Project Verified?

Written by: Paul Thompson

Primary Source: Thornapple CSA

One of the regular readers of the Thornapple Blog posted a photo of the Non-GMO Project Verified label on Facebook this week. This occasions a deep philosophical quandary: What’s the difference between “project verified” and “process verified”?

Now I’ll start right out by admitting that this quandary is so deep that it probably never occurred to most readers of the Thornapple Blog, but of course that’s just an invitation for me to go off on one tangent after another. More to the point, I’ve been curious about trying to figure out what’s going on in the non-GMO labeling space myself, and I’m not at all sure that I have things straight. If anyone from the Non-GMO Project or some other certifier wants to jump in and straighten me out, please feel free to use the comment box.

“Process verified” is pretty much answerable, if not entirely straightforward. This is language that the U.S. Department of Agriculture uses for an accreditation program that they have introduced to give consumers confidence that food labels actually mean something. If I have this right (and I might not) you could pretty much cook up just about any standard that you want and introduce some kind of accounting procedure to insure that the standard has been met and the USDA will be willing to decide whether or not it is “process verified.” The terminology derives from standards that refer to a process, rather than some measurable feature of the product. So if I thought there was a market for “Hoosier-free” corn chips, I could define the “Hoosier-free” standard as “containing no corn grown in Indiana”. I would not be able to tell whether a corn chip was made from corn grown in Indiana by doing a lab test, (or at least I think not). There’s no analytic procedure that can reliably distinguish a grain of corn grown in Indiana from one grown across the border in Illinois, Ohio or Michigan. But I could still have a meaningful “Hoosier-free” standard if I had a reliable procedure to ensure that all of the corn going into these corn chips was in fact grown in Illinois, Ohio or Michigan. I might have to have people watch the corn being harvested in these states and then have them ride along with the trucks all the way to my chip factory, but I could do it. That would be a “process standard”: it certifies the product by monitoring the process, rather than doing some kind of end-of-the-pipe test. On the other hand, I could certify that my corn-chips are “quinoa free” just by sending them to a lab where they can do an analysis that is capable of telling the difference between quinoa and corn. I wouldn’t have to have people watching the production process.

Now, is all that crystal clear? The USDA has a “process verified” program to ensure that labels like “organic” or “fair-trade” have been coupled with an accounting or certification procedure that actually matches up with what’s being claimed on the label. On the other hand, terms like “gluten-free” “prime” or even “fancy” don’t have to be process verified because a trained and properly equipped inspector can tell whether a product meets the standard just by testing or looking at it.

Now before getting too deep into “project verified” I should probably admit that the question I posed at the outset was a little mischievous because there really isn’t anything that’s “project verified.” Hey, it wouldn’t be the Thornapple Blog without a little bit of sarcasm, now would it? What there is are “Non-GMO Project verified” labels. The Non-GMO Project is the name of an outfit that’s cooked up a process based label that they have submitted to USDA’s process verified program. Or at least I think they have. It’s one of the things I could certainly be wrong about, but let’s get on with this complicated story for the moment.

One of my sources of confusion was that you actually can send a food product to a lab and determine whether it contains GMOs. (We’re not going down the “What’s a GMO tangent?” Just shut-up and keep reading.) There are arguably some exceptions to this when it comes to oils like canola or corn oil, but taco shells and tofu? You can tell. Also, all organic products are non-GMO. The Non-GMO Project has a website where they explain why, in their view, you might want to be certified as Non-GMO Project Verified instead of or in addition to organic, and I would suggest that if this is the question that’s bothering you, you should just go right there. There are also some “non-GMO” labels out there that (I think) do send your stuff to the lab, rather than watching your production process. So what’s up with a process label for non-GMO?

Well, here you can also go to the website, but my reading is that the answer to this question is a blend of precaution and philosophy. The precaution piece is when The Non-GMO Project claims that their process label is the most reliable one. The philosophy piece is wrapped up in some ideas about solidarity (again, I think). As I understand it, the big thing is that you can’t be a company that is selling both GMO and non-GMO products, like if were to allow a corn chip plant to make both ordinary and Hoosier-free corn chips, just that I watched to make sure that they never mixed these two things up.

Or at least that’s what I’ve been able to piece out so far. Maybe I have the whole thing wrong.

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Paul Thompson
Paul B. Thompson holds the W. K. Kellogg Chair in Agricultural, Food and Community Ethics at Michigan State University in East Lansing, Michigan. He formerly held positions in philosophy at Texas A&M University and Purdue University. His research has centered on ethical and philosophical questions associated with agriculture and food, and especially concerning the guidance and development of agricultural technoscience.
Paul Thompson

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