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May 17th, 2013

Farm Bill 2013: The Bill Goes to the Senate Floor… Again

By Patty Lovera

Read the report

Confused about the Farm Bill? Click here to read our report, Farm Bill 101.

This week, both the House and Senate Agriculture committees adopted their versions of the 2013 Farm Bill. This is the latest move in the long-running attempt to pass a “normal” 5-year farm bill to replace one that was last passed in 2008. Several attempts to pass a farm bill in 2012 were unsuccessful and the farm bill that is currently in effect is a short-term extension that expires in September 2013.

There are some significant differences between the House and the Senate, in both what their bills actually contain and in the process used to get them through the committee. Both sides had an abbreviated process, skipping the normal step of conducting a series of hearings to explore various issues before writing the bill. But the Senate Agriculture Committee took the streamlining even further, managing to discuss, amend and pass its version of the bill in a little under three hours on Tuesday. The House Agriculture Committee finished theirs in a marathon session that took most of the day, wrapping up just before midnight Wednesday night.

Now each bill (HR 1947 and S 954) has to go to the floor for the whole body to vote on. The Senate is going first, with leadership claiming they will do the Farm Bill as early as next week. The full House may see their bill in June.

Read the full article…

May 14th, 2013

Monsanto and Other GM Firms are Winning in the U.S. – and Globally

By Wenonah Hauter

For the Presss: High Resolution Image of Wenonah Hauter

Wenonah Hauter, Food & Water Watch Executive Director

Originally posted at The Guardian’s Comment is Free

If you have a feeling that genetically modified (GM) foods are being forced upon the population by a handful of business interests and vociferously defended by the scientists that work in the ag industry or at the research institutions it funds, you might be onto something. The zeal with which GMO proponents evangelize transgenic seeds (and now, transgenic food animals) is so extreme that they are even pouring vast sums of money to defeat popular efforts to simply label GE foods—like the nearly $50 million spent to defeat the popular ballot measure to label GE foods in California, Prop 37. What’s more, it’s not just happening in the United States. A new report by Food & Water Watch shows the extent to which the U.S. State Department is working on behalf of the GM seed industry to make sure that biotech crops are served up abroad—whether the world wants them or not.

The report analyzes over 900 State Department diplomatic cables from 2005 to 2009 and reveals how far the U.S. government will go to help serve the seed industry’s agenda abroad, knowing that resistance to GMOs worldwide is high. It lobbies a vociferously pro-biotech agenda, operates a rigorous public relations campaign to improve the image of biotechnology and challenges commonsense safeguards and rules — including opposing popular GM food labeling laws.

Here are some of the tidbits gleaned from our comprehensive look at the cables:

  • Between 2007 and 2009, annual cables were distributed to “encourage the use of agricultural biotechnology,” directing U.S. embassies to ”pursue an active biotech agenda”.
  • There was a comprehensive communications campaign aimed to “promote understanding and acceptance of the technology” and “develop support for U.S. government trade and development policy positions on biotech” in light of the worldwide backlash against GM crops.
  • Where backlash was high, some embassies downplayed efforts. In Uruguay, the embassy has been “extremely cautious to keep [its] fingerprints off conferences” promoting biotechnology. In Peru and Romania, the U.S. government helped create new pro-biotech nongovernmental organizations.
  • The State Department urged embassies to generate positive media coverage about GE crops. Diplomatic posts also bypassed the media and took the message directly to the public; for example, the Hong Kong consulate sent DVDs of a pro-biotech presentation to every high school.
  • The State Department worked to diminish trade barriers to the benefit of seed companies, and encouraged the embassies to “publicize the benefits of agbiotech as a development tool.”

Click here to read the report, “Biotech Ambassadors: How the U.S. State Department Promotes the Seed Industry’s Global Agenda”.

Monsanto was a great beneficiary of the State Department’s taxpayer-funded diplomacy, helping pave the way for the cultivation of its seeds abroad: the company appeared in 6.1 percent of the biotech cables analyzed between 2005 and 2009 from 21 countries. The embassy in South Africa even informed Monsanto and Pioneer about two recently vacated positions in the agency that provided biotech oversight, suggesting that the companies advance “qualified applicants” to fill the position. Some embassies even attempted to facilitate favorable outcomes for intellectual property law and patent issues on behalf of the company.

The cables also show extensive lobbying against in-country efforts to require labeling of GM foods. In 2008, the Hong Kong consulate “played a key role” in convincing regulators to abandon a proposed mandatory labeling requirement. One in eight cables from 42 nations between 2005 and 2009 addressed biotech-labeling requirements.

What’s more, the U.S. government is now secretly negotiating major trade deals with Europe and the countries of the Pacific Rim that would force skeptical and unwilling countries to accept biotech imports, commercialize biotech crops and prevent the labeling of GM foods.

The vast influence that Monsanto and the biotech seed industry have on our foreign affairs is just one tentacle of a beast comprised by a handful of huge corporations who wield enormous power over most food policy in the United States. My new book, Foodopoly: The Battle Over the Future of Food and Farming in America (which is being launched in Europe this week) deals extensively with this corporate influence over our food system.

It’s no accident that we’re here: a farm policy of “get big or get out” that has been going on for decades has only benefited big companies that are becoming more and more consolidated. They wield unprecedented power over the market, putting small and midsized farmers out of business and favoring factory farms and the cultivation of GM commodities that fuel them—GM corn and soy, which are also the cornerstone of junk foods produced and sold worldwide (fueling an obesity epidemic in America and beyond.)

Thanks, Monsanto. And thanks, State Department. Not only are you selling seeds—you’re selling out democracy.

May 13th, 2013

Busy Few Days for Biotech Food Watchers

By Patty Lovera

Read the report, “Monsanto: A Corporate Profile”

If you’re following what Monsanto’s up to these days, it’s a truly mixed bag. Today, the Supreme Court ruled unanimously that a farmer had infringed on Monsanto’s patent by saving biotech seeds and replanting them. The farmer, Vernon Hugh Bowman, was ordered to pay Monsanto $84,000. Thus, Monsanto’s bullying of farmers who don’t play by their rules continues.

The good news? Last Friday, the USDA announced that it would be doing environmental impact statements for crops tolerant to dicamba and 2,4-D—the chemical that Monsanto and Dow, respectively, are seeking to commercialize to deal with superweeds that have evolved to become tolerant of applications of Roundup. The industry currently estimates that at least 60 million acres of crops are now resistant to at least one herbicide.

This more rigorous review of the chemicals is good news and shows that the USDA can be pressured to do the right thing if enough people speak up.

The USDA received over 400,000 petitions against Dow’s applications to deregulate 2,4-D corn and soybeans, and 500 individual comments and 31,000 letters on Monsanto’s petition to deregulate dicamba-tolerant soybeans and cotton. Food & Water Watch supporters submitted more than 50,000 comments opposing the approval of these crops.

This delay in commercialization is a victory for people concerned about industrial agriculture. So far, the Department has failed to address the critical need for a new approach to evaluating biotech crops and the chemical use that accompanies them. To fully address all of the environmental impacts of crops engineered to withstand applications of harsher herbicides, USDA must also review the evolution of superweeds that become resistant in droves to any and all herbicides matched with these biotech crops and the danger posed to the environment, farmer and farm worker health and neighboring crops that could be damaged by drift.

Finally, stay tuned tomorrow for the release of our new report that analyzes State Department diplomatic cables between 2005 and 2009. You’ll be interested to see how many times the name Monsanto comes up in official State Department communications about biotech crops.

May 10th, 2013

Outsourced, Imported Food is a Recipe for Disaster

By Anna Ghosh

Thanks to Michael Pollan’s new book, there’s a lot of buzz right now about Americans’ meals being outsourced, but a connected and equally troubling trend – with even riskier food safety implications – is that Americans’ food is increasingly being imported from countries with abominable track records for food safety. And the country on the top of the list is China. 

This week, Food & Water Watch Assistant Director Patty Lovera testified before the House Committee on Foreign Affairs Subcommittee on Europe, Eurasia and Emerging Threats to discuss China as the leading producer of many foods Americans eat: apples, tomatoes, peaches, potatoes, garlic, seafood, processed food and food ingredients like xylitol and vitamin C.

Headlines about risky food from China have become all too common – melamine in milk, a chicken for beef swap, toxic juice, exploding watermelons (really, you can’t make this stuff up). Even our pets are threatened. Since 2007, chicken jerky treats imported from China are suspected to have caused more than 600 cases of canine illness and deaths to date.me

In her testimony, Patty explains how combining trade policy with a food safety regulatory system that’s not up to the job of dealing with the rising tide of imports is a recipe for disaster. She warns about the risks involved when cash-strapped agencies turn to third party certifiers (doubly outsourced), and how consumers’ only tool to be able to make informed decisions about where their food comes from – Country of Origin Labeling (COOL) – needs to be improved and expanded.

May 9th, 2013

Farm Bill Update: Will Congress Make Improvements or Continue to Kick the Can?

Patty Lovera

Food & Water Watch Assistant Director Patty Lovera

By Patty Lovera

It’s time for another installment in the saga of the never-ending Farm Bill debate. In previous episodes, Congress passed a terrible bill to extend portions of the last Farm Bill as they tried to escape the “fiscal cliff” on New Year’s Day. That kept some parts of farm policy alive until the end of September, 2013, but abandoned important programs for organic and sustainable agriculture, conservation and beginning farmers.

And now, Congress is once again working to try to pass something before the short-term Farm Bill expires. Both the House and Senate Agriculture Committees say they will develop their versions of the bill this month (Exactly which day or week isn’t quite clear). The committees say they will “mark up” the bills quickly and get them out of committee so the full House and Senate can vote on them this summer.

At this stage of the game, we don’t know exactly what will be in the bills the committees work on. But we can make some predictions on what will need improving.

On competition, we will be urging the committees to include a ban on packer ownership of livestock, creation of a special counsel at USDA to deal with competition in agriculture markets, and to not include any measures that limit USDA’s ability to enforce rules on contracts for poultry growers that were in the 2008 Farm Bill.

There will once again be battles over the food safety net for low-income families, especially in the House, where there will likely be multiple attempts to make big cuts to the Supplemental Nutrition Assistance Program (formerly known as food stamps), the main federal nutrition program (background info on SNAP).

Organic and sustainable agriculture were victims of last year’s political gridlock, which allowed some important programs to expire and be abandoned by the last Farm Bill extension. This version of the bill should restore these programs for beginning farmers and ranchers and conservation. Specifically on organic agriculture, the bill should restore funding for the organic certification cost-share program (which helps operations that are new to organic pay for initial certification costs), and organic data collection and research programs at USDA.

Senator Gillibrand (D-NY) is offering an important addition to the Farm Bill that would require USDA to develop and implement a mechanism for employees of the Food Safety and Inspection Service to coordinate the reporting, evaluation, and abatement of potential occupational safety hazards. This is a critical improvement, given the recent news about health threats to workers and USDA inspectors in poultry plants due to the chemicals used to disinfect chickens. This problem will only get worse if the USDA is allowed to go forward with its proposal to deregulate poultry inspection and speed up the lines in poultry slaughterhouses, with likely increases in chemical use to pick up the slack.

Let your members of Congress know that you expect them to do a better job this time around on the Farm Bill. You can take action here: http://fwwat.ch/FBMay

Fighting Back in Fracking Country

By Seth Gladstone

Ban Fracking!After enduring the harsh realities of fracking for almost a decade, the people of Pennsylvania are fed up. They’re sick – literally – of the poisoned drinking water and air pollution. They’re tired of the incessant noise and the truck traffic. And they’re coming to terms with the boom-and-bust reality of rural industrialization, environmental degradation and eventual abandonment that fracking inevitably brings.

Now the people of Pennsylvania are pushing back against the horrors of extreme gas drilling by taking matters into their own hands and making their voices heard. Recently they delivered more than 100,000 petitions to Governor Corbett and the state legislature calling for a moratorium on fracking in the state. 20 large boxes, each filled to the brim with page after page of residents’ signatures, were hauled into the Statehouse. With that, the people had spoken.

“Pennsylvanians are disgusted with fracking,” said Food & Water Watch statewide organizer Sam Bernhardt. “They’re organizing street by street and town by town – at churches, at colleges and at coffee shops. Across the state, local officials have been feeling the heat from residents for years, and now our leaders in Harrisburg are feeling the heat as well.”

Many of the residents working so hard for a moratorium are motivated by the personal tragedies beset on their families by fracking. Sadly, these families are a large and growing constituency. The Pennsylvania Alliance for Clean Water and Air maintains a List of the Harmed, citing more than 1,200 separate cases of Pennsylvania residents whose health or safety was harmed by fracking operations. Considering that the oil and gas industry has been cited for more than 4,300 environmental violations in recent years, it’s a wonder that the list isn’t larger.

One reason so many cases of human health impacts go unreported in Pennsylvania is the controversial Act 13, a state law passed last year that has done almost as much harm to the people of Pennsylvania as the gas drillers themselves. For many residents now engaged in the struggle to halt fracking, Act 13 was the final straw that pushed them into action.

Billed as a regulatory mechanism that would empower local communities subjected to fracking, Act 13 was actually a sinister Get Out of Jail Free Card for the industry. It prevents medical doctors from sharing with patients who are exposed to toxic fracking chemicals the facts and details about those chemicals and their health risks. Essentially, Pennsylvania doctors are prohibited from discussing with fracking victims the details of how and why they are ill. Shocking.

If there’s any good that’s come from the countless hardships Pennsylvania families have faced due to fracking, it’s the education and inspiration these circumstances have provided to activists in states like New York that are working feverishly to prevent such tragedies in their own communities. But this comes as little solace to the sick and tired in Pennsylvania for whom only a fracking moratorium in their own state will console. For them, 100,000 petitions delivered to the statehouse are only the beginning of their effort.

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May 8th, 2013

Nestlé Flexes Its Muscle With Political Contributions

By Ben King Bottled Water at Grand Canyon

It’s no secret that big businesses try to influence the political environment and government through lobbying, PAC money and plying elected officials with campaign contributions. After reviewing contributions made by Nestlé Waters, it seems that the company is no stranger to this strategy. 

From Michigan to Florida, Nestlé has been very generous with contributions to members of Congress whose districts include springs and other water sources or bottling facilities. 

In 2007, Nestlé gave thousands in campaign contributions to Indiana Governor Mitch Daniels [R], who supported the Great Lakes Compact, a legal agreement among states in the Great Lakes region governing management of the local water supply. The Compact included a loophole that exempted the bottled water industry from following its water withdrawal regulations. Nestlé also received $850,000 in property tax credits from the state for a bottled water facility built in Greenwood, Indiana during his term.

In 2004 and 2008, Nestlé gave big contributions to New York State Senator Carl Marcellino [R], a vociferous opponent of a new bottle deposit bill which would have imposed fees for certain plastic bottles, including those for bottled water, to encourage recycling. Marcellino called the bill a “money grab” out of the pockets of beverage makers.

But it seems that there’s nowhere that Nestlé has spent more money than in the state of Maine. 

As Food & Water Watch blogged last month, Nestlé is trying to enter into a new 25-to 45-year contract with the Fryeburg Water Company, which has been supplying the company with water since 1997. Though Nestlé claims the agreement will benefit the public by generating substantial revenue, there is no certainty that this plan would actually keep water rates down. The State Public Utility Commission is currently reviewing the contract. 

In this contentious environment, Nestlé, its employees and lobbyists have spent nearly $650,000 on campaign contributions and support in the state of Maine. Notably, they spent $218,000 to defeat a state bottled water tax in 2004 and 2005, and another $106,000 to help repeal a state beverage tax in 2008. They’ve also given to dozens of candidates and PACs across the state, from Aroostook County to Portland. Among these legislators are more than a few representing districts where Nestlé’s springs and bottling operations are located, including those in Denmark, Fryeburg, Kingfeld and Poland.

But Nestlé’s influence on state government doesn’t end there. One member of the State Public Utility Commission – the very body deciding whether to allow Nestlé’s new contract – has already recused himself from that decision because of his ties to the company, and the two remaining commission members also have documented ties to the corporation. Maybe that’s not surprising though – two of the commissioners were appointed by Governor Paul LePage [R], the third by former Governor John Baldacci [D]; both candidates received campaign contributions from Nestlé.

Residents of Maine, and all states for that matter, deserves public servants who make decisions based on what’s best for their constituents, not their corporate donors. Communities need to stand up to protect one of their most precious resources–their water–from being subject to corporate takeover. 

Ben King is a Food & Water Watch spring water research and policy intern and a Master of Public Policy student at Georgetown University.  


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Fighting Foul Fowl

By Anna Ghosh

 grocer store chicken, poultry

Warning: do not read this while eating a chicken sandwich. Discussing the privatization of poultry inspection is gross, but letting the USDA get away with it is even more disgusting, not to mention makes our food less safe and puts workers in danger. Tell Secretary Vilsack not to privatize poultry inspection!

According to the National Chicken Council, “Americans buy more chicken than any other food at the center of the plate.” It’s safe to assume that Americans would like that chicken to be healthy, wholesome and free of fecal matter, bile, scabs, bruises and other unappetizing contamination. But the USDA isn’t concerned about these things. They call them “quality defects” and would rather leave it up the company employees to deal with; compensating for less inspection with more anti-microbial chemicals. But as the Washington Post uncovered, this is a deadly solution.

Since 2011, Food & Water Watch and its allies have been fighting plans to privatize poultry inspection as a matter of consumer and worker safety. In March of 2012, Food & Water Watch analyzed the USDA’s HACCP-based Inspection Models Project (HIMP), the pilot that the current privatization scheme is based on, and found that large numbers of defects are routinely missed when company employees instead of USDA inspectors perform inspection tasks. In April of 2012, inspectors and more than 150,000 consumer spoke out about HIMP, prompting investigative stories from ABC News and the New York Times. We’ve also spent some time fact checking USDA officials, and former officials as Food & Water Watch Senior Lobbyist Tony Corbo did today in Food Safety News:

A year ago, Food & Water Watch was contacted by a consumer in Georgia who had bought a package of chicken that he intended to barbeque for his family on Mother’s Day.  When he opened up the package, he found that some of the chicken breasts had some hard yellow substances on them.  He sent us photos of the packaging and of the suspect chicken breasts.  It turned out that those yellow substances were of partially digested chicken feed or ingesta.  That product should never have been allowed into commerce.  The package wrapper had the USDA-Inspected legend on it with the establishment number P-177.  P-177 happens to be the Pilgrim’s Pride plant in Gainesville, Georgia.  That plant also happens to be one of the 20 HIMP broiler plants that Dr. Raymond is so proud of where the privatized inspection model is being piloted by USDA.   You can take a look at the photo of the ingesta on that chicken on our website and an analysis of the inspection data from some of the HIMP plants we did that revealed that not only feathers were missed by the company employees, but a whole host of other “defects” such as visible fecal contamination.

I showed the photos that we had received from that consumer to Congressman Jack Kingston of Georgia who at the time was the Chairman of the House Agriculture Appropriations Subcommittee and the main congressional advocate to privatize poultry inspection, and to the current USDA Under Secretary for Food Safety Elisabeth Hagen and FSIS Administrator Alfred Almanza.  I explained what the photos represented and I told all of them that when I go to KFC to order fried chicken, the cashier always asks:  “Do you want original recipe or crispy?”  Not “Do you want original recipe or CRUNCHY?”  Yes, Dr. Raymond, I want my taxpayer dollars to go to government inspectors to keep the food I feed my family safe and wholesome.

As Mother Jones Food Blogger Tom Philpott points out, while the Obama administration boasts about the minor government savings and major savings for big poultry companies, the USDA’s claims of food safety are shaky and concern for worker safety nonexistent. No matter how many chemical dunks are used, privatized poultry inspection will lead to unsafe food and unsafe working conditions. Period. Let Secretary Vilsack know how you feel about foul privatized foul here: http://fwwat.ch/ickychix

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April 30th, 2013

New Review Points to Glyphosate’s Dangerous Health Effects

Let me decide, make GE food labeling the lawBy Genna Reed

A new review of hundreds of scientific studies surrounding glyphosate—the major component of Monsanto’s Roundup herbicide— sheds light on its effects within the human body. The paper describes how all of these effects could work together, and with other variables, trigger health problems in humans, including debilitating diseases like gastrointestinal disorders, diabetes, heart disease, obesity and Alzheimer’s disease.

Glyphosate impairs the cytochrome P450 (CYP) gene pathway, which creates enzymes that help to form and also break down molecules in cells. There are myriad important CYP enzymes, including aromatase (the enzyme that converts androgen into estrogen) and 21-Hydroxylase, which creates cortisol (stress hormone) and aldosterone (regulates blood pressure). One function of these CYP enzymes is also to detoxify xenobiotics, which are foreign chemicals like drugs, carcinogens or pesticides. Glyphosate inhibits these CYP enzymes, which has rippling effects throughout our body.

Because the CYP pathway is essential for normal functioning of various systems in our bodies, any small change in its expression can lead to disruptions. For example, humans exposed to glyphosate have decreased levels of the amino acid tryptophan, which is necessary for active signaling of the neurotransmitter serotonin. Suppressed serotonin levels have been associated with weight gain, depression, and Alzheimer’s disease.

This paper does not claim to yield new scientific discoveries. Instead, it looks at older studies in a new light. Critics will say the links between glyphosate and health problems made in this paper are purely correlational, but this work is important because it brings all of the possible health effects of glyphosate together and discusses what could happen: something the USDA, EPA and FDA have failed to do.

Just as Monsanto attempted to discredit Seralini’s study on rats fed GE corn, the company called this peer-reviewed journal article “another bogus study” due to its “bad science.” In a classic pot-calling-the-kettle-black scenario, what Monsanto doesn’t mention is that the majority of research showing glyphosate’s safety has been done by Monsanto itself, which could be called bad science as well due to its limited and biased nature.

The authors of the new review call for more independent research to validate their findings, stating that “glyphosate is likely to be pervasive in our food supply, and, contrary to being essentially nontoxic, it may in fact be the most biologically disruptive chemical in our environment.” If the body of independent research on GE foods and the herbicides used with them shows one thing, it is that there are unanswered questions begging for unbiased research. And while these questions remain unanswered, Americans have the right to know how their food was produced – take action to tell your members of Congress to support mandatory GE labeling.

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Higher Education Brought to You By the Biotech Industry

Money and BooksBy Tim Schwab

Journalism and agriculture students at public universities, watch out.

Your administrators are laying out the red carpet for corporate junkets at a campus near you. With names like HungerU and Biotech University, these “educational” opportunities amount to little more than a slick propaganda campaign from biotech corporations.

DuPont Crop Protection (translation: herbicides and pesticides) is visiting universities in California and Arizona this week, wooing students with $2,500 grants and embarking on a mission to “educate college students about the significance of modern agriculture.” It’s called HungerU.

That’s a catchy name, but does a profit-driven chemical producer whose goal is to expand herbicide and pesticide sales really have much to offer students on the issue of food security? Something tells me its answer to hunger is more chemicals.

Meanwhile, Biotech U goes beyond the ag school to influence an entirely different set of future professionals: journalism students. Each year, the industry-friendly United Soybean Board partners with our nation’s journalism schools in an effort to “educate” future reporters about the role of biotechnology. The program includes all-expense paid gigs on agricultural reporting in exotic places like Turkey and China. This year, the winner goes to Italy. Who wouldn’t want a trip to Italy?

Noting that these future journalists will be “shaping the public’s perception of biotechnology in the coming decades,” Biotech U is part of a long-term strategic plan by the biotech industry to foster public acceptance of genetically engineered crops. The program also intends to “enlist future biotech advocates identified within university journalism programs to develop a draft program at other journalism schools.”

These insidious efforts by the biotech industry are a very small part of the hundreds of millions of dollars pouring into academia from corporations, distorting the science and perverting the mission of higher education. Our public universities increasingly function like corporate laboratories—taking corporate research money to conduct experiments in corporate-sponsored laboratories, then publishing pro-industry findings in corporate-sponsored “scientific” journals.

Food & Water Watch detailed the ways in which industry is buying influence at our public universities in our report Public Research, Private Gain.

This new era of corporate influence is undermining intellectual freedom and academic independence. Professors that might otherwise pursue research that might challenge the bottom lines of biotech companies—for example, studying the negative health, environmental or economic effects of pesticides and biotech crops—simply choose not to for fear of losing future industry research funding or upsetting tenure-granting administrators. That means federal agencies writing the rules and regulations that govern biotech corporations often base their decisions on a body of science that only says industrial agriculture is safe, good and necessary.

Meanwhile, farmers that might want to want to pursue an alternative production model to agrochemicals, monocultures and factory farms have little research or academic support.

And students—our next generation of journalists, farmers and policy makers—graduate from schools that increasingly offer only the virtues of big business instead of teaching students to think critically about the dominant model of industrial agriculture or consider alternative solutions.

Don’t biotech and pesticide companies already have too much influence over our public universities? If you attend one of these schools, call your university administrators and tell them enough is enough.

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