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By Federal Express

March 22, 2003
 
 

Paul Gosselin
Chief Deputy Director
California Department of Pesticide Regulation
1001 I Street
Sacramento, CA  95814-2828

Dear Mr. Gosselin:

This letter is being written to protest the use of processed free glutamic acid (MSG) in agricultural products used on produce in the state of California including, but not limited to, its use in AuxiGro WP (AuxiGro), and including, but not limited to its use ON TOMATOES AND MELONS TO INCREASE YIELD AND BRIX (CDPR Tracking Number 198417; EPA Registration Number 70810-1; Applicant Emerald BioAgriculture Corporation; Brand Name AuxiGro WP; CAS numbers 56-12-2, 56-86-0)

We have found the CDPR to be irresponsible in granting prior approvals for use of AuxiGro.  The data submitted to the CDPR by Emerald BioAgriculture Corporation (formerly Auxein Corporation) have fallen far short of providing full disclosure of the toxic potential of processed free glutamic acid (MSG) and the potential for allergic and/or sensitivity reactions that might be caused by not only the processed free glutamic acid (MSG) contained in AuxiGro but by other potentially allergenic substances such as the milk protein contained in its "inert" ingredients."  Among its other shortcomings, the material submitted to the CDPR by Emerald BioAgriculture failed to disclose that AuxiGro:

1) Contains what the applicant refers to as "L-glutamic acid:" a known neurotoxic amino acid and endocrine disrupter that also causes adverse reactions including heart irregularities, asthma, migraine headache, depression, and seizures in people who are sensitive to the substance;

2) Contains neurotoxic free glutamic acid that is made through a patented process of bacterial fermentation wherein selected genetically modified bacteria secrete glutamic acid through their cell walls;

3) Contains hydrolyzed casein (milk) protein, a product that will not only be offensive to vegetarians and various religious groups including Jewish people who keep kosher, but one that contains milk protein -- hidden milk protein -- a hidden potentially lethal allergen;

 4) Contains carcinogenic material, and

 5) Is misbranded

In making its applications to the CDPR, Emerald BioAgriculture (formerly Auxein Corporation) has both misrepresented the composition and safety of the free glutamic acid used in AuxiGro and failed to provide the CDPR with full disclosure.

Emerald BioAgriculture has failed to show the CDPR data demonstrating that processed free glutamic acid (MSG) kills brain cells, is an endocrine disrupter (causing reproductive disorders and gross obesity after being fed to the very young), causes behavior and learning deficits, and causes adverse reactions such as asthma, heart irregularities, migraine headache, and depression in both children and adults.

Emerald BioAgriculture has never demonstrated that AuxiGro is "safe." Emerald BioAgriculture has made its claim for the safety of its product on short term studies that do not even pretend to assess the long term effects of its neurotoxic component (processed free glutamic acid - MSG) using statements such as "should not" and "very likely will not."

Emerald BioAgriculture has presented no data on the amounts of processed free glutamic acid (MSG) that will remain in and on AuxiGro treated produce when that produce is brought to market. Instead of telling the whole story of how AuxiGro is being proposed for use by Emerald BioAgriculture, Emerald BioAgriculture has told the CDPR that "it should wash off," but has not mentioned that Emerald BioAgriculture recommends that AuxiGro be used with a surfactant that will keep the AuxiGro from washing off.  And joke of all jokes, Emerald BioAgriculture seems to have glossed over the fact that to be effective -- to increase fungicide resistance, growth, and/or yield -- AuxiGro must be taken up into the plant where it would remain in the leaves (lettuce and spinach for example), fruit (grapes, melons, and tomatoes for example), roots (potatoes and carrots for example), seeds, and stems when purchased by unwary consumers.

Emerald BioAgriculture has presented no data demonstrating that minute amounts of processed free glutamic acid (MSG) will not cause brain lesions, neuroendocrine disorders, and/or adverse reactions.  Indeed, research identifying the least amounts of processed free glutamic acid (MSG) needed to cause brain lesions, neuroendocrine disorders, and adverse reactions in humans has never been done.

We have observed that the CDPR has ignored the shortcomings in the Emerald BioAgriculture applications. The CDPR has failed to evaluate the conflicts of interests of its advisors who, by and large, come from universities and colleges in the state of California system (or have close ties to those institutions) that have benefited from funding provided to those schools and to individual researchers in those schools by the Ajinomoto Company, Inc. (Ajinomoto), the world's largest supplier of processed free glutamic acid, including the processed free glutamic acid used in AuxiGro.

The CDPR has ignored the fact that the glutamic acid used in AuxiGro is a manufactured product similar to, if not identical to, the processed free glutamic acid used by Ajinomoto in the flavor enhancer it produces called "monosodium glutamate."  It seems to be a hallmark of the argument for the safety of AuxiGro that the glutamic acid in AuxiGro arrives in the Emerald BioAgriculture production facility by some kind of divine intervention rather than by production by Ajinomoto using bacterial fermentation just as the glutamic acid in their "monosodium glutamate" is produced.

When asked, the CDPR has misrepresented the facts pertaining to AuxiGro test trials in California.

Although at first provided, in the last 3-4 years, the CDPR had refused to provide records of test trials of AuxiGro in California.  Refusal has been effected by saying that records would be sent, but never sending them.

The CDPR has ignored requests for information about Emerald BioAgriculture's applications to the CDPR for approvals of AuxiGro.

The CDPR has refused to answer questions posed by the Truth in Labeling Campaign -- questions to which answers would have demonstrated that Emerald BioAgriculture had omitted data, not given full disclosure, misrepresented data, and made false and deceptive statements.

The Truth in Labeling Campaign has written repeatedly to the CDPR beginning with its first formal protest of the use of processed free glutamic acid (MSG) and AuxiGro on June 8, 1999.  Unless destroyed by the CDPR, those letters should be on file at the CDPR and be public record.  Those letters and the data that accompanied them demonstrated that the processed free glutamic acid (MSG) kills brain cells, cause neuroendocrine disorders, and causes adverse reactions.  Those letters and data further demonstrated that to be effective, the processed free glutamic acid (MSG) used on produce would have to be taken up by the plants as opposed to washing off.  Those letters and data demonstrated there are no data that identify the least amount of processed free glutamic acid (MSG) needed to kill a brain cell or cause an adverse reaction such as asthma, tachycardia, migraine headache, or depression.  Examples of those letters can be viewed at www.truthinlabeling.org/June8-1999letter.htmlwww.truthinlabeling.org/cdpr-cortez-8-17-01.html;  and www.truthinlabeling.org/cdpr-cortez-8-4-01.html.

According to the statement of Barry Cortez, Chief, Pesticide Registration Branch, CDPR, "As a result of scientific evaluation, it has been determined that no direct or indirect significant adverse environmental impact is anticipated from the registration of [AuxiGro]; therefore, no public report on the individual products will be filed."

But we didn't find that much of a scientific evaluation had been done.  The Truth in Labeling Campaign has asked the CDPR the following questions, which the CDPR has not answered.  If the CDPR had responded, they would have had to admit that there is no evidence that demonstrates that use of AuxiGro is "safe." They would also have had to admit that there is an abundance of evidence that demonstrates that use of processed free glutamic acid (MSG), and, therefore, use of AuxiGro, places humans at risk.  These are some of the questions that haven't been answered by the CDPR:

Question: How, and by what company, is the processed free glutamic acid used in AuxiGro produced?  Is it produced by Ajinomoto or others by a method of bacterial fermentation wherein "...bacteria...excrete glutamic acid they synthesize outside of their cell membrane into [a liquid nutrient] medium and accumulate there.  The glutamic acid is separated from the fermentation broth by filtration, concentration, acidification, and crystallization..." (Leung, A., and Foster, S. Encyclopedia of Common Natural Ingredients. NY: Wiley, 1996).

Question: What are the specific contaminants in the processed free glutamic acid used in the manufacture of AuxiGro?

Question: What is the amount of processed free glutamic acid residue that will be left in and on produce from application of AuxiGro?

Question: What amount of processed free glutamic acid causes adverse reactions in highly MSG-sensitive people?

Question: We have been told that the CDPR has determined that the small amounts of L-glutamic acid being applied would not have an adverse effect on people consuming treated produce.  How was that determination made?  What data were used in making that determination?

Question: Material coming from the EPA states that AuxiGro contains carcinogens.  Why is the CDPR licensing a product that contains carcinogens?

Question: Material in hand states that AuxiGro contains hydrolyzed casein (milk) protein. We know, therefore, that in treating crops with AuxiGro, a form of milk protein is being deposited on and in those crops.  We know that no consumer would ever dream that unprocessed produce would have been treated with a product that contained milk in any form; and the rights of vegetarians and certain religious groups -- and anyone else, for that matter -- to choose what they will eat will be violated. We also know that it is common knowledge that minute amounts of certain allergens, including milk, will trigger adverse reactions, including anaphylaxis, in people who are acutely sensitive to those allergens.  (Laoprasert, N, Wallen, ND, Jones, RT, Hefle, SL, Taylor, SL, Yunginger, JW. Anaphylaxis in a milk-allergic child following ingestion of lemon sorbet containing trace quantities of milk. Journal of Food Protection 61(11):1522-4,1998.)  Why is the CDPR licensing a product that will not only be offensive to particular groups of people, but one that contains a hidden potentially lethal allergen?

Question: Material in hand states that there is processed free glutamic acid in AuxiGro over and above the 29.2% active ingredient listed on the label.  Therefore, AuxiGro is misbranded.  Why is the CDPR licensing a product that is misbranded?

We are aware that MSG-sensitive people have reacted to processed free glutamic acid in potatoes sprayed with agricultural products that contained processed free glutamic acid.  I believe that the CDPR has received letters from some of those people, yet has investigated none of them.  I know that my husband, Jack Samuels, was one who reacted to a potato.  Since potatoes are tubers, and it is the tubers that grow under ground that are eaten (and not the stems or leaves of the potato plants), we know that when potatoes are treated with agricultural products that contain processed free glutamic acid, there is residue remaining in the potato.

The Truth in Labeling Campaign has asked Mr. Cortez how a proper scientific evaluation could be made without having the answers to those questions.  The answer, of course, is that a proper scientific evaluation could not be made without that information.  The answer is that a proper scientific evaluation has not been done.  The question, of course, is one that Mr. Cortez has not, and will not, answer.  My guess is that the big business interests that profit from the sale of processed free glutamic acid (MSG) as a food additive and an agricultural stimulant are extremely pleased with Mr. Cortez and the CDPR.

The Truth in Labeling Campaign objects to the use of free glutamic acid, a neurotoxic amino acid which, when ingested, has been shown to kill brain cells in the area of the hypothalamus and when ingested by neonates and infants to cause reproductive disorders and gross obesity as the immature subjects move toward and into puberty.  The Truth in Labeling Campaign objects to the use of free glutamic acid that has ben shown to cause adverse reactions in humans.  the Truth in Labeling campaign protests the CDPR's irresponsible behavior in approving AuxiGro for us on crops grown in California and asks that the CDPR rescind prior approvals and deny the approval for tomatoes and melons presently being requested.

Respectfully submitted,
 
 

Adrienne Samuels, Ph.D.
Director
Truth in Labeling Campaign
1547 Santa Sabina Court
Solana Beach, CA  92075

858-481-9333
 

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This page was last updated on June 5, 2004.