February 1, 2003
The Honorable G. Steven Rowe
6 State House Station, 6th Floor
Augusta, ME 04333
Re: Petition to Suspend Use of State of Maine Quality Trademark for Milk and Milk Proteins
Dear General Rowe,
I am writing to you after a discussion I had with Marilyn Anderson from the Maine Coop Voices United. She told me of the attempt by Monsanto to force Maine to allow milk from cattle treated with recombinant bovine growth hormone (rbGH) to be eligible for the Maine “Seal” (currently prohibited by present law) and for the Attorney General to legally prosecute dairies that advertise that their milk comes from farmers that pledge not to use milk from rbGH-treated cattle. Since I testified before the Maine legislature when they were hearing the original mandatory labels bills for milk and other dairy products derived from rbGH-treated cattle, I would like to weigh in on a few issues that are used in Monsanto’s Petition. I will argue that: milk from rbGH-treated cattle differs from milk from untreated cattle, unanswered questions exist about certain safety issues associated with milk from rbGH-treated cattle, labeling milk as to use of rbGH does not deceive consumers, and FDA does not require a “contextual statement” on milk labeled as coming from cattle not treated with rbGH. In sum, we support the right of Maine to use its Quality Seal in the way that it presently does (i.e. by requiring that 80% of the milk come from dairies in Maine and that farmers pledge not to use rbGH) and urge you to deny Monsanto’s Petition. To grant Monsanto’s petition would endorse the idea that consumers do not have a right-to-know whether their milk comes from cows that have not been treated with rbGH (or from farmers who pledge not to use rbGH), which we think would be a bad idea.
I. Milk from rbGH-treated cattle differs from milk derived from untreated control cattle
Monsanto attempts to argue that milk from rbGH-treated cattle “is equivalent in all respects to other milk.” We disagree. First, Monsanto’s rbGH differs from cattle’s natural growth hormone. A cow’s natural growth hormone is a protein that consists of 190 or 191 amino acids. Monsanto produced a version of the natural bGH which differed by a single amino acid (methionine), which was added to one end of the molecule (the N-terminus). This difference facilitated the production of rbGH by bacteria, e.g. the yield of rbGH produced per bacteria was higher when the gene coded for an rbGH molecule that ended with a methionine than one that did not. Thus, milk from rbGH-treated cattle will contain rbGH, while milk from untreated cattle will not.
Monsanto’s rbGH product, POSILAC, which has an extra amino acid (methionine) at one end of the molecule is also more immunogenic (e.g. stimulates the immune systems more) than natural bGH produced by a cow’s pituitary gland, e.g. there are differences in how the immune system reacts to a cow’s natural bGH and Monsanto’s rbGH. A paper published in 1994 using Monsanto’s rbGH product, “Identification of antigenic differences of recombinant and pituitary bovine growth hormone using monoclonal antibodies,” demonstrated “that small differences in structure, for example through additional N-terminal amino acids, can markedly change the immunogenic characteristics of a protein” (Erhard et al., 1994: pg. 16).
Thus, rbGH differs from cow’s natural bGH in ways that can be detected by the immune system. Further, some of the bGH in cow’s milk will consist of rbGH; conversely, rbGH will not occur in the milk of untreated cows. So, the presence of rbGH in the milk of cows treated with rbGH constitutes a difference with the milk from untreated cows.
For more go to: http://www.consumersunion.org/pdf/bGH-ME2-03.pdf