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Truth in Labeling Campaign> MSG> MSG in Agriculture> Details from the Federal Register

MSGThe EPA has approved using unrestricted amounts of processed free glutamic acid (MSG) on crops. (Details from the Federal Register)

A series of Notices and Final Rules preceded the EPA Final Rule to which the Truth in Labeling Campaign formerly objected in August, 2001. The first Notice, published July 3, 1997 in the Federal Register, was Notice of a request made by Auxein Corporation (now know as Emerald BioAgriculture) to allow an experimental program wherein there would be no limit or restriction on the amount of processed free glutamic acid (MSG) that might be found in or on the test crops vegetables purchased by consumers.

The second Notice, published August 8, 1997, was a Notice to register AuxiGro WP Plant Metabolic Primer (AuxiGro), a pesticide product that contains processed free glutamic acid (MSG). Registrations for use of AuxiGro on specific crops were subsequently approved by the EPA without publication in the Federal Register.

On September 5, 1997, the July 3, 1997 request for an experimental program was granted.

The next Notice, published October 29, 1997, was Notice of a petition to allow spraying of "the biochemical glutamic acid" "in or on all food commodities" with no limit on the amount that might remain in and on sprayed crops at the time of harvest. "Biochemical glutamic acid" was the first name used by Auxein/Emerald BioAgriculture for processed free glutamic acid (MSG).

On January 7, 1998 the EPA published its approval of the October 29, 1997 petition. That Final Rule sanctioned the use of unregulated amounts of processed free glutamic acid (still referred to as "the biochemical glutamic acid") regardless of how much processed free glutamic acid residue might be left in or on any or all food commodities -- when the processed free glutamic acid is applied as a plant growth and crop yield enhancer. By the time we became aware that the EPA had approved spraying processed free glutamic acid (MSG) on crops, it was too late to formally object to the 1998 Final Rule.

On September 25, 1998, the EPA granted Auxein/Emerald BioAgriculture a Technical Amendment and Correction of their Pesticide Tolerance Exemption. The Truth in Labeling Campaign had pointed out to both Auxein/Emerald BioAgriculture and the EPA that the glutamic acid used in AuxiGro was not pure L-glutamic acid, but was a manufactured product that contained D-glutamic acid, pyroglutamic acid and other contaminants as well as L-glutamic acid. The Auxein/Emerald BioAgriculture response was to ask that the EPA approve use of the term "L-glutamic acid" to replace the term "glutamic acid" which had previously been used as a name for the processed free glutamic acid (MSG) used in AuxiGro and approved for use by the EPA.

On December 6, 2000, the EPA published Notice of the filing of a petition to "Establish Tolerances for Certain Pesticide Chemicals in or on Food." That petition asked the EPA to sanction the use of unregulated amounts of processed free glutamic acid (referred to as "the biological pest control agent glutamic acid"), regardless of how much processed free glutamic acid residue might be left in or on any and all raw agricultural commodities when sold to the public -- no matter what the product might be called, i.e., a fertilizer, fungicide, pesticide, plant growth enhancer or anything else regulated by the EPA. Cleverly, the EPA did not mention that those "Certain Pesticide Chemicals" were processed free glutamic acid (MSG) and GABA, and that the product in which they would be used was AuxiGro. Not in the title, and not in the summary. Needless to say, since no Federal Register search for "glutamic acid," "gamma aminobutyric acid (GABA)," or "AuxiGro" would have pointed to the December 6 Notice, we were not aware that the December 6, 2000 Notice had been published in the Federal Register until long afterward -- long after the time had run for commenting on the Notice.

The Notice that was published on December 6, 2000 became a Final Rule on June 21, 2001. But unlike the Notice, and for some reason we may never know, the EPA used the words "L-glutamic acid" to describe the processed free glutamic acid (MSG) of the June 21, 2001 Final Rule, and a concerned consumer brought it to our attention. Thus, for the first time, the Truth in Labeling Campaign had the opportunity to file a formal Objection to the use of processed free glutamic acid (MSG) on crops.

The text of the June 21, 2001 Final Rule: L-Glutamic Acid and Gamma Aminobutyric Acid; Exemptions from the Requirement of a Tolerance contains very little information, but refers the reader to the December 6, 2000 Notice. In turn, the December 6 Notice states that the petitions to establish tolerances for "certain pesticide chemicals in or on food" should be granted; saying only that supporting data were submitted with Pesticide Petitions 7F4842 and 7F4843, but not even alluding to what those data were. Thus, to understand what lies behind the June 21, 2001 Final Rule, the reader must become conversant with the January 7, 1998 Final Rule, wherein there is reference to the two Pesticide Petitions.

The following are the major Notices and Final Rules relevant to this issue:

July 3, 1997 Notice of Filing of Pesticide Petitions -- petition for establishing an exemption from the requirement of a tolerance for residues of glutamic acid in or on snap beans, peanuts, cotton, potatoes, tomatoes, lettuce, green peppers, spinach, broccoli, cauliflower, and cabbage.

The glutamic acid used in the pesticide product called AuxiGro, which is the subject of this petition, is not 100 percent pure L-glutamic acid like the glutamic acid found in protein and in higher organisms. The glutamic acid used in the pesticide product called AuxiGro is processed free glutamic acid (MSG).

With the proposed exemption from the requirement of a tolerance for residues of glutamic acid, there would be no limit or restriction on the amount of this glutamic acid that might be found in or on treated crops when brought to market. Thus, there would be no limit or restriction on the amount of processed free glutamic acid (MSG) that might be found in or on the test crop vegetables when purchased by consumers.

This was an application to conduct an experimental program wherein there would be no restriction on the amount of processed free glutamic acid (MSG) that could remain in or on the experimental vegetables when harvested.

August 8, 1997 Auxein Corporation; Application to Register a Pesticide Product: Notice -- application to register the pesticide product AuxiGro containing the active ingredients GABA: gamma aminobutyric acid at 29.2 percent and glutamic acid at 36.5 percent. (The glutamic acid presently acknowledged on AuxiGro labels is 29.2 percent.) AuxiGro was said to be a plant growth enhancer for use to increase yields and the quality of crop plants and early ripening in certain vegetables.

This was the initial application to register AuxiGro, a pesticide product that would be approved to leave unlimited amounts of processed free glutamic acid (MSG) in and on crops that had been treated with it. It was an application to register AuxiGro for use as a plant growth and crop yield enhancer. No registrations of AuxiGro were published in the Federal Register.

September 5, 1997 Glutamic Acid; Pesticide Tolerance Exemption; Final rule -- Final Rule establishing a temporary exemption from the requirement of a tolerance for residues of processed free glutamic acid (MSG), still called "the biochemical glutamic acid" when used to enhance the growth, vegetable quality, and yield of the following crops: broccoli, cabbage, cauliflower, cotton, green peppers, lettuce, peanuts, potatoes, snap beans, spinach, and tomatoes.

With the September 5, 1997 Final rule, the July 3, 1997 request for an experimental program was granted. The EPA allowed that there would be no limit to the amount of residue of processed free glutamic acid (MSG) that could remain in and/or on treated experimental produce when brought to market. The EPA also allowed that all of the experimental crops treated with AuxiGro and its processed free glutamic acid (MSG) could be sold to consumers.

October 29, 1997 Notice of Filing a Pesticide Petition to Establish an exemption from the requirement of a tolerance for residues of the biochemical glutamic acid -- application to establish an exemption from the requirement of a tolerance for residues of glutamic acid in or on all food commodities.

The glutamic acid in question is not 100 percent pure L-glutamic acid like the glutamic acid found in protein and in higher organisms. The glutamic acid which is the subject of this application is processed free glutamic acid (MSG).

With the proposed exemption from the requirement of a tolerance for residues of glutamic acid, there would be no limit or restriction on the amount of this glutamic acid that might be found in or on treated crops when brought to market. Thus, there would be no limit or restriction on the amount of processed free glutamic acid (MSG) that might be found in or on nuts, seed, grains, fruits, or vegetables when purchased by consumers.

January 7, 1998 Final Rule: Glutamic Acid; Pesticide Tolerance Exemption -- Final Rule allowing unrestricted use of processed free glutamic acid (MSG) as a plant growth and crop yield enhancer.

With the January 7, 1998 Final Rule, the EPA granted the October 29, 1997 request for removal of all limits or restrictions on the amounts of processed free glutamic acid (MSG) that might be found in or on nuts, seed, grains, fruits, or vegetables when purchased by consumers.

(The text of the January 7, 1998 Final Rule tells us, in some detail, what data the applicant made available to the EPA, and how the EPA came to its decision to allow the unrestricted use of processed free glutamic acid (MSG) as a plant growth and crop yield enhancer.)

December 6, 2000 Notice: Notice of Filing Pesticide Petitions to Establish Tolerances for Certain Pesticide Chemicals in or on Food -- Application for allowing unrestricted use of processed free glutamic acid (MSG) on all crops, using any and all products coming under EPA jurisdiction.

June 21, 2001 Final Rule: L-Glutamic Acid and Gamma Aminobutyric Acid; Exemptions from the Requirement of a Tolerance -- Final Rule granting the December 6, 2000 application. This Final Rule allowed unrestricted use of processed free glutamic acid (MSG) on all crops, using any and all products coming under EPA jurisdiction. It is this Final Rule to which the Objection of the Truth in Labeling Campaign was filed.

The truth, the whole truth, and nothing but the truth about MSG