Time Running Out on Public Comment on Cloned Meat

I am republishing this article as a reminder that the end of the public comment period is ending. If you do not want to write to the FDA directly, please sign the petition at The Petition Site.

As you have likely already heard, the FDA (U.S. Food & Drug Administration) has determined that cloned meat and milk are compositionally no different from non-cloned meat and milk (FDA Press Release). I would urge people to submit their comments to the FDA. The comment period ends April 2, 2007.

The "industry" argues that cloned meat and milk is compositionally no different from non-cloned meat and milk, and the FDA has accepted this assessment. A study done by Japanese scientists, found that feeding mice on a 14 week diet of cloned meat didn't seem to hurt them.

I have problems with introducing cloned meat and milk into the country's food supply. Those problems go well beyond the issues of personal squeamishness. They even go beyond my personal ethics. There are major questions of food safety involved. There are issues of who this ruling benefits, and there is the issue of cost.

First, let's address food safety. I see this in two categories. One category is actual health safety of meat and milk, and the other is food security. While meat and milk from cloned animals may or may not be "compositionally" the same as meat and milk that is not cloned, how that actually works within the food supply is a totally different issue. We are consistently bearing the costs of the increasing industrialization of our food supply. From the dramatic environmental impacts of hog factories, to "mad cow" disease, to e-coli and lysteria contamination, it is increasingly clear that there are major problems with the "efficiency" of mass production, processing and distribution of the food supply. Such methods may be "efficient," and profitable, but they clearly are not safe.

Cloning introduces another level of complexity and potential error to a system that is already having problems. For example, David Hennessey, in a 2003 study done for the USDA entitled "Slaughterhouse Rules: Animal Uniformity and Regulating for Food Safety in Meat Packing" found that while increasing carcass uniformity increased line speed, it also increased the level of human errors in processing. In other words increasing the "uniformity" of product (and a significant part of the cloning argument is uniformity) decreasing the attentiveness of human operators at processing facilities. This dramatically increases the probability of an error that could have widespread health implications.

The uniformity of cloning presents yet another health issue. That is that dangerous bacteria and viruses may mutate to maximize on the cloned animals. This could be significant both in the raising of those animals, but particularly in the processing areas. Bacteria would be seeing an identical environment day after day. It seems likely that "custom adaptations" would be likely under such a scenario. This could result in a major health event, which in combination with processing and distribution processes, could be at "wildfire" stage before it is controlled.

The second part of the "safety" issue related to food security. Using cloning in food production - be that plant or animal - decreases the security of the food supply. A bug, bacteria, virus, blight, or genetic modification in another species or crop, can decimate an entire clone line. For example, much of the corn crop in the United States is essentially a single clone. Anything that disastrously attacks that line could sweep across much of the corn supply of the United States. The same thing could happen to a cloned meat and milk supply. In short, cloning in the food supply puts our "eggs" in increasingly few baskets. In doing so, it undermines the security of the food supply.

Another aspect of food security is who controls the food supply. With the increasing industrialization of the food supply, security has dramatically declined. A multitude of producers are increasingly being replaced by corporate agriculture. An array of processors located in communities across the country are increasingly boiled down to massive regional plants. This is yet another example of putting all the eggs into fewer baskets. However, there is an issue beyond this in that the technology itself places us in a more vulnerable position. The cloning of meat and milk goes to the hands of the few, and the hands of the corporate. Increasingly food supply is concentrated and those with the reins have the power. Regardless of any benign intent on the part of corporations, past practice has clearly shown that profit trumps safety. When the controls of government are largely shaped by the corporate "customer" then the consuming public is at risk. The risk in this case is a basic necessity - food.

Finally, one has to ask "Who benefits from cloning?" Cloning is tremendously expensive and fraught with a high failure rate. Contrary to the hype and myth, cloning will not create the perfect cow. In fact, geneticist John Wolliams (in the preceding article) argues that standard breeding programs do increase quality and production across the generations of a herd. However, With a clone, that improvement would cease. Cloning is a brick wall for progress."

So if cloning is expensive and unpredictable, stops improvements in the herd (or crop), and increases the safety risks, why is it being pushed? I see two possibilities. One possibility is the patenting of the gene lines of corporate clones. This would allow the cell line holders to extract profit on an ongoing basis. Farmers utilizing cloned animals for breeding (since they are too .expensive to eat) would owe a fee to the patent holder on each calf produced, and perhaps on milk produced. In others words, cloning provides an ongoing profit stream for the patent holder.

The second possibility is that the approval of cloned meet and milk is a stepping stone to a different product and goal entirely. That purpose would be the approval of transgenic (splicing genes from different species into one animal) cloning. There are numerous hints that this may actually be the goal. First is that the real money in genetic manipulation of animals is getting them to produce human proteins and antibodies. Try a search on transgenic human protein, and you will find pages of studies being done. Studies such as: Recombinant human protein C expression in the milk of transgenic pigs and the effect on endogenous milk immunoglobulin and transferrin levels; or Transgenic Mice Expressing Recombinant Human Protein C Exhibit Defects in Lactation and Impaired Mammary Gland Development, or Transgenic Livestock as Drug Factories from "Scientific American" January 1997.

In conclusion, I am writing the FDA to argue against the approval of cloned meat and milk. I feel that it will not improve the quality or safety of our food supply, and concentrates control of our food supply into too few hands. Further, this approval facilitates the path for the approval of transgenic animals. If corporations want to pursue transgenics, it should be clearly isolated in the medical arena and not within the food supply. For all of the failures of cloned animals (which one assumes could enter the food chain legally), the failures in transgenics are even higher and more suspect. They should be clearly isolated from any aspect of either herd, production or processing.

Other Resources
** FDA Comment Submission form: Docket # & Title: 2003N-0573 - Draft Animal Cloning Risk Assessment; Proposed Risk Management Plan; Draft Guidance for Industry; Availability

FDA. A Risk-Based Approach to Evaluate Animal Clones and Their Progeny - DRAFT

FDA Says Clones Are Safe To Eat - also in the Seattle Times

David Hennessey. August 2005. American Journal of Agricultural Economics. Slaughterhouse Rules: Animal Uniformity and Regulating for Food Safety in Meat Packing

L. Kelly. Review of Science Technology, 2005, 24 (1), 61-74. https://www.oie.int/eng/publicat/rt/2401/24-1%20pdfs/06-kelly61-74.pdf
"The safety assessment of foods from transgenic and cloned animals using the comparative approach"

Posted by rowan at March 27, 2007 6:16 AM | [eMail this article!] |