Beyond Non-GMO for Supplements

The interest in non-GMO (genetically modified organism) certification for food and supplement products in the United States has skyrocketed, even for things like bottled water. Reliable scientific evidence has shown the controls and verification of non-GMO have little (if any) impact on product safety, quality or “healthiness." But the movement has a legitimate purpose and lessons to offer.

Non-GMO represents a widespread lack of consumer trust in food and supplements, in the companies who make them, and in the governments that regulate them. Like many debates, there is some truth offered by both sides.

A key assumption about non-GMO often made by consumers and industry is that it’s a substitute for other necessary attributes of quality, such as testing for impurities or adulterants that can be harmful. A case can be made that non-GMO requirements often put additional, unnecessary strain on supply chains. Those in the sacrosanct brotherhood of raw materials sourcing and quality professionals are aware of the tradeoffs that come from meeting all the various requirements.

Many appropriate criteria are used to select an ingredient—including specifications, limits for contaminants, supplier quality and verification, supplier history and experience with the product, supply risk assessment, good agricultural practices (GAP) verification and others. Fortunately, most supply chains for food ingredients are designed to ensure a basic level of safety. The recent, sudden shift toward availability of new sources of minimally processed ingredients that can be certified non-GMO or organic had good intentions to improve quality. But new regulatory guidelines and the Food Safety Modernization Act (FSMA) are also here now, and they offer broader and relevant aims to support public safety. What often goes unnoticed is the consumer-preferred certification du jour, as primary purchasing criteria, can put us at risk of selecting less-safe and lower-quality materials.

Many people, especially those outside of the United States, have observed that Americans want everything. We want it “new and improved;" to “taste great;" to be “natural," “healthy" and free from “toxins;" to be shelf stable; and available at a reasonable price. Despite the demands, Americans assume that products marketed are safe and meet label claims. Meanwhile, they have a mistrust of government and corporations to determine safety and quality of products. As a result, now we also want our foods unprocessed, traceable, local and sustainable. The demands seem reasonable to someone who doesn’t understand how difficult it is to ensure food safety for more than 300 million people. But they are completely nutty to someone who does. We just can’t have everything all at once.

Although the FDA system is a global model for ensuring safety of food, it’s under a lot of stress. The lack of premarket review for food and supplement ingredients and products, in spite of the incredible growth of new materials entering U.S. borders every year, is an example of the leeway that favors business and innovation. We are given tremendous freedom, as well as tremendous responsibility. The food industry has responded, in setting up supply chains that mostly produce high-quality, safe ingredients for food. Now, new food safety and dietary supplement regulations and self-regulatory efforts for supplement ingredients, in the face of incredible industry growth, offer a unique set of forces like no time in recent memory.

During a time of massive evolution, we risk throwing away effective preventive controls by prioritizing consumer preferences over public safety. A few scenarios show the balance between public safety and our demand for non-GMO/minimally processed/new and improved. Here’s one:

• That unprocessed, certified organic quinoa that is GPS traceable to a family chicken farm in Ecuador owned by Uncle Eddie, who started growing quinoa just this year due to the spike in demand? Unfortunately, Uncle Eddie did not have prior experience in GAPs or the proper training to understand that crops grown next to a chicken farm are considered high-risk for Salmonella contamination. Because of consumer demand for raw, unprocessed ingredients, the quinoa did not undergo any processes that kill Salmonella. Meanwhile, the product arrives with something akin to a Good Housekeeping seal that carries perceived value. Despite the lack of clear preventive controls and effective monitoring, the material is approved for sale because the certification is there.

At what cost (including opportunity cost) does non-GMO certification bear on a firm’s ability to produce safe and healthy products? Could it demand a decision between choosing ingredients for the certification, versus improving material selection criteria and testing for adulterants such as pesticides and mycotoxins? Just because we can trace an agricultural material to a farm and verify it does not contain DNA inserted by man using technological means does not automatically make it safe to consume.

This is not to say the non-GMO and organic programs are worthless; in fact, they offer a great benefit. They have served to educate industry firms who were previously unknowing about the provenance and processes applied to their raw materials. They have brought to focus the level of documentation and trust that consumers ask for in the products they consume to support their health. But we should be cautious in allowing consumers to take control of the ultimate aims for product safety and quality.

As part of supplement raw material industry self-regulatory efforts, non-GMO and organic practices are being discussed within the larger picture. This includes applying food safety principles in a more rigorous way to dietary ingredients; assessing agricultural and collection practices at the field and aggregation levels; improving foreign supplier verification, understanding transformational steps at each point in the process; establishing better specifications and testing for identity and contaminants; and performing risk assessment to determine where to best focus efforts. It is important to include non-GMO and organic as specific but narrow examples of evidence to support the push, because the knowledge gained from them helps us understand how to improve on standards.

The future is in building consumer trust to a level where we can communicate what is being done, and that will be enough. This trust will come from educating to a broader and deeper understanding of quality standards, with evidence in full view showing the requirements are being met. Non-GMO is a good start.

Blake Ebersole has led a number of botanical quality initiatives and formed collaborations with dozens of universities and research centers. As president of NaturPro Scientific (npscientific.com), Ebersole established quality compliance and product development services for supplements and ingredients such as ID Verified™. Follow him on Twitter at @NaturalBlake.