The world according to Monsanto : pollution, corruption, and

154 the world according to monsantoproved that the FDA regulation constituted a deliberate violation of federallaw. 4Despite this legal setback, the complaint led to the declassification ofsome forty thousand pages of internal FDA documents related to GMOs.The least one can say is that this treasure trove of notes, letters, and memorandapresents a not-very-pretty picture of the way the agency handled thisdelicate issue, in light of its duty to protect the health of American consumers.In a document dated January 1993, FDA representatives acknowledgedin plain language that, in accordance with government policy, theiraim was to “promote” the biotechnology industry in the United States. 5 Butthe highlights of this mass of information are the reports written by agencyscientists, intended to express their opinions on the draft regulations submittedto them. The Alliance for Bio-Integrity had the excellent idea of puttingthese documents online. 6 Some of them, of course, were addressed tothe Biotechnology Coordinator.For example, on November 1, 1991, Maryanski received a memorandumfrom the Division of Food Chemistry and Technology. The documentpointed to all the “undesirable effects” that might be produced by the techniqueof genetic manipulation, such as an “increased levels of knownnaturally occurring toxicants, appearance of new, not previously identifiedtoxicants, increased capability of concentrating toxic substances from theenvironment (e.g., pesticides or heavy metals), and undesirable alterationsin the levels of nutrients.” 7And on January 31, 1992, Samuel Shibko of the Toxicology Section of theFDA, wrote: “We cannot assume that all gene products, particularly thoseencoded by genes from non-food sources, will be digestible. For example,there is evidence that certain types of proteins . . . are resistant to digestionand can be absorbed in biologically active form.” 8A few days later, it was the turn of Dr. Gerald Guest, director of the Centerfor Veterinary Medicine, to sound the alarm: “In response to your questionon how the agency should regulate genetically modified food plants, Iand other scientists at CVM have concluded that there is ample scientificjustification to support a pre-market review of these products. . . . The FDAwill be confronted with new plant constituents that could be of a toxicologicalor environmental concern.” 9Dr. Louis Pribyl of the FDA’s microbiology division dismissed out of handthe argument commonly put forth by promoters of biotechnology: “There is