Public comment dockets have become an interesting space for policy makers and the public to engage in conversations with one another about various issues in public health. The ever-developing internet has allowed dockets to take on a life of their own – public comments submitted in almost a blog post format for perusal. If you haven’t ever checked out the dockets before, I strongly encourage you to take a look at the subjects being opened for public comment. They include some really important issues – from tobacco legislation to air quality regulation.
On November 12, 2015, the Food and Drug Administration (FDA) opened a docket to “receive information and comments on the use of the term ‘natural’ in the labeling of human food products, including foods that are genetically engineered or contain ingredients produced through the use of genetic engineering.” The FDA asking for public opinion on the issue of the “natural” definition is not a new event. In 1991, the organization proposed trying to define the term in labeling in order to create “consumer consensus” on what the term meant and how it should be regulated for use. Easier said than done. The comments were apparently sporadic enough to discourage the FDA from defining this term through rulemaking. At that moment, the FDA maintained that “natural” would be interpreted as the following: “nothing artificial or synthetic (including all color additives regardless of source) has been included in, or has been added to, a food that would not normally be expected to be in the food.”
The increased development of genetically modified organisms (GMOs) has been enough cause to establish a new docket on the issue. Three citizen petitions were received by the FDA requesting a hard definition of “natural,” and one petition to eradicate the term from labeling altogether. The docket (as of the end of the day yesterday) has received 3,336 electronically submitted comments. You can read the public submissions as they are uploaded online.
Many of the comments have broad-sweeping consistencies; largely that “natural” does not apply to food created in laboratories or from unsustainable farming systems (pesticides are largely noted in these comments). Additionally, it should also be applied to food that is not pasteurized, not artificial, and not “man made in any form.”
The OED defines “natural” as “existing in or caused by nature; not made or caused by humankind.” This seems like a reasonable definition overall and fits the description of commentators on the docket. But when this definition is realistically applied to something “caused by humankind” like the larger global food system – it falls apart. Why is it so hard to define “natural” in these instances? Can it be done, and should it?
“Natural” is inherently difficult to grasp because “nature” is just as abstract. Raymond Williams – a scholar who had dedicated much of his work to the meaning of words – noted the challenge of the word “Nature” in his essay, “Ideas of Nature” (1980). Throughout literary and scientific history, Nature has meant a myriad of things for humans. According to Williams, Nature described a primitive form of life that existed before human society, and a quality of innocence that existed before the fall in the Garden of Eden. Nature has also been considered a force – one that simultaneously destroys, creates, preserves, and changes life (72 – 73). As time went on and in the interest of studying “natural processes” in the wake of scientific inquiry, “Nature” and “Man” as conceptual arenas had to be separated. Through this separation, man was able to not only observe nature without contestation, but largely control it. This control seemed inherent to the philosophical definition of “human,” Williams speculated, and it has arguably created the historical social disparities we still see today – arguably byproducts in the history of science. Sherry Ortner (1972), for example, has written that because women have been historically considered closer to nature in their ability to biologically reproduce, women have been considered less separate from Nature, and thus inferior to men – who are considered more separate from Nature. Though now considered a simple feminist description, it is important to note that even misogyny was thought to have been solidified through the Nature – Man divide. We even see similar arguments held in old explanations of racial and class hierarchies.
But what these scholars and many after them have shown is that defining nature is contingent on an abstract, ever changing definition imposed by a particular group of humans. The irony of this? All humans are a product of nature. Philosophically this has been difficult for us as a species to come to grips with – particularly the flip-side that nature is also a product of humans. I think Williams wrote it best:
“In this actual world there is then not much point in counterposing or restating the great abstractions of Man and Nature. We have mixed our labour with the earth, our forces with its forces too deeply to be able to draw back and separate either out. Except that if we mentally draw back, if we go on with the singular abstractions, we are spared the effort of looking, in any active way, at the whole complex of social and natural relationships which is at once our product and our activity” (83).
Considering that our food systems are products of longstanding engagements between “nature” and “man,” defining “natural” today to label human food products becomes an enormous philosophical endeavor. This is particularly weighty with the case of GMOs, where genetic modification has reached sophisticated lengths beyond selection and hybrid breeding. Lines are being drawn by many different types of consumers as to where modification is no longer “natural,” and a newly bounded definition that limits human intervention on food products could have consequences (negative and positive) for the future of food production.
Is it “natural” for Americans to have access to seasonal food all year round? Are foods grown in greenhouses more or less “natural” than seasonal, non-pasteurized crops? Is hunting and gathering more “natural” than intensive agriculture, and does this “natural-ness” translate into “healthier”? These are questions consumers have been asking themselves in regards to the “natural” label, and they are certainly reflected in the comments posted to the FDA docket in question. But the answers to these questions are also clearly based on generalized assumptions of current food systems, assumptions about food science and research, and romantic notions of what it means to be “existing in or caused by nature.” Our relationship with nature has changed, and thus both Nature and Humans have changed. As Williams and others have noted, this needs to be acknowledged, as well as the fact that “nature” and “mankind” are not separate entities and never have been. This is where the OED definition becomes incredibly flawed, and the possibility for a new definition of “natural” for food product labeling potentially dangerous. Such separations mute human accountability, assume the stability of human-made categories, and simplify both ecological and social relationships.
Cronon, William. “The Trouble with Wilderness: Or, Getting Back to the Wrong Nature.” Environmental History 1, no. 1 (1996): 7–28. doi:10.2307/3985059.
Ortner, Sherry B. “Is Female to Male as Nature Is to Culture?” Feminist Studies 1, no. 2 (1972): 5–31. doi:10.2307/3177638.
Ph.D, Lisa H. WEASEL. Food Fray: Inside the Controversy over Genetically Modified Food. AMACOM Div American Mgmt Assn, 2008.
Williams, Raymond. Culture and Materialism: Selected Essays. Verso, (1980) 2005.
**Cover image from USDA film strip, published in the article “Stewart’s Wilt of Corn” by J. Pataky (2003) from the American Phytopathological Society.