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RfC on Sentence on “broad scientific consensus” of GMO food safety fails to achieve consensus: It is time to improve it.

The Request for Comment (RfC) here created by Jytdog for the purpose of reaffirming the findings of this previous RfC on the language and sourcing of the sentence of a “broad scientific consensus” of the safety of GMO food (found in numerous articles) has closed here . There is no longer a consensus supporting the sentence. The closer stated:

Should the sentence be removed? Or maybe modified (and if so, to what)? There is no clear consensus on any particular action....Some of the opposes in this discussion appear to agree with the substance of this section but feel that the wording of the one sentence is overly broad; they might support more nuanced statements. I recommend that someone propose an alternative wording

I would also like to note that the closer of the earlier RfC made a similar recommendation:

... it may be helpful to refer to to some of the literature reviews to represent alternative views on the matter with respect to due weight.

With these recommendations in mind, I have provided a new sentence in the article and below for discussion that I believe is more WP:NPOV than the original that failed to achieve consensus at the recent RfC. Because the sentence occurs at numerous articles:

I suggest we continue to consolidate talk here at Talk:Genetically modified food. David Tornheim (talk) 23:20, 21 July 2015 (UTC)

  • This is my suggested revised sentence:
While GMO Proponents, such as the AAAS[1] and AMA[2] and Pamela Ronald[3] claim there is a "scientific consensus" regarding the safety of GMO technology and GMO foods, published peer reviewed articles in scientific journals challenge this claim of a scientific “consensus”[4] and report a lack of sufficient study of GMO safety.[5]

David Tornheim (talk) 23:20, 21 July 2015 (UTC)

References

  1. ^ American Association for the Advancement of Science (AAAS), Board of Directors (2012).Legally Mandating GM Food Labels Could Mislead and Falsely Alarm Consumers
  2. ^ American Medical Association (2012). Report 2 of the Council on Science and Public Health: Labeling of Bioengineered Foods "Bioengineered foods have been consumed for close to 20 years, and during that time, no overt consequences on human health have been reported and/or substantiated in the peer-reviewed literature." (first page)
  3. ^ Ronald, Pamela (2011). "Plant Genetics, Sustainable Agriculture and Global Food Security". Genetics. 188 (1): 11–20. doi:10.1534/genetics.111.128553. PMC 3120150. PMID 21546547. "There is broad scientific consensus that genetically engineered crops currently on the market are safe to eat. After 14 years of cultivation and a cumulative total of 2 billion acres planted, no adverse health or environmental effects have resulted from commercialization of genetically engineered crops ..."
  4. ^ Hilbeck, Angelika; Binimelis, Rosa; Defarge, Nicolas; Steinbrecher, Ricarda; Székács, András; Wickson, Fern; Antoniou, Michael; Bereano, Philip L; Clark, Ethel Ann; Hansen, Michael; Novotny, Eva; Heinemann, Jack; Meyer, Hartmut; Shiva, Vandana; Wynne, Brian (24 January 2015). "No scientific consensus on GMO safety" (PDF). Environmental Sciences Europe. 27: 4. doi:10.1186/s12302-014-0034-1.{{cite journal}}: CS1 maint: unflagged free DOI (link)
  5. ^ Domingo, José L.; Bordonaba, Jordi Giné (5 February 2011). "A literature review on the safety assessment of genetically modified plants" (PDF). Environment International. 37: 734-742.“...the risk assessment of GM foods in general, and crops in particular for human nutrition and health, has not been systematically performed as indicated in the scientific literature (Domingo, 2007; MagañaGómez and de la Barca, 2009)....it was reported that the results of most studies with GM foods indicated that they might cause some common toxic effects. There is no doubt that one of the main issues concerning GM food safety assessment is based upon detection of their potentially toxic properties, which could provoke unintended effects of the genetic modification (Tyshko et al., 2007).”“...the number of studies specifically focused on safety assessment of GM plants is still limited.”
No consensus means that the status quo ante prevails (pending consensus for any changes, of course). Besides, the close mostly addresses the formulation and structure of the RfC, rather than the merits. With regards to this particular proposal, I would object on grounds of WP:GEVAL and WP:UNDUE, for reasons that have been discussed extensively above. There are also other neutrality violations such as the use of scare quotes and the implication that the AAAS and AMA are advocacy organizations. Sunrise (talk) 00:43, 22 July 2015 (UTC)
That might apply if the statement of scientific consensus is verifiable, with the directly applicable guideline being WP:RS/AC. Jytdog hastily initiated the RfC during a discussion of sources, seeking decisive support for the statement, and the support is not there. Regardless of how ill-formed the RfC may have been, and how taxing to follow the discussion of 18 sources simultaneously, if there was a single definitive source unequivocally supporting the strong statement, it would have stood out. --Tsavage (talk) 02:53, 22 July 2015 (UTC)
I agree that the RfC wasn't necessary in the first place, especially since there was almost no chance it would result in a change to the article. That said, what you describe isn't how RfCs work, because if your arguments were agreed to be correct, then the RfC would have closed that way. You would need to provide new arguments that weren't already considered, or to appeal the closure. (Or claim the BLP exemption, but that one should be self-evident.) Sunrise (talk) 03:44, 22 July 2015 (UTC)
what you describe isn't how RfCs work - RfCs don't "work" in any particular way, they are "an informal process for requesting outside input concerning disputes, policies, guidelines or article content." (WP:RFC) The results are what we use to assist us in finding collaborative solutions. Formal closure is explicitly recommended against except for contentious topics and where consensus is not obvious: here, formal closure was sought, and now we have it.
Finding a statement to be insufficiently sourced - unverifiable - is against policy and requires action, not inaction. The RfC unambiguously sought to establish consensus support for the broad scientific consensus statement: the statement was challenged, and failed to find consensus. All arguments for the statement, the 18 sources, were presented and considered. The burden of support is on those wishing to maintain challenged content. The question is one of interpretation of sources and wording, not of including or excluding material: with over 30 editors participating, no consensus was found for that wording. The simple and obvious remedy is to fix it. --Tsavage (talk) 11:15, 22 July 2015 (UTC)
There was no consensus in the RfC, not a consensus that the content was insufficiently sourced. Since we had consensus in the past for the content and sources, the burden is on the person wanting to make the change. If you want something "fixed", then propose a change. Do keep in mind though that many editors do not see an issue with the current version of the statement. Kingofaces43 (talk) 13:31, 22 July 2015 (UTC)
A quotation from the author of the RfC might be relevant to this discussion: "[I]f there is no consensus then we have to rework the statement." GrayDuck156 (talk) 00:11, 23 July 2015 (UTC)
the closer has more authority than i. the closer also suggested we try to rework it. so that is what we should do. we need to work that out here. Jytdog (talk) 00:39, 23 July 2015 (UTC)
  • Comment: The RfC closing notes end on the obvious, common sense course: "I recommend that someone propose an alternative wording." I've been pointing out the same thing throughout: recasting the statement would not exclude or obscure one iota of scientific evidence, and, properly written, would make the whole thing clearer. A blanket pronouncement of "broad scientific consensus" without explanation, for a publicly controversial topic like this, is ultimately not helpful to the reader. This attempt to maintain at all costs a specific wording that numerous editors, recently and through the Talk archives, do not agree with, is entirely against the fundamental policy-driven goal of collaborative editing. It is clearly time to reword.
As for the proposed version above, in my opinion, as a first step, it can be done differently, in a way that does not introduce new points of contention, namely, the dissenting scientific evidence, and the characterization of organizations as GMO proponents (the article needs to be revised; the food safety info in the lead should summarize a relevant section, where all views are set out in appropriate detail). Perhaps @Jytdog:, who is central to all of this, can do away with the "broad scientific consensus" phrase, and create for consideration an initial alternative to that particular statement. --Tsavage (talk) 02:57, 22 July 2015 (UTC)
As I said above, I prefer the term "consensus" since it's an easy way to describe a situation where dissent is possible. It does seem that the term has become politicized for this topic since the first RfC, and I'd be fine with simply removing it for that reason. The problem is, again, that I don't think that's what you have in mind, because most of the other possible wordings which are compliant with policy allow no possibility of dissent. Sunrise (talk) 03:44, 22 July 2015 (UTC)
Based on what I gathered during the RfC, I don't think it is accurate to state in Wikipedia's voice that scientific evidence overwhelmingly indicates that all currently available GM food is as safe as conventional food. If we had a high quality review source that said that directly, fine. But we don't. And there's WP:RS/AC. We have sources that say something next to that, while the pro-consensus statement argument is that, well, they DO say that, if you know how to interpret them. Explaining the case for safety - no inherent greater risk in method; no documented cases of harm; regulatory oversight - rather than summarizing it in a sweeping statement seems a more informative and neutral way to go. --Tsavage (talk) 04:44, 22 July 2015 (UTC)
Per WP:MEDRS statements from expert organizations are ideal for these kind of statements. They're usually the ones that put out statements of consensus since scientists generally don't spend time spelling out that there is a consensus in papers. It's a bit of a moving goalpost to say we only stick with reviews in this context. We already have one review in the sources that were discussed the specifically says, "There is broad scientific consensus that genetically engineered crops currently on the market are safe to eat."[1]
If we’re going to start pulling from reviews, we have plenty of other sources.
  1. “It is also consistent with a consensus in the scientifific community that the recombinant DNA process is not inherently less safe than conventional forms of plant breeding and that the content of crop plants and foods should drive their regulatory scrutiny, not the process by which they were bred (National Research Council 1989, 1994, 1996,2000, and 2010; European Commission Eurobarometer 2010).”[2]
  2. Discussing substantial equivalence in terms of safety, “This clearly indicates a large consensus amongst scientists worldwide on GE crop evaluation.” [3]
  3. A meta-analysis looking at COI in GM related papers (finding there is relatively little), “Overall, the analysis of all 698 reports collected here makes it clear that GM crops have been extensively evaluated for potential risks and that genetic modification technologies based on recombinant DNA do not carry a greater risk than other types of genetic modification. Claims either that there is not sufficient peer-reviewed literature evaluating GM food/feed safety issues or that COIs prevail in the published literature are not supported by this analysis.” [4]
That’s only just a start glancing through recent reviews. We’ve got consensus statements in all the right places, so I’m still not seeing this continued fussing about the statement. If someone really wants to make a change, then propose one to discuss so we can avoid these long-winded diatribes that are more in line with a forum rather than addressing encyclopedic content. Kingofaces43 (talk) 14:26, 22 July 2015 (UTC)
so we can avoid these long-winded diatribes that are more in line with a forum rather than addressing encyclopedic content Yet you seem to be opening up the RfC debate once again: are these new sources to add to the 18, or replacements? --Tsavage (talk) 02:23, 23 July 2015 (UTC)
  • This one's done. No consensus for change. If someone wants to propose alternative wording, good luck. It's worth noting that the paragraph in question states
There is broad scientific consensus that food on the market derived from GM crops poses no greater risk to human health than conventional food.[4][5][6][7][8][9] However, opponents have objected to GM foods on grounds including safety, environmental impact and the fact that some GM seeds that are food sources are subject to intellectual property rights and owned by corporations.
This presents the objections fairly and with appropriate weight. JMO. Lfstevens (talk) 06:47, 22 July 2015 (UTC)
  • There is no consensus that the sources support the claim - and indeed they do not. No reliable source has been cited yet that would support an extraordinary SC statement. It seems editors here are suggesting that whatever way the RfC fell, it is being read as "don't touch the article". If "Support" was the winning argument, then we would certainly need luck to change the statement. But editors do not agree that this statement is supported, and no new sources have come forth that remedy this situation. If we are going to advocate for any particular presentation, let it be one that is supported by the sources we are providing. If we are using anti-GMO labeling position papers and misrepresenting other sources (which we are presently), this is an urgent issue and one we've spent the last month trying to address. It does not make sense to argue that the RfC says no change is needed. Perhaps it would help to have a simple list of the sources and what they do say, and build the safety statement/paragraph from that. petrarchan47คุ 08:25, 22 July 2015 (UTC)
  • I've only seen one suggestion - David's. Good for him for trying but that violates WP:GEVAL and is not going to fly. I suggest folks concentrate on suggesting language to build consensus around, to replace the current content. Jytdog (talk) 00:40, 23 July 2015 (UTC)
@Jytdog: My suggestion is that you take a pass at it - a safety-related summary statement - since you've been so closely involved over time with the current statement, the sources, and the set of articles. What seems to be well-supported is:
1. "the recombinant DNA process is not inherently less safe than conventional forms of plant breeding"[5]
2. "the scientific research conducted so far has not detected any significant hazard directly connected with the use of GM crops"[6]
(Sample sources courtesy of Kingofaces43, from above.) --Tsavage (talk) 02:15, 23 July 2015 (UTC)
  • If are going to say there is a conflict in rs over what the scientific consensus is, we need a source that mentions the conflict, otherwise it is original research. What I found particularly bad about the RfC was that we were provided with numerous sources, many of which failed the MEDRS standards that the proposer claimed was so important. It was as if quantity could make up for lack of quality. I would like to revisit the issue. So far the only review studies that have been presented say that there is no scientific consensus, and I would therefore oppose presenting a false equivalency by presenting alternative views as having parity. With the current sources, the neutral position is to report what the review studies say and use them to explain the dissenting opinion. Similarly in climate change articles we do not present the mainstream view that there is a consensus that global warming is real and balance opposing views. TFD (talk) 02:21, 23 July 2015 (UTC)
TFD spoke my mind. The Domingo review is to date the only review to look at impact of GM food on human health, and it remains the highest quality MEDRS-compliant source we have on this issue. It says specifically that there is not a consensus, and perhaps this is exactly why the OP was never able to come up with MEDRS/quality sources saying otherwise, also explains the need for SYNTH/OR. petrarchan47คุ 09:07, 23 July 2015 (UTC)
The Domingo review has serious flaws, in that it does things like take the Seralini studies at face value that have been resoundingly rejected by the scientific community. That is why Domingo is a "minority opinion" - he is in a very slim group (including say Suzuki) that is outside the consensus and raises concerns about food safety, but is not apocalyptic about it, like the truly FRINGE group including Jeffrey Smith, Seralini, etc. Jytdog (talk) 12:11, 23 July 2015 (UTC)
Jdog, you are an anonymous WP editor. Your opinion of the science is irrelevant and there is no need to repeat it continuously here. If you have RS denouncing Domingo, that would be relevant. The Seralini study was attacked, but not by all as you suggest. And we need to take into account that these attacks are sometimes politically motivated - but that is not an argument to be made here; here, we find the best sources per MEDRS (in this case), and use them. If Domingo's inclusion of Seralini was seen by the scientific community as discrediting the review, proof should be forthcoming, otherwise these comments from you continue to sound like nothing more than biased, pro-GM opinions coming from an advocate for the industry. petrarchan47คุ 03:31, 24 July 2015 (UTC)
  • I've compiled a list of sources and quotes from the RfC, broken down by type. Additional eyes would be appreciated. Reference quality varies as I've copied those that have fully formatted refs, and just included a link for the others. Quotes are likewise mostly based on what was quoted in the RfC, or in a few cases from past discussions in the archives. Sunrise (talk) 12:15, 23 July 2015 (UTC)
Let's not reinvent the wheel here, if we use the same sources there is no chance it will have community support, as is the case presently. Please review the RfC and integrate what we've learned. Are you familiar with MEDRS? If not, please review it. I notice that you have placed the AAAS position paper at the top of your highest quality sources. From my RfC vote, I'll repeat:
AAAS letter (the only source besides #3 to claim "consensus")
  • not peer-reviewed
  • includes a false representation of the WHO's position
  • contrasts GM food with "conventional plant breeding techniques", not "conventional food"
  • not a review (FAILS MEDRS)
  • ADVOCACY, not science: "The AAAS document, "Statement by the AAAS Board of Directors On Labeling of Genetically Modified Foods," is a position piece opposing mandatory labeling legislation in the US." - Tsavage 17:01, 8 June
petrarchan47คุ 03:31, 24 July 2015 (UTC)
Those points are a bit tendentious. As I'm sure you're well aware dealing with MEDRS for awhile now, we consider position statements from organizations to be equal to reviews in many cases. That's usually where one will go for statements of consensus. Scientific organizations putting out position papers is not considering advocacy. Breeding and food are used synonymously (one is the process and the other is the product resulting from the process). If the community is going to decide on a change, we need concerns of substance to address. Kingofaces43 (talk) 04:00, 24 July 2015 (UTC)
@Kingofaces43: I'm not clear on what your last comment adds:
  • Is the AAAS as a working scientific organization on the same level as the US National Academies, the National Institutes of Health, the CDC, the British National Health Service, and the WHO (the named examples in MEDORG)?
  • And, according to our AAAS article, AAAS op-ed pieces, AAAS lobbying events, and an official AAAS climate change statement, are all described in the Advocacy section - is that a different sort of advocacy?
  • Also, WP:MEDORG says: "The reliability of these sources range from formal scientific reports, which can be the equal of the best reviews published in medical journals, through public guides and service announcements, which have the advantage of being freely readable, but are generally less authoritative than the underlying medical literature." - where does a single-page, politically-timed, press release-style Board of Directors' position statement opposing GM food labeling fit on that scale?
  • Plus, the AAAS release only states that there's no inherent greater risk in GE methods than conventional, it doesn't say all GM food is safe - how is a method (breeding) the same as its result (food)?
This seems to come back to what was already argued in the RfC. We should be moving forward. --Tsavage (talk) 08:51, 24 July 2015 (UTC)
Your last point is distortion of what the document says, "consuming foods containing ingredients derived from GM crops is no riskier than consuming the same foods containing ingredients from crop plants modified by conventional plant improvement techniques." I.e., It's not about "methods", it's about the food. Please don't misrepresent sources. — ArtifexMayhem (talk) 20:20, 24 July 2015 (UTC)
Please don't misrepresent sources. Please read the source more closely. AAAS has taken the well-supported view that GE methods aren't inherently more risky than conventional methods (which it quotes earlier), and restates it to imply a blanket food safety consensus. In fact, it only says the same thing, i.e. if the same final product is achieved using GE or using conventional methods, the results would be the same, therefore the risk would be the same - it does not comment on actual GM food products, only hypothetical equivalent ones, and it does NOT say that all currently available GM foods are safe. As titled, the public "Statement by the AAAS Board of Directors On Labeling of Genetically Modified Foods," opposes labeling, so it's only natural they'd try to frame things to best support their case. Please realize, I'm personally not arguing that GM foods are safe or unsafe - how would I know?! - only that the sources don't support the scientific consensus statement; I would oppose POV editing that I encountered regardless of what views were being pushed for any topic. Why are we stuck on this - no one is trying to get rid of sources, only to change contentious wording? --Tsavage (talk) 21:07, 24 July 2015 (UTC)
Artifex Mayhem's reading of the sources is correct.Jytdog (talk) 21:41, 24 July 2015 (UTC)
The AAAS opposes labeling because "[Labeling] efforts are not driven by evidence that GM foods are actually dangerous. Indeed, the science is quite clear: crop improvement by the modern molecular techniques of biotechnology is safe. Rather, these initiatives are driven by a variety of factors, ranging from the persistent perception that such foods are somehow “unnatural” and potentially dangerous to the desire to gain competitive advantage by legislating attachment of a label meant to alarm. Another misconception used as a rationale for labeling is that GM crops are untested." By reading the entire document it seems very clear that when they say "consuming foods containing ingredients derived from GM crops is no riskier than consuming the same foods containing ingredients from crop plants modified by conventional plant improvement techniques" that they mean exactly that. — ArtifexMayhem (talk) 23:22, 24 July 2015 (UTC)
I find that by reading the entire document, the intent to present GM food as safe is clear, which is no surprise as that is what it is precisely intended to do. That doesn't alter the fact that they've based their key claim on an EU finding that they first quote:
  • biotechnology, and in particular GMOs, are not per se more risky than e.g. conventional plant breeding technologies"
and then creatively paraphrase:
  • "consuming foods containing ingredients derived from GM crops is no riskier than consuming the same foods containing ingredients from crop plants modified by conventional plant improvement techniques
All they've done is extend methods to their obvious outcomes, in order to discuss the same finding in terms of food consumption: if GE is inherently no riskier than conventional breeding, then its products are no riskier than the same products arrived at by conventional means. You may conclude from that that all currently available GM food is therefore no riskier, but that is not what it says. Interpreting the document in the way you suggest defies WP:RS/AC, which for what we're discussing requires clear and direct equivalent wording, not consideration of whole document context.
It's fascinating how long the consensus statement has been defended, against ongoing reasonable opposition. Back in 2013, an editor questioned this particular source and the comment disappeared under an avalanche of words:
  • "I also agree that the AAAS board of directors one-page editorial statement is a problematic source. There's no indication that the AAAS members were polled; it's basically an ex cathedra statement at the ranking at the lowest level of evidence."[7]
How many ways can the obvious be stated: this is not a reliable, independent source upon which Wikipedia can base a "broad scientific consensus" statement. --Tsavage (talk) 00:49, 25 July 2015 (UTC)
@Sunrise: Thank you for compiling this list of quotes that are not as one-sided as the promotional AAAS statement. However, I still see a greater pro-GMO focus to the selection and ranking of the quotes and sources (many of which originate with the pro-GMO agenda of advocates like Pamela Ronald and Jon Entine), without sufficient consideration for the concerns raised in the RfC about cherry-picking, lack of WP:NPOV and misrepresentations of the various quotes as to whether they truly reflect the agency's position on GMO food safety (and concerns petrarchan47 mention above). These concerns about problems with balance in many of the quotes are particularly evident from reading these sources I mentioned in the RfC (regardless of whether you consider them RS, I have found no inaccuracies in anything they have reported):
As an example, the article "Who says GMOs are safe? (and who says they’re not)" mentions quotes from The Royal Society of Canada, French Agency for Food, Environmental and Occupational Health & Safety (ANSES) and The Australian Medical Association that are not so pro-GMO as the quotes selected. I believe you have not included them in your list. Included in the article is mention of this web-site which lists "124 other health related organizations from around the world that are in agreement with the IAASTD report, and/or support mandatory GMO labeling." The sources we keep seeing and lists of organizations supporting the "scientific consensus" are based on cherry picking, not a systematic review of credible agencies, medical and scientific bodies and the appropriate literature. Also, if you are upgrading or downgrading the quality of a reference, I think some evidence should be provided for whether it is good RS or not RS, rather than immediately assume we are all in agreement with your assessment. David Tornheim (talk) 23:28, 27 July 2015 (UTC)
Hi David - I only included sources that were directly linked in the RfC. It would have been impractical to include all statements that were cited within those sources as well, as the list would have become many times longer, though I'm happy to start including sources linked since the RfC ended as well. The three sources that you mentioned are in the list, under "probably not (or definitely not) MEDRS" - this classification should be fairly straightforward, though of course everything is open for discussion. I tried to minimize the number of "editorial" decisions necessary, which is why the page deliberately contains no evaluation of source quality beyond the basic groupings.
On that note, I would also point out that there isn't any ranking (Petra made this mistake as well). From the first line of the page, "Entries are in no particular order and loosely follow the order in which they were presented in the RfC." For example, the AAAS happens to be at the top of the first section because it's first in the list of references. Sunrise (talk) 05:43, 28 July 2015 (UTC)

In my view, our attempts at reworking the statement should start by reducing the number of citations to no more than three; any more is WP:CITEOVERKILL and of little value to the reader. In paring sources, we should adhere to three principles.

  • First, the sources cited by the article should be created by doctors who have expertise in researching food safety. As indicated by WP:RS/MC, sources should be authored by experts in the field, not general purpose science practitioners or those who merely have an interest in genetically-modified foods.
  • Second, any geographically-unlimited claim should be based on sources that can legitimately claim expertise in the food production and distribution systems of nearly every country on earth. As stated in WP:OPINION, "English language Wikipedia articles should be written for an international audience." A reader in New Zealand, for example, should not be told that available GMO food is safe based on the testimony of United States-specific organizations.
  • Third, any claim should fully and accurately reflect each source and not wishful thinking. So, for example, a source that only says that no overt health problems have been clearly caused by the eating of GMO foods should not be used to claim that GMO foods are safe or that they are no more risky than any other class of foods.

World Health Organization publications are possibly the only sources that meet the first two criteria. The AAAS certainly does not meet either criteria; it is a US-specific organization whose members include few doctors (some are even high school students: http://membercentral.aaas.org/membership/categories). Perhaps the best source, one that was cosponsored by the WHO, is this one: http://www.unep.org/dewa/agassessment/reports/IAASTD/EN/Agriculture%20at%20a%20Crossroads_Global%20Report%20%28English%29.pdf. It includes the following quotation:

"Food safety is a major issue in the GMO debate. Potential concerns include alteration in nutritional quality of foods, toxicity, antibiotic resistance, and allergenicity from consuming GM foods. The...approval process of GM crops is considered inadequate. Under current practice, data are provided by the companies owning the genetic materials, making independent verification difficult or impossible." GrayDuck156 (talk) 06:02, 25 July 2015 (UTC)

GrayDuck156's Proposed Revised Language

So, how about revising the sentence to something like the following:

"According to the World Health Organization, genetically-modified foods currently available on the international market are not likely to present risks for human health[1], but the approval process for genetically-modified crops is considered inadequate[2]. GrayDuck156 (talk) 03:45, 27 July 2015 (UTC)
This is a good summary safety statement to consider. Separating the health risk and the approval process I think is critical. The strongest safety evidence seems to be that there has been no harm so far, which speaks to "currently available." Bearing on available GM food, and not considered anywhere I could find in the GM articles, is the uniquely lax control over GMOs in the US, which is well-documented. From a 2014 brief prepared by a senior analyst at the Law Office, Library of Congress Restrictions on Genetically Modified Organisms: United States:
  • "Compared to other countries, regulation of GMOs in the US is relatively favorable to their development. GMOs are an economically important component of the biotechnology industry, which now plays a significant role in the US economy.[2] For example, the US is the world’s leading producer of genetically modified (GM) crops."
  • The United States does not have any federal legislation that is specific to genetically modified organisms (GMOs).
  • A substantial number of legal academics have criticized the US’s approach to regulating GMOs.
And from one of the documents cited supporting the criticism, a 2006 legal analysis of the FDA, EPA and Dept. of Ag authorities and practices[8] (2006):
  • The FDA is responsible for insuring that all food products on the market in the United States, other than meat and poultry, are safe
  • The FDA’s statutory authority is the Federal Food, Drug, and Cosmetics Act (FFDCA), enacted in 1938. 9 No statutory provisions or FDA regulations expressly cover genetically modified foods
  • Interpreted under the Act, both the inserted gene of a transgenic plant and the product that it expresses are food additives, unless they are GRAS. GRAS is "generally recognized as safe," and the FDA has determined that [i]n most cases, the substances expected to become components of food as a result of genetic modification of a plant will be the same as or substantially similar to substances commonly found in food, such as proteins, fats and oils, and carbohydrates,” and therefore will be GRAS.
  • The food additive manufacturer, not the FDA, determines whether a food additive is GRAS. A manufacturer does not need to report to the FDA that it has made a GRAS determination, but it may do so and may receive from the FDA an affirmation that the particular substance is GRAS. Thus, the FDA's regulatory requirements with respect to genetically modified food are primarily voluntary. (emphasis added)
  • As evidenced by the preceding analysis, the statutory structure under which biotechnological products are regulated in the United States is based on legislation enacted decades ago, long before transgenic products were scientifically conceivable.
  • The regulatory inconsistencies identified in this section are irrational and introduce substantial inefficiencies and unreasonable risks into transgenic product regulation.
This appears to be extremely straightforward and germane to any discussion of approved GM food. The above sources can be used to support the second part of the proposed new statement (and, separately, should be made more clear in the relevant articles). --Tsavage (talk) 12:41, 27 July 2015 (UTC)
The first sentence is OK but doesn't need to be attributed to the WHO, and should be made relative to conventional food; the main stream view discusses risks of GMOs in light of conventional food - the whole consensus is built on an understanding that "food" is complex stuff and no food - conventional or GMO or organic is perfectly safe. In the second sentence, the view that the regulatory process is inadequate is not mainstream. It is significant minority at the most. Jytdog (talk) 13:16, 27 July 2015 (UTC)
Again, there is nothing one can do with mere opinions void of citations. When you declare something a "minority view" (something reserved, it seems, for statements unflattering to the pro-GM narrative), please bring references otherwise there is no reason to add your thoughts to this TP (we don't rely on 'authority' over research).
  • "Whatever the motivation, the alfalfa deregulation set a pattern for how the USDA views GMOs: Yes, GMOs cause harm; no, we don't plan to do anything about it. Last week's bluegrass decision, by creating an avenue through which the USDA can avoid conducting environmental impact statements, raises that attitude to the level of policy." Welcome to the Age of GMO Industry Self-Regulation
  • "it should be noted that most of these studies have been conducted by biotechnology companies responsible of commercializing these GM plants" pubmed 21296423
  • Studies finding GMOs are safe and as nutritious as conventional foods are mostly "performed by biotechnology companies or associates, which are also responsible [for] commercializing these GM plants" ENSSER
  • "According to the information reported by the WHO, the genetically modified (GM) products that are currently on the international market have all passed risk assessments conducted by national authorities. These assessments have not indicated any risk to human health. In spite of this clear statement, it is quite amazing to note that the review articles published in international scientific journals during the current decade did not find, or the number was particularly small, references concerning human and animal toxicological/health risks studies on GM foods." pubmed 17987446
  • "adverse microscopic and molecular effects of some GM foods in different organs or tissues have been reported. Diversity among the methods and results of the risk assessments reflects the complexity of the subject. While there are currently no standardized methods to evaluate the safety of GM foods, attempts towards harmonization are on the way. More scientific effort is necessary in order to build confidence in the evaluation and acceptance of GM foods." pubmed 19146501
  • "So it is the company, not any independent scientific review, providing the research that is relied on to assert safety. FDA guidance to industry issued in 1997 covered voluntary “consultation procedures,” but still relied on the developer of the product to provide safety data. There is currently no regulatory scheme requiring GM food to be tested to see whether it is safe for humans to eat. The FDA approach can be understood as the result of having a dual mission. In addition to its mission to protect food safety, the FDA was charged with promotion of the biotech industry." American Bar Assnpetrarchan47คุ 19:53, 27 July 2015 (UTC)
I don't see a proposal there, just a bunch of conspiracy theorizing and soapboxing based on sources we would never use in WP. Please propose language based on usable sources. Look, GMOs are mainstream, and food from GMOs is mainstream. WP is not a place for righting great wrongs. And P, this is the last time I will warn you about Michael Taylor, who is a living person, not a zombie from hell. BLP applies to Talk pages and http://www.responsibletechnology.org/ is not a reliable source for information about him. I will give you formal warning on your Talk page. Jytdog (talk) 20:01, 27 July 2015 (UTC)
There is no proposal as yet, we are gathering sources as a group for perusal, just as you did with the 18 sources that do not support, after all, the hotly contested statement you have added to many WP articles. Why are you so unhappy with this process here, when you took part in it during the RfC? I am not in agreement with your take on my input above, nor with your changing David Tornheim's section heading, which I have reverted back. Your defensiveness of Michael Taylor is strange, and I don't understand the reaction nor the scary warning notice to my TP. Regardless, please stop trying to bash everyone for simply trying to get the story straight.
Instead, why not bring citations as asked? You claim that it is not a popular notion that US regulations of GMOs are lax, but you did not bring evidence beyond your own uber-pro-GM opinion, which at this point is so predictable you really don't need to even comment here. I can pretty much do it for you. petrarchan47คุ 22:13, 27 July 2015 (UTC)
I probably have enough diffs of you violating BLP with regard to Taylor already but I wanted to warn you a last time. You will do as you will. Jytdog (talk) 23:01, 27 July 2015 (UTC)
Again, this is an untruth and can be proven by anyone interested - just search "Taylor" on this talk page. These are the only times I've mentioned him: The USDA's Tom Vilsack and the FDA's Michael Taylor (both hold top positions) have worked for Monsanto, Taylor, in charge of food safety, as VP and chief lobbyist. and (quotation from here) After leaving the FDA, Taylor went to the Department of Agriculture, where he quickly and quietly helped get rBGH approved for consumer use. I don't know what you're freaking out about. I worked at the BLP for Edward Snowden for a year and a half where all sorts of things were said about him, and among the whole community no one reacted in any way comparable to how you are doing now. I am at a loss. petrarchan47คุ 00:06, 28 July 2015 (UTC)
Skating on very thin ice; repeating what you already did. Hm. Please read BLP - blogs and other crap sources cannot be used to support negative claims about people. And I never said anything about being limited to this Talk page - I mean across all of Wikipedia. Do not push this, P. Read all the bad sources you want and write all the negative things you want, outside of WP; you cannot do that here, nor bring such sources here, with regard to living people. Jytdog (talk) 01:53, 28 July 2015 (UTC)
I realize you always have to have the last word, but please drop this off topic nonsense - if I've made actionable comments about Michael Taylor, this GM talk page is not the place to discuss it. I expect you will summon me to the nearest noticeboard if you have a case. Until then, keep it to yourself. petrarchan47คุ 15:17, 28 July 2015 (UTC)
What I have said is that per Mainstream World - on "the sky is blue" level, food from GMOs is regulated adequately. There are offices in countries around the world full of scientists and lawyers who regulate it and have regulated it for about 20 years now. It is like saying that regulation of microwave ovens is "inadequate". It is FRINGEy and based on a FRINGEy understanding of the science. It is not the mainstream view and the statement is UNDUE for that view per NPOV and PSCI. Jytdog (talk) 23:01, 27 July 2015 (UTC)
No. Citing your understanding of "the science" and trying to compare it to some other user's understanding of science in no way proves your claim that "regulation is sufficient", especially when the RS says otherwise. Neither does making up the bogus comparison of regulation of microwave ovens. Neither does saying that because there is a "world full of scientists and lawyers who regulate it", when we all know that regulators can be corrupted and/or or otherwise fail to protect the public from known potential dangers, such as with "Tobacco science" or Fukushima Daiichi nuclear disaster or Chernobyl disaster. You need RS to prove that experts in the field assert that GMO's are sufficiently regulated (when the RS says otherwise), not hand waving and appeal to your view from authority and/or claims of expertise. Where is the RS supporting your claim? David Tornheim (talk) 23:52, 27 July 2015 (UTC)
Yes, GMO food is regulated, in that there are laws and regulations and people, but that is as far as the mainstream statement can go. "Adequately" depends on the viewpoint: adequately according to the public? according to scientists? or according to legal scholars (who are the appropriate law experts)? Science is used to inform legislation, but obviously does not drive it; in lawmaking, scientific opinion and evidence are routinely ignored when conflicting outcomes are favored. That was my point in bringing up the US legal material: trying to tie regulatory issues exclusively or primarily to science is like saying scientists write the laws. An impression is given that active government food safety oversight exists in the US, when in practice that oversight primarily consists of regulators saying to companies, "Let us know if you think there's going to be a problem." That conclusion is indicated by analysis not of scientific evidence, but of the laws that govern what reaches the market. It's not all just about science. --Tsavage (talk) 00:05, 28 July 2015 (UTC)
Experts in the field, are the ones actually regulating food from from GMOs every day. They are doing what is mainstream. Like how farmers farm every day is mainstream, like how firefighters fight fires every day is mainstream, etc etc etc. It is a regular function of society. You can fill libraries with the documentation of the underlying laws and regulations and their procedures and the standards they have developed and the documents posted on their websites of the outcomes of their evaluations; a real world scientific/legal bureaucracy generates scads of documenation. And almost every one of the many sources used to support the current statement, say this as well. Regulation everywhere is always a balance between protecting the public interest and allowing innovation. Regulators always want better tools and more information; they always settle for what can be reasonably done in the real world.
The view that current systems are inadequate is just FRINGEy protest-y; it is is protesting against the mainstream, standard practice. WP does not give the most weight to the protest POV; that turns NPOV on its head. Jytdog (talk) 02:00, 28 July 2015 (UTC)
Of what relevance is your personal opinion of how the world works? The bottom line here is that we're not talking about mainstream and minority assessments when it comes to the US GM regulatory system, it's simple facts that are missing from these articles, like the fact that nearly 100% of GM foods on the market in the US were not subject to government testing whatsoever, they were cleared by definition, and any safety assurance there may be comes voluntarily from the companies. And if you want expert opinion on regulatory systems: how they work and how to work them, you certainly don't go to scientists...lawyers are the experts here. More giant holes of omission in the GM articles...
To liven up the dry facts with a first-hand quote, here's Jane Henney, FDA Commissioner at the time: " In 1992, we developed a policy for foods that were being developed using the tools of modern biotechnology. We did that to communicate to industry what we saw as the issues around these foods, and what we would expect [them to do] with respect to testing and food safety issues. ... We clearly communicated that if foods were being changed using these methods, ... or if there was anything posed, like an allergen, we would require labeling on those particular products. [The] industry, to the best of our knowledge, ... has complied with that. ... As we have held meetings on these matters, I think we are satisfied that there were no safety issues missed. There was nothing introduced into the marketplace that would have posed a problem. ..." --Tsavage (talk) 03:00, 28 July 2015 (UTC)
My view is of no relevance. What is of great relevance is that all these regulatory engines actually exist and function. Do I need to prove that they do? No. They are what is being protested. They are the mainstream. What you write above is not accurate. Companies do tests that regulators want to see. Regulators review the results. Sometimes they ask for more tests to be done. When they have all the data they are going to get, regulators decide if the proposed product is safe enough for its proposed use. Companies don't decide. You need to learn more about the regulatory process before you make claims about it. Our article has pretty good information and there is even more in the sources provided in the article. Please do your homework. Thanks. Jytdog (talk) 03:13, 28 July 2015 (UTC)
[Edit conflict] This type of statement (which you also made towards me today) goes against policy, please stop. Please see WP:OWNBEHAVIOR - Examples given:
P, please read WP:CIR. Asking folks to base discussion grounded in an understanding of what actually goes on, is not OWN. It helps us reach policy-based consensus, which is what we are after. Jytdog (talk) 05:04, 28 July 2015 (UTC)

@Jytdog: I agree with Tsavage that your personal views about how regulation works and how well it works is not relevant at all here, and it is a distraction. Additionally, your definitions of "mainstream" do not comport with Wikipedia. Wikipedia defines Mainstream as follows:

Mainstream refers to a current of thought that is presently widespread. It includes all popular culture and media culture, typically disseminated by mass media.

The mainstream popular majority view is that GMO's are not safe and should be labelled, and with your familiarity with the Genetically modified food controversies article, I'm sure you are well aware of that. But I'll provide RS anyway. For example: [this]. Also, 93% of Americans think GMO's should be labelled according to this New York Times survey. So the "mainstream" view of GMO's, GMO safety and labeling and adequacy of regulation does not comport with your views of what "mainstream" means.

We all know that Wikipedia is not going to report the mainstream view as if it were a fact, because the public can be wrong and so can the media. So Wikipedia relies instead on the "mainstream scholarship" WP:VALID or "mainstream scientists" WP:PSCI as experts, not the public and not the views of civil servant regulators, farmers, firefighters or lawyers who are "in the trenches". This bizarre tangent saying that low level regulators are mainstream "experts" is not helpful to improving the article, because it has nothing to with WP:RS and WP:PAG.

Please let us focus on correcting the "scientific consensus" statement that was not sustained by your RfC and in this section addressing GrayDuck156's proposed statement. Please provide solid RS to back up your objections and assertions, rather than giving personal opinions and expecting us to trust your views are solidly based on RS, especially when RS is provided that says otherwise. These tangents are distracting and in my opinion wasting our time, which has the effect of keeping the status quo defective sentence in place. You have agreed that the sentence needs revision, and you have been asked a number of times to provide an alternative sentence, which you think would gain consensus, and I have yet to see it. What I see is opposition and distraction to attempts to improve the problematic sentence. Please let us stay focused on improving the article. --David Tornheim (talk) 03:55, 28 July 2015 (UTC)

Our article on the controversies has a section on public opinion where we report polls like that. That's great. and if you actually read that NY Times poll, you see that only "26 percent said these foods are not safe to eat, or are toxic." That's all. About a quarter of all people. Not the mainstream view, even among the masses. The scientific community is even more clear (what was it, something like 88% understand that food from GMOs is as safe as conventional food), as members of the scientific community understand the science. Jytdog (talk) 05:09, 28 July 2015 (UTC)

Arbitrary break

respoding to the above - OK some sources about mainstream "approval process" which is what the proposed language says: Please see the existence of FDA and the way it regulates GM food, European Food Safety Authority and how it regulates GM food, Food Standards Australia New Zealand and how it regulates GM food, CTNBio in Brazil and how it regulates food, and how it is done in Argentina. And here is Canada. This is not citing "low level regulators" this is describing how regulation actually works. The real world, mainstream reality that is all around us.

It is rare the media report simply on what regulators actually do as opposed to reporting on some flare up (in which case they are reporting on that) but there are some examples:

  • Chicago tribune Jan 2014
  • this piece from Grist is actually not bad. (and David, please do read this for the whole "Voluntary" thing, which is not really voluntary at all)
  • the Pew Trusts produced an objective report in 2001, here

There are scads more, already cited in our articles.

If you read about these regulatory agencies, which have approved many many kinds of GM food products that are on the market today, you will find clearly described methods to evaluate food safety. The earth is round, there are functioning bureaucracies through which currently marketed GM food has come to market. There are many articles that simply describe reality. Unless you want to take the FRINGE conspiracy view that all of these agencies are corrupt, you have to describe what they actually do and describe that as the adequate, mainstream approach to approving the GM food that has actually been approved. We can give a voice to critics, but per NPOV they must get less WEIGHT, and the farther away from the mainstream the critics go, the less weight they get.Jytdog (talk) 04:42, 28 July 2015 (UTC)

Sure "these regulatory agencies" have approved GM foods (what number or percentage is "many many"?), the question is, what is that approval process? You point to the Chicago Tribune, Grist and Pew Trusts as sources that tell us, but why not instead use a gold standard secondary source, such as a Library of Congress brief on Restrictions on Genetically Modified Organisms: United States (Mar 2014, last updated 9 Jun 2015), prepared to answer exactly such questions - it says (emphasis added):
  • Under the FFDCA, substances added to food can be classified either as “food additives,” which require approval from the FDA that they are safe before they can be marketed,[45] and substances added to food classified as “generally recognized as safe” (GRAS), as to which preapproval is not needed.[46] In a 1992 policy statement, the FDA reaffirmed that in most cases it would treat foods derived from GMOs like those derived from conventionally bred plants, and that most foods derived from GM plants would be presumptively GRAS. However, with respect to a GMO product “that differs significantly in structure, function, or composition from substances found currently in food,” premarket approval of the substance as a food additive would be required.[47]
There is no mention of the key FDA regulatory designation of GRAS in our GM food articles (unless I missed it), when that is the cornerstone, the first point of potential intervention, of the current US regulatory policy for safety of GM plant food for human consumption. Also, there is no mention of GMOs in our Generally recognized as safe article. It seems like a big omission of basic factual information. (Library of Congress has GMO restriction reports for 22 individual countries, an European Union report, and one on International Protocols.) --Tsavage (talk) 11:40, 28 July 2015 (UTC)
Again, what you write here is very confused, and you are being adamant about it. This makes things difficult. Please do read the Grist article - it explains pretty clearly what the actual regulatory process in the US is and the way it actually works. (you also should be aware that new things are added to the GRAS list all the time - you have to do experiments and submit data to the FDA if you want to get something added to the GRAS list. see this. More relevant, please do read this explanation from the FDA of how they regulate GM food. there is a link there, to this page, where you will find 169 letters from the FDA to companies about specific GM products. You will not find the word GRAS in any of them. And if you look at the GRAS list, you will not see GM foods added to it, as they go through the FDA. The FDA does not actually treat GM foods under its GRAS procedures. Treating GM foods in a way similar to how GRAS proposals are treated is one thing; saying that they are treated under the GRAS provisions is different, and wrong. Jytdog (talk) 17:02, 28 July 2015 (UTC)
The Grist article, "The GM safety dance: What’s rule and what’s real," is an interesting enough read, a food writer on a one man's quest to find his truth, but it's not a useful encyclopedic source, entirely subjective, and based mostly on interviews in a he said-she said style. And it doesn't come to any real point (except to point to a Part 2):
"So: Are people like Hansen and Gurian-Sherman right to say there’s no required safety testing? Or is Giddings right that the testing is de facto mandatory? In a very real way, both are right."
You're arguing around basic facts, yet not saying much other than, "Read this. And this..." And I've read all that stuff. Turning to the confusing FDA site does nothing for interpretation; instead, I'm quoting and referring to reliable analysis of regulations (policies that the White House has just announced "can make it difficult for the public to understand how the safety of biotechnology products is evaluated, and navigating the regulatory process for these products can be unduly challenging, especially for small companies" - not a great source either, and mostly a primary source in your links, which means expert knowledge of the overall framework is required for proper understanding.
This isn't the discussion in which to detail specifics of the FDA food safety policy, still, the basic facts I've been able to gather from the Library of Congress report and its 105 cited sources, is that GRAS is the default designation for GM food plants, which allows them not to be classified as "food additives," thereby avoiding government safety testing. Voluntary application for review results in the FDA examining data supplied by the applicant, to confirm or deny GRAS/food additive exemption. In any case, a basic description of the US GM food regulatory process should be in the appropriate articles, not solely the subject of Talk page debate.
My point once again is only that any sort of blanket statement that implies that all GM food on the market has been government-tested should be clarified at least for the US case. -Tsavage (talk) 22:47, 28 July 2015 (UTC)
Your takeaway that the FDA actually classifies GMO food as GRAS is not accurate. And no where in the GM suite of articles does WP come even close to saying that GM food (or any drug, or any pesticide, or any food additive) is "government-tested". I don't know any developed country where any regulated product gets through the regulatory process with government testing. People wanting to sell X, pay to have X tested, and submit the data to the relevant regulator of X. Jytdog (talk) 23:37, 28 July 2015 (UTC)

Your takeaway that the FDA actually classifies GMO food as GRAS is not accurate. OK, let's say I'm competency-challenged, please translate this, taken from the relevant FDA Statement of Policy - Foods Derived from New Plant Varieties: Guidance to Industry for Foods Derived from New Plant Varieties (emphasis added):

FDA has reviewed its position on the applicability of the food additive definition and section 409 of the act to foods derived from new plant varieties in light of the intended changes in the composition of foods that might result from the newer techniques of genetic modification. The statutory definition of "food additive" makes clear that it is the intended or expected introduction of a substance into food that makes the substance potentially subject to food additive regulation. Thus, in the case of foods derived from new plant varieties, it is the transferred genetic material and the intended expression product or products that could be subject to food additive regulation, if such material or expression products are not GRAS.
With respect to transferred genetic material (nucleic acids), generally FDA does not anticipate that transferred genetic material would itself be subject to food additive regulation. Nucleic acids are present in the cells of every living organism, including every plant and animal used for food by humans or animals, and do not raise a safety concern as a component of food. In regulatory terms, such material is presumed to be GRAS. Although the guidance provided in section VII. calls for a good understanding of the identity of the genetic material being transferred through genetic modification techniques, FDA does not expect that there will be any serious question about the GRAS status of transferred genetic material.
FDA expects that the intended expression product or products present in foods derived from new plant varieties will typically be proteins or substances produced by the action of protein enzymes, such as carbohydrates, and fats and oils. When the substance present in the food is one that is already present at generally comparable or greater levels in currently consumed foods, there is unlikely to be a safety question sufficient to call into question the presumed GRAS status of such naturally occurring substances and thus warrant formal premarket review and approval by FDA. Likewise, minor variations in molecular structure that do not affect safety would not ordinarily affect the GRAS status of the substances and, thus, would not ordinarily require regulation of the substance as a food additive.
I've already mentioned this more properly from a reliable secondary source, and there it is again, from the original policy statement.

no where in the GM suite of articles does WP come even close to saying that GM food is "government-tested Let's replace "government-tested" with: we don't want to present the regulatory process in a way that may give the wrong impression of the nature and degree of government involvement. If the usual FDA procedure is to examine voluntarily submitted applicant data to see whether or not a GM product should be subject to premarket testing, or whether it is premarket approval exempt per GRAS designation, then we should say that, and explain how substantial equivalence is applied to make this determination (as described, for example, in the three paragraphs just excerpted). --Tsavage (talk) 03:18, 29 July 2015 (UTC)

Perhaps we should simply add something like this segment from the Michael Taylor article to the relevant GM articles: The 1992 guidance, for example, treats "transferred genetic material and the intended expression product or products" in food derived from GM crops as food additives subject to existing food additive regulation, under which that material may be considered either generally recognized as safe (GRAS) or not, initially at the producer's determination.[8] If the food additive is not GRAS, the producer is required to submit data proving that the food additive does not "adulterate" the food - in other words, that the additive is not injurious to health. taken from the FDA's website. petrarchan47คุ 06:29, 29 July 2015 (UTC)
  • Note: the above needs to have a secondary source, and probably needs attention at the original article (Taylor) as well - per WP:RS: While specific facts may be taken from primary sources, secondary sources that present the same material are preferred. Large blocks of material based purely on primary sources should be avoided. All interpretive claims, analyses, or synthetic claims about primary sources must be referenced to a secondary source, rather than original analysis of the primary-source material by Wikipedia editors. So I revoke my suggestion to add this bit as-is. petrarchan47คุ 17:04, 29 July 2015 (UTC)
Most of what I am doing above there, is just describing what the regulatory process actually is so that we are starting with the same set of facts. Jytdog (talk) 17:21, 29 July 2015 (UTC)
Tsavage, I would translate the key points of your quote roughly as follows:
  • Paragraph 1: "Food additives are defined as substances that are intended or expected to be introduced into food. If GMOs are regulated under food additive regulation, then the additives would be the introduced nucleic acids and the intended expression products."
  • Paragraph 2: "Nucleic acids in themselves do not raise safety concerns, and as such nucleic acids are GRAS." [NB: not GMOs as a whole]
  • Paragraph 3: "The expression products will probably be GRAS if those expression products are already consumed in food at equal or higher levels. This also applies to minor variations if those variations do not affect safety."
  • Paragraph 4 (which you didn't quote): "The expression products may not be GRAS if they differ significantly from those already consumed in food, so in such cases regulation as a food additive may be required."
--Sunrise (talk) 23:01, 29 July 2015 (UTC)
@Sunrise: I suppose your point is "not GMOs as a whole" - are you clear on the FDA definition of "food" in that policy, which encompasses ALL food, it doesn't seem that you understand how the FDA considers "GMOs"? The larger question is, why are you providing your own "translation" of a primary source, when I've already provided a high quality secondary source that summarizes the GRAS aspect of that FDA policy? The Library of Congress source is fully equipped with its own citations, which provide additional detail as required, so in this case, we don't need to spend more time arguing about reliability of sources, unless the purpose is to argue. To repeat the relevant material from a few replies above:
  • Under the FFDCA, substances added to food can be classified either as “food additives,” which require approval from the FDA that they are safe before they can be marketed,[45] and substances added to food classified as “generally recognized as safe” (GRAS), as to which preapproval is not needed.[46] In a 1992 policy statement, the FDA reaffirmed that in most cases it would treat foods derived from GMOs like those derived from conventionally bred plants, and that most foods derived from GM plants would be presumptively GRAS. However, with respect to a GMO product “that differs significantly in structure, function, or composition from substances found currently in food,” premarket approval of the substance as a food additive would be required.[47][9]
Out of curiosity, do you have expert level familiarity with the US food regulatory framework and how it is applied to GM products? In any case, it would seem best for the editing process to stick to good quality secondary sources when they are available (which is what I have attempted to do with Jytdog), rather than spin out discussion based on original interpretation of primary sources.
The bottom line is that without mention of GRAS in the GM food and regulation articles, there is a significant omission of basic information on US GM food safety regulations and procedures, which in turn is central to the context for a Wikipedia summary statement about GM food safety. --Tsavage (talk) 23:54, 29 July 2015 (UTC)
I was responding to your request to "please translate this" - I wasn't making any points, or indeed looking at the context of the document. It did seem unusual that you were requesting this analysis for what is indeed a primary source. (I included the "NB" because I thought that was a place where you might be misunderstanding the source.)
I don't have great familiarity specifically with regulation or legal decisions (Jytdog has more), though I'm able to competently discuss the science involved if it becomes relevant. To the extent that your point is that the regulation section should include a mention of GRAS, I don't have any objections to that, though directly including something like "most foods derived from GM plants would be presumptively GRAS" would probably need context in the form of explaining why that would be. Sunrise (talk) 07:34, 30 July 2015 (UTC)
@Sunrise: Unfortunately, not helpful. The quoted material is clear, and I was inviting Jytdog to explain his contrary claim, "Your takeaway that the FDA actually classifies GMO food as GRAS is not accurate." He still hasn't responded.
As for putting GM plants would be presumptively GRAS in context of substantial equivalence, and the fact that the US does not have federal legislation specific to GMOs, and covers GMOs from a position of "it's the result not method that counts," that's already been covered in this particular discussion (if you're stepping in to answer for Jytdog, and haven't read the entire thread, please scroll up). I will start editing content eventually; right now, I'm following the Talk-first process to the perhaps bitter end, to see if any sort of actual collaboration eventually results, or whether some editors keep arguing endlessly. --Tsavage (talk) 11:45, 30 July 2015 (UTC)
Working to find a consensus on a complex and controversial issue is not "arguing endlessly". In any case, it is unclear what content you are proposing at this point in time. What are you proposing? Jytdog (talk) 11:51, 30 July 2015 (UTC)
By "context" I was thinking more broadly, in terms of describing the scientific reasons why the majority of current GMOs do not in fact raise safety concerns (and thus why a statement like "usually GRAS" might be reasonable). I wasn't answering "for" anybody - I just noticed a point about which it seemed you had made a good-faith request for clarification, so I decided to answer it. Also, if you haven't actually said that the "FDA actually classifies GMO food as GRAS" per Jytdog, then my NB was unnecessary, though you definitely said that GRAS is the "default" classification for GM plants, which AFAIK is also incorrect. Sunrise (talk) 21:20, 30 July 2015 (UTC)

@Sunrise:, @Jytdog: You don't seem to be reading or addressing: "the FDA reaffirmed ... that most foods derived from GM plants would be presumptively GRAS"[10] Continuing to argue against that without addressing it is what I'd call arguing endlessly.

Jytdog, there's no additional content proposal yet, we're discussing your objection to the "inadequate regulation" part of the proposed new safety summary; you'd said:

  • "the view that the regulatory process is inadequate is not mainstream. It is significant minority at the most"
  • "It is FRINGEy and based on a FRINGEy understanding of the science. It is not the mainstream view and the statement is UNDUE for that view per NPOV and PSCI"

Since the Regulation section only superficially describes regulation, and primarily covers the US (in a paragraph that is incomplete, misleading, and sourced to a FAQ published by Monsanto), sorting out regulation seems to be a necessary step. GRAS is a cornerstone of FDA food safety policy that's unmentioned in the article. --Tsavage (talk) 23:50, 30 July 2015 (UTC)

Tsavage, you're continuing to quote the same primary source after (rightly) asking us to keep to secondaries. Could you please specify what you think is not being addressed? For my part, I've already agreed that a discussion of GRAS would be a good addition to the Regulation section, as long as it can be described neutrally. Sunrise (talk) 21:07, 31 July 2015 (UTC)
@Sunrise:, this IS a secondary source, it's been repeatedly linked to, described - "why not instead use a gold standard secondary source, such as a Library of Congress brief on Restrictions on Genetically Modified Organisms: United States (Mar 2014, last updated 9 Jun 2015), prepared to answer exactly such questions" - and is STILL not being acknowledged by you or Jytdog.
Jytdog has changed venues for this discussion, so there's no point in continuing here at the moment. An overhaul of the Regulation section (and the whole article) is needed, but for now I guess it's seeing what happens at the RS noticeboard. Endlessly arguing the same things over and over and over... --Tsavage (talk) 00:33, 1 August 2015 (UTC)
Tsavage It might be a mistake to think the RS noticeboard is peppered with uninvolved peers weighing in with guideline based responses. Instead, the same folks who supported the sources in the formal RfC are questioning how anyone could doubt the prestigious AAAS. Perhaps we should hold another RfC here on the use of this source. Otherwise, the RS noticeboard is serving as an informal RfC that only a few people know about. Seems a bit like forum shopping, hoping for a more friendly audience. But I'm not sure we'll get the most neutral result without another formal RfC. petrarchan47คุ 14:53, 6 August 2015 (UTC)
@Petrarchan47: In the current situation, I don't see any choice other than to follow the discussion through these twists and turns, which have now led to RSN. I don't want to be part of subjecting editors on a site-wide board to random, out of context parts of the ongoing discussion that is and belongs here, but the alternative is to not participate there, and risk some new mini-"consensus" on some detail, that can be brought back here to stretch things out further. Right now, the RSN question is trying to establish only the authority of the AAAS, not whether it supports the content, which is kinda bizarre, since in any evidence-based approach, evidence based on authority alone has practically no value - "because the AAAS said it, it must be valuable" isn't a WP:V argument, which is the policy it all comes down to. In any case, the discussion eventually has to return here. I'm for now still just refusing to be worn down. :) --Tsavage (talk) 03:59, 8 August 2015 (UTC)
Sorry, I seem to be editing far too quickly today and missing things that I shouldn't - again below, and once more on a different article. My apologies, and struck. I'd just like to make it clear that as I implied in my previous comment, I have no objection to using the secondary source for this article. I'm also happy to continue discussing, since I don't think the RSN discussion directly affects this (though I'm going to sign off for now, and de-stress or otherwise fix whatever it is that's causing problems for me today). Sunrise (talk) 05:42, 1 August 2015 (UTC)
  • Support revised language as a whole, not for its individual parts. By including both portions, the language is more WP:NPOV by more accurately reflecting the ambivalent statements and uncertainty found in the WHO (and other credible sources) with regard to adequacy of GMO food safety testing. David Tornheim (talk) 22:23, 27 July 2015 (UTC)
  • We should describe what actually happens, not what should happen. The US is way past "rule of law". We live in a world of "whatever". How about describing what happened in the potato case (assuming it's not a one-off)? Lfstevens (talk) 07:03, 29 July 2015 (UTC)
Lfstevens, I don't understand your second sentence - would you please elaborate? thx. Jytdog (talk) 17:21, 29 July 2015 (UTC)
Lfstevens, I second Jytdog's request for clarification, and expand it to the whole of your proposal. Is "what actually happens, not what should happen" a suggestion that we take a less academic, more investigative, journalistic approach? If so, that sounds...exciting. I doubt it would achieve much support, but I'd like to hear more! --Tsavage (talk) 00:56, 30 July 2015 (UTC)
  • Support of version: While GMO Proponents, such as the AAAS[1] and AMA[2] and Pamela Ronald[3] claim there is a "scientific consensus" regarding the safety of GMO technology and GMO foods, published peer reviewed articles in scientific journals challenge this claim of a scientific “consensus”[4] and report a lack of sufficient study of GMO safety. -- No scientific consensus on GMO safety. The current article version does not mention a consensus, i can except the current version as well, but the issue might be explained in more detail elsewhere. Also i support the revised version ""According to the World Health Organization, genetically-modified foods currently available on the international market are not likely to present risks for human health[1], but the approval process for genetically-modified crops is considered inadequate" Many of the other articles still claim there is a consensus. -- after looking more closely at the sources it appears that the current version is acceptable, but references show issues.prokaryotes (talk) 03:47, 27 August 2015 (UTC)
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