February 12, 2014

A Critique of the Soil Association’s Opposition to Golden Rice

Patrick Moore, Ph.D.


The Soil Association, with 27,000 members, is the largest organic food organization in the UK, responsible for the certification of 80 percent of organic food production. They have issued a document “Golden Rice Briefing” (undated, but by the references clearly recent) in which they set out their “reasons” for their opposition to Golden Rice. Golden Rice is a genetically modified variety of rice produced for humanitarian purposes to reduce the more than two million childhood deaths caused by vitamin A deficiency each year.


While we understand that most organic food standards forbid the growing of GM varieties we believe it is immoral for a food organization to repeat the lies and fear tactics of anti-GMO activists such as Greenpeace, GMWatch, and Friends of the Earth. Specifically we condemn the Soil Association's following statements and positions:
  • The Soil Association states that the more than 3 billion people who eat rice as their staple food should give it up altogether, as a way of addressing vitamin A deficiency. It is impossible to give up one’s primary source of energy without starving to death.
  • They associate Golden Rice with cancer. This is an irresponsible fear tactic.
  • They indicate that they are against the fortification of foods by adding nutrients, which would set back human health more than 100 years.
  • They claim that Golden Rice is a “waste of time and resources”. When Golden Rice is released and is adopted it will prove to be one of the most cost-effective cures on a per capita basis in history. Their assertions indicate a dismal state of knowledge about genetics, biochemistry, nutrition, and science in general.
  • They have joined those extremist groups that are responsible for prolonging the approval of Golden Rice. They would sacrifice two million children per year on the altar of their ideology.
  • They repeat the red herring that beta-carotene in Golden Rice might break down before it is eaten. This is an ignorant assertion and is only mentioned to spread doubt.


Patrick Moore, Ph.D., Leader, Allow Golden Rice Now! Campaign

February 2014



“Healthy Soil, Healthy People, Healthy Planet” – this is how the Soil Association presents its objectives.


It is baffling; to say the least, how the Soil Association thinks preventing the introduction of Golden Rice could lead to Healthy People. I have supported Golden Rice since it was announced in 1999. I find it hard to believe that anyone but the most callous misanthrope would oppose it, given that it could prevent more than 2 million child deaths per year. Here is my rebuttal of the Soil Association’s science-retarded campaign to prevent Golden Rice from playing an important role in saving these children from blindness and death.


I have inserted my annotated comments in green throughout the text.


Here begins the Soil Association’s Document:


Golden Rice Briefing

A symptom of poverty


Vitamin A deficiency is widespread in many parts of the developing world resulting in the blindness and death of millions of children. It is a symptom of the fact that people are so poor they have to survive on virtually nothing but rice, which lacks certain nutrients.


The most important missing nutrient is beta-carotene which all animals, including humans, require and from which they synthesize vitamin A.  Neither white rice nor brown rice are effective as a source of vitamin A.   Why does the Soil Association refer to “certain nutrients” when it is certain that vitamin A deficiency is the cause of these millions of deaths? The reason is clear. They want to set the stage for the argument that just adding a source of vitamin A to the diet is not sufficient to prevent these deaths. In this they are dead wrong but it doesn’t stop them from the attempt to obfuscate.

Yes vitamin A deficiency is a result of poverty, among people who are too poor to afford a varied diet. But in most places where it is a problem, they do eat at least a cup of rice each day, and they are not starving. If the rice they ate was Golden Rice they would not lose their eyesight and die.


Scientists and engineers get excited when there is the potential for their research to solve a humanitarian issue – and rightly so. However, there are inevitably times when, in this excitement, certain things get overlooked and the research can plough ahead without much thought as to whether it is the right solution to spend time and resources on. Golden Rice is sadly a classic case of misspent time and resources.


If Golden Rice delivers as promised, and all indications are that it will, it will be one of the most cost-effective cures for a major killer in history. 250 million pre-school children are lacking in vitamin A. More than 2 million die each year. Additionally, up to 500,000 go blind and most of these die prematurely. Once Golden Rice is approved for cultivation it will be sustainable in perpetuity. Every Golden Rice plant will breed true and farmers will be able to save seeds and replant them. All other interventions require additional ongoing expense. Golden Rice is anything but a waste of time and resources.


Here are a few numbers to compare: We believe the total annual cost of distributing vitamin A capsules is more than US$500 million). During the 8 years it took to develop Golden Rice (1991-1999) about US$4 billion was spent on the distribution of vitamin A pills. The Golden Rice Project spent $2.4 million on the science during that same period, that is 0.006% of the cost of the pills. The total cost for Golden Rice development and regulatory approval is about $35 million.


Once the Golden Rice is released it will be sustainable forever at no additional cost compared to regular rice. Compare this with the cost of vitamin A pills, which don’t get to many of the people who need them. From 1991 - 2014 the program to distribute vitamin A pills cost US$11.52.25 billion or nearly more than 65 300 times the cost of developing Golden Rice. The annual US$500 million cost would continue forever and still 2 million children die each year despite the distribution of pills.


The Bill and Melinda Gates Foundation is taking the lead in supporting the field trials of Golden Rice. The Helen Keller International NGO will conduct nutritional studies. These organizations do not invest time and money in lost causes. They are very careful in choosing priorities for their philanthropic programs. When it is finally approved for commercial production, Golden Rice will prove to be one of the most cost-effective cures for a major affliction in the history of public health.


Whilst in the eyes of scientists the solution is to create rice which provides one missing nutrient, this is only treating the part of the symptom, not the problem – poverty.


I would argue that the real problem is the death of more than two million children every year. It is surely better to live in poverty with a healthy immune system and the sight of both eyes than it is to be blind or dead. It would be wonderful if we could rid the world of poverty. Perhaps that could be the next step after curing this deficiency that takes more than two million innocent children each year.


 In the eyes of humanitarian experts, the solution is to reduce the number of people having to survive on rice in the first place. It is poor distribution and access, both to other foods and the tools and skills to grow them, which are the main reasons children are going blind. Furthermore, they are suffering from broader malnourishment than just vitamin A deficiency.


Here a false dichotomy is drawn between “scientists” who are portrayed as misguided, and “humanitarian experts” who are somehow wiser. In fact the two inventors of Golden Rice, Professors Ingo Potrykus and Peter Bayer, are humanitarian scientists who were aware of the vitamin A crisis and turned their science skills into crafting a solution. They then ensured that they could donate their technology, without any financial reward, to assist the in developing countries. Neither has worked for a corporation but rather in government labs and universities.


One would imagine that the Soil Association, representing farmers and such, would know the difference between a “staple food” such as rice, corn, potatoes, cassava etc. and “nutrient” foods such as green vegetables, fresh fruit, nuts etc. No humanitarian would want to “reduce the number of people having to survive on rice”. Rice, like the other staples, provides the calories, in the form of starch, which gives the body energy. All cultures rely on one or more staple foods. Nearly 3.5 billion people rely on rice as their staple food. Unfortunately it does not have as many nutrients as corn or potatoes.


The people who die from vitamin A deficiency are not wealthy enough to afford both a staple food and additional nutrient-rich foods. They might be able to afford more nutrient-rich foods if they gave up rice, but then they would likely starve for lack of calories (energy).


It is not the distribution system that causes children and young mothers to die from the nutritionally acquired immune deficiency syndrome or to go blind, it is lack of vitamin A. While there may be other nutrients that would be beneficial for these children, they would not be dying by the millions if only they had a source of vitamin A.


GM technology out performed by less glamorous solutions

The best solution to vitamin A deficiency is to use supplementation and fortification as emergency ‘sticking-plasters’, and in the meantime, for funding support and research to go into measures which tackle the broader issues of poverty and malnutrition.

There are already up to half a dozen strategies used to tackle vitamin A deficiency. Sadly they are less exciting to some journalists, politicians and scientists than the idea of beta-carotene producing rice, containing genes from a bacteria and maize plant. But they work and have saved many lives.

We know they work, as, for example in the Philippines vitamin A deficiency in young children has fallen by 25% in just 5 years – a fantastic achievement1, without any GM rice.


Now the Soil Association resorts to a ridiculous argument, that Golden Rice is somehow “glamorous” and “exciting”. Well, it is exciting because it has a better chance of solving the problem than any other strategy. The example of the Philippines, reducing vitamin A deficiency by 25% at tremendous cost that must go on forever, is not very exciting. And what about the 75% remaining! And what about India with 2 million under 5 years deaths annually since the 1980’s, despite knowledge of other interventions for vitamin A deficiency.

Golden Rice has the potential to eliminate vitamin A deficiency completely and forever in rice eating populations, at no additional cost to the poor people who need help.


Golden Rice was not developed mainly for the Philippines but for countries with larger problems such as India (no progress in reduction for 25 years), Bangladesh, Laos, Cambodia, and Myanmar, countries that suffer vitamin A deficiencies between 42-48% of the population today. Golden Rice is being developed in the Philippines because that is where the International Rice Research Institute is based and because they have received the funding to develop the Golden Rice into the local rice varieties.


If there were indeed “half a dozen strategies to tackle vitamin A deficiency” why are two million children still dying every year? What is the Soil Association doing to help with this? I would guess nothing, as appears to be the case for all the principal opponents of Golden Rice.


The alternatives

‘Sticking plaster’ short-term measures

Vitamin A supplement provision – particularly successful projects include those combining Vitamin A with immunizations, for example when new mothers have just delivered and during National Immunization Days (NIDs) to eradicate polio2


Vitamin A pills cost about 2 cents each, but at least US$1.00 each when distribution costs are taken into account, even when these distribution costs are reduced by sharing the logistics of measles or polio vaccination campaigns. But measles and polio campaigns success means that they are winding down.  This will put up the costs of vitamin A supplementation further than the current more than US$500 million annually.


Vitamin A pills are probably the most costly alternative and must be continued ad infinitum. It is simply not a sustainable strategy and vitamin A pills fail to reach many who suffer. In 1992 the UN International Conference on Nutrition, in the decade when vitamin A pills were first used, clarified that supplementation was only an interim measure.


Why would the Soil Association even bother to talk about “short term strategies” as solutions?


Fortifying rice and flour through processing methods – Flour is mandatorily fortified in the Philippines3. There are also improvements in the ability to fortify rice, however the full potential of this still ‘remains untapped’ and lacks adequate research4.


We add iodine to salt, and vitamin C to apple juice. These are excellent programs, but they depend on food processing and distribution infrastructure. Rice, most of which is consumed where it is grown, is eaten unprocessed. It is the staple for 99% of the people of Laos for example, where most villages do not even have any roads connecting them.

 Golden Rice is, in fact, a type of fortification known a “biofortification” because the biology of the plant itself does the work of putting the nutrient into the food. It is the ultimate “organic” nutrition supplement. This is by far the most cost-effective and sustainable approach.


The problem with normal fortification, where the vitamin is added to the food, is that it must be done in a factory or processing plant, and the food must then be distributed. Much of the rice grown on small farms in developing countries is eaten on the farm and it is therefore not possible to fortify it before consumption. Biofortification is the logical best choice.


Biofortification can be achieved by conventional breeding with crops where an existing low level of micronutrient can be improved upon.  But no white rice contains any vitamin A precursors, so the use of genetic engineering techniques was the only possibility.  Incidentally, the technique was only used once, about a decade ago, to create the Golden Rice varieties being developed today.  Since then all the work in developing counties, and all the introduction of the nutritional trait into locally preferred rice varieties, has been accomplished using conventional breeding only. 


The availability and publicity of cheap food containing sources of vitamin A, for example fortified milk and ready-made meals containing supplements and carrots (rich in vitamin A) in the Philippines have had major success


The Philippines is one of many countries where the deaths and blindness caused by vitamin A deficiency is a problem. Philippine families are very well aware of the paucity of nutrition in their diet, cannot afford to improve it and want to try Golden Rice. The people who are most at-risk cannot afford additional food.

Long-term measures with multiple benefits


The use of awareness campaigns warning parents of the cause of child blindness – a key weapon is to advise parents, the key target audience, of the dangers of rice based diets (which lead to more problems than just vitamin deficiency – problems that could actually be worsened by encouraging more rice consumption).


This shows how misguided the Soil Association is. We are to warn people who eat rice as their staple food of “the dangers of rice-based diets”? All three and a half billion of them? Down with sushi, curry on rice, rice bowls, and rice pilaf? In the Philippines rice is so important that a meal without rice is not even considered a meal! This suggestion is symptomatic of the ridiculous measures fanatics and ideologues will go to uphold their “zero-tolerance” intolerance of new technologies, in this case transgenic biotechnology, otherwise known as genetic engineering and genetic modification or gmo-crops.  (But they don’t oppose these same techniques routinely used in the manufacture of bread, cheese, wine, beer and insulin.)


The campaign against GM technology is a classic propaganda campaign based on fear of the unknown. As Greenpeace has said of Golden Rice, “there may be unforeseen health issues”. “Unforeseen” sounds scary, but it really indicates that they know of nothing that could be harmful. And note the tentative nature of “may be”.  Indeed there isn’t anything to the campaign but fear tactics to raise cash contributions from well intentioned, but misguided, supporters.


How could “problems be worsened” by eating more rice if there is no nutrition in the rice in the first place? This is entirely illogical thinking.


The truth is we are all “genetically modified”, a random mixture of our mother’s and father’s genes. Every living thing is genetically modified, that’s how evolution works. It’s just that the propagandists have taken the neutral term “genetically modified” and associated it with scary thoughts, like Frankenstein Foods, Killer Tomatoes, and Terminator Seeds. All these terms are borrowed from scary Hollywood movies, and the campaign against GM food is based just as much on fantasy as those movies.


It is actually common in nature for genes to move from one species to another. In nature this is a random process, or at least we are not in control of it. GM technology gives us the ability to choose which genes are moved from which species to another. This allows us to put desirable traits into our food crops that would be unlikely to occur by the random movement of genes in nature.


The molecular processes involved are identical, whether by conventional seed breeding or by genetic engineering. The conclusion: biosafety assessment must be based on the product, not the process involved in creating the product. This means that a product where only beta-carotene is added, for example, should not require years of exhaustive assessments. Canada has been operating in this manner for more than a decade without any problems. The Chief Science Advisor to the European Commission, Anne Glover, has recently stated that GM crops are no riskier than conventional crops.

Projects which target poverty in smallholders - these include providing farmers with a range of seeds, tools and skills necessary for growing more diverse crops to target broader issues of malnutrition. The benefits include: more resilient and increased incomes, often reduced reliance on external inputs, and of course more balanced diets. A fantastic example of this is the work carried out by Send A Cow in Uganda and Kenya, including the development of kitchen gardens5.


The intention is that Golden Rice seeds made available to farmers will contribute to:       “a range of seeds, more regular and increased incomes, often reduced reliance on external inputs, and of course more balanced diets”.  World Bank economist Kym Anderson has calculated that conservative adoption of Golden Rice will add US$4.0 billion - US$18.0 billion annually to Asian GDP due to the greater productivity of the population.  Moreover, much of vitamin A deficiency occurs among the landless and people who live in urban slums where there is no land available. Those poor farmers who do have land often need every square inch of it to grow enough calories (rice) to stay alive. Is the Soil Association sending thousands of agronomists with a “range of seeds, tools, and skills” into the tropical countries where 250 million pre-school children need vitamin A, or just blocking serious attempts by others to do that?


Breeding and providing biofortified crops: breeding crops high in nutrients is proving to be easier than creating GM versions. The best example is the creation of sweet potatoes that grow in tropical conditions, cross-bred with vitamin A rich orange sweet potatoes, which grow in the USA. There are successful campaigns providing these potatoes, a staggering five times higher in vitamin A than Golden Rice6, to farmers in Uganda and Mozambique78.


It is possible to produce biofortified crops through conventional breeding with species that already have the ability to put the nutrient into the crop, as is the case with sweet potatoes. Rice does not have this potential, if it did the inventors of Golden Rice would have used conventional breeding techniques. Most vitamin A deficiency occurs in South-East Asia where rice provides 660 billion calories daily. In contrast sweet potato provides 7 billion calories daily (0.15% of rice).


Above we have the list of the Soil Association’s “better ways” to address vitamin A deficiency. None of them have solved the problem to date. This is why humanitarian scientists have concluded that Golden Rice is the logical best solution. But the ideologues press on.


Golden Rice is proposed as an additional intervention for combatting vitamin A deficiency – not a replacement for all other encouragements to a varied diet, education, and reduction of poverty.

Stealing the limelight

Golden Rice, sadly, was never going to be an emergency ‘sticking-plaster’ – as with all genetic modification it takes years to develop.


Golden Rice is intended to provide a free nutritional supplement within the existing staple crop, to those that can benefit from it, and with no downside.  As such it is sustainable, and never intended as an “emergency sticking plaster”.  It does not take “years to develop” GM varieties. Graduate students are making them in university labs around the world to earn their degrees. It is the regulatory apparatus that is the problem and the time-waster. Golden Rice could have been ready for commercial cultivation years ago if it were not for the suspicions raised about the technology used to create it. Indeed, given what we now know about human nutrition even the initial ‘proof of concept’ Golden Rice from 1999 would make a significant contribution to vitamin A deficiency alleviation.  It is not the science but this suspicion and the related ridiculous maze of bureaucracy and regulations that is holding up Golden Rice. The majority of the process and funding for the development of Golden Rice has been due to the regulatory procedure, which itself is the result of the anti-GM movement. If vitamin A deficiency were a disease and Golden Rice was discovered as a cure it would have been approved years ago.


How ironic that rice containing an essential nutrient is more difficult to introduce than a pharmaceutical that is essentially a biocide meant to kill a disease agent, with a good chance of nasty side effects on the patient.


 Incredibly, whilst portrayed as the leading solution for at least 15 years, it has not yet actually helped a single person.


Actually, in two human studies, with adults in the US and children in China, the beta- carotene in Golden Rice increased the vitamin A of the subjects more efficiently than beta carotene from other sources, including spinach: “the high bioconversion efficiency of Golden Rice b-carotene to vitamin A shows that this rice can be used as a source of vitamin A. Golden Rice may be as useful as a source of preformed vitamin A from vitamin A capsules, eggs, or milk to overcome VAD in rice-consuming populations.” (Tang et al, 2012). It has not been made routinely available to those that need it due to a combination of ridiculously onerous regulations, brought on by the fear campaign, and by the campaign to block all GM varieties, regardless of the benefits they can bring. These two factors feed into each other. It is time to break this dam.

It is not credible to deny access to the cure and then to complain that the cure doesn’t work. If activists don’t think it will work, why are they so vociferously opposed to it?


when (or if) it finally is released for general use, it will not be helping to reduce people’s reliance on a rice based diet.


As mentioned previously, the Soil Association surely can’t be serious about telling people they should give up rice as their staple food. There is nothing wrong with rice as a source of carbohydrate for dietary energy. It is simply lacking a source of vitamin A.  


The concept of "biofortification” is considered by the Food Policy Research Institute to be the most intelligent and sustainable intervention against micronutrient deficiency. Golden Rice is the first purposely-created biofortified food, created even before the term was invented. Biofortification does not stop with vitamin A. High iron, high zinc, other vitamins, folate, high quality protein, and healthy fatty acids are all in the pipeline. Dr. Potrykus states that it is possible to develop rice with all the micronutrients that are missing from the diets of poor people in the rice-eating cultures. Through a combination GM technology and conventional breeding it will be possible to eliminate all nutrient deficiencies. This would not be possible without the science of genetic engineering.


 It is another example of where scientists have overlooked the social nature of a problem, in which they optimistically see a simple, quick fix and have ploughed on regardless of difficulty, expense and time, and of course, while ignoring the readily available alternatives.


There we go with the “stupid scientists” again. Perhaps they should be banned too? If the alternatives are so “readily available” why aren’t they in place after so many years? Because they are not practical, cost too much, and are not sustainable over the long run, that’s why.


We believe that we could have gone further to curing blindness in developing countries years ago if only the money, research and publicity that have gone into Golden Rice over the last 15 years had gone into proven ways of curing the Vitamin A deficiency that causes blindness.


The amount of money spent on Golden Rice, about $35 million over 20 years, is nothing compared to the $16.8 billion spent on HIV/AIDS research in 2011 alone. Malaria research and prevention cost $10 billion in 2010. Vitamin A deficiency causes more deaths per year than either of these major diseases. And vitamin A deficiency is not a disease where microbe must be killed; it is simply the lack of an essential nutrient.


Who is the “we” in “we could have gone further”?  Just who does the Soil Association suggest should be delivering their so-called “better ways”? Do they have a program with a budget? No they don’t.


The Golden Rice Humanitarian Project, The International Rice Research Institute in the Philippines, the national rice programmes in Asia, the Bill and Melinda Gates Foundation, and Helen Keller International, do have programs with a budget, and they are moving forward to cure vitamin A deficiency. The members of the Golden Rice Humanitarian Board are all volunteers with no pay for their Golden Rice work.


Other concerns
Controversy in its development

Efforts to create a ‘not for profit’ crop, to be made freely available to the people who would need it most, should be applauded. However in the development of Golden Rice there has been controversy, in particular, due to studies testing children without adequate permission.


This refers to a bit of dirty business, initiated by Greenpeace in 2001, when they said a woman would require 9000 grams (9 kilos) of cooked Golden Rice to receive any nutritional benefit. It continued in 2012 with Greenpeace trying to discredit the excellent results achieved in peer reviewed published research: “A bowl of 100 to 150 grams cooked Golden Rice (50 grams dry weight) can provide 60% of the Chinese Recommended Nutrient Intake of vitamin A for 6–8-year-old children” (Tang et al).


After Golden Rice was first grown in field trials in the US in 2004 it was decided to develop nutritional studies to determine how efficiently humans who ate it would convert the beta-carotene in the rice into vitamin A. In 2009 a study was published in the peer-reviewed American Journal of Clinical Nutrition that proved that adults fed Golden Rice very efficiently produced vitamin A in their bloodstream. Led by child nutritionist Dr. Guangwen Tang at Tufts University in Boston, and funded by the U.S. National Institutes of Health, the same scientist team, now collaborating with experienced clinical researchers in China, undertook to investigate how efficiently Chinese children could utilise different foods, including Golden Rice and spinach, as a source of vitamin A. Ethical clearances were received from the authorities in both China and USA. Following the detail of the agreed Protocol, and meetings with them, the scientists received permission from the parents and each of the 23 children, to give them one serving of “rice that has been altered to contain beta-carotene”. The research successfully established that children, as expected, convert the beta-carotene in rice to vitamin A even more efficiently than adults.  The results were published in the same American Journal of Clinical Nutrition on August 8th 2012 (5 years after the field work was completed).


When the study was published Greenpeace sent an electronic message into China from their Hamburg, Germany office, “American scientists are using Chinese children as guinea pigs for potentially toxic rice”. Actually a Chinese-American scientist, in collaboration with top Chinese clinicians, fed perfectly nutritious Golden Rice to children and proved it worked. The message went viral on the Chinese version of Twitter, Chinese citizens were infuriated, and three top Chinese government clinical researchers were fired to save politician’s face.  Eventually, is a case which is not yet concluded, Dr. Tang was disciplined by her own university (including for following to the letter the Protocol agreed in writing with the same university) for what most independent observers conclude are, at most, minor deviations within complex research of no safety nor scientific consequence.  Although the officials overreacted to a politically motivated scare they also have emphasized the validity of the results and importance of the research results for global public health.


Will it work?

One reason it is taking so long to develop was because the first generation had poor levels of beta-carotene and required further gene changes.


We now know, as a result of the research reported above, that even the earliest Golden Rice produced by 1999 could make a significant impact on vitamin A deficiency. (That this was not investigated at the time was also due to sustained opposition from anti-GMO activists) In any event the levels of beta-carotene produced were increased by 2004. What is the Soil Association’s point?


There are still concerns regarding potential declines in beta-carotene during storage, as it can break down in the presence of oxygen and light9, so it is unclear how much beta-carotene might be available when the GM rice is actually eaten.


The beta-carotene in Golden Rice remains visible for at least 2 years, much longer than rice is normally stored.   

Rice is not stored in sunlight. Just as with carrots, and corn, the beta-carotene remains available through storage. All estimations of Golden Rice’s effect take degradation through storage and cooking into account. This is another red herring repeated over and over by desperate ideologues.


Health risks

It is unwise for a long-term major solution to focus on fortification of foods as there are general issues with fortification – due to differences between individuals, some people in the population will inevitably get too little and others too much. Overdosing on beta-carotene has been linked to an increased cancer risk10.


The Soil Association should be very ashamed to make this statement. At first the anti-Golden Rice campaigners said there was not enough beta-carotene in Golden Rice to help with the deficiency. Now they say there could be too much? It is simply impossible to get too much beta-carotene from eating Golden Rice. Excess beta-carotene is excreted, and long terms studies with healthy doctors and nurses consuming beta-carotene daily for 12 years and 9 years respectively recorded no adverse effects. 


The Soils Association appears here to be in opposition to the fortification of food in general. Does this indicate that they oppose putting iodine in salt to prevent mental retardation, fluoride in toothpaste (and in some countries, water) to prevent tooth decay, vitamin A in milk to prevent immune-system deficiency and blindness, niacin in flour to prevent pellagra, vitamin D in vegetable oils to prevent rickets, folic acid in flour to prevent spina bifida and other birth defects? Fortification, especially biofortification such as with Golden Rice, holds the promise of eliminating micronutrient deficiency worldwide. It is astounding that an organization concerned with producing food could take such a ridiculous position. If adopted, a policy against food fortification would set global health back more than 100 years.


To claim there may be health risks to people who will otherwise go blind or die without the vitamin A is immoral. There is absolutely no evidence that there is anything in Golden Rice that could cause harm.


Genetic modification of metabolic pathways in plants can have unintended effects due to the complexity of the genetic pathways and break-down of genetically engineered metabolic products. There are concerns that other metabolic products may emerge in the GM rice plants which have unintended health risks, in particular Retinoic acid, which can damages human foetuses11.


This is an irresponsible assertion and indicates a lack of basic biology.


Here is the science:


Beta carotene must be converted, by animals including man, to vitamin A (retinol) before the retinol gets converted to retinoic acid (2 steps). Thus b-carotene is safer than vitamin A which is found in animal products such as eggs, milk, butter and liver.  Are carrots, which contain more beta-carotene than Golden Rice, likely to damage fetuses?


Retinal, retinol and retinoic acid are absent in plants (http://www.ncbi.nlm.nih.gov/pubmed/12867709) and therefore the respective biosynthetic pathway does not exist to create them in plants.


 “Retinoic acid is a metabolite of vitamin A (retinol) that mediates the functions of vitamin A required for growth and development. Retinoic acid is required in chordate animals, which includes all higher animals from fish to humans.”


In other words, retinoic acid is essential for good health in species with a backbone.


Will it ever be ready?


All the initial work on Golden Rice was focussed on a strain of rice Japonica, a short-grain variety, not suitable for growing in the areas where Vitamin A deficiency is highest. It is only recently that the long-grain variant Indica has been targeted, grown in countries such as the Philippines where vitamin A deficiency is a major problem.


The japonica variety was used in the initial stage because it was easier to work with for the “proof of concept” phase of the development. All the work now being done, and for the last decade, is with the indica variety.


After more than 15 years, Golden Rice is still far from commercialisation. The International Rice Research Institute reports that it hasn’t yet been deemed safe for humans, animals or the environment, or has it been shown to reduce vitamin A deficiencies in community conditions – they say this will take a further two years or more1


Golden Rice is actually very close to being ready for commercialization. If it were not for the unnecessarily onerous regulatory requirements it would already be available. But it is better late than never. Golden Rice will eventually be approved. The primary focus of the Allow Golden Rice Now! Campaign to ensure that this comes sooner rather than later. You can easily deduce that the Soil Association would prefer it were never released and that 2 million children per year continued to be sacrificed on their ideological altar. Two more years is two years too many, but let’s make sure it’s not three or four years due to the intransigence of Luddites and anti-science extremism.


Regulatory clearance will confirm that Golden Rice is safe, period. The studies to be conducted by Helen Keller International are to measure the effectiveness of Golden Rice in delivering vitamin A to children under real-life community conditions.



There is no evidence that opposition to GM rice from scientists and NGOs has delayed the development of Golden Rice.


Scientists have tried to get Golden Rice approved; anti-Golden Rice NGOs have stopped at nothing, including lies and scare tactics, to stop it. This is an historical fact. It is also clear from this document that the Soil Association wishes to prevent the development of Golden Rice and is willfully complicit in the same lies and scare tactics.


 What is clear after 15 years of claims about Golden Rice is that it did not provide the instant, miracle cure to blindness that pro-GM scientists, GM companies and some politicians claimed it would back in 1998.


No one made claims of “instant, miracle cure” asserted here. If one checks the Internet they will see that this is only an accusation made by the anti-GMO movement. No one could have predicted the irrational, fanatical, fear-based campaign that would develop among anti-GMO NGOs. No doubt the fundraising potential was perceived early on. If it were not for the anti-science nature and ideological bent of this campaign Golden Rice would already be growing in farmer’s fields and beginning to bring an end to vitamin A deficiency. Yes, there are other afflictions that must be addressed. But vitamin A deficiency is the biggest killer of children in the world today. It is immoral and a Crime Against Humanity to oppose it with lies and dirty tricks.


 We now know that those claims were untrue.


Those claims have already been proven by carefully conducted scientific research, and will be proven true in populations when Golden Rice finally becomes available to those who so desperately need it.


 We also know from those developing it that Golden Rice is still years away from being available, and that those developing it still do not know if it is safe, nor if it will work, nor if it will prove acceptable to the people suffering from Vitamin A deficiency.


Then let us try. All we ask is for the denunciation of the destruction of the field trials, and other methods of willfully blocking Golden Rice, and for an exception to be made to the “zero-tolerance“ position on GMOs, on humanitarian grounds, for Golden Rice. We know that it is safe, that it will work, and that it will be accepted.


 What we do know is that there are already effective cures for Vitamin A deficiency, both short-term and long-term, we know that these work, and we know that the long-term solutions solve not just the problem of Vitamin A deficiency, which does not occur in isolation, but the wider problem of multiple vitamin deficiency.


If these cures you speak of “work” why does the problem persist? Why do more than 2 million, mostly children, die annually from the preventable cause, which is vitamin A deficiency?

Is it because the Soil Association is doing nothing to help, and yet carping from the sidelines as millions of children die?


(I have not placed footnotes in the text so as not to interfere with the Soil Association’s footnotes. Below is a list of resources that support the case for Golden Rice and provide useful information on the subject)


The Golden Rice Humanitarian Project: http://www.goldenrice.org/index.php


The Allow Golden Rice Now! Campaign: http://www.allowgoldenricenow.org/


Nutritional study with Golden Rice: http://ajcn.nutrition.org/content/96/3/658.abstract


World Health Organization on vitamin A deficiency: http://www.who.int/nutrition/topics/vad/en/


Who destroyed the Golden Rice Field Trials? http://www.slate.com/blogs/future_tense/2013/08/26/golden_rice_attack_in_philippines_anti_gmo_activists_lie_about_protest_and.html


A Senseless Fight: http://www.cosmosmagazine.com/features/senseless-fight/


Crime Against Humanity: http://www.independent.co.uk/news/science/former-greenpeace-leading-light-condemns-them-for-opposing-gm-golden-rice-crop-that-could-save-two-million-children-from-starvation-per-year-9097170.html


Tables Turned on Greenpeace: http://www.nutraingredients.com/Industry/GM-golden-rice-Tables-turn-on-Greenpeace


Greens Must Embrace GM: http://www.independent.co.uk/voices/editorials/if-the-environmentalist-movement-is-to-stay-relevant-it-must-embrace-worldchanging-technologies-like-gm-9096768.html


Greenpeace War against Life: http://www.breitbart.com/Big-Peace/2013/10/13/Greenpeace-Willing-to-Let-Children-Go-Blind-or-Die?utm_source=twitterfeed&utm_medium=twitter


The Genomic Misconception, Klaus Ammann: http://www.sciencedirect.com/science/article/pii/S1871678413000605


Journal references on vitamin A and health effects:


Grodstein F, Kang JH, Glynn RJ, Cook NR, Gaziano M. A randomized trial of beta carotene supplementation and cognitive function in men: The Physicians' Health Study II. Arch Intern Med. 2007; 167 (20): 2,184-2,190.


 Kang JH, Grodstein F. Plasma carotenoids and tocopherols and cognitive function: A prospective study. Neurobiol Aging. 2008; 29(9): 1,394-1,403.


 Kang J. H. et al. Vitamin E, vitamin C, beta-carotene, and cognitive function among women with or at risk of cardiovascular disease. Circulation. 2009; 119:2772–2780.


Shekelle RB, Lepper M, Liu S, Maliza C, Raynor WJ Jr, Rossof AH, Paul O, Shryock AM, Stamler J : “Dietary Vitamin A and Risk of Cancer in the Western Electric Study”  Lancet, (1981): 1185-1190



The Soils Association’s references begin here:


1 IRRI website: http://www.irri.org/golden-rice/faqs/what-is-the-status-of-the-golden-rice-project-coordinated-by- irri

1 http://www.fnri.dost.gov.ph/images/stories/7thNNS/biochemical/biochemical_vad.pdf

2 http://www.who.int/vaccines/en/vitamina.shtml

3 Philippine Food Fortification Act of 2000’ http://faolex.fao.org/cgi- bin/faolex.exe?rec_id=032376&database=FAOLEX&search_type=link&table=result&lang=eng&format_name=@ER ALL

4 http://riforg.gainhealth.org/rice-fortification/rice-key-facts-and-figures

5 http://www.sendacow.org.uk/about-us For impacts, in particular in terms of balanced diets see http://www.sendacow.org.uk/assets/files/Related-downloads/Send-a-Cow-Impact-Report-WEB.pdf

6 See quote from Dr. Medina http://www.bbc.co.uk/news/science-environment-23581877 and quantities listed in Burri, B. J. (2011) ‘Evaluating Sweet Potato as an Intervention Food to Prevent Vitamin A Deficiency’, Comprehensive Reviews in Food Science and Food Safety, 10: (2) 118,130

7 http://www.harvestplus.org/content/uganda-and-mozambique

8 Burri, B. J. (2011) ‘Evaluating Sweet Potato as an Intervention Food to Prevent Vitamin A Deficiency’, Comprehensive Reviews in Food Science and Food Safety, 10: (2) 118,130

9 http://www.clrri.org/ver2/uploads/noidung/14-03_1.pdf

10 Satia et al (2009) ‘Long-term Use of β-Carotene, Retinol, Lycopene, and Lutein Supplements and Lung Cancer’ Journal of American Epidemiology’, http://aje.oxfordjournals.org/content/early/2009/02/10/aje.kwn409.abstract?maxtoshow=&HITS=10&hits=10&RE SULTFORMAT=1&author1=Satia&andorexacttitle=and&andorexacttitleabs=and&andorexactfulltext=and&searchid =1&FIRSTINDEX=0&sortspec=date&resourcetype=HWCIT

11 Quoted from Dr Michael Hansen, Senior Scientist, Consumers Union – whilst carrots contain high levels of beta-carotene with no known effects on foetus development, he argues that any carrots which had resulted in adverse effects would likely to have been selected out over time. In other words, food has a long co- evolutionary relationship with humans, which is short-circuited in GM crops.