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The California Department of Food and Agriculture (CDFA) and the California Department of Pesticide Regulation (CDPR) have approved the use of processed free glutamic acid in agricultural products to be sprayed on, and otherwise applied to fruits, vegetables, grains, and ornamentals. That approval came with input from the International Glutamate Technical Committee (IGTC) through "scientists" at UC Davis and UCLA.
In May, 1999, spraying MSG on wine grapes (calling the spray a fertilizer) was approved by the CDFA. Steven D. Wong, Branch Chief, Agricultural Commodities and Regulatory Services (phone 916-654-0574) told us that there was no demonstration that use according to label directions would present a significant health hazard to workers, consumers of products grown with the aid of the MSG-containing product, or to the general public. At that time, to have a product approved for use as a fertilizer in California, a company needed do little more than make application.
In April, 2000, and again in July, 2001, spraying MSG on wine grapes (calling it a fungicide) was approved by the CDPR. At that time, Barry Cortez, Branch Chief, CDPR, told us that the CDPR would only turn down a product if it appeared to be ineffective, and AuxiGro didn't appear to be ineffective. After reading the law, however, we found that according to Section 12825 of the Food and Agricultural Code:
"Pursuant to Section 12824, the director,...may cancel the registration of, or refuse to register, any pesticide:
(a) That has demonstrated serious uncontrollable adverse effects either within or outside the agricultural environment.
(b) The use of which is of less public value or greater detriment to the environment than the benefit received by its use.
(f) Concerning which any false or misleading statement is made or implied by the registrant or his or her agent, either verbally or in writing, or in the form of any advertising literature."
AuxiGro met each of those three criteria.
Does spraying processed free glutamic acid onto crops and into the environment pose a problem? We think it does. Does applying processed free glutamic acid to the soil pose a problem? Yes, we think so, and we have made our thoughts known. On June 8, 1999, even though we knew full well that the glutamate industry had been generous in funding chemists and food scientists at UC Davis and underwritten research at UCLA, and that those chemists and food scientists, and/or their friends at Davis or at the CDFA or CDPR, might be asked to evaluate our comments, we formally presented our concerns to the CDPR.
It was not until the spring of 2001, however, that we found that AuxiGro contained more awful ingredients than the "L-glutamic acid" -- the neurotoxic, endocrine disrupter that can cause adverse reactions such as asthma, migraine headache, heart irregularities, and seizures in people who were sensitive to it. AuxiGro, we learned from government documents, contains hydrolyzed casein (milk) protein, a substance known to have caused the death of milk-sensitive children who consumed minute quantities of milk protein hidden in processed food. AuxiGro, we learned from other government documents, also contains carcinogens.
As of August 20, 2004, California had already approved the following crops for spraying with MSG
GRAPES (ALL OR UNSPECIFIED)
ONION (DRY, SPANISH, WHITE
PLUM (INCLUDES WILD PLUMS)
TOMATOES, FOR PROCESSING
On July 9, 2004, California proposed to also allow cole crops to be sprayed with MSG. Cole crops include:
We have suggested that produce treated with AuxiGro be avoided. We have suggested that family and friends avoid grapes and wine entirely, or at least ask their grocers and wine merchants to certify that the grapes and wine they buy haven't been sprayed with AuxiGro or any other fertilizer/fungicide/growth-enhancer that contains processed free glutamic acid (MSG).
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."
These are some of the questions that haven't been answered by the CDPR (or the EPA, for that matter):
Question 1: 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 2: What are the specific contaminants in the processed free glutamic acid used in the manufacture of AuxiGro?
Question 3: What is the amount of processed free glutamic acid residue that will be left in and on produce from application of AuxiGro?
Question 4: What amount of processed free glutamic acid causes adverse reactions in highly MSG-sensitive people?
Question 5: 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 6: Material coming from the EPA states that AuxiGro contains carcinogens. Why are the CDFA and the CDPR licensing a product that contains carcinogens?
Question 7: 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 are the CDFA and 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 8: 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 are the CDFA and the CDPR licensing a product that is misbranded?
Question 9: We are aware that on June 21, 2001, the EPA published the Final Rule: L-Glutamic Acid and Gamma Aminobutyric Acid; Exemptions from the Requirement of a Tolerance. According to the June 21, 2001 publication of that Final Rule in the Federal Register, that Final Rule establishes exemptions from the requirement of a tolerance for residues of what the EPA refers to as "L-glutamic acid" and also gamma aminobutyric acid on all food commodities when applied/used in accordance with good agricultural practices.
We are also 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 your office has received letters from some of those people. I know that my husband, Jack Samuels, was one of them. 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 EPA Final Rule promulgated on June 21, 2001, did not exempt the processed free glutamic acid (they call it "L-glutamic acid") from the requirement of a tolerance for residues of "L-glutamic acid" in all food commodities.
Since the June 21, 2001 Final Rule did not address the issue of an exemption from the requirement of a tolerance for residues of "L-glutamic acid" in all food commodities, the EPA has not taken a final tolerance action that would allow the CDPR to license AuxiGro.
In licensing AuxiGro for use in California, the CDPR is acting inappropriately. Why is the CDPR licensing a product that will cause there to be residue of processed free glutamic acid in crops when the EPA has not issued an exemption from the requirement of a tolerance for those residues in crops?
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 this 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.
June8-1999letter.html Consumer challenge to the safety of use of MSG on crops June 8, 1999
CDPRnotices-4-02.html Notice of product approval April 19, 2002
CDPRnotices-5-30-02.html Notice of product approval June 3, 2002
CDPRmelon-announcement.html Notice of product approval February 26, 2003
CDPR-7-7-04.html Notice July 9, 2004
CDPR-3-21-05.html Notice of product approval March 7, 2005
cdpr-12-1-04 AuxiGro.html Notice of product approval December 6, 2004
CDPR-1-31-07.html Notice of product approval January 8, 2007
CDPR_4_16_07.html Notice of denial of approval April 16, 2007
cdpr-cortez-8-4-01.html Letter from Adrienne Samuels August 4, 2001
cdpr-cortez-8-17-01.html Letter from Adrienne Samuels August 17, 2001
CDPRletter5-10-02.html Comments from the Truth in Labeling Campaign May 9, 2002
CDPRletterSusanClark.html Letter from Susan Clark May 13, 2002
cdpr-3-22-03.html Letter March 22, 2003
Letter July 22, 2004