A national thought leader on GMO issues and longtime healthy and sustainable food activist/advocate, Megan Westgate helped launch the Non-GMO Project in 2006. She lives with her family on an organic permaculture homestead in the Lake Whatcom watershed in Washington State and is co-author of The Non-GMO Cookbook. In this interview conducted by Arty Mangan of Bioneers, Megan talks about  how, as a young activist, she was drawn to the issue of GMOs and how  the Non- GMO Project is rigorously providing real information to consumers about what’s in their food.

ARTY MANGAN: I first heard you speak at the Eco Farm conference about 15 years ago, and I was really impressed with the Non-GMO Project. Around that time, I served on a Santa Cruz County subcommittee that ultimately resulted in the County Board of Supervisors banning the growing of GMOs in our county, so I was very excited to hear about your work to inform the public about GMOs in food products because then, and even today, the labeling regulations are woefully inadequate in informing people if a food product contains GMOs. What inspired you to do this work? How did you conceive of the idea of testing for GMOs?

 MEGAN WESTGATE: In the early 2000s, I had a handful of experiences that exposed me to the topic of biotechnology and GMOS at a time when it was not a very public conversation. Some of those touchpoints came through work I was doing as a student activist. I had the opportunity to go to a Ruckus Society activist training camp on biotechnology. They were preparing for a big march in Boston that summer, and the GMO issue was just starting to heat up.

As soon as I heard about this idea of manipulating the genes of our food in a laboratory and then releasing it into the wild untested, I became very concerned and realized how important it would be to make sure that we protected our food supply and our living systems from these experiments.

A few years later, I was working at the Food Conspiracy Co-op in Tucson, Arizona, and I heard about an initiative from a retailer in Berkeley and another one in Toronto to work on labeling GMO food. I had seen firsthand in our food co-op that people were coming into the store looking for foods that were non-GMO, and there wasn’t a clear way to tell. Meanwhile, the application of genetic engineering in the core commodity crops, such as corn and soy, was increasing exponentially. Upwards of 80 to 90 percent of those commodity crops were being genetically engineered and those ingredients were being used in so many packaged foods, and no one really knew what was going on.

So, this idea emerged that we could create a standard and a certification system to help the public know which products were non-GMO. I still feel that the fact that this is necessary is pretty ludicrous. The lack of application of the scientific method to the whole process of releasing GMOs into our food supply and into the world is deeply troubling to me; the lack of oversight of the government is concerning. But, on the flip side, I am deeply encouraged by how we, through grassroots activism and public will, have been able to protect the non-GMO food supply in this country despite the corporate money behind developing GMOs and despite of the lack of government oversight. So far, we have been able to protect the non-GMO food supply, and people in North America can now go into a grocery store and easily find non-GMO options.

ARTY: The FDA website claims that extensive research shows that GMOs are just as safe and as healthful as their non-GMO counterparts. What’s the process for a new GMO food to be approved?

MEGAN: There’s almost no regulatory process in place to approve GMOs. The exception to that is something called the Plant Protection Act. Because of the way that traditional transgenic GMOs are developed, they are considered a plant pest because some of them contain genes from Bacillus thuringiensis [a soil bacteria that is a parasite to certain plant pests] and have been engineered to produce insecticide in every cell of the plant.

But the biotech company that produces those GMOs goes through a simple process to show that they’re not a plant pest, and even the ones that probably are still get approved. And that’s it. There is no regulatory process to assess whether they are safe and healthy for people to eat or what their long-term impact on the environment might be. Is this new genetically modified organism going to cause problems for the water supply or soil health? No one knows, because no one is obliged to do that research.

The lack of any application of a genuine scientific process is deeply concerning to me. That process should start with observation and then move into inquiry. None of that has been applied to look at what the impact of releasing a slew of genetically engineered organisms on the living systems of planet Earth, including human health, might be.

ARTY: How often does the FDA reject a new GMO product?

MEGAN: I’m not aware of that happening. And even more concerning is the way the technology is evolving: a lot of genetic engineering is now being applied to things being produced not for crops in the field but in vats inside of warehouses, and those have even less, if any, oversight. Techniques such as gene editing, CRISPR and Synthetic Biology have just about zero regulatory process, so there isn’t even any mechanism for them to be rejected.

ARTY: Michael Hansen, Ph.D., Senior Scientist at Consumer Reports, prior to the Impossible Burger being released, studied how Impossible Burger Inc. used CRISPR to develop the novel protein Leghemoglobin, a molecule that mimics the flavor of beef blood. At a 2016 Eco Farm Conference, Hansen said that the data showed there were unanticipated mutations throughout the genetic sequence of the novel protein. He felt that because of the uncertainties of the potential health risks of those mutations, that there was no way the FDA could rationalize approving the product and yet they did. How are new biotechnologies entering the food system and what are some of the consequences?

MEGAN: One of the things that’s most concerning to me about the new applications of biotechnology is that many of the developers are branding and positioning these products as non-GMO, which is completely inaccurate and unscientific. They’re doing that on the basis of them not being transgenic, meaning that they haven’t combined DNA from multiple different species, which is how GMOs have traditionally been made, and the majority of GMOs coming into the food supply are still coming through transgenic crops. When we started the Non-GMO Project, there were a handful of those crops, and it was relatively easy to track the development of new products because they were being made by just a handful of agrochemical companies, Monsanto being the most widely known.

But Biotechnology is evolving; it’s becoming less expensive and more accessible, and there is a ton of venture capital flowing into it. As a consequence of those combined factors, The Non-GMO Project needs a team of three full-time researchers just to keep track of the new products being developed, and we’re tracking more than 500 biotech companies now, up from just a handful 10 years ago.

These companies recognize that, overall, the majority of consumers in North America don’t want to eat GMOs, so they’re positioning these products as non-GMO, but that’s scientifically inaccurate because they’re still been developed using biotechnology. There is a well-established international definition for what biotechnology is. It’s the definition that we use in our standard. It’s the same definition that’s used by the UN. It’s used in the Cartagena Protocol. All of these new products are incontrovertibly produced using biotechnology, i.e., using in-vitro nucleic acid techniques to alter DNA. It is different than traditional breeding out in a field; it’s manipulating DNA in a laboratory, and whether or not the resulting GMO is transgenic [taking a gene from one species and inserting it into another species], it’s still biotechnology, and anything produced with these techniques is a GMO.

The concern about working in this way, as Michael Hansen has spoken to, is that we’re very far from being able to understand and control DNA sufficiently to make changes like that in our environment and bodies and understand the long-term impact to the entire web of life, so the whole premise is faulty.

Bioneers influenced me in my early years coming out of college and doing activism by helping me be grounded in the sense that we have to look at the interconnectedness of living systems. We have to look at the whole. We can’t only break things down to their constituent parts and think that gives us a full understanding. That’s the essence of colonialist thinking that has been imposed on human beings but also on nature with technologies such as biotechnology and the production of GMOs. It’s hubris to think that we can reduce things in an incredibly complex system into their parts and manipulate those parts and gain full control of the outcome without unintended consequences. We know that that’s absolutely not true. We know that at a scientific level, and many of us also sense it on an intuitive level, that it’s disrespectful and risky to go into living systems and manipulate them in extractive ways.

ARTY: With all the risks and uncertainties you just talked about, let’s discuss the current GMO labeling standard. What is the reality of the national GMO labeling law. Is it really serving consumers and giving them proper information?

MEGAN: The only reason we have any sort of federal GMO labeling in the United States, after many years of there being no movement on it, is because grassroots campaigns built up momentum at a state level for GMO labeling laws. At the time that the National Bioengineered Food Disclosure Standard was passed, there were 54 GMO labeling laws on ballots in 26 states, and in Connecticut, Maine and Vermont labeling laws had successfully been passed. One of the key provisions of the National Bioengineered Food Disclosure Standard was to supersede all of those state laws and roll them back and take away the power they had to actually give eaters/shoppers in those states informed choice about what they were eating. So, the only reason that there was momentum at a federal level is because the biotech industry felt threatened by the transparency that state labeling laws required.

The national law, which supersedes those state labeling laws, provides almost no information to consumers about whether or not there are GMOs in a product.

And perhaps just as bad is the language used to disclose that the product contains GMOs, the word they can use is “bioengineered.” We did a lot of research, as did other groups such as the Center for Food Safety, for example, to find out if “bioengineered” is a term most Americans recognize as having anything to do with GMOs, and the answer is no. Bioengineered has typically been used in the medical space, so they clearly chose language that would obfuscate the truth.

And beyond all of that, only a very narrow subsection of products requires labels. Labels of any kind are only required for products that have testable GMO DNA intact, and for the most part, the testing methods used to identify GMOs at a molecular level are not able to do it accurately once a product has been heavily processed, which, of course, is the case for most packaged foods. That’s why to meet the Non-GMO Project standard we require that testing be done at a point in the supply chain where there is still testable DNA intact.

Another huge loophole with this law is that the majority of GMOs grown in this country are grown for animal feed. For example, the majority of corn, one of the biggest agricultural crops, goes to animal feed and ethanol. That’s why with the Non-GMO Project standard we require testing of animal feed, but that’s completely out of the scope of the National Bioengineered Food Disclosure Standard. So really, the truth is that the national standard does not provide any meaningful insight to consumers as to whether or not a product contains GMOs.

The Non-GMO Project has continued to be really meaningful for shoppers because people know that when they see the Non-GMO Project logo (a butterfly) that real, rigorous testing has been done, that we’ve looked to see if new GMO techniques – such as CRISPR, Synthetic Biology, gene editing, etc. – have been used (because those too are also completely excluded from the  National Bioengineered Food Disclosure Standard).

ARTY: Enforcement is complaint driven, and if my understanding is correct, the only consequence of violating the regulation is that the FDA will post the violation on their website.

MEGAN: Yes, that’s correct. In the final version of the rule that passed, there were no financial penalties for violation, so basically there are no enforcement provisions. That’s why I say when you look at how meaningless the regulation is overall and at the timing of its passage, it’s crystal clear that its only purpose was to block the meaningful legislation that was getting put into place in certain states.

ARTY: Essentially the Non-GMO Project is taking on the responsibility that the FDA is defaulting on.

MEGAN: It is. And that’s really why we started the Project, because even at the time that the project formed, there had already been years of efforts to get the federal government to do something. In the EU, GMOs have to be labeled. In many countries around the world, governments ensure that citizens can easily see which products have been produced using biotechnology. There were efforts in the United States to get those same protections in place for our citizens, and it’s because they weren’t going anywhere that we started the Non-GMO Project, and where things ultimately landed with the National Bioengineered Food Disclosure Standard confirmed that our best bet was to do this ourseleves, as a consumer movement, so we could define for ourselves what we are concerned about and what information we want to know about each product we consume.

ARTY: Occasionally my wife will come home with a product that’s labeled “GMO free.” And I’ll wonder: “What does that mean? What is their standard?” But when I buy something that’s certified by the Non-GMO Project, I know what that means. What distinguishes the Non-GMO Project’s certification from other labels that make a GMO free claim?

MEGAN: We are a nonprofit organization, and we have the most rigorous and the only third-party standard for GMO avoidance. What that means is we have a standard that’s been developed according to international best practices, and we have public comment periods. There’s a high value placed on transparency and also opportunities to participate in our standard revision processes.

We also have separation of function. We work with accredited testing labs. We work with technical administrators. Everyone has a separate role, and our function as a nonprofit is in setting the standards. it is not the Non-GMO Project itself that directly evaluates products. We contract that out to top notch accredited labs, i.e., an independent, highly respected third party. We set standards, we oversee the implementation of the standards; but there are outside certification experts who do product reviews and assess whether or not they meet our standards. And all the information about who our labs and our technical administrators are, what the requirements are for all of them, and what our standards consist of is all publicly available on our website. There’s nothing like that level of transparency with any other non-GMO certification claims out there.

ARTY: For human food and supplements you have an action threshold for high-risk inputs of less than 1% GMOs. How do you establish that threshold? And what is your response to people who criticize that for not being 100% GMO free?

MEGAN: That threshold is based on what’s in the European Union standard. In the EU, if something is more than .9% GMO, it has to labeled. And because we didn’t have that provision in place at a regulatory level in the U.S., we did the inverse of that and said, well, okay, anything below .9% is our standard.

There’s also a pragmatic element to it. By the time the Non-GMO Project started in 2007, the majority of corn, soy, canola and cotton was already genetically engineered. It had already been released into the environment. Corn is really promiscuous. Its pollen can travel large distances. For someone who is concerned about or doesn’t understand why it’s not zero, picture an organic farmer who’s growing organic corn, and a little bit of pollen with GMOs blows in from their neighbor’s fields. We believe that there should be testing and that GMOs need to be kept under a strict limit, but at the same time, it would be almost impossible, especially with corn, to have a zero limit. You wouldn’t really any food available in the United States that could meet that standard, just because of how widely GMOs are produced.

ARTY: 99.1 % pure is a pretty high standard in this dirty world we live in.

MEGAN: We have the most rigorous standard that anyone has, and it’s not an easy standard to meet. Companies, farmers and processors have done a tremendous amount of work to build a non-GMO supply chain to respond to eater demand. One of the things that inspires me the most, even 20 years into doing this work, is just seeing the power that eaters have to change the way our food is grown and made, and really, from the simple demand of shoppers in grocery stores saying they wanted non-GMO food, it led to this massive shift. We’re getting to 99.1% non-GMO. The work to do that throughout the entire supply chain has been enormous, and it’s happened because of the eater demand. I find that deeply inspiring. It helps me imagine what else can we could do to change our food system simply by being informed and educated, and asking questions.

ARTY: Are you able to detect the use of CRISPR and other newer technologies in your testing?

MEGAN: There are scientists working on developing tests for them, and there are early results showing that gene-edited products can be detected with a fair amount of confidence. The challenge is getting to affordable, commercially viable testing for all of them.

So right now, for the new techniques, we require affidavits, which is why we have three full-time researchers tracking everything. As far as I know, we’re the only organization in the world maintaining this database of all of the developers and all of the products, so that we know where to look and where to ask questions. Without that information and without the testing, it’s pretty much impossible to control for these new GMOs, especially because the developers of these products are positioning them as non-GMO, and that’s happening throughout the supply chain and food industry, so brands, when they’re procuring ingredients, are getting things that are being sold to them that as non-GMO that in fact have been developed using biotechnology, such as synthetic biology products. It takes a lot of work for us in our certification program to do the research and make sure that we’re asking questions where they need to be asked, and getting the paperwork in place that is necessary to have confidence about the non-GMO status.

ARTY: You have taken on some fairly powerful entities. You’re doing the job that the FDA should be doing. I’m sure the biotech industry is not a big fan of the Non-GMO Project. Have you gotten pushback or pressure from any of those entities?

MEGAN: Not directly. I do think that it’s partly because of the approach that we’ve taken. While I certainly have serious concerns and objections and a sense of what is right that is different than what’s happening, we’ve been committed to not being in dualistic mindset of right and wrong and engaging with a fighting energy that often happens in activism, and particularly in non-GMO activism. We’ve made it less about attacking Monsanto and more about affirming that we have a right to know what’s in our food.

People have a right to safe, healthy food. People have a right to feel good about what they’re putting into their bodies and feeding their children. That approach has diffused some of the pushback that might otherwise have been there, because that’s a pretty hard thing to argue with. I believe that increasingly, even more so than when the project started, we’re at a time in human history on planet Earth where divisiveness does not serve us. That doesn’t mean that we don’t need to stand stronger than ever for the things we believe and to speak the truth as we see it, but it also means that we can’t afford to be putting our energy into the drama of fighting. We need to put our energy into creating the reality to support the health of living systems on Earth.

ARTY: How do you assess the impact of the Non-GMO Project on the market?

MEGAN: For me, one of the main things I look at is just how many verified products we have, which at this point is more than 120,000 SKUs [the unique identifying number for each product] that are in the marketplace that have the butterfly on them, and that’s mind-blowing to me, because when we started the project, it really seemed like a long shot. There were entrenched corporate interests that were influencing regulations, that were influencing development, that were influencing public opinion through marketing dollars, and I wasn’t sure that we would ever get our butterfly onto a single product.

I remember in the first few years when we set our goal of getting 10,000 products verified, it seemed so audacious – but it’s good to have audacious goals.  Now, all over North America, people have access to non-GMO choices and to clear information that helps them make those choices.

People have the power to change the way food is grown and made; we have the power to choose new stories. We all have the gift of imagination that can create something new. Food is such an incredible nodal point in the health of people and of living systems on the Earth.  And non-GMO is really just one way of doing that.

The Non-GMO Project is also starting to look at nutrient density and the connection between that and soil health and regenerative agriculture practices. And I’m really excited about what, as eaters, we can continue to dream together for a new future where food is actually nourishing all life.