David is a handful of farm and consumer organizations, and Goliath is a coalition of agrichemical companies backed by top officials of the U.S. Food and Drug Administration (FDA) and the U.S. Department of Agriculture (USDA). At issue is the safety of milk, and the right of consumers to know what chemicals and drugs have been added to the milk they buy in the grocery store. Consumer advocates say the public has a right to know. The agrichemical industry and the Clinton administration say not.
Last November 5 the U.S. Food and Drug Administration (FDA) declared rBGH "safe" for use in milk cows, and last month Monsanto, the chemical company, began selling its version of the drug to dairy farmers.[1] Other companies hoping to get into the business are Eli Lilly, UpJohn, and American Cyanamid. Monsanto's version of the drug is intended to be injected into milk cows every two weeks, to stimulate milk production by 5% to 20%. Consumer and farm organizations, including Consumers Union, publisher of CONSUMER REPORTS magazine, have presented evidence that byproducts of the hormone treatment are measurable in milk and are not safe for humans or for cows; they also say approval of rBGH clearly violated FDA's own regulations.[2] They want the product withdrawn from the market, and, until that happens, they want hormone-containing milk labeled so that consumers can make an informed choice about the milk they buy.
In eleven different surveys, American consumers have indicated overwhelmingly that they do not want milk that contains genetically-engineered hormones, and that they want milk labeled so they can make an informed choice in the grocery store.[3] For example, in a survey of 1000 people in Wisconsin (a leading milk-producing state), 75% of respondents said they would pay as much as 44 cents extra per gallon to avoid genetically-engineered hormones in their milk. This attitude was consistent regardless of income levels, educational background, or residence in rural or urban areas.
In response to consumer concerns, the FDA and Monsanto have spoken with a single voice: the FDA has warned grocery stores not to label milk as free of the hormone,[4] and on Feb. 18 Monsanto sued two milk processors that labeled milk as free of the hormone.[5]
It is no accident that the FDA and Monsanto are speaking with one voice on this issue. The FDA official responsible for the agency's labeling policy, Michael R. Taylor, is a former partner of King & Spaulding, the Washington, D.C. law firm that has brought the lawsuits on behalf of Monsanto. Taylor, a lawyer, is a classic product of the revolving door. Starting in 1980, he worked for FDA for 4 years as executive assistant to the commissioner. In 1984 he joined King & Spaulding and remained there until 1991; during that time the law firm represented Monsanto while the company was seeking FDA approval of rBGH. In 1991, President Bush's FDA Commissioner, David A. Kessler, Jr., revolved Taylor back into FDA as assistant commissioner for policy.[6] Kessler himself was retained by President Clinton, as was Taylor. Last month Taylor signed the FEDERAL REGISTER notice warning grocery stores not to label milk as free of rBGH, thus giving Monsanto a powerful boost in its fight to prevent consumers from knowing whether rBGH produced their milk.
FDA offers two justifications for preventing labeling: 1) FDA is not requiring anyone to keep track of who is using rBGH and who is not and, without a paper trail, grocery stores might make false claims if they said their milk was rBGH-free. 2) FDA says there is "virtually" no difference between milk from cows injected with rBGH and cows not injected. Virtually means "almost." (More on this claim below.)
To remedy the first problem, Consumers Union had suggested that FDA simply require Monsanto to maintain a public list of people who buy rBGH, thus allowing grocery stores and milk wholesalers to determine easily whether any particular farmer is, or isn't, using the controversial drug. FDA refused. And Monsanto is not revealing who is buying rBGH.
By its lawsuits, Monsanto has sent a clear message to anyone who might be tempted to label milk with words about rBGH. Evidently Monsanto fears that informed consumers might choose not to buy milk produced by rBGH-treated cows. An internal company memo dated Sept. 21, 1993, equates a government labeling requirement with a government "ban" on its product.[7]
Monsanto has a lot at stake. The company has been hurt in recent years by lawsuits and publicity over several of its chemical products that it insisted were safe, such as the herbicide 2,4,5-T used in Agent Orange in Vietnam, and PCBs, which Congress banned in 1976. Some Wall Street analysts believe that Monsanto has bet its future on genetically-engineered farm and food products, and that failure of rBGH could damage the company significantly. Monsanto has reportedly spent $300 million since 1984 developing the rBGH hormone. According to Consumers Union, rBGH should earn Monsanto $300 to $500 million annually in the U.S., and $1 billion each year worldwide.[8]
Both the food and pharmaceuticals industries are reportedly very worried that consumer rejection of rBGH in milk would dim the future for all genetically engineered foods.[9] According to industry analysts, some 60 genetically-engineered food products are scheduled for approval by FDA in the next few years. For its part, the Clinton administration is counting on genetic engineering to give America a competitive advantage in the global marketplace and thus boost the President's flagging prospects for re-election.
Monsanto is clearly aware of the Clinton Administration's enthusiasm for genetically-engineered foods to boost the economy. An internal company memo[7] dated Sept. 21, 1993, suggests that, to persuade the Administration to allow rBGH onto the market, a Monsanto lobbyist should "Let [USDA] Secretary Espy know that companies like Monsanto will likely pull out of the agriculture biotech area if the Administration will not stand up to persons like Senator Feingold [of Wisconsin, an opponent of rBGH use]." Espy is now solidly on board promoting rBGH.
FDA Commissioner Kessler has also proven himself to be a loyal soldier in the consumer wars. He has consistently opposed giving consumers a choice by labeling milk. He says things such as, "The public can be confident that milk and meat from BST-treated cows is safe to consume." (BST is Monsanto's name for rBGH.) And, "There is virtually no difference in milk from treated and untreated cows."[10]
Unfortunately, a considerable body of scientific evidence from the U.S., England and Europe indicates that Commissioner Kessler is simply not telling the whole truth. Substantial evidence indicates that milk from rBGH-treated cows is very likely to feature:
None whatsoever. Zero. Even FDA says there are no consumer benefits. In fact, because the U.S. already produces a surplus of milk, which is purchased by Uncle Sam, increasing milk production with rBGH will COST the taxpayer an additional $200 million or more each year, estimates Consumers Union. That's family money pumped into some chemical company's pocket. That's who benefits.
To keep abreast of the growing anti-rBGH campaign and boycott, stay in touch with the Pure Food Campaign [1130 17th Street, N.W., Suite 630, Washington, DC 20036; telephone (202) 775-1132] and with Food & Water [Rural Route 1, Box 114, Marshfield, VT 05658; telephone (802) 426-3700.]
References
[1] Keith Schneider, "Lines Drawn in a War Over a Milk Hormone,"
NEW YORK TIMES March 9, 1994, pg. A12.
[2] "Statement of Michael Hansen, Ph.D, March 10, 1994," Consumer Policy Institute, Consumers Union, [101 Truman Ave., Yonkers, NY 10703-1057; telephone (914) 378-2000].
[3] Michael Hansen, "Testimony Before the Joint Meeting of the Food Advisory Committee & the Veterinary Medicine Advisory Committee on Whether to Label Milk From rBGH-Treated Cows by Michael K. Hansen, Ph.D.," May 6, 1993. Available from: Consumer Policy Institute, Consumers Union, 101 Truman Ave., Yonkers, NY 10703-1057. Telephone (914) 378-2000.
[4] Keith Schneider, "F.D.A. Warns the Dairy Industry Not to Label Milk Hormone-Free," NEW YORK TIMES February 8, 1994, pg. A1.
[5] Schneider, note 1 above. In an interview with RHWN March 15, Matt Bennett of King & Spaulding refused to discuss these lawsuits, referring us to Tom McDermott at Monsanto in St. Louis, whom we could not reach before our press deadline.
[6] "Two New Deputy Commissioners Named By Kessler," FDA TALK PAPER [T91-38] (Rockville, Md.: Food and Drug Administration, July 15, 1991). Available from Brad Stone at FDA Press Office; phone (202) 205-4241.
[7] Virginia V. Weldon, "Coehlo Talking Points for Espy Dinner," a memo on Monsanto company letterhead dated Sept. 21, 1993.
[8] Michael K. Hansen, BIOTECHNOLOGY AND MILK; BENEFIT OR THREAT? AN ANALYSIS OF ISSUES RELATED TO BGH/BST USE IN THE DAIRY INDUSTRY (Mount Vernon, N.Y.: Consumer Policy Institute/Consumers Union, 1990), pg. 1.
[9] Kathleen Day, "Hormone Hubbub Hinders Program," WASHINGTON POST March 15, 1994, pgs. D1, D5.
[10] "FDA Approves Monsanto's BGH, Consumer Groups Call Boycott, Milk Industry Gears Up Ad Campaign," CORPORATE CRIME REPORTER Nov. 15, 1993, pg. 4.
Bovine growth hormone (BGH) is a normal product of the pituitary gland of cows. To make the synthetic product, rBGH, drug companies have learned to snip out a fraction of cow DNA that codes for this hormone, insert it into the DNA of E. COLI bacteria, grow the bacteria in vats, and extract large quantities of rBGH from the vats. (A synthetic human growth hormone has been manufactured by similar techniques for several years.)[1]
Introduction of the rBGH product last month was met by an uproar from consumers who want the product banned until safety questions have been resolved and who want milk labeled if it is produced from rBGH-treated cows. Monsanto, the chemical company that has brought the first rBGH product to market, vigorously opposes labeling.
FDA has sided with Monsanto in opposing labeling of milk produced by drug-treated cows, and has gone one step further. FDA opposes labeling of products that are free of rBGH. FDA has even threatened legal action against milk suppliers and grocers who label their milk as free of the rBGH drug.[2] FDA says there is "no significant difference" between milk from rBGH-treated cows and milk from cows not treated, and thus a label saying "rBGH-free" would imply a difference that did not exist, and this would constitute false labeling.[3] Monsanto has filed two lawsuits against milk processors who labeled their product as free of rBGH and has mailed warnings to others who might be tempted to label their milk as rBGH-free.[4] The FDA's position on labeling was developed under the direction of Michael R. Taylor, a lawyer who joined FDA in 1991 after almost a decade as a partner in the law firm that Monsanto hired to gain FDA approval of rBGH and that last month brought Monsanto's lawsuits against milk producers who labeled their products rBGH-free. (See RHWN #381.)
Despite what FDA statements might lead consumers to think, Monsanto's rBGH is not identical to a cow's natural growth hormone. The two hormones have a different amino acid sequence. The Monsanto product is the cow's natural hormone with an extra amino acid (methionine) attached.[5]
According to agricultural researchers at the University of California at Davis, the FDA faced a similar situation once before, when the agency evaluated synthetic human growth hormone (rHGH).[6] A manufacturer of rHGH produced a product that differed from the natural product (HGH) in the same way that Monsanto's rBGH differs from natural BGH; that is to say, the rHGH had an additional methionine residue at one end. The PHYSICIANS DESK REFERENCE, a standard medical reference book on drugs, says that 30% of rHGH-treated patients developed antibodies (in other words, had an allergic reaction) compared to only 2% of HGH-treated patients. By analogy, this seems to raise the distinct possibility that some people will have an allergic reaction to Monsanto's rBGH who might not have an allergic reaction to natural BGH. FDA has steadfastly refused to evaluate the potential for human allergic reactions to rBGH.
There is considerable evidence that rBGH appears in the milk of rBGH-treated cows.[7] However, FDA has not developed, and has not required Monsanto to develop, a measuring technique that can distinguish between Monsanto's rBGH product and the cow's natural hormone. This appears to be a violation of law by FDA. Section 512 of the 1968 Animal Drug Amendments to the 1938 Federal Food, Drug and Cosmetic Act requires manufacturers submitting new animal drug applications to provide "a description of practical methods" for analysis and monitoring of drug residues in food.[8] The American Medical Association pointed out in 1991 that it is possible to develop a measuring technique to distinguish between the natural product BGH and the genetically-engineered product rBGH.[9] For reasons that are known only to FDA, the agency has not developed such a technique. Because FDA has not developed the necessary analytic technique, the agency can continue to say that rBGH is indistinguishable from BGH, implying falsely that the two hormones are identical.
Although human health effects of milk from rBGH-treated cows are uncertain, health effects on cows are better understood. Normally for about 12 weeks after a cow calves, she produces milk at the expense of her own tissues. She loses weight, she is infertile, and she is more susceptible to diseases such as mastitis (inflammation of the udder). Eventually her milk output diminishes, her food intake catches up, and she begins to rebuild her body. By injecting rBGH, a farmer can postpone for another 8 to 12 weeks the time when the cow begins rebuilding her body. This means that the cow is stressed for another 8 to 12 weeks and is more susceptible to infection during that period.[10]
The Monsanto rBGH product, sold under the trade name Posilac, comes with an insert sheet containing information about the drug. The Posilac insert sheet says, in part, "Cows injected with Posilac are at an increased risk for clinical mastitis (visibly abnormal milk). The number of cows affected with clinical mastitis and the number of cases per cow may increase. In addition, the risk of subclinical mastitis (milk not visibly abnormal) is increased. In some herds, use of Posilac has been associated with increases in somatic cell counts."[11] Somatic cell counts are another name for pus in milk. The insert sheet mentions other health effects of rBGH on cows: "Use of Posilac has been associated with increases in cystic ovaries and disorders of the uterus during the treatment period." And: "Use of Posilac may result in increased digestive disorders such as indigestion, bloat, and diarrhea."
There is abundant evidence that, when cows get mastitis, farmers give them antibiotics. Mastitis (or the pus it puts into milk) is a major cause of lost revenues to dairy farmers. According to the U.S. General Accounting Office (GAO), FDA has approved use of 30 antibiotics on dairy cows but an additional 50 antibiotics are suspected of being used illegally on dairy cows. A 1988 Illinois survey found over 200 different animal drugs on dairy farms, 58% of them not approved for use on dairy cows. Furthermore, the routine tests that FDA applies to milk nationwide can only detect 4 types of antibiotics, so FDA is not in a position to protect consumers from illegal use of antibiotics (which are sold without prescription at farm supply stores). Antibiotic residues in milk --which seem certain to increase with rBGH use --may cause adverse allergic reactions in some consumers, and very likely will contribute to development of strains of bacteria that are resistant to antibiotics, thus reducing the effectiveness of antibiotic medicinals against human and animal diseases.[12]
References
[1] Gail Feenstra, "Introduction," in William C. Liebhardt, THE
DAIRY DEBATE; CONSEQUENCES OF BOVINE GROWTH HORMONE AND
ROTATIONAL GRAZING TECHNOLOGIES (Davis, Cal.: University of
California Sustainable Agriculture Research and Education
Program, 1993), pgs. 19-20.
[2] Keith Schneider, "F.D.A. Warns the Dairy Industry Not to Label Milk Hormone-Free," NEW YORK TIMES February 8, 1994, pg. A1.
[3] Michael R. Taylor, "Interim Guidance on the Voluntary Labeling of Milk and Milk Products From Cows That Have Not Been Treated With Recombinant Bovine Somatotropin," FEDERAL REGISTER Vol. 59 No. 28 (Feb. 10, 1994), pgs. 6279-6280.
[4] "Statement on Misleading Promotion and Advertising Activities," an anonymous statement on Monsanto letterhead dated March 4, 1994, faxed to us by staff of Tom McDermott [(314) 694-3605] of Monsanto in St. Louis, Mo.
[5] Judith C. Juskevich and C. Greg Guyer, "Bovine Growth Hormone: Human Food Safety Evaluation." SCIENCE Vol. 249 (1990), pgs. 875-884.
[6] Gail Feenstra, cited above, pg. 27.
[7] This evidence is reviewed in Gail Feenstra, cited above, pgs. 20-23.
[8] FDA requirements are discussed in Samuel S. Epstein, "Potential Public Health Hazards of Biosynthetic Milk Hormones," INTERNATIONAL JOURNAL OF HEALTH SERVICES Vol. 20 No. 1 (1990), pgs. 73-84.
[9] Council on Scientific Affairs, American Medical Association, "Biotechnology and the American Agricultural Industry," JOURNAL OF THE AMERICAN MEDICAL ASSOCIATION Vol. 265 (March 20, 1991), pg. 1433 says, "Therefore, an antibody-based detection assay could be devised to determine the percentage of recombinant vs native bST present in the milk from rbST-treated animals."
[10] Donella Meadows, "Out to Pasture," GREEN ALTERNATIVES, February/March 1994, pg. 56. And Kathleen Byrnes, "Synthesis," in William C. Liebhardt, THE DAIRY DEBATE; CONSEQUENCES OF BOVINE GROWTH HORMONE AND ROTATIONAL GRAZING TECHNOLOGIES (Davis, Cal.: University of California Sustainable Agriculture Research and Education Program, 1993), pgs. 319-349.
[11] We asked Monsanto for a copy of the Posilac insert sheet. Staff of Tom McDermott [(314) 694-3605] in St. Louis, Mo., told us March 23 they were not sure whether their division had a copy; they said they would check and call us back, but we did not hear from them again before our press deadline. We received a copy from the Pure Food Campaign [1130 17th Street, N.W., Suite 630, Washington, DC 20036; telephone (202) 775-1132].
[12] Michael K. Hansen, "Testimony before the Agriculture Committee of the Canadian Parliament on Potential Animal and Human Health Effects of rbGH Use by Michael K. Hansen, Ph.D.," dated March 9, 1994. Available from: Consumer Policy Institute, Consumers Union, 101 Truman Ave., Yonkers, NY 10703-1057. Telephone (914) 378-2000.
[13] Marietta Sue Brady and others, "Resistance Development Potential of Antibiotic/Antimicrobial Residue Levels Designated as 'Safe Levels,'" JOURNAL OF FOOD PROTECTION Vol. 56 No. 3 (March 1993), pgs. 229-233.
Bovine growth hormone causes cows to produce more milk, but it does not act directly. Instead, BGH releases a chemical called IGF-1 ("insulin-like growth factor #1") which then causes increased milk production.[3] IGF-1 is a normal constituent of milk from both cows and humans. Several studies have shown that milk from rBGH-treated cows contains elevated concentrations of IGF-1. This is important because IGF-1 is chemically identical in cows and in humans--a fact FDA did not know when the agency first declared rBGH "safe" for human consumption in 1985. Thus rBGH-treated cows will very likely produce milk that contains increased levels of a growth factor known to be biologically active in humans. The consequences of this are unknown, but FDA has said the risks--whatever they may be--are worth taking. (FDA does not balance risks against benefits, but two benefits of rBGH use have been identified: an estimated $300 to $500 million in annual income to Monsanto, the only company presently marketing an FDA-approved rBGH, and an estimated 12% increase in the nation's supply of milk. Since the nation already produces more milk than it can use, the federal government will purchase the additional milk at an estimated cost to the taxpayer of $200 million or more per year.)
When an expert committee of the federal National Institutes of Health (NIH) examined the rBGH issue, it concluded that milk and meat from rBGH-treated cows are as safe as from cows not treated. However, they noted that, "Whether the additional amount of IGF-1 in milk from [rBGH-treated] cows has a local effect on the esophagus, stomach or intestines is unknown." Among the report's six recommendations was, "Determine the acute and chronic local actions of IGF-1, if any, in the upper gastrointestinal tract."[4] This has not been done. Perhaps the uncontrolled experiment now being conducted on the public by FDA and Monsanto will reveal new information on this point.
The NIH panel chose not to consider the issue of cow health or the secondary human health consequences of cow health. As we pointed out in RHWN #381 and #382, there is abundant evidence indicating that cows treated with rBGH are more prone to udder infections called mastitis. Mastitis infections add pus to milk. Because increased pus diminishes the value of milk, dairy farmers respond to mastitis with antibiotics, often unapproved and illegal antibiotics. (Mastitis presently costs dairy farmers $2 billion each year, or $200 per cow per year on the average dairy farm.[5])
Indeed, leaked internal documents reveal that Monsanto itself used several unapproved drugs to control mastitis increases in its rBGH test herds.[6]
In 1990, an FDA survey found antibiotics and sulfa drugs in 51% of 70 milk samples taken in 14 cities.[7] Subsequently FDA announced it had found no antibiotics in a follow-up survey, but the WALL STREET JOURNAL reported two months later that FDA had actually found drugs in 80% of the samples.[8] An FDA spokesperson acknowledged that antibiotics are "widely misused" by dairy farmers and veterinarians.[9]
A CBS-affiliated TV station in New York conducted its own survey of milk from stores in New York, New Jersey and Connecticut in early 1990 and reported that 80% of 50 samples contained tetracyclines, a family of antibiotics. The survey also revealed that 26% of the samples were tainted with the drug sulfamethazine, a suspected carcinogen banned from dairy use.[10]
In 1993, federal General Accounting Office (GAO) recommended that FDA not approve rBGH until the question of secondary health effects (mastitis --> antibiotics --> humans) has been resolved. On March 2, 1993, the GAO sent a letter to Donna Shalala, Secretary of Health and Human Services (of which FDA is a part) saying that in interviews FDA officials "did... acknowledge the possibility that there was an antibiotic-human food safety concern that they should investigate." But, GAO said, subsequent communications from FDA "did not address our concern: does rBGH use result in higher concentrations of antibiotics in milk or not, and if so, is the higher level acceptable from a food safety standpoint?" The GAO went on to note that FDA has said its review of human food safety issues has been completed. GAO asked, "But how can a food safety determination be made when the rBGH-mastitis-antibiotic issue has not been addressed, much less resolved?" "In conclusion," the GAO said, "we would like to point out that the increase in mastitis levels reported in the rBGH pivotal studies suggests that the potential for an increase in milk antibiotic levels is very real... [The FDA's] response suggests that our recommendations have not bee seriously addressed."[11] FDA went ahead and approved rBGH.
How can Monsanto risk an experiment on the milk supply of the American public? If widespread harm should occur, might not the company be liable for billions of dollars in damages and possible bankruptcy?
Luckily for Monsanto, and others similarly situated, recent court rulings have provided safe shelter for corporations whose consumer products result in massive litigation.
The new corporate shelter was invented by Judge Jack Weinstein in the case of Vietnam veterans seeking damages from Dow, Diamond Shamrock, Monsanto and other companies that produced Agent Orange. Agent Orange was an herbicide used in Vietnam to defoliate jungles. Many American troops exposed to the chemical during the war say they and their children were harmed. The National Academy of Sciences and the Veterans Administration in 1993 said the vets WERE harmed.[12]
The courts allowed the companies to settle with some of the plaintiffs for a fixed amount, with the stipulation that no future lawsuits can be brought against the Agent Orange manufacturers, even by people who weren't party to today's settlement because they did not know they had been harmed. In future, if a person develops a disease they believe was caused by Agent Orange, they cannot sue --their Constitutional right to due process was extinguished by the original settlement.
This is exceptionally important because litigation typically proceeds in stages. As we saw in the case of asbestos, each new lawsuit brings forth more evidence of what a company knew when. Jury awards and penalties increase as a company's deceptions and coverups are progressively revealed. The first plaintiffs may fail completely, but the 20th or 50th may be awarded many millions of dollars in compensatory and punitive damages, as the courts see, and then punish companies for, a pattern of unethical behavior.
The new legal doctrine cuts off the possibility of a series of suits against a company, thus providing almost complete protection against suits that might cause bankruptcy.
This new legal doctrine has recently been used to limit the liabilities of companies that marketed silicone breast implants. It is a creative legal invention which sharply limits the liability of corporations that market possibly-harmful products that have not been fully tested for safety. Recently more than 8 million Vietnam veterans asked the U.S. Supreme Court to review this new legal doctrine, on the ground that their Constitutional rights had been taken from them. The attorney generals of all 50 states joined with the vets asking the Supreme Court to review this new doctrine.[13] The Supreme Court refused. And that is one reason why companies are willing to risk exposing the general public to drugs in their food without fully understanding the consequences. Under doctrines invented by the Reagan/Bush courts, corporations are protected but the public is not.
References
[1] A reader, Robert Plano, points out that in RHWN #382 we
erroneously understated the degree of difference between natural
BGH and Monsanto's synthetic rBGH; in RHWN #382 we said rBGH is
natural BGH with an amino acid (methionine) added; in fact, Plano
points out, FDA says Monsanto's product is the natural BGH with
one amino acid removed (alanine) and another added (methionine);
see Judith C. Juskevich and C. Greg Guyer, "Bovine Growth
Hormone: Human Food Safety Evaluation." SCIENCE Vol. 249 (1990),
pg. 877. FDA says these differences make no difference.
[2] David S. Kronfeld, "Recombinant Bovine Growth Hormone: Cow Responses Delay Drug Approval and Impact Public Health" in William C. Liebhardt, THE DAIRY DEBATE; CONSEQUENCES OF BOVINE GROWTH HORMONE AND ROTATIONAL GRAZING TECHNOLOGIES (Davis, Cal.: University of California Sustainable Agriculture Research and Education Program, 1993), pgs. 67-112. Kronfeld raised this point in "Safety of Bovine Growth Hormone," SCIENCE Vol. 251 (January 18, 1991), pg. 256, and FDA responded in SCIENCE Vol. 251 (January 18, 1991), pgs. 256-257.
[3] T. B. Mepham, "Public health implications of bovine somatotrophin [sic] use in dairying: discussion paper," JOURNAL OF THE ROYAL SOCIETY OF MEDICINE Vol. 85 (December 1992), pgs. 736-739.
[4] Melvin M. Grumbach and others, "NIH Technology Assessment Conference Statement on Bovine Somatotropin," JOURNAL OF THE AMERICAN MEDICAL ASSOCIATION Vol. 265 No. 11 (March 20, 1991), pgs. 1423-1425.
[5] William M. Murphy and John R. Kunkel, "Sustainable Agriculture: Controlled Grazing vs. Confinement Feeding of Dairy Cows," in William C. Liebhardt, THE DAIRY DEBATE; CONSEQUENCES OF BOVINE GROWTH HORMONE AND ROTATIONAL GRAZING TECHNOLOGIES (Davis, Cal.: University of California Sustainable Agriculture Research and Education Program, 1993), pg. 121.
[6] Samuel S. Epstein and Peter Hardin, "Confidential Monsanto Research Files Dispute Many BGH Safety Claims," THE MILKWEED [Madison, WI; phone: 608/455-2400] Vol. 128 (1990), pgs. 3-6, discussing P.J. Eppard and others, TOXICITY OF CP115099 IN A PROLONGED RELEASE SYSTEM IN LACTATING COWS. REPORT MSL 6345. (St. Louis, Mo.: Monsanto Agricultural Co., 1987).
[7] Bruce Ingersoll, "Technology & Health: FDA Detects Drugs in Milk But Fails to Confirm Results," WALL STREET JOURNAL February 6, 1990, pg. B6.
[8] Bruce Ingersoll, "Politics and Policy: GAO Says FDA Can't Substantiate Claims About Milk," WALL STREET JOURNAL November 21, 1990, pg. A16.
[9] Bruce Ingersoll, "Technology & Health: FDA Plans a Nationwide Test of Milk for Antibiotics, Other Drug Residues," WALL STREET JOURNAL December 28, 1990, pg. 10.
[10] Bruce Ingersoll, "New York Milk Supply Highly Tainted, TV Station Says, Based on Own Survey," WALL STREET JOURNAL February 8, 1990, pg. unknown.
[11] Correspondence from Eleanor Chelimsky, Assistant Comptroller General, General Accounting Office, to Donna E. Shalala, Secretary of Health and Human Services, March 2, 1993.
[12] Institute of Medicine, VETERANS AND AGENT ORANGE: HEALTH EFFECTS OF HERBICIDES USED IN VIETNAM (Washington, D.C.: National Academy Press, 1993).
[13] P.B. Onderonk, Jr. and others, "No. 93-860 In the Supreme Court of the United States, October Term, 1993, Shirley Ivy... v. Diamond Shamrock... on Petition for Writ of Certiorari to the United States Court of Appeals for the Second Circuit."
The demand for milk does not change much year to year. An economist would say the demand for milk is "inelastic." Therefore, increasing milk production tends to lower the price of milk, a classic case of the law of supply-and-demand.
Since 1950 U.S. dairy farmers have been producing more milk than Americans can consume. To prevent supply-and-demand from bankrupting the dairy industry, the government buys up surplus milk via a "price support" program, to help dairy farmers survive, to assure the future of the nation's milk supply. During 1980-1985 the government spent an average of $2.1 billion each year buying surplus milk. In 1985 Congress passed the Food Security Act to try to reduce the total cost of the dairy price support program by reducing the number of dairy herds. During 1986-87, the government paid farmers to kill their cows and stop dairy farming for 5 years. Some 14,000 farmers participated in this voluntary program, slaughtering a total of 1.55 million milk cows.[1] But even that drastic program did not solve the problem. Excess milk production, which continues today, has steadily driven down the "support price" (the price farmers receive for milk).
Ironically, because of a web of federal and state laws and regulations, a lower milk price on the farm does not necessarily translate into lower milk prices in the grocery store. In fact, during recent years the support price paid to farmers for milk has dropped steadily from $12.50 per hundredweight in 1986 to $10.10 in 1990, a 19% decrease; yet the price of milk in the grocery store during the same period rose from $1.11 per half-gallon of whole milk to $1.49, a 29% increase.[2] Therefore, there is no good reason to believe that increasing milk production with rBGH will provide cheaper milk for the consumer.
Historians and economists have observed a pattern when new farm technologies become available. The "early adopters" of a new technology benefit for a time. The first farmers to adopt the new technology get the jump on their competitors; their milk yield rises faster than their costs and for a time their profits increase. (Because of inelastic demand, during this period more profitable farms drive less profitable farms out of business.) Before long, however, increased milk yields and wider use of the technology remove the early adopter's advantage. As we have noted, the consumer may never see a price decrease, but increased yields drive down farm prices, reducing farmers' profits. The farmer is soon back at square one, pressed to the wall by a cost-price squeeze, scrambling for the next competitive advantage. This has been dubbed the "technology treadmill."[3]
The latest treadmill technology, rBGH, will very likely repeat this pattern. It will benefit the early adopters and increase milk production which, in turn, will drive down the support price of milk. After the early adopters' competitive advantage disappears, the net result will simply be more surplus milk that will have to be purchased at taxpayer expense.
In the meantime, introduction of rBGH will have driven a certain number of farms out of business--maybe as many as 30,000 or 40,000 farms--accelerating a trend that has been under way for decades. (Ten thousand dairy farms have gone out of business in Minnesota alone since 1980.)
Because large farms are usually best-equipped to manage complex technologies, and because they are best able to take and survive financial risks, large farms tend to be the "early adopters" of a high-tech innovation like rBGH. Large dairy farms tend to be located in the sunbelt. Mid-sized farms tend to be located in the midwest and northeast. For example, California has 2500 large dairy herds averaging 400 cows each. Wisconsin, on the other hand, has 35,000 mid-sized dairy farms averaging 50 cows each.
According to eight studies by federal agencies and by university researchers, rBGH will tend to favor the survival of large farms in the sunbelt, and will tend to drive mid-sized farms out of business in the midwest and northeast.[4] A long and well-established body of literature has demonstrated that the presence of mid-sized farms is vital to the social and economic health of many rural communities. Thus yield-enhancing technologies, like rBGH, degrade rural community life, and drive less-successful farmers into cities where they may become part of the "urban problem."
If you think of agriculture as an industrial enterprise where the aim is to grow as much as possible with as few people as possible, without regard to environmental or social costs, replacing family farmers with genetically-engineered drugs is a "successful" approach. On the other hand, if you think of a mid-sized farm as a family occupational base, and as the backbone of rural community life, displacing farmers by drugs is clearly antisocial and bad public policy.
The large farms whose survival will be favored by rBGH confine their herds year-round in the style of a "feed lot." The cows spend their lives confined in a building with a concrete floor (sometimes abrasive, sometimes slippery with urine and manure) which gives rise to foot and joint problems. Manure and urine are concentrated, which creates serious environmental problems of disposal. Sunlight and fresh air--excellent disinfectants--are not abundantly available; disease rates tend to be elevated in confined herds. Confined animals are fed a diet high in grain with protein supplements, including meat. Raising grain in the modern way is an energy-intensive operation employing heavily-polluting inorganic fertilizers, insecticides, herbicides, and tillage practices that intensify soil erosion. In sum, dairy factories create serious new environmental problems, and exacerbate old ones.
To reduce their own labor and to increase profits, since 1983 many American farmers have shifted away from confined feeding to a technique called "rotational grazing" developed first in France and then in New Zealand where it is the dominant dairy technology.
In rotational grazing, the daily forage requirement for cattle is met by dividing pastures into smaller paddocks and moving animals every 12 hours to 3 days. With a sufficient number of paddocks in the system, each paddock will be rested between 15 and 40 days, depending on forage regrowth before regrazing. This system allows cattle to do much more for themselves to produce milk, compared to confinement feeding.
A new book from the ag school at University of California at Davis offers case studies of rotational grazing on 34 farms in Maine, Wisconsin, Pennsylvania, and Vermont.[5] The farms vary in size from 40 cows on 12 acres to 800 cows on 2000 acres.
With remarkable consistency, these case studies reveal the following consequences of rotational grazing compared to confinement feeding:[7]
References
[1] Michael K. Hansen, BIOTECHNOLOGY AND MILK; BENEFIT OR THREAT?
AN ANALYSIS OF ISSUES RELATED TO BGH/BST USE IN THE DAIRY
INDUSTRY (Mount Vernon, N.Y.: Consumers Union/Consumer Policy
Institute, 1990), pg. 3.
[2] Hansen, cited above in note 1, pg. 5, Figure 1.
[3] W.W. Cochrane, THE CITY MAN'S GUIDE TO THE FARM PROBLEM (Minneapolis, Mn.: University of Minnesota Press, 1965), pg. 66. See also W.W. Cochrane. FARM PRICES: MYTH AND REALITY. Minneapolis, Mn.: University of Minnesota Press, 1958.
[4] David Campbell, "The Economic and Social Viability of Rural Communities: BGH vs. Rotational Grazing," in William C. Liebhardt, THE DAIRY DEBATE; CONSEQUENCES OF BOVINE GROWTH HORMONE AND ROTATIONAL GRAZING TECHNOLOGIES (Davis, Cal.: University of California Sustainable Agriculture Research and Education Program, 1993), pg. 291.
[5] William C. Liebhardt, "Farmer Experience with Rotational Grazing: A Case Study Approach," in Liebhardt, cited above in note 4, pgs. 132-188.
[6] William M. Murphy and John R. Kunkel, "Sustainable Agriculture: Controlled Grazing vs. Confinement Feeding of Dairy Cows," in Liebhardt, cited above in note 4, pg. 117.