rBGH licensing will not conform with scientific procedures or current government policy, says the Toronto Food Policy Council (TFPC)

Recombinant Bovine Growth Hormone (rBGH) has for a decade been a very controversial product. Although not yet licensed for use in Canada, its costs and benefits have been the subject of much debate among farmers, dairy processors, public health authorities and consumers. Proponents of the drug have claimed it can increase milk production in many cows and provide farmers with more management options. Critics believe the drug poses human and animal health problems, and that its widespread use will cause a significant and undesirable restructuring of the Canadian dairy sector.

It is the view of many in the agriculture and health sector that the licensing and use of rBGH will not conform with both established scientific procedures or government policies, rules and regulations that give direction to the Canadian dairy sector. Consequently, dramatic changes to such procedures and policies would be required to bring them into compliance with the new realities imposed by rBGH licensing.

The drug’s manufacturers and the drug review process have been consistently criticized for:

incomplete regulatory evaluation and controls;
questionable scientific and statistical analysis of potential human and animal health impacts of the drug;
incomplete analysis of the implications for the dairy sector;
contradictory regulations governing milk and the dairy industry;
contradictory arguments regarding labelling of milk rBGH-treated cows.

More specifically, seven fundamental weaknesses are apparent in the position favouring rBGH licensing.

Contrary to industry and government claims, levels of BGH and Insulin-like Growth Factor - 1 (IGF-1) will be present in the milk supply as research does not prove that they are mostly denatured by commercial pasteurization. Most of the research studies have used pasteurization temperatures and time frames that overcook the samples, and are not used by commercial processors. Consequently, the research results are not necessarily indicative of what happens in a processing plant.
There are no chronic safety data assessing the impacts of humans consuming milk from rBGH-treated cows. The longest test for human exposure impacts is only 90 days. Yet, there is evidence that negative effects of exposure to elevated levels of IGFs may not appear until 18 months later. The generally accepted standard for human health assessments is two generation rodent and rabbit assays for birth defects, and two-year feeding studies with toxicological testing.
The regulatory system has failed to properly evaluate the potentially negative health impacts of IGF-1. IGF-1 levels rise in milk when rBGH is administered. Because human and bovine IGF-1 are identical, many health experts are worried that increased exposure to this compound, which at normal levels performs useful functions in the body, will cause health problems, including accelerating cancer tumour development. It has been assumed by industry and regulators that IGF-1 levels add little to the total IGF-1 already circulating in the human body, and that the additional amounts consumed in milk are digested in the stomach. But research suggests that the qualities of milk may protect IGF-1 from the action of stomach enzymes, resulting in its absorption in the gut wall. The implications of this are unknown. The regulators have failed to address this deficiency in our knowledge.
Because of the changes to BGH and IGF-1 content, milk from rBGH-treated cows will be in contradiction of the Food and Drug Act definition of milk, which states that milk is the normal secretion of a cow. The TFPC contends that the milk from rBGH injected cows cannot be considered normal.
Independent analysis of industry data shows that rBGH use increases mastitis in herds using rBGH, and such increases may result in increased antibiotic use and pressure on the milk quality control system. The industry has pooled its data in such a way that the effects of mastitis on those cows who react badly to rBGH use is effectively hidden.
rBGH licensing will compromise existing rules of scientific breed improvement, a cornerstone of long-term progress in milk production. The use of the drug makes the animal's inherent genetic qualities for milk production impossible to determine. Canada's export market in cows, profitable because of the integrity of the genetic improvement system and associated record keeping, is in jeopardy if rBGH is licensed.
Government and industry opposition to labelling means that the market will not be able to tell us whether consumers find biotechnology products acceptable.

Given these contradictions, weaknesses and errors, it is the view of many that no license for rBGH be granted at this time. Instead, the Toronto Food Policy Council believes that the federal government should consider the following options for the dairy sector:

Dairy farmers should have a long-term dairy policy based on the financial and environmental sustainability of the sector, and that as part of this policy, no hormones should be permitted for the expressed purpose of modifying an existing dairy cow (either inherently, genetically, or through transgenic manipulation) so that it produces more milk than its inherent capacity in a normal Canadian dairying environment.
Any new technologies should focus only on therapeutic or environmental aspects of dairying, for example, alternative approaches to managing animal health, feeding regimes, pasture and crop management, and animal housing designs.
Dairy processors and retailers should be accountable to consumers, through product labeling of processes used in dairy farming and processing should be part of such accountability.
New products should be screened for their potential broad social benefits prior to the review process undertaken by Health Canada, to determine whether the product has sufficient merit in terms of long-term health and sustainability to warrant a detailed review of its efficacy and health impacts.

The TFPC's full report on this topic is available from their office, 277 Victoria St., Rm 203, Toronto, ON M5B 1W1.

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