argues that people are exposed to too
many nutrients and wants to see the establishment of a one-size-fits-all
international standard set that stipulates how much of each nutrient people
need, a amount that in some cases is less than the already established
recommended daily allowances.(11)
But the good news, at least for pharmaceutical companies, is that there
would be more profit to be made in treating a host of vitamin-deficiency
And, once these guidelines are adopted by Codex,
people would no longer have the freedom to purchase therapeutic amounts of
dietary supplements to compensate for a nutrient-deficient and legally
poisoned food supply to which we’re subjected.
Supplements would no longer be consider food as
they are under
DSHEA but instead would be regulated as drugs, available only
by prescription or in amounts so limited as to render them insufficiently
helpful in the prevention of disease.
People are subject to disease not because they are deficient in
We are subject to disease because we either do
not get the nutrients we need from our food sources or because we are
exposed to environmental toxins and harmful food adulterants like
hydrogenated oils, high fructose corn syrup, MSG, pesticide residues,
aspartame, and GMOs, falsely deemed safe by the FDA. These adulterants
contribute directly to a long list of predictable degenerative diseases.
But thanks to the tireless work of Mrs. Taylor,
the chemical cartel will get wealthier by making us sick and wealthier still
by treating us for illnesses its products cause.
Facts Under the Rug
In addition to her work toward the implementation of Codex, it’s worth
noting that Christine Taylor Lewis has done her part to rewrite
history to make her husband’s tenure at the FDA to appear less corrupt than
it, in fact, was.
Talk about housekeeping. While serving as the
thesis advisor to a Tuft’s university student, Taylor oversaw the details of
a dissertation entitled the “Labeling of Genetically Modified Foods:
Stakeholder Perceptions of the Food and Drug Administration’s Public
Consultation Processes and Food Industry Reactions to the United States
Voluntary and European Union Mandatory Policies.” (12)
This thesis belongs to Janice Lee Albert, who happened to be an employee of
the UN’s Food and Agricultural Organization in Rome while working on her
Albert’s dissertation focuses on the controversy over labeling GMOs, a topic that deeply involved
Michael Taylor, her thesis advisor’s
However, that marital relationship is never
disclosed in the dissertation. In fact, while Mr. Taylor’s work is described
throughout the dissertation, Albert fails to identify him by name as a key
participant in the controversy.
On the contrary, when Michael Taylor is finally
mentioned by name, it is as one of twenty-four people Albert interviewed to
obtain their views on the appropriateness of the FDA’s labeling decisions.
Astonishingly, Albert identifies Michael Taylor
as an “Independent Expert,” revealing nothing about the fact he
previously worked as a lawyer for the
company who’s product was getting special treatment or
the fact that he was the one in charge
of implementing the concept of “substantial equivalence” at the FDA
went to work for Monsanto afterwards
Under Christine Lewis Taylor’s supervision,
Albert’s thesis defends the FDA’s controversial labeling decision and its
consultation processes with the public as being “conducted as intended by
Albert claims that members of the public who are
dissatisfied with the FDA’s decision not to label GMO products just don’t
understand the all the factors that go into making decisions at the FDA.
She’s probably correct on that point: Most of the public is under the
mistaken assumption that the FDA has a responsibility to protect it from the
unsafe products of an untested technology.
Thanks to her explanation, at least we now know
that certain employees of the FDA consider their only legal obligation is to
offer the public an opportunity to voice its concerns, not act upon them.
Albert contends that the exact nature of the public concerns about GMOs was
outside the scope of her dissertation and therefore unnecessary for her to
address or even note. Nevertheless, a thorough pre-market study of the
health risks associated with GMOs should never have been outside the scope
of the FDA’s responsibilities.
Scientists and journalists have lost their jobs for daring to cross the
powerful biotech industry to publicize the health risks of GMOs.(13)
The well-controlled media dutifully ignores the pile up of evidence of the
nature of the dangers.
In recent months, research has been published
showing that GM corn increases infertility (14) and that the key
ingredients in Monsanto’s Round-Up Ready, the herbicide used on all GMO
crops, cause death to human cells.(15)
Given what we now know about the dangers of GMOs, we should dispense with
the discussion of whether or not to label them and move right to the topic
of banning them altogether.
Identifying What Ails
Americans should be able to have confidence that the food they eat is safe.
The Trust for America’s Health, however, is
using recent food-borne illness events as an excuse to make radical and
unnecessary changes to a regulatory system has been purposely underfunded
While focusing exclusively of food borne
illnesses, it has ignored the predictable diseases suffered by millions that
are caused by the chronic consumption of foods adulterated with ingredients
that an industry-dominated FDA deems to be GRAS, that is, “generally
regarded as safe.”
Restoring and protecting our health requires a real understanding about what
ails us. To put things in perspective, food borne illnesses are responsible
for some 5,000 death a year; but over 700,000 people die each year from
government-approved medicine,(17) and millions more suffer from
predictable diseases that could be prevented if we had a safe, clean,
whole-foods based food supply.
If we allow those behind the food “safety” bills
to use this crisis as an opportunity to change the food safety system,
transnational corporations will have even more control over our health than
they do now.
Prevention, as they say, is the best cure.
(1) “Fixing Food Safety: Protecting
America’s Food Supply from Farm-to-Fork,” a report from The Trust for
(2) “Keeping America’s Food Safe: A Blueprint for Fixing the Food Safety
System at the U.S. Department of Health and Human Services,” a report
from The Trust for America’s Health.
(3) “Blueprint for a Healthier America: Modernizing the Federal Public
Health System to Focus on Prevention and Preparedness,” a report from
The Trust for America’s Health,
(4) F. William Engdahl, Seeds of Destruction: The Hidden Agenda of
Genetic Manipulation, published by Global Research, 2007.
(5) Erik Millston, Eric Brunner and Sue Mayer “Beyond Substantial
Equivalence,” published in Nature (7 Oct 1999).
(6) Citizen Petition Before the United States Food and Drug
Administration: Petition Seeking the Establishment of Mandatory
Pre-Market Safety Testing, Pre-Market Environmental Review & Labeling
for all Genetically Engineered Foods” filed by Center for Food Safety,
Washington DC, et al., with Jane Henney, Commissioner, Food and Drug
Administration, March 21, 2000.
(7) “Investing in Africa’s Future US agricultural development Assistance
for Sub-Saharan Africa” By Michael R Taylor and Julie Howard, 2005, The
Partnership to Cut Hunger and Poverty in Africa:
(8) “The Global Food Security Act” by Annie Shattuck. Foreign
Policy in Focus, April 17, 2009.
(9) “Food Safety Updated: Developing Tools for a More Science-and
Risk-Based Approach,” Michael R. Taylor, Margaret O’K.Glavin, J. Glenn
Morris, Jr., and Catherine E. Woteki. Published by the Milbank Memorial
Fund and Resources for the Future, July 2003.
(10) “Highlights of ‘A Model for Establishing Upper Levels of Intake for
Nutrients and Related Substances: Report of a Joint FAO/WHO Technical
Workshop on Nutrient Risk Assessment, May 2-6, 2005″ by Christine Lewis
Taylor, PhD, Nutrient Reviews, Vol 65, Issue 1, pp 31-38.
(11) “The NAS Risk Assessment Model for Establishing Upper Intake Levels
for Nutrients: A Critical Perspective From Psycho-physiological
Perspective,” Richard Malter, PhD. 2000.
(12) “Labeling of Genetically Modified Foods: Stakeholder Perceptions of
the Food and Drug Administration’s Public Consultation Processes and
Food Industry Reactions to the United States Voluntary and European
Union Mandatory Policies.” Janice Lee Albert.
(13) Jeffrey M. Smith, Seeds of Deception: Exposing Industry and
Government Lies About the Safety of the Genetically Altered Foods You’re
Eating. Yes! Books, 2003.
(14) “Biological effects of transgenic maize NK603xMON810 fed in long
term reproduction studies in mice” Austrian Agency for Health and Food
Safety, managed by the Austrian Federal Ministry of Health, Family and
Youth, and carried out by Veterinary University Vienna. November 2008
(15) “Glyphosate Formulations Induce Apoptosis and Necrosis in Human
Umbilical, Embryonic, and Placental Cells” by Nora Benachour and
Gilles-Eric SĂ©ralini, Chem. Res. Toxicol., December 23, 2008 Copyright
© 2008 American Chemical Society.
(16) “Starvation Diet: FDA Lacks Adequate Resources for its Nutritional
Health and Consumer Protection Missions” published by the Center for
Science in the Public Interest, Washington DC. October 2003.
(17) “Death by Medicine” by Gary Null PhD, Carolyn Dean MD, Martin
Feldman MD, Debora Rasio MD, and Dorothy Smith PhD. Life Extension
Magazine, March 2004.