GMOs and Bioengineered Food – Pesticide Proliferation

What we do to the environment we do to ourselves.

Biotech crops continue to spread across the world but that does not necessarily mean GMOs and bioengineered food are good for people and the environment.

When I began my quest, at the beginning of July, to learn more about GMOs and bioengineered food, I did not have a preconceived destination. I did know that I wanted to attempt to filter out the noise surrounding this highly controversial subject to find some useful information for you and me so we could each form our own opinion and decide if we wanted to take further action or not.

It was while I was writing GMOs and Bioengineered Food – What is It? that I decided to write a 4-part series hoping to find a balance between too little and too much material. The second and third posts, GMOs and Bioengineered Food – Historical Milestones and GMOs and Bioengineered Food – Laws and Regulations, illustrated how we got to where we are today and gave an overview of how the EPA, FDA, and USDA handle their regulatory authority and responsibilities in the United States.

Originally, I thought this fourth and final post in the series would cover general environmental issues, but when I had it mostly written, I realized that I wanted to focus on one specific issue—the proliferation of pesticide use on a massive scale, not just in the U.S. but across the entire world, driven by increasing adoption of genetically engineered (GE) crops and spurred on by agrochemical companies.

Pesticides are Everywhere and in Everyone

One of the creepiest commercials I can ever remember seeing is the one that portrays an attractive 30-something family man as a hero because he wipes out a single dandelion growing in a crack in his driveway using the handily attached spray wand on his gallon-size jug of Roundup.

Pests and weeds (bugs and plants people do not like) have been around forever, are ubiquitous, and contribute to healthy ecosystems. Of course, there needs to be some kind of balance between us and them. Yet, humans seem to have developed a zero-tolerance for these constituents of nature and are on a mission to try to eradicate them by spraying pesticides everywhere.

Farmer Spraying Pesticide on Lettuce and Cabbage Crops
Farmer Spraying Pesticide on Lettuce and Cabbage Crops – Photo Credit iStock/aluxum

So what is a pesticide?

The word pesticide is derived from the Latin pestis (deadly contagious disease; a curse, bane) and cide (killer or act of killing). It is an umbrella term that covers a wide variety of substances that humans use to kill living plants, animals, and other organisms that we do not want living in our buildings, yards, playgrounds, parks, or agricultural fields and orchards. Insecticides kill insects, herbicides kill plants, rodenticides kill rodents, fungicides kill fungi, and so on.

Non-GE crops may be sprayed with pesticides, too, but GE crops with built-in pesticide tolerance (especially to herbicides) actually promote pesticide use because they can withstand heavy and repeated spraying with pesticides.

65% of the GE crops approved in 2017 were genetically engineered with herbicide tolerance contributing to the global pesticide market that is valued at about $65 billion per year and growing.1, 2

Pesticides and People

The widespread acceptance of pesticides results in billions of pounds of pesticides being sprayed on agricultural fields and orchards all over the world, as well as in our homes and yards.3 Just in the U.S., there are over 16,000 registered pesticides and not that long ago, the EPA approved huge increases in what is called “tolerable” pesticide residues on crops and food.4, 5

In the real world, which is where everyone lives, we are exposed to pesticides in our air, water, and food every day.

High School in Waialua, Hawaii Next to Pesticide Test Field
A High School in Waialua, Hawaii Next to a Pesticide Test Field – Photo Credit Jon Woodhouse/The Maui Independent

In 2015, the World Health Organization designated glyphosate (the herbicide in Roundup) as a probable human carcinogen (meaning it probably causes cancer in people).6 Monsanto, the company that created Roundup during the 1970s, is facing more than 5,000 lawsuits in the U.S. alone.7

This is just one example.

Pesticides and the Environment

Pesticide makers want you to believe the pesticides only kill the targeted pest or weed but that is a gross oversimplification.

You have likely read about how neonicotinoid pesticides are endangering the bees and butterflies that pollinate our food crops and orchard trees as they go about their business. If we kill off nature’s pollinators, a lot of the food you currently buy at the grocery market will disappear, but even more worrying is that no one really knows what kind of a chain reaction could occur in the wild.

Dead Zone along Louisiana Coastline in Gulf of Mexico
A Dead Zone along the Louisiana Coastline in the Gulf of Mexico – Photo Credit NASA

Another less publicized issue is dead zones in waterways and estuaries where no aquatic life can survive in the water or on the adjacent land. This, in turn, leads to erosion and flooding. Dead zones are created by fertilizers and pesticides running off fields and orchards into streams, rivers, and lakes. Pesticides kill organisms in the soil and you cannot grow plants or trees in the dead soil, therefore, fertilizers are applied to rejuvenate the soil and then pesticides are sprayed to kill bugs and weeds, which kills the soil.

Superbugs and superweeds are already evolving that can withstand the pesticides we try to kill them with, which causes a twofold problem. First, fields are sprayed more often and with a greater array of more toxic pesticides. Second, agrochemical companies race to invent poisons that are even more powerful. Then the pests and weeds evolve and the cycle continues.

Palmer Amaranth (Pigweed) Superweed Growing in Agricultural Field
Palmer Amaranth Superweed Growing in an Agricultural Field – Photo Credit Lisa Behnken/University of Minnesota Extension

Palmer amaranth (pigweed) is one weed that has evolved to resist herbicides and is now considered a superweed.

This led to the development of GE crops that can tolerate a more powerful herbicide called dicamba. This herbicide endangers people and as it drifts from fields where it is being sprayed dicamba settles on other crops and plants and kills them, too. This is just one superweed problem that has spurred state and federal investigations and lawsuits.8, 9

What Can You Do?

After wading through and digesting five weeks of research and discussing it with my family, I came to the conclusion that genetic engineering technology could probably be used to benefit society and even the environment, but I believe that our current approach to feeding the world is endangering people and the environment, while lining the pockets of a handful of multi-national corporations focused on quarterly profits.

We need to change.

It is up to each one of us to care enough about ourselves, our children, and the people of the future to take action to change the world. Governments and corporations only change when people say, “we are not going to take it anymore,” and demand change through their actions.

Farmers are on the front lines. Just like everyone else, they are trying to make a living, and they may feel they have no choice but to accept GE crops and the harmful agrochemicals they require. Farmers should not have to go to work wearing hazmat suits.

Young Female Farmer Standing in an Agricultural Field
A Young Female Farmer Standing in an Agricultural Field – Photo Credit NRDC

Let’s help farmers make a living providing healthful food to eat while protecting themselves, their families, us, and the environment. Here are a few ideas to get you started. Even if you can only do something occasionally, it all adds up.

  • Buy certified organic food. It is GMO-free and good for the soil.
  • Shop at the farmers market where you can actually talk to the people growing your food.
  • Make more meals with whole ingredients (packaged foods contain many GMO corn and soy products).
  • Shop at grocery stores that sell local and regionally grown food. Co-ops are a great source.
  • Donate your time and/or money to an organization, like Agrarian Trust, that helps young farmers who want to practice sustainable agriculture get access to farmland.
  • Eat vegetarian meals more often (a lot of GMO corn and soy crops are used to feed livestock animals).
  • Pass up fast food and make your own lunch sometimes (fast food contains a lot of GMO corn and soy).
  • Sign up for a CSA (community supported agriculture) share and get fresh seasonal food every week during the growing season.
  • Tell your elected officials that you want to eat pesticide-free food.
  • Let food companies know why you stopped buying their products and what they need to do to win you back as a customer.

“If, having endured much, we have at last asserted our “right to know,” and if by knowing, we have concluded that we are being asked to take senseless and frightening risks, then we should no longer accept the counsel of those who tell us that we must fill our world with poisonous chemicals; we should look about and see what other course is open to us.” —Rachel Carson, Silent Spring (1962)

Reader Note: At the end of this post, in the resource sections, I listed the books, films, and websites I used throughout this series as well as articles specific to this post. You can find other resources in the previous posts.

Featured Image at Top: Farmer Spraying Pesticide on His Crops Using a Drone – Photo Credit iStock/baranozdemir

Related Posts


  1. Brief 53: Global Status of Commercialized Biotech/GM Crops: 2017 – International Service for the Acquisition of Agri-biotech Applications (ISAAA), 06/26/18 (p. 107)
  2. Whitewash – by Carey Gillam, published by Island Press, 2017 (p. 236)
  3. Pesticides Use and Exposure Extensive Worldwide – by Michael C.R. Alavanja, Ph.D., National Center for Biotechnology Information, 2009
  4.  Whitewash – by Carey Gillam, published by Island Press, 2017 (p. 229)
  5. Food Fight – by McKay Jenkins, published by Avery, 2017 (p. 280)
  6. IARC Monograph on Glyphosate – World Health Organization, International Agency for Research on Cancer
  7. Monsanto Ordered to Pay $289 Million in Roundup Cancer Trial – by Tina Bellon (Reuters), The New York Times, 08/10/18
  8. This miracle weed killer was supposed to save farms. Instead, it’s devastating them – by Caitlin Dewey, The Washington Post, 08/29/17
  9. Challenging EPA, Monsanto Over the Crop-Damaging Pesticide “Xtendimax” – press release, Earthjustice, 2018

Resources – Books

Resources – Films

  • Consumed (This is a fictional anti-GMO movie that may help some viewers get a grip on the situation.)
  • Food Evolution (This pro-GMO documentary contains some useful information.)
  • GMO OMG (This film covers the issues associated with GMOs like corporate ownership of the food system)
  • Genetic Roulette: The Gamble of Our Lives (This anti-GMO documentary contains some useful information.)

Resources – Websites and Articles

GMOs and Bioengineered Food – Laws and Regulations

You have a right to know what is in your food.

Except for the 2016 bioengineered (BE) food labeling law, the U.S. has no federal laws specific to GMOs (genetically modified organisms) or biotechnology.

However, that does not mean that there is no regulation of the biotech industry or the products they create.

In the United States, three federal agencies, the Environmental Protection Agency (EPA), Food and Drug Administration (FDA), and Department of Agriculture (USDA), are largely responsible for ensuring that bioengineered food, drugs, plants, animals, and other products are safe for people, agriculture, and the environment.

Roundup Ready Soybean Field
Roundup Ready Soybean Field – Photo Credit Monsanto

This post will give you an overview of some of the U.S. laws that are used to regulate bioengineered food (including the pending labeling standard) and provide links to resources so you can learn more if you want to.

This is the third post in a series of posts about GMOs and bioengineered food. The first two posts, GMOs and Bioengineered Food – What is It? and GMOs and Bioengineered Food – Historical Milestones, introduced you to genetic engineering and provided a historical framework. The last post will look at potential environmental issues.

How Does the Federal Government Regulate GMOs and Bioengineered Food?

When Congress enacts a law, they state what they want to be accomplished (either broadly or in detail) and they grant authority to one or more federal agencies to carry out the law.

In turn, the federal agency or agencies charged with implementing the law establish policies and issue formal regulations through what is called the rulemaking process, which includes informing the public via the Federal Register and allowing public comment at various points in the process.

Before we talk about laws and regulations, it might be helpful to understand a little bit about how the EPA, FDA, and USDA coordinate their regulatory activities.

Coordinated Framework for the Regulation of Biotechnology

During the 1970s and early 1980s, the regulatory arena for biotech products was chaotic with federal agencies acting inconsistently, overriding each other, and approving products without following existing laws.

This exacerbated fears the public was already voicing about the safety and ethics of genetic engineering technologies and products as well as worries about the impact they might have on society and the environment. Many scientists shared these concerns advocating for caution and research safety standards. Companies trying to get approval to conduct field tests outside of their controlled laboratories or to bring products to market were frustrated by the confusing and inconsistent regulatory process.

Although Congress held hearings and considered enacting biotechnology-specific legislation, they failed to do so.

U.S. Office of Science and Technology Policy (OSTP) LogoPresident Ronald Reagan was not a fan of regulatory controls, but in 1984, he allowed the White House Office of Science and Technology Policy to form a working group to develop a coordinated system for regulating biotechnology using existing laws.

When the Coordinated Framework for the Regulation of Biotechnology was issued on June 26, 1986, it contained a matrix showing which agency was responsible for regulating what and policy statements from the EPA, FDA, and USDA describing how each agency regulates products of biotechnology.

Until 2017, the Framework had only been updated once, in 1992, to reaffirm that federal oversight “focuses on the characteristics of the biotechnology product and the environment into which it is being introduced, not the process by which the product is created.”1

In July 2015, the Obama administration issued a memorandum to the EPA, FDA, and USDA directing the agencies to update the Framework, develop a long-term strategy, and commission an independent report, which they did.

  1. The National Strategy for Modernizing the Regulatory System for Biotechnology Products published in September 2016 describes the federal government’s long-term strategy for ensuring the regulatory system is equipped to assess future risks.
  2. The January 4, 2017 release of the updated Coordinated Framework for the Regulation of Biotechnology includes the agency’s current roles and responsibilities, methods for coordinating activities and sharing information, and several case studies that outline the regulatory process for various hypothetical genetically engineered products like a plum with pesticide properties or algae for biofuel.
  3. The National Academy of Sciences published their report entitled Preparing for Future Products of Biotechnology on June 28, 2017. The 212-page report is worth reading; however, this excerpt from page 10 sums it up nicely.2

“The pipeline of biotechnology products likely to emerge over the next decade probably will result in disruptive innovations and significant societal impacts; a carefully balanced, coordinated approach toward future biotechnology products that incorporates input from stakeholders—including interested and affected parties, relevant federal agencies, and nontraditional product developers—will be required.”

Overview of Laws for Regulating Bioengineered Food

In general, the EPA, FDA, and USDA are each responsible for regulating the aspects of biotechnology products that fall under their area of responsibility and authority to ensure bioengineered food and other products are safe for human health and the environment (EPA), safe for people to eat and drink (FDA), and safe to grow in agricultural settings and forests (USDA).

Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)

U.S. Environmental Protection Agency (EPA) LogoThe EPA uses a registration process to regulate the sale, distribution, and use of all pesticides including what are called plant-incorporated protectants, which are genetically engineered plants that produce their own pesticides. Registered pesticides must be reviewed at least every 15 years.

A pesticide may be registered if it will generally not cause, “(1) any unreasonable adverse effects to man or the environment taking into account the economic, social and environmental costs and benefits of the use of a pesticide, or (2) a human dietary risk from residues that result from the use of a pesticide in or on any food.”3

The FIFRA also gives the EPA authority to require permits for companies wanting to test their products on more than 10 acres of land or one surface acre of water. Smaller scale experiments do not require permits.

Toxic Substances Control Act (TSCA)

The EPA is required to conduct a pre-manufacturing review of all new chemical substances to prevent their manufacturing, processing, distribution, use, or disposal from presenting an unreasonable risk to people and the environment.

In 2016, the TSCA was amended by the Frank R. Lautenberg Chemical Safety for the 21st Century Act, which added a new requirement. Now, the EPA is required to determine that new chemical substances are safe before they go on the market.

The TSCA excludes food, food additives, drugs, cosmetics, medical devices, pesticides (but not pesticide intermediates), tobacco, nuclear materials, and firearms from EPA jurisdiction because they are covered by other laws.

Federal Food, Drug and Cosmetic (FD&C) Act

U.S. Food and Drug Administration (FDA) LogoThe FDA regulates a wide variety of products under the FD&C Act, including human and animal foods, dietary supplements, cosmetics, human and veterinary drugs, human biological products, and medical devices.

Under the FD&C Act, a substance (which could be a GMO) that is intentionally added to food is considered a food additive. Unless the substance is generally recognized as safe (GRAS) for its intended use, it requires premarket approval from the FDA, which offers a voluntary consultation process to help address safety and regulatory issues during early stages of product development.

Genetically engineered animals are regulated by the FDA under the “new animal drug” provision of the law, which makes it illegal to introduce a new animal drug into the market without FDA approval. So-called new animal drugs include animals genetically engineered to produce pharmaceuticals for human use (e.g. insulin) or food for human consumption (e.g. salmon).

The FD&C Act gives the EPA authority to set tolerances for pesticide residues on food for people and animals.

Protection and Inspection Acts

U.S. Department of Agriculture (USDA) LogoThe Animal Health Protection Act, Plant Protection Act, and Virus-Serum-Toxin Act give the USDA regulatory oversight over products that are pests or could cause disease in livestock animals, are deemed plant pests or noxious weeds, or are veterinary biological products used to prevent, diagnose, and treat animal diseases.

If the USDA conducts a risk assessment and determines that a GMO is unlikely to pose a plant pest risk, then it is no longer subject to provisions of the Plant Protection Act, although it might be subject to other regulations.

The Federal Meat Inspection Act, Poultry Products Inspection Act, and Egg Products Inspection Act give the USDA authority and responsibility for ensuring that the United States’ commercial supply of meat, poultry, egg products, and certain farm-raised fish, in interstate commerce, is safe, wholesome, and correctly labeled.

The FDA oversees the safety of substances added to meat, poultry, and egg products under the FD&C Act, while the USDA considers whether the use of such substances is suitable under the various Inspection Acts.

National Environmental Policy Act (NEPA)

NEPA, passed by Congress in 1969, requires all branches of the federal government to consider the environment prior to undertaking any major federal action that significantly affects the environment. Each agency has its own guidelines about what constitutes a major federal action, which could be approving a bioengineered food or other product.

National Bioengineered Food Disclosure Standard (NBFDS)

President Obama signed the National Bioengineered Food Disclosure Standard (public law 114-216) on July 29, 2016.

Genetically Engineered AquAdvantage Salmon Compared to Atlantic Salmon
Genetically Engineered AquAdvantage Salmon Compared to Atlantic Salmon of Same Age – Photo Credit AquaBounty

The law:

  • Provides a definition of bioengineering as it relates to food.
  • Requires the Secretary of Agriculture to establish a national mandatory bioengineered (BE) Food disclosure standard.
  • Pertains only to food and drink for human consumption.
  • Pertains only to food and drink that already requires labeling by either the FDA or USDA.
  • Prohibits food products from animals being considered BE just because they eat BE food themselves.
  • Prohibits any state from establishing their own BE food labeling standards and overturns state laws previously passed (e.g. Vermont).
  • Exempts food served in restaurants and food manufacturers with less than $2.5M in annual revenue.

National Bioengineered Food Disclosure Standard Proposed Rule

The USDA published their NBFDS proposed rule (regulation) on May 4, 2018, and allowed the public to comment until July 3, 2018.

Cheeseburger with French Fries on Wooden Table
Do this cheeseburger and fries contain GMOs? You may never know. Photo Credit iStock/nitrub

Notable features of the proposed rule are:

  • The percentage and predominance of BE ingredients will be used to determine whether a food requires BE disclosure or not.
  • Only foods on a list created by the USDA will be subject to disclosure. The proposed list includes canola, corn, soybeans, cotton, sugar beets, non-browning apples, papaya, potatoes, and some squashes. The list will be updated annually.
  • Highly refined ingredients like oil and sugar produced from BE plants such as corn and sugar beets may end up being excluded from disclosure.
  • Quick Response (QR) CodeThere are three options for BE food disclosure on food and packaging: text stating the food is BE or may contain BE ingredients, a symbol, or an electronic or digital link you scan with your smartphone (if you have one) to go to a website for more information.
  • Although failing to make a BE food disclosure is prohibited, Congress did not authorize the USDA to enforce the law other than to conduct audits and hearings. There is no provision for penalties for non-compliance.
  • Manufacturers have until January 1, 2022, to comply with the law.

After reading this post, I hope you feel at least a little informed about how the EPA, FDA, and USDA regulate bioengineered food. In the next and final post of this series, we will look at environmental issues and concerns.

Featured Image at Top: Meshed Gears that Say Rules, Regulations, Compliance, Policies, and Standards – Photo Credit iStock/EtiAmmos

Related Posts


  1. 2017 Coordinated Framework for Biotechnology Products –White House OSTP, 01/04/17 (p. 4)
  2. Preparing for Future Products of Biotechnology – U.S. National Academies of Sciences, Engineering, and Medicine, 2017 (p. 10)
  3. Summary of the Federal Insecticide, Fungicide, and Rodenticide Act – U.S. Environmental Protection Agency