To the staff and supporters of the Wallace Institute

I am startled by the reaction of the Organic Trade Association and the Wallace Institute to my assertion that organic food may pose a higher risk of attack from E. coli O157:H7 and Salmonella typhimurium than mainstream foods.

For decades, the supporters of organic food told us they were primarily interested in protecting consumers’ health. The major reason for "alternative agriculture" was to protect their advocates from the unknown dangers of synthetic fertilizers and pesticides.

Therefore, I naturally thought that your first reaction to the question of excessive bacterial danger in organic foods would be to search out whether such a threat existed. After all, your customers are the most risk-averse in the world.

Instead, your first reaction is to deny any problem—offering a New York Times news story as your "credible scientific protocol." The Times says that the lettuce mentioned in the CDC data was contaminated in the packing process—but the Times has been cheerleading for organic foods for as long as I can remember. Recently, The Times has been more famous for the causes it blindly supports than for its objectivity as a news source.

In fact, I find that I understated the bacterial risks of organic food in my first article. I said that the consumers of organic and natural foods were eight times more likely to be attacked by dangerous bacteria. When I began getting hostile questions, I looked at the data again. Many of the confirmed cases were not traced to food sources at all, but to such sources as swimming pools, day-care centers, and nursing homes. Those sources are matters of personal hygiene rather than food contamination. If we tally only the confirmed O157 cases traced to food sources, organic and "natural" foods made up 36 percent of the total in 1996.

(Incidentally, I never claimed that the Odwalla apple juice cited in the CDC data was organic. I freely admit that I sometimes lump organic and "natural" foods into one large category since they appeal to the same consumers for roughly the same reasons.)

You are certainly correct that one year’s data on E. Coli O157 confirmed cases is not an adequate basis for putting new regulations on organic food. The data is limited and lumpy. However, it is certainly a valid basis for raising the question of organic safety. It is especially important when this is the only data the CDC has allowed to reach the public—and when we have other important, damning information about the bacterial dangers of organic food in the era of E. coli O157:

• We know, on the basis of science and experience, that animal manure is a major reservoir of bacteria, some beneficial, some dangerous, and it is certainly a key reservoir of E. coli O157.
  
  
• On the basis of science and experience, we also know that it is enormously difficult to make the composting process hot enough for long enough throughout a compost pile to be sure of killing all of the dangerous bacteria.
  
  
• We know that the O157 bacterium is particularly heat-resistant.
  
  
• Cornell University says that the heavy use of sulfur and copper compounds in organic production may represent a more serious ecological problem than mainstream farm chemicals.
  
  

So long as the foodborne bacterial dangers were moderate, the additional bacterial risks in organic food were not a very important problem. But now we know that the vicious new E. coli O157 is a far more deadly and dangerous bacterium than the earlier strains. The old bugs sometimes carried off the weak, and gave the strong a stomach upset. But the O157 bug can kill even the strong, and inflict permanent kidney and liver damage on its survivors.

Clearly, O157:H7 is so serious a danger to the public that the bacterial risks of using animal manure as a fertility source for food crops must be rethought.

Experts join me in this view, with Dr. Robert Tauxe not least among them. Dr. Tauxe, as you know, is Director of the Foodborne and Diarrheal Diseases Branch of the Centers for Disease Control. Regardless of whatever you say he told you recently, Dr. Tauxe was highly and publicly critical of using animal manure in food production in a recent article in the Journal of the American Medical Association. He suggested that we must stop using such farming systems to produce our food. (See "Public Health Experts Take Aim at a Moving Target: Foodborne Infections," JAMA, Jan. 8, 1997.)

We asked the Centers for Disease Control to look closely at the issue of bacterial risks in organic and "natural" foods, to see if our hypothesis of elevated risk is valid. You seem proud to proclaim that the CDC is not making such a review. We are very surprised, since such a review would seem to be in the interests of your consumers, and the best way to vindicate your industry. Your opposition speaks volumes.

You bemoan the lack of a "credible scientific protocol" in my article. It is ironic that the Wallace Institute feels it is suffering from "unfounded allegations." Mainstream farmers already know something about that. In fact, organic farming and alternative agriculture have "earned" their place in the market by giving the public unfounded allegations about the "dangers" of modern farming:

• You misrepresent pesticides as a cancer risk to the public. The National Research Council, the American Cancer Society and the Canadian Network of Toxicology Centers all deny there is any significant cancer risk from pesticide residues. Their scientific protocols are completely credible. Even the Environmental Protection Agency says that only 3 percent of our cancers are due to the entire category of "environmental dangers" including pesticides, asbestos, radon, electromagnetic fields, and other natural phenomena such as sunlight exposure.
  
  
• You claim that modern farming is not sustainable. However, the Soil and Water Conservation Society of America says that it is the most sustainable in history. Their conclusion is based on technical advances such as (a) chemical fertilizers that ensure high soil fertility, (b) stress-tolerant and pest-resistant new seed varieties, (c) integrated pest management, which makes the pesticides more effective, and (d) conservation tillage, which uses chemical weed killers to avoid the erosion and carbon losses of "bare earth farming" with plows and cultivators. The Society recognizes that pests evolve to overcome any pest control regime—so research for new ones must continue. The Society’s scientific protocols are excellent.
  
  
• You strongly suggest that organic foods are more nutritious than conventionally produced food. But your own research, reported in the Journal of Alternative Agriculture, has been unable to find any such nutritional advantages. You note that the variety of carrots makes more difference in the carrots’ nutritional content than the farming system with which they are grown.
  
  
• You maintain that modern farming is bad for the environment. But the high yields and efficient processing of the modern food system are saving close to twenty million square miles of wildlands from being plowed down for low-yield food production. That’s equal to the total land area of the U.S., Europe, South America, and South Asia.
  
  

I am not opposed to organic farming. Everyone has a right to fruits and vegetables that they can enjoy. If chemophobes gave up eating fruits and vegetables because of the pesticide traces, their cancer risks would double.

However, thanks to unfounded allegations about the health and environmental "risks" of modern farming, public funding for high-yield farming research is declining just when we need it most to protect the wildlands of a more-populous and affluent world in the twenty-first century. Regulators are responding to "public opinion" by trying to reduce or even eliminate the use of the farm chemicals that support high yields.

The public is put at even greater risk because organic supporters allege (without credible scientific protocols) that food irradiation represents a danger to the public and they therefore oppose the one proven way of stopping O157 in our food system.

At this point, based on the credible scientific evidence, O157 contamination of organic and "natural" food has already claimed more consumers’ lives and inflicted more permanent consumer injuries than all the pesticides ever used. At the same time, the organic movement is doing its best to frighten the public into mandating the broad use of organic farming—and that would cause the destruction of huge tracts of wildlands and wild species while supporting genocide on a global basis.

It is not a record of which you should be very proud.

Sincerely,

Dennis T. Avery, Director
Center for Global Food Issues, Hudson Institute

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