A Pediatrician's Letter to the AAP
American Academy of Pediatrics Refuses to Even Consider the Validity of its Anti-GMO Report
Editor’s note. The last Firebreak article narrated how a group of scientists had challenged the American Academy of Pediatrics report on GMO risks and advice to parents to eat organic food. For eight months they have tried to get the AAP management to edit the inaccuracies, poor sources and bias of the report and for eight months, AAP leadership refused to listen or give the scientists a right to challenge the conclusions of their report (claimed now as official advice to AAP members).
Below find the letter from American Academy of Pediatrics member and fellow, Dr Nicole Keller, that was sent to the Pediatrics managing editor Dr Lewis First and lead author Dr Steven Abrams. It is five pages long and thoroughly details many of the paper’s weaknesses, contradictions and risks to the AAP’s reputation. Research inputs for this letter were also provided by Dr Andrea Love and Dr Kevin Folta.
Such a well-researched intervention with a large volume of credible citations should be taken seriously and corrections to the paper urgently made (if not forcing the AAP to retract the paper) so the email replies from the AAP management (copied below at the end of the letter) should alarm not only AAP members, but the scientific community as a whole.
Letter to the American Academy of Pediatrics (sent March 25, 2024)
Hello Drs. Abrams and First,
I am a general pediatrician and member/fellow of the AAP. As a member, I appreciate the work our organization does to conduct and communicate sound science to keep our pediatric patients safe and pediatricians knowledgeable. I had recently reached out to Dr. Abrams and Dr. First after reviewing the January Pediatrics Article addressing Genetically Modified Organisms. In February, I heard the Pediatrics On Call Podcast episode that also addressed the report. I wanted to send this email to suggest a more thorough review on this topic and by doing so, make sure I did my part in helping the AAP stay on track on each topic we assess. My intentions are genuine as I truly feel the education offered on this topic contains many inaccuracies. I hope my persistence in this discussion can at least spark some conversation and re-evaluation of the full body of evidence so we can continue to deliver sound medical advice for pediatricians and our patients.
Our responsibility as pediatricians is huge when discussing such an important topic as our food choices – after all, we all eat! But the report on GMOs (and the accompanying parent piece on the healthychildren.org website) adds to misinformation on the subject. And while the report states it wants to avoid creating unsubstantiated food fears, the focus mostly on proposed risks of GE food consumption (chiefly pesticide residues on GE foods) instead adds to mixed messages circulating on the topic. Education on any topic should present an unbiased discussion of the body of evidence to best understand the subject. This report is lacking in scientific rigor as it omits updated and more robust data on the subject (for example regarding pesticide carcinogenicity), fails to discuss risks in context of dose and individual toxicity levels of each unique chemical (detection doesn’t equal harm!) and doesn’t discuss limitations of studies used to support claims made. All this results in an inaccurate impression of the perceived versus actual risk of pesticide exposures and misses a chance to reassure readers about the robust food monitoring programs in place to ensure food safety – including for bioengineered foods. The journalistic flaws on these pieces leave readers with a sense of uncertainty and doubt regarding genetic engineered (GE) crops and points the finger at society’s favorite bad guy of pesticides, glyphosate. The message is also delivered with use of inflammatory language throughout the unbalanced discussion on the subject – we can do better. As the AAP is a trusted and typically reliable organization, most pediatricians and parents will take the information presented in these pieces at face value. Only critical readers will take pause to fully evaluate the claims and verify the conclusions and recommendations.
One of the biggest missed opportunities in the papers surrounds pesticide exposures. The reports consistently imply that pesticides aren’t thoroughly researched, that residues are not monitored and that these residues will lead to health risks. The reader is led to believe to minimize health risks, they should consider avoiding GE foods due to pesticide exposures. It suggests instead families can choose organic products if they desire to avoid synthetic chemicals on their foods. But why are we suggesting families need to avoid GE foods in favor or organic options in the first place? We should know that both natural and synthetic pesticides have varying levels of toxicity. Natural is not automatically safer than synthetic/artificial. This is a classic example of an appeal to nature. Measles is natural. But the man-made vaccine and its chemical components is safer than the natural illness. This mixed messaging from physicians on which chemicals to fear or not fear spreads confusion and distracts from the important messages that eating more produce and staying up to date on vaccines are incredibly important for good health. The reality is that agricultural chemicals (organic and conventional) are indeed well researched to ensure consumer safety in joint efforts by the FDA, USDA and the EPA.
Beyond the natural versus synthetic concern, detections of conventional approved pesticides (focusing mostly on glyphosate) discussed in the clinical report are suggested to lead to ill health effects. The report states, “presence of glyphosate and other toxic herbicides in food products is the main hazard to children’s health.” Yet, there is no clarification that those levels of detection cited are levels of magnitude under the well-researched tolerances and NOAELs (no observable adverse effect levels) and even dramatically lower than the very conservatively set ADI (acceptable daily intake) levels which already have a built in safety quotient for each unique chemical based on its toxicity. It is also claimed that acceptable pesticide exposure levels for adults are not acceptable for children who are growing and consuming more volume for their size compared to an adult. In reality, the EPA sets tolerance levels to take into account sensitive populations like kids and pregnant people. The reports also fail to tell the reader that routine testing of produce commodities is undertaken by the EPA and USDA with their Pesticide Data Program to ensure levels detected continue to be under levels that may cause harm. The report then calls for more research on chemicals that in reality, already have robust research behind them - let alone routine re-evaluation protocols in place to keep future monitoring in place. This is reminiscent of anti-vaccine rhetoric when vocal opponents claim vaccines haven’t been researched enough- we know this is false. The same is true here about the concerns presented regarding GE foods.
Interestingly, it is mentioned in passing in the clinical report, that, “urinary detection merely reflects exposure and does not determine health effects” but persists to suggest these detections may be linked to significant health impacts. Turns out, we can also correlate volume of organic food consumption with rising rates of autism yet that does not mean one caused the other. Studies showing associations of higher urine pesticide concentrations with ill health effects are wrought with small sample sizes, confounding variables and selection bias. It is inappropriate to suggest these miniscule detections of pesticides on food (which have consistently been found to be well below levels set by organizations that ensure our vaccine and food and medication safety) are dangerous. To further demonstrate the harm in these statements, let’s compare agricultural chemicals to chemicals in medicine. When it comes to vaccines, parents often state worries over chemicals in vaccines as a cause of medical harm in children. As pediatricians, we know these small levels of aluminum, for example, in a vaccine are well below levels of harm and serve a purpose to keep the vaccine safe and effective. Similarly, the parts per billion (and in some detections, parts per trillion) of glyphosate have also not been shown to have any real-world harms – even in growing children. You can see the contradiction - if we suggest potential for harm from these exceedingly low doses of pesticides on foods, then how can we on the other hand say small quantities of chemicals in vaccines or use of antibiotics are safe? We must remember the dose makes the poison! The report is conflating hazards (anything can be dangerous at a certain dose) and risks (the realistic level of harm from typical exposure). The risk of dietary pesticide exposure causing harm is extremely low – this pesticide residue calculator shows us how many servings an adult or child would need to consume of a certain food to see harms from pesticide exposure based on recent PDP data.
This report also adds to unnecessary chemophobia regarding the chemical glyphosate. It talks about spraying fields, “up to 3 times during the growing season” and, “heavy use of herbicides late in the growing season” as reasons for finding more chemical exposures in humans. These statements in themselves are grossly inaccurate as farmers use glyphosate in a prescribed amount often only once early in the growing season. Pesticides cost farmers money, time, wear and tear on machinery let alone unwanted passes over the soil. It is in a farmer’s best interest to not over-use any chemical. Glyphosate has been around for over 40 years and as such has extensive research surrounding its appropriate use and safe levels of exposure. It works on a pathway in plants that humans incidentally don’t even have (the EPSPS pathway). At this time, it has consistently shown to have low toxicity to humans and the surrounding environment. Beyond its consistently demonstrated low toxicity, glyphosate’s purported carcinogenicity has been criticized by dozens of organizations across the world as the evidence does not support this conclusion. This AAP report cites flawed research (Zhang et al 2019 which has been criticized as you can see here by Kabat et al 2021) and omits more robust research (Andreotti et al 2018) that doesn’t fit the narrative of carcinogenicity. Continuing to exaggerate risks around this chemical adds to misinformation about food, farming, and active programs in place to continue monitoring for concerns – the same programs we trust to keep our vaccines and medicine safe.
A second unfortunate impression of this report is how it recommends elitist food options without any evidence that those decisions will result in improved health. This is a major equity issue. I understand the report suggested making food choices in the context of a family’s unique circumstance, but, when the suggestion is to buy a significantly more expensive product to minimize only phantom risks of the other, it is problematic. You see, when we offer fear with conditions, people tend to hear the fear and not the conditions. Additionally, there is no evidence that an organic diet (which by default is non-GMO) offers health benefits. Regardless of how we frame the discussion in our clinics, parents will do anything to keep their child safe - and when they hear potential of risk from a certain food option, it will be hard to ignore. And if they can’t budget to buy the pricier non-GMO/organic option, will they skip the produce all together out of fear of the other options? Research suggests this is an unfortunate result of these fears. The non-GMO label is on all types of foods whether there even is a GE version and it raises food costs regardless. This misplaced fear is therefore damaging to patients who can’t afford or access these items. And the bottom line is the higher price tag of non-GMO and organic foods are not justified by any real health benefits.
A third area of harm this report doesn’t consider is climate effects of our food production. As the AAP just released their new policy on climate change and children’s health, this is also an incredibly pertinent point to be made. GE technology is one of the tools that can help us grow food more efficiently, with less resources, and less land. It is irresponsible to make people fear GE technology and practices when it is a useful, highly researched and routinely monitored tool in food production. This is opposed to the unnecessarily restrictive and ideologic rules of organic farming which in the end make organic farming resource heavy, more taxing on the soil and needs more land to result in the same volume of food.
By focusing on the worry that GE crops result in increased volume of pesticide application, we also distract from the other potential benefits of GE technology. It is briefly mentioned that GE crops can also be created to add nutrients. Beyond the fact that this potential is quickly glossed over in the report, this science has created other new crops that may help our crops withstand drought (for example wheat), disease (potatoes and late blight) and high windstorms. We have potential to modify crops to ensure an adequate and safe food supply to feed a growing population. And do so without increased land and resources is incredibly important for climate health. But when powerful organizations like the AAP vocally tout fear, getting these new technologies approved and accepted becomes challenging. The call should be for continued evidence-based agriculture. We should support raising food in the most efficient ways to help us minimize resources and maximize safe and abundant food supplies to help people and the planet. And to do so, having genetic engineering as a tool in the toolbox will be needed.
The report did some moments of soundness. It gave an accurate assessment regarding the process of genetic engineering being safe – this has been shown over decades of study. It is a precise tool that is used to make small changes to a product to improve it – the first GE product was insulin, after all – a very useful tool in our medical world. Additionally, as mentioned previously, it was appropriate to suggest taking a patient specific approach to dietary recommendations regarding what each family can realistically make work for their families – although this may be challenging in practice as we are not often privy to a family’s budgetary constraints. Lastly, the recommendation to make healthy lifestyle choices by adding more fruits, vegetables, whole grains, etc into everyone’s diet was important to recommend. It is clear the risk of not eating a diet rich in produce is very risky to health. This recommendation to focus on a diet rich in produce is indeed made at the end of the two articles but is disappointingly overshadowed by the discussion of overstated risks of pesticide residues. It is unfortunate that the reports didn’t clearly and confidently conclude that consuming both GE and non-GE foods are safe and reassure readers that routine monitoring programs for pesticide exposure are in place and run by the same organizations we trust to keep our medications and vaccines safe.
Unfortunately, in the end, the overall tone of this report and the accompanying parental piece give impressions that agricultural technologies (genetic engineering and pesticides) haven’t been thoroughly researched and that our foods aren’t monitored for safety - albeit by the same government agencies the AAP trusts to ensure vaccine and medication safety. The proposed risks of pesticide exposure were not put into perspective. There was no reassurance about the programs in place to monitor and research these technologies and chemicals. It would have been refreshing to see the AAP take this opportunity to quell food fears by discussing the full breadth of evidence. Feeding our families affects all of us and involves dozens of decisions every day- an exhausting marathon of choices. For that reason alone, it is such an important topic to get right. And when we know the vast majority of people don’t consume enough produce already, we now have unnecessarily added doubts over perfectly safe and healthy food options.
Lastly, in doing lateral searches on citations and authors during my review on these pieces, I found links to the Ramazzini Institute and the Global Glyphosate Study as well as the Heartland Health Research Alliance – pro-organic organizations and studies primarily funded by organic food supporters. And while funding and associations don’t automatically indicate foul play, these conflicts seem important to disclose and should be noted.
In closing, it would be great to see the AAP use our platform to send powerful messages supported by the body of evidence to make the most beneficial impacts. And when we make a mistake, we should also aim to address the errors. We have great power as the nation’s most trusted voice in childhood health. Let’s use that responsibility wisely.
If anyone is open to more discussion, me and fellow scientists Dr. Kevin Folta (email) and Dr. Andrea Love (email) would be happy to help.
Thank you for your time and attention to this subject.
Nicole Keller, DO, FAAP
Reply by Pediatrics editor, Dr Lewis First (March 26, 2024)
Editor’s note: Shouldn’t the editor-in-chief of a scientific journal, after receiving five pages or critical analysis, corrections and counter-evidence, and after four months of public reaction in the scientific community, then take a closer, more serious look (rather than simply saying the peer review process was thorough)? Maybe he was too busy.
It should be added that under the AAP Pediatrics article history, there was no timeline of any peer review process. It simply stated: “Accepted October 23 2023”.
Reply by Lead Author, Steven Abrams (March 26, 2024)
Editor’s note: Dr Abrams did not reply to the five pages of criticisms to his article. He simply passed the buck down the chain. No further comment or reaction from the AAP leadership was made. The scientific process was stifled.
The next article in this AAP denial of science series will examine how the Academy treated another scientist trying to ensure scientific facts are respected.
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