Industry Watchdog Calls for Public Meetings on the Use of Genetically Engineered Vaccines

The Story: A Quick Overview

  • One of the most prominent differentials between conventional and organic food is the latter’s strict prohibition on genetically modified farm inputs and ingredients.
  • At the encouragement of the livestock industry, the USDA and certain certifiers have allowed the use of genetically engineered vaccines in organic production—sanctioning a don’t ask/don’t tell protocol.
  • A briefing paper just released by OrganicEye provides organic industry stakeholders an overview of current vaccination practices, exploring essentiality and options for the organic industry coming into legal compliance.
  •  OrganicEye has sent a letter to the USDA, as a preliminary alternative to litigation, requesting the National Organic Standards Board convene a public forum to fully explore the issue.

LA FARGE, Wis. — One of the foundational precepts in the organic farming and food movement, understood by agribusiness executives and consumers alike, is the legal prohibition on genetically engineered materials used in farm production or food processing.

However, the USDA, and some certifiers, have quietly looked the other way as commercial livestock interests have reportedly started using genetically engineered vaccines in animals producing certified organic meat, eggs, and dairy products. Now OrganicEye, a preeminent industry watchdog, has formally requested the USDA convene a public forum to discuss the issue as an alternative to litigation.

OrganicEye has released a briefing paper providing organic industry stakeholders an opportunity to drill down to fully understand this controversy and what options may exist to remediate the current situation.

“Other than some state regulations pertaining to interstate transportation of livestock, there are not any federal legal requirements to vaccinate animals,” said Mark A. Kastel, Executive Director of OrganicEye and its Senior Farm Policy Analyst.

The use of synthetic and non-organic materials in organic production, including drugs, is governed by Congress’ passage of the Organic Foods Production Act of 1990. The law and its implementing regulations require a review of materials by the National Organic Standards Board (NOSB).

The NOSB, a 15-member expert and diverse advisory panel established by Congress, has been faced with the conundrum that some of the previously approved vaccines are being phased-out and substituted with ones produced through genetic modification — banned as a “prohibited method” in organic production.

As a compromise, although still likely illegal, the board recommended to the USDA that it include a regulatory amendment on vaccine approval allowing genetically modified versions only in cases when traditionally produced vaccines are no longer commercially available. The USDA has failed to enact the recommendation from the NOSB and has stated it has no intention to do so.

“The impetus for us to act now is the impending introduction of vaccines for livestock produced using mRNA technology similar to that used by Pfizer and Moderna to produce their respective versions of the SARS-CoV-2 vaccine,” added Kastel. “There is a continuing controversy in the country concerning this new technology and we should work to preserve organics as the last safe haven for eaters who want to secure a truly ‘natural’ diet.”

OrganicEye maintains that the predisposition of the USDA’s National Organic Program to “kick the can down the road” on this and other highly-controversial issues is “unacceptable.”

In discussions pursuant to vaccines at previous NOSB meetings, some certifiers, accredited by the USDA and charged with implementing the law by inspecting farms and processors, have publicly admitted that they do not even check to determine if vaccines violate the prohibition against genetic engineering.

“It’s a matter of don’t ask/don’t tell when it comes to genetically modified vaccines used in organics,” Kastel lamented.

OrganicEye emphasized that federal regulations mandate the review of all synthetic materials, which are by default banned in organics unless carefully determined safe for human health and the environment. An additional prerequisite is for the NOSB to establish that they are “essential” in organic production.

In terms of its essentiality, the question remains as to whether, if animals are maintained in a healthy environment with plenty of outdoor access and pasture for ruminants like beef and dairy cows on family-scale farms, the entire regime of commonly used vaccines are truly essential given they aren’t legally mandated.

“I believe there is an opening for the USDA Animal Plant and Inspection Service (APHIS) and Center for Veterinary Biologicals (CVB) to be prompted to create a very clear, easily understandable categorization system such that organic farmers don’t use a genetically engineered vaccine by mistake that could result in economic damage,” said Dr. Hubert Karreman, a North Carolina dairy farmer, Doctor of Veterinary Medicine, and Charter Fellow of the American College of Veterinary Botanical Medicine. Dr. Karreman served on the NOSB from 2005-2010, including three years as Chair of the NOSB Livestock Subcommittee.

OrganicEye stated in their letter to the USDA, “As with many other controversial elements in organic regulations, powerful lobbyists and industry interests, mostly with expertise in conventional livestock production as in the case of vaccines, have influenced the NOSB and USDA in terms of universally relying on vaccines rather than providing more healthful and secure living environments for domesticated animals. 

These pharmaceuticals may, in some cases, provide a crutch that enables industrial-scale livestock factories to qualify for organic certification at the expense of family-scale farms and ranches, eroding the confidence that consumers have in the organic label.”

OrganicEye is currently promoting a campaign to put pressure on the Biden administration to reduce its dependence on political appointees from corporate agribusiness in organic regulatory oversight—a practice that has resulted in legally-questionable conduct.



There is also concern among some organic stakeholders that the biotechnology industry is intentionally engaged in a form of subterfuge by changing the nomenclature of some current technologies, suggesting that some methods of manipulating the genome of plants and animals, such as “CRISPR” (Clustered Regularly Interspaced Short Palindromic Repeats) or “gene editing” do not constitute genetically modified organisms or genetic engineering.