July 22, 2004
Barry Cortez, Branch Manager
California Department of Pesticide Regulation
1001 I Street
P.O. Box 4015
Sacramento, CA 95812-4015
Dear Mr. Cortez:
According to Section 12825 of the California Food and Agricultural Code, the director may cancel the registration of, or refuse to register, any pesticide:
1) the use of which is of less public value or greater detriment to the environment than the benefit received by its use; or
2) 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.This letter is being written to protest the use of processed free glutamic acid (MSG) in agricultural products used on produce in the state of California including, but not limited to, its use in AuxiGro WP (AuxiGro), and including, but not limited to its use as a desiccant, disinfectant, fertilizer, fungicide, and/or growth regulator for increased yield and prevention of powdery mildew in crops such as almonds, grapes, melons, and cole crops. The most recent request for approval of use of AuxiGro (for a label amendment) was made as CDPR Tracking Number: 207128. EPA Registration Number: 70810 - 1; Applicant Emerald BioAgriculture; CAS numbers 56-12-2, 56-86-0.
We ask that the director allow no expansion of use of processed free glutamic acid (MSG) in California, and that he cancel the existing registration of AuxiGro on the grounds that its use is of less public value or greater detriment to the environment than the benefit received by its use.
We can find no "public value" in producing crops that are larger than they might otherwise be, and/or yields that are greater than they might otherwise be. Any benefit there might be (which is not "public value") would be financial gain to Ajinomoto, Company, Inc. (Ajinomoto); to the distributor that Ajinomoto uses in selling its processed free glutamic acid (MSG) to Emerald BioAgriculture; to Emerald BioAgriculture; and, possibly, to the producers and distributors of AuxiGro treated crops.
On the other hand, the potential for detriment to the environment is undeniable. MSG is a neurotoxin, potentially toxic to everyone -- potentially toxic even to those people who do not respond with adverse reactions such as migraine headache, asthma, nausea and vomiting, fatigue, disorientation, and depression. We know that MSG kills brain cells in laboratory animals. We know this from studies wherein MSG was given in food and from studies were MSG was given in drinking water. We know that learning disabilities and endocrine disorders such as gross obesity and reproductive disorders often follow the death of brain cells in animals. We know that children and the elderly are most at risk from the toxic effects of MSG.
Processed free glutamic acid (MSG) is an endocrine disrupter. It is well documented fact that processed free glutamic acid (MSG) consumed in food and drink causes brain lesions in the area of the hypothalamus; and, when ingested by the young, subsequently causes endocrine disorders such as reproductive disorders and obesity. (See the enclosed "Scientists Tell Us that Use of MSG Places Humans at Risk" www.truthinlabeling.org/humansatrisk.html)
Processed free glutamic acid (MSG) causes adverse reactions including skin rash, irritable bowel, heart irregularities, asthma, migraine headache, depression, and seizures in people who are sensitive to it. Emergency room physicians are well aware of the toxic potential of processed free glutamic acid (MSG), and virtually every headache clinic in this country lists processed free glutamic acid (MSG) as a migraine headache trigger.
Processed free glutamic acid (MSG) is also known to cause or exacerbate a variety of conditions including neurodegenerative disease such as Alzheimer's disease, Parkinson's disease, and ALS. Today, drug companies are working hard to producing glutamate blockers for people stricken with those diseases. Namenda, one such drug, is already being marketed by Forest Pharmaceuticals.
AuxiGro contains carcinogenic material.
We ask that the director allow no expansion of use of processed free glutamic acid (MSG) in California, and that he cancel the existing registration of AuxiGro on the grounds that in making application to the CDPR, false and misleading statements were made or implied by the registrant. In making its applications to the CDPR, Emerald BioAgriculture (formerly Auxein corporation) has both misrepresented the composition and safety of the free glutamic acid used in AuxiGro and failed to provide the CDPR with full disclosure.
Emerald BioAgriculture has never demonstrated that AuxiGro is "safe." Emerald BioAgriculture has made its claim for the safety of its product on short term studies that do not even pretend to assess the long term effects of its neurotoxic component (processed free glutamic acid - MSG), using statements such as "should not" and "very likely will not."
The data submitted to both the U.S. Environmental Protection Agency (EPA) and the CDPR by Emerald BioAgriculture have fallen far short of providing full disclosure of the toxic potential of processed free glutamic acid (MSG) and the potential for allergic and/or sensitivity reactions that might be caused by the processed free glutamic acid (MSG) contained in AuxiGro and by other potentially allergenic substances such as the milk protein contained in AuxiGro's "inert" ingredients. Among its other shortcomings, the material submitted by Emerald BioAgriculture:
Failed to disclose case studies and research reports that have demonstrated that what the applicant refers to as "L-glutamic acid" is a know neurotoxic amino acid and endocrine disrupter. Processed free glutamic acid (MSG) kills brain cells, is an endocrine disrupter (causing reproductive disorders and gross obesity after being fed to the very young), causes behavior and learning deficits, and causes adverse reactions such as asthma, heart irregularities, migraine headache, depression, and seizures in both children and adults who are sensitive to it;
Provided no data on the amounts of processed free glutamic acid (MSG) that will remain in and on AuxiGro treated produce when that produce is brought to market. Instead of telling the whole story of how AuxiGro is being proposed for use by Emerald BioAgriculture, Emerald BioAgriculture has told both the EPA and the CDPR that "it should wash off," but has not mentioned that Emerald BioAgriculture recommends that AuxiGro be used with a surfactant that will keep the AuxiGro from washing off. And joke of all jokes, Emerald BioAgriculture seems to have glossed over the fact that to be effective -- to increase fungicide resistance, growth, and/or yield -- AuxiGro must be taken up into the plant where it would remain in the leaves (lettuce and spinach for example), fruit (grapes, melons, and tomatoes for example), roots (potatoes and carrots for example), seeds, and stems when purchased by unwary consumers.
Provided no data on the amount of processed free glutamic acid (MSG) that would have been taken up by each crop and remain in the crop when brought to market. (If you understand how AuxiGro works, you will realized that unless processed free glutamic acid (MSG) is absorbed into the plant destined to become food, the AuxiGro can not do the job it was designed for.)
It would also appear that the information contained on the AuxiGro label is inadequate, deceptive, and misleading.
AuxiGro contains neurotoxic free glutamic acid that is made through a patented process of bacterial fermentation wherein selected genetically modified bacteria secrete glutamic acid through their cell walls. The consumer has no way of knowing that.
AuxiGro contains hydrolyzed casein (milk) protein, a product that will not only be offensive to vegetarians and various religious groups, but one that contains milk protein – hidden milk protein – a hidden potentially lethal allergen. The consumer has no way of knowing that.
The AuxiGro label states that AuxiGro contains 29.2% L-glutamic acid in its active ingredients. The "L-glutamic acid" contained in its inert ingredients is not mentioned.
It is of great concern to us that those who evaluated the AuxiGro application in the past ignored its shortcomings. The CDPR seems not to have been concerned with possible conflicts of interests of its advisors who, by and large, come from universities and colleges in the state of California system (or have close ties to those institutions) that have benefited from funding provided to those schools and to individual researchers in those schools by the Ajinomoto, the world's largest supplier of processed free glutamic acid, including the processed free glutamic acid used in AuxiGro.
It is of great concern to us that the CDPR has ignored the fact that the glutamic acid used in AuxiGro is a manufactured product similar to, if not identical to, the processed free glutamic acid used by Ajinomoto in the flavor enhancer it produces called "monosodium glutamate." It seems to be a hallmark of the argument for the safety of AuxiGro that the glutamic acid in AuxiGro arrives in the Emerald BioAgriculture production facility by some kind of divine intervention rather than by production by Ajinomoto using bacterial fermentation, just as the glutamic acid in their "monosodium glutamate" is produced. "Pharmaceutical grade" L-glutamic acid is manufactured, and contains contaminants just as all manufactured L-glutamic acid does. The difference is that there is a limit on the amount and/or number of contaminants in any L-glutamic acid that claims to be "pharmaceutical grade."
Honest answers to the following questions would demonstrate that Emerald BioAgriculture had omitted data, not given full disclosure, misrepresented data, and made false and deceptive statements.
Question: 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).Every day we have new evidence of the toxic effects of processed free glutamic acid (MSG). We now know, for example, that MSG causes macular degeneration (retinal degeneration). We also know that the toxic effects of MSG can be cumulative. In one well done 2002 study by Ohguro et al., no retinal damage was observed when MSG was fed to laboratory animals for a short period of time (a month), but as time during which MSG was fed to those animals increased to 3 months and 6 months, there was observable damage. (Ohguro et al. A high dietary intake of sodium glutamate as flavoring (Ajinomoto) causes gross changes in retinal morphology and function. Experimental Eye Research 75:(3), 307-315, 2002). (Copy enclosed)
Question: What are the specific contaminants in the processed free glutamic acid used in the manufacture of AuxiGro?
Question: What is the amount of processed free glutamic acid residue that will be left in and on produce from application of AuxiGro?
Question: What amount of processed free glutamic acid causes adverse reactions in highly MSG-sensitive people?
Question: What is the least amount of processed free glutamic acid (MSG) needed to kill brain cells in humans or subhumans of any age and/or any degree of vulnerability to exposure to the substance?
Question: 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: Material coming from the EPA states that AuxiGro contains carcinogens. Why is the CDPR licensing a product that contains carcinogens?
Question: 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 is 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: 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. Why is the CDPR licensing a product that is misbranded?
We ask that the director allow no expansion of use of processed free glutamic acid (MSG) in California, and that he cancel the existing registration of AuxiGro
Adrienne Samuels, Ph.D.
Truth in Labeling Campaign
1547 Santa Sabina Court
Solana Beach, CA 92075
cc: Governor Arnold Schwarzenegger
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IF MSG ISN'T HARMFUL, WHY IS IT HIDDEN?