While I appreciate the Genetic Literacy Project’s elucidation of the issues with many science-critical claims (i.e. genetics), their cavalier attitude to the critics of GMOs seems to underlie a more serious issue with the organization: ignorance and hypocrisy. They recently published an article seemingly rebuking an article from Independent Science News on the FDA’s assessment of ‘golden rice’. ‘Golden rice’ is a genetically modified rice that seeks to increase the amount of beta-carotene (a precursor to vitamin A) in the rice in order to alleviate vitamin A deficiencies in several East Asian countries.
The article does offer some important news source and information, but overall paints a pretty misleading image of the entire issue regarding golden rice and fails to rebut many of the vital concerns brought up by the original Independent Science News’ article: external validity of American/Chinese studies, health risks, the actual total content of beta-carotene in the rice, etc.
However, an FDA approval carries a lot of gravitas worldwide, and the decision is being met with attempts by anti-GM groups to discredit the nutritional value and usefulness of Golden Rice.
The nutritional value/usefulness of golden rice is dubious regardless of FDA statement for or against it. It might be helpful to read the literature referenced in the Independent Science News article you allegedly read and responded to; Schaub et. al ’17 and indeed both FDA memos. Interestingly, as the ISN article notes, milled rice has a higher concentration of beta-carotene.
Just after the FDA’s approval, Independent Science News, a website known for its opposition to genetic engineering and recombinant technologies, published an article headlined “GMO Golden Rice Offers no Nutritional Benefits Says FDA.” Sustainable Pulse, another anti-GM organization reprinted the article, focusing on a misleading nutritional fact that both groups (among others) have perpetuated:
Couching the reporting of the websites in detailed descriptions of their heretical views seems to be typical of GLP articles.
This has been a common criticism of golden rice from groups like ISN and Greenpeace, which argue the approved version of Golden Rice doesn’t have enough beta-carotene, the precursor to Vitamin A, to make a nutritional difference. Instead, these groups advocate planting bananas, carrots, spinach or sweet potatoes, none of which are as affordable or even practical in places suffering from Vitamin A deficiency.
Fascinatingly enough, a comment on the ISN article elucidated a huge issue here: this is a blatant lie and the author of this article knows it. So much of a lie that the author, Andrew Porterfield, has linked to empirical research demonstrating that beta-carotene rich foods can and are grown in Southeast Asia. Even more disturbing is the seemingly deliberate exclusion of the alternative mentioned in the ISN article: Asians greens (Chandra-Hioe et. al 2017).
The FDA did state that. Also, Health Canada wrote that “Replacement of all rice and rice products in Canada with GR2E rice would result in a very small 0.8-8% (34 µg-239 µg per day) increase in ß-carotene intake.” But a health claim is not the same thing as a nutrition statement. So the FDA and Health Canada statements don’t translate into “no nutritional value,” nor does it mean that, as Latham and Wilson wrote, “the tradeoff experienced by the Golden Rice project between beta-carotene production and yield in its various GMO rices has not been resolved.”
I’d “concede” that the FDA letter is being partially misrepresented in the ISN article (I don’t work for them nor am I affiliated with them), but there is important information within that helps bolster golden rice’s critics claims; confirmation of relatively low beta carotene levels.
The FDA also has since rebutted Latham and Wilson’s article, saying the claim of “no value” is misleading. In the comments section of the ISN website, this response was posted from Marianna Naum, communications team lead from the FDA’s Office of Food and Veterinary Medicine:
Which was responded to in whole by Latham & Wilson, mostly convincingly. There is still the issue of the semantics of no nutritional claim vs no health claim that is (rightfully) brought up by the GLP article, but the Naum statement in no way ‘rebuts’ the majority of the content of the article, nor some of the interpretation of the FDA letter itself.
It’s Time For Math
Additionally, U.S. consumers eat rice at very low levels compared to consumers in the specific Asian countries with vitamin A deficiency for which golden rice was developed. IRRI reports that consumption of rice by children in Bangladesh is 12.5 g/kg body weight/day, compared to about 0.5 g/kg bw/d for U.S. consumers). Rice is the major staple in those countries and levels of rice consumption are many-fold higher than they are in the U.S. While a U.S Consumer would be unlikely to eat enough of the rice to achieve that value (10-19 % of the NDI or RDA), that does not mean that the level of consumption of golden rice in the targeted countries would be insufficient to accomplish the intended effect of supplementing their very low consumption of vitamin A-containing foods. Consuming rice containing the levels of pro-vitamin A in GR2E rice as a staple of the diet could have a significant public health impact in populations that suffer from vitamin A deficiency.
If we take the FDA figures at face value (dubious) and combine them with figures given earlier in the article (i.e. the Health Canada figures) we can compute the percent increase in beta-carotene that would result from a switch from current rice strains to golden rice. In the Health Canada statement, it notes that:
Replacement of all rice and rice products in Canada with GR2E rice would result in a very small 0.8-8% (34 µg-239 µg per day) increase in ß-carotene intake
We’ll use the entire range here.
In the FDA statement it states:
IRRI reports that consumption of rice by children in Bangladesh is 12.5 g/kg body weight/day, compared to about 0.5 g/kg bw/d for U.S. consumers).
Consequently, Bangladeshi children consume 25 times more rice than Americans per bw/d.
Now we run into some statistical/comparative issues: the Health Canada data is inferring the increase in beta carotene increase in the Canadian population, the FDA data talks about American consumers (presumably including adults) and the Bangladeshi data is about children. We have three incomparable figures that we can’t really use.
But even given the poor figures, we can give an (even rougher) estimate:
A 0.8-8% increase in North American populations * 25 = 20-200% increase in beta-carotene intake in a Bangladeshi population.
The questions now are:
- How does that level of increase of beta carotene translate into vitamin A?
- How much does that level of level of vitamin A increase affect vitamin A deficiency?
- How well do the assumptions used in the Health Canada calculation hold up?
- What is the external validity of Bangladeshi children data to other age populations & other countries?
Back To The GLP Article
In countries throughout Asia that consume up to 300 grams of rice every day, this means a lot more beta-carotene could be consumed than in the United States, where even 45 grams might be a high figure. Rice is a much cheaper stape, and also much more affordable than meat and other animal products, and colored fruits and vegetables like bananas and carrots (the latter which was bred to enhance beta-carotene content, incidentally, in the 14th century).
We finally have some (unsourced) data on the consumption of rice in Asian countries, noticeably using the upper limit of the range.
Again, we will take (at face value) the ratios of beta carotene in golden rice from the FDA; 0.504-2.35 mg/kg (see the Niederhuth quote from the GLP article).
0.504 mg/kg * 1 kg/1000 g * 300 g/day = 0.1512 mg beta carotene/day
2.35 mg/kg * 1 kg / 1000 g * 300 g/day = 0.705 mg beta carotene/day
We now have a figure for how much beta carotene Asians in the countries with the highest levels of rice consumption would consume in a ideal golden rice world.
We can compare this to the calculations Health Canada gave for Canadian rice replacement;
34 µg-239 µg per day
Or in other words; 0.034 mg-0.239 mg per day. This is an elegant confirmation that Canadians consume less rice than Asians.
Now, we must estimate what proportion of the daily amount of beta carotene this is.
We note that the standard amount of Vitamin A in the United States (which obviously isn’t a cross-cultural standard) is 900 mcg of Vitamin A. Beta carotene is a precursor to Vitamin A, meaning that 12 mg of beta carotene of required to produce 1 mg of vitamin A. Thus, the daily required amount of beta carotene is 900 mcg * 12 = 10800 mcg * 1 mg / 1000 mcg = 10.8 mg.
The amount consumed by these Asian countries by rice would be:
0.1512 mg / 10.8 mg = 1.4%
0.705 mg / 10.8 mg = 6.5%
This is evidently not very much vitamin A, even under the most generous of assumptions.
It is obvious in the FDA letter than beta carotene levels are considerably higher than that of normal rice. The FDA letter states that beta carotene in the non-Golden Rice controls was below the limit of quantification of 0.07 mg/kg, in Golden Rice it was 0.504 to 2.35 mg/kg…many times higher. Wilson and Latham never actually tell you how much higher Golden Rice’s beta carotene levels compared to equivalent consumed rice varieties. Instead they compare it to older versions of Golden Rrice or other crops like carrots.
While true, the issue at the core of the golden rice debate is one of risk-benefit calculations. As Wilson & Lantham point out, there are issues with the crop yield from golden rice that have to be balanced with whatever potential vitamin A benefits golden rice may yield, alongside concerns of proprietary genomes, health risks, environmental issues, transparency, food sovereignty and cost effectiveness.
These concerns cannot be dismissed simply by appealing to the higher concentration of beta carotene, especially in regards to well-tested native alternatives that have higher concentrations of beta carotene.
There have been a myriad of calculations estimating how much beta carotene/retinol golden rice would provide a person.
A 2003 study going over the benefits and hazards of golden rice estimated that golden rice would only provide 70 micrograms of retinol per day, far below the required 1080 micrograms.
Greenpeace similarly estimated that an individual would have to eat 3.7 kilograms of golden rice to achieve their daily value.
Throughout the FDA letter and this piece, a number of assumptions have been taken for granted: that the people who would eat golden rice have enough other macro/micronutrients to digest the beta carotene, that the rice would keep all of the beta carotene when stored, that people would actually adopt and eat the golden rice, that the implementation of golden rice in these countries wouldn’t have negative externalities.
During the whole Chinese golden rice experiment scandal, one of the major critiques of the paper was that the bioavailability of beta carotene is different in healthy Western(ized) populations with proper nutrition than in malnourished unhealthy populations: the very populations that the intervention is supposed to target. Because the individuals who are suffering from VAD (Vitamin A deficiency) are the same ones who do not receive enough fat in their diets: the very molecule necessary for bioconversion of beta carotene into vitamin A. As a result, it is very likely that the systematic malnutrition people with VAD experience will make it very difficult for the beta carotene to be efficacious in treating VAD.
Another issue with golden rice as a solution to vitamin A deficiency is that it rapidly degrades in temperate conditions, the exact environments in which rice would be need to grown, distributed and stored. Given that vitamin A deficiency is disproportionately concentrated in rural areas, which have poor storage and temperature conditions, we can reasonably infer that large quantities of beta carotene within the rice will degrade. The distributional mechanisms by which golden rice would have to be produced and distributed (season-dependent growth) would mean that the golden rice would only have significant amounts of beta carotene during specific parts of the year, thus succumbing to the seasonal variability that golden rice advocates posit as an issue for native sources of vitamin A.
We also know that cooking rice and similar foods decreases the amount of carotenoids in them.
But even more than the issues influencing the actual quantity of beta carotene that is available and converts to vitamin A, all of that hinges on people accepting the rice and eating it. We know that populations are often picky about the texture and taste of particular foods and would pay premiums for their preferred versions of foods. Consumers do not prefer GM foods & when educated about them, desire them even less. Even exposure to positive information has minimal effect on customer’s willingness to purchase golden rice.
Now we all know that golden rice is yellow. But what does this have to do with the issues of golden rice as a solution for VAD? Well, unbeknownst to most, but there is a fatal disease of rice called “yellow rice disease” (or beriberi) that infects rice with a yellow color. While there are obviously visible physiological differences between golden rice and rice with yellow rice disease, a campaign mounted to promote golden rice would require eradicating the defense mechanism populations in developing countries have against yellow-coloured rice.
Now, it’s obvious from the calculations of this article that golden rice wouldn’t provide a meaningful solution to vitamin A deficiencies in Asia. But why is it that the FDA and other regulatory agencies are so willing to let products only tested by proprietary corporate labs go right on through the regulatory process?
Throughout the article, you may have noticed that I qualified all my collection of data figures from the FDA with statements like “at face value”. The issue with modern food politics is that the regulatory agencies that are supposed to safeguard our food and ensure quality and safety have been compromised by agribusiness. As anyone who’s paid nearly attention to the news lately, this issue isn’t solely confined to the FDA or food regulatory agencies, but is indicative of a broader societal problem of the corporatization of politics.
Politicians get money from corporate donors, “super PACs” and wealthy individuals. By virtue of the politicians role in selecting regulatory agency leaders, government agencies are inherently politicized and beholden to the interests of politicians, and by proxy, the agricultural industry. This presents a huge issue when interpreting the evaluations published by these regulatory agencies, as they rarely, if ever, make their data public.
Moreover, the people that should be playing a central role in the discourse over golden rice, the people directly affected by these decisions, have been excluded and marginalized in this discussion, only ostensibly included as tokens to promote a specific viewpoint. Indigenous concerns about food sovereignty and food colonialism are almost absent.
If golden rice isn’t sufficient to solve the vitamin A deficiency in Southeast Asia, then what is? Well, the current system uses vitamin A tablets (note that artificial vitamin A is just as good as natural), but hasn’t achieved widespread success. This is likely a result of the inherent problems of widespread distribution of any type of medicine, as well as the contributing factors of imperialist impotence and malice. Let us suppose that a proper vitamin A supplementation programme would not suffice. What other alternatives could we substitute to supplement diets?
Let’s start with the foods: Vandana Shiva, for all her flaws, has listed a number of traditional Indian foods alongside their vitamin A value. For Micronesia, bananas have been mentioned as a major source. Other yellow and green leafy vegetables have been noted for their high amounts of carotene.
What programmes could policymakers implement, one might ask.
There’s a whole literature of results on this! A 2002 review of how micronutrition deficiencies can be addressed covered most of the classical ones, but others have included home gardening (the follow-up study is here), nutrient education, and fighting parasites. A 2017 review in the journal World Nutrition demonstrated the high efficacy of interventions with fortification, while a 2000 review emphasized the broad consensus that food-based strategies that center indigenous foods & education.
While there are problems with the rabid anti-GMO view that some corners of the internet have professed, it is equally anti-scientific to espouse the view that there are no concerns to be had. Much of the scientific journalism on the GMO question has uncritically espouse one view or the other. This is not a call for ‘both side-ism’, but for critical engagement with opposing arguments rather than the ideological dismissal we have seen here.