by Charles Benbrook, PhD
Chief Scientist
The Organic Center

These comments are submitted on behalf of The Organic Center, a nonprofit organization carrying out research on the consumer health benefits of organic food and farming. We strongly support reauthorization and strengthening of the Child Nutrition Programs and the Special Supplemental Nutrition Program for Women, Infants and Children (WIC). These programs have met a vital need and will no doubt continue to provide essential assistance to some of the nation’s most vulnerable, especially if the current recession proves deep and long-lasting.

In the reauthorization process, we urge the Department to continue moving toward more flexibility and choice, as well as a more significant role for state and local agencies involved in program implementation. As our population diversifies into ever-more varied mixes of cultures, ethnic groups, educational backgrounds, occupations, and family structures, nutrition needs and challenges also grow more variable. Clearly, food and nutrition specialists living in local communities are going to have unique insights and experience to draw upon in delivering nutrition education information and the other nutrition program services that are so critical in achieving the broad goals of these programs.

The general nutritional goals and requirements of WIC and other nutrition programs should be established at the federal level. We strongly support the already announced decision to include fresh fruits and vegetables and whole grains in the 2009 WIC program. Many states are already working on how to incorporate these critical food groups in the WIC program in the most cost-effective way.

We are aware that hundreds of mothers in many states have participated in focus groups discussing changes in the WIC program. We are told that somewhere between a quarter and two-thirds of the mothers at most focus groups expressed a need for, and support the opportunity to choose organic foods and beverages bearing the USDA National Organic Program seal, especially for dairy products and fresh fruits and vegetables.

Why Organic Food Belongs in the WIC Program

In the 1980s concern emerged among toxicologists and pesticide regulatory scientists over the human developmental risks posed by pesticides. At that time, nearly all aspects of pesticide regulation were based on laboratory experiments carried out with healthy, adult rats and mice. In 1989 the Environmental Protection Agency asked the National Academy of Sciences (NAS) to carry out a thorough assessment of the risks posed by pesticide to pregnant women, infants, and children, and the adequacy of then-current pesticide regulatory policies. In 1993 the NAS released the widely acclaimed report Pesticides in the Diets of Infants and Children.

The report explained that infants and children are not just little adults, and that they face unique risks when exposed to certain pesticides, especially during critical windows of development. The report also concluded that pesticide regulatory policy had to change in order to assure that these most vulnerable segments of the population are adequately protected. A sustained, wide-reaching effort has been underway since 1993 to amend federal law (accomplished in 1996) and implement new, infant and child-protective pesticide regulations (ongoing). This effort has triggered valuable new science deepening concerns over low-level pesticide exposures during critical windows of development, and triggered extensive media coverage of the underlying issues.

Attention in the media over the last 15 years focused on pesticide risks to infants and children no doubt explains why so many new mothers understand that even very-low levels of pesticide exposure during pregnancy and the first months of their child’s life can have adverse lifelong consequences. While most WIC mothers do not know which foods or pesticides pose the greatest risk, or why, their desire to avoid exposures for themselves and their families is easy to understand, as is their interest in purchasing organic food through the WIC program.

Compelling research carried out by Dr. Chensheng (Alex) Lu and colleagues at the University of Washington and Emory University over the past six years shows that serving organic food and beverages to children, especially fruit and vegetable-based products, is the surest way to essentially eliminate risky dietary exposures. Their research has focused on the high-risk class of insecticides called the organophosphates, and their findings are published in three seminal research reports in Environmental Health Perspectives (Lu et al., “Dietary Intake and Its Contribution to Longitudinal Organophosphorus Pesticide Exposure in Urban/Suburban Children,” published online 1/15/2008; Lu, et al., “Organic Diets Significantly Lower Children’s Dietary Exposure to Organophosphorus Pesticides,” Vol. 114, No. 2, 2005; and Curl et al., “Organophosphorus pesticide exposure of urban and suburban preschool children with organic and conventional diets,” Vol. 111, No. 3, March, 2003).

In an analysis encompassing most major children’s foods, we reached essentially the same conclusion by analyzing the impact of an organic diet on pesticide dietary risk levels. The analysis drew upon pesticide residue data collected by the USDA’s Pesticide Data Program (PDP), and the EPA’s data on pesticide toxicity. A Dietary Risk Index (DRI) was calculated for foods tested in the PDP – mostly fruits and vegetables. Switching to organic food reduces pesticide risks, as measured by the DRI, by over 95%. (For details on study methods and findings, see the March 2008 State of Science Review “Simplifying the Pesticide Risk Equation: The Organic Option,” accessible at

Reducing pesticide dietary exposures, and other pesticide-related risks, is an important, widely accepted and thoroughly documented benefit of organic food, and is reason enough to include organic food products among WIC and other nutrition program options. Other reasons include the opportunity to serve infants and children food that tastes better, contains more nutrients per serving, and is free of nearly all synthetic food additives.

We have issued reports in the last two years drawing on the growing number of published studies comparing organic and conventional foods that conclude that organic production systems, on average, produce food that is more nutrient and antioxidant-dense. The typically higher level of plant secondary metabolites and polyphenols in organic fruits and vegetables helps explain why organic produce is, on average, tastier than conventionally grown produce.

Why is this generally the case? The marginally higher average yields on conventional farms contributes on many farms to what agronomists call the “dilution effect.” In short, the typically much higher nitrogen fertilizer application rates on conventional farms, coupled with other management practices, pushes plants to grow faster and produce larger fruit that is relatively high in sugar and moisture content. But such produce also tends to contain lower concentrations of most vitamins and antioxidants per gram, serving, or calorie consumed. This reduction in nutrient density as crop yields increase is the signature impact of the “dilution effect.”

Benefits Linked to Organic Dairy Products

The case for including organic milk and dairy products in the WIC and other nutrition programs is particularly compelling. Milk is obviously the most important single food in the diets of most infants and children. Organic dairy farmers are required by NOP regulations to provide access to pasture for their cows during the months of the year when weather supports pasture growth. Numerous studies have shown consistently and conclusively that cows consuming 30% or more of their daily dry matter intake from pasture produce milk that is higher in protein and conjugated linoleic acid (CLA), a heart-healthy fat that plays important roles in development.

A recent study published in the biomedical literature found that mothers with a high proportion of dairy intake from an organic origin (>90 percent organic dairy) have higher levels of rumenic acid in their breast milk. Rumenic acid is responsible for most of the health benefits of CLA from pasture-produced milk. Another recent study in the British Journal of Nutrition reported that consumption of organic dairy products was associated with lower risk of eczema in the first two years of life (Kummeling et al., Consumption of organic foods and risk of atopic disease during the first 2 years of life in the Netherlands,” British Journal of Nutrition, 2007).

It is true that some conventional dairy farms are heavily reliant on pasture and, as a result, are also likely to produce milk that contains elevated protein and CLA levels. It is also true that pasture is not available during part of the year on most organic dairy farms, for example during New England winters or a drought in the arid southwest. Still, Agricultural Resources Management (ARMS) survey data collected by the USDA in 2005 shows unequivocally that pasture and grass forages make up a significant share of the diet of most cows on organic farms during most of the year, compared to a much smaller portion on most conventional dairy farms. For these reasons, mothers are on solid ground in expecting over time a nutritional premium from the routine purchase of organic milk and dairy products.

In addition to the nutrition premium associated with organic dairy products, cows on organic farms are not administered supplemental hormones to increase production. They are not given antibiotics to treat mastitis and other common infections, nor antimicrobial feed supplements to help them tolerate high-energy, high-grain rations deficient in fiber and forages (the “natural” feed of ruminant animals). They are not given reproductive hormones to increase the success rate when artificial insemination is used for breeding.

These common health maintenance, reproductive, and production-enhancing technologies are necessary on many high-production conventional farms to keep cows producing despite suffering from a net loss in energy (they are using more energy to live and produce milk than they are getting from their feed). One result is that cows on conventional dairies are often difficult to rebreed and are culled after just two, and sometimes even one, lactation.

Regulators lack the methods and data required to rigorously quantify the significance of these risks linked to drug and hormone use on conventional dairy farms and for this reason, controversy persists about them. Fortunately mothers who wish to avoid exposing their children to any such risks, while scientists sort out the true consequences of these and other production-enhancing technologies, have an option that allows them to do so.

Avoiding exposures to food additives and artificial colors is another reason to provide WIC mothers the option to purchase certified organic food and beverages. There is a growing body of evidence suggesting that the artificial food dyes approved for use in food by the Food and Drug Administration are exacerbating behavioral problems, especially hyperactivity, among children and adolescents. The U.K. Food Standards Agency has asked food companies to voluntarily end use of the six artificial food colorings approved for use in the U.K., because of the evidence that removal of the colors reduces the severity of behavioral problems in many children. By choosing to serve children organic foods, mothers and school systems can dramatically reduce the daily intake of food additives, a clearly positive, preventive step that will help reduce the number of school-age children afflicted with hyperactivity and other behavioral problems. It turns out that teachers are right — good nutrition is, in fact, a pillar of sound education policy.

Accordingly, we strongly recommend that the USDA directs states to assure that organic food and beverages are among the choices offered through WIC and other nutrition programs, for at least some foods in all the food groups within these programs.

The Organic Price Premium

Given the goals of the WIC program and the reality that WIC funds are limited relative to need for the program, efforts have been made to seek out and approve those staple foods that deliver the most calories per dollar spent. The generally higher cost per serving of most of organic food will limit the quantity of a given food that a mother can purchase with a fixed WIC allotment. The same economic calculus applies to other USDA nutrition programs, although the premium tends to be smaller when organic foods are purchased in bulk.

The generally higher nutrient density in organic foods, coupled with the near-absence of pesticide, hormone, and food additive risks, justify a higher price for organic food. But how much? No one can say with certainty because we lack the science and methods needed to estimate the magnitude of the economic benefits from consumption of organic food. Plus, such calculations will be highly circumstantial and variable, and require lifelong and indeed multi-generational health monitoring and data collection.

Despite uncertainty about the magnitude of the benefits stemming from consumption of organic food, some mothers have decided that organic food is a worthwhile investment in their children’s well-being. The conscious choice to seek out organic food, even when it costs more, reflects a commitment by mothers to provide their children with the highest quality food possible and the safest path through the critical early years of development.

Given the breadth of evidence in support of a range of benefits from consumption of organic food, the Department would need compelling reasons to prohibit mothers from purchasing organic foods through the WIC program. In particular, the Department would need to explain why mothers should not be free to choose a somewhat smaller quantity of what they regard as higher-quality food.

We believe the USDA should work to cultivate in Americans an appreciation of and desire for high quality food, coupled with the need for a more balanced diet. The WIC and other nutrition programs can do both through its educational activities and outreach services and by providing freedom to choose organic products for those who wish to purchase them.

Thank you for this opportunity to share our views.

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