When we first learned that processed free glutamic acid (MSG) was to be used on growing food crops, the U.S. Environmental Protection Agency (EPA) had already approved its use "on all food commodities, when applied as a plant growth and crop yield enhancer in accordance with good agricultural practices." Indeed, the EPA was in the process of approving AuxiGro as a pesticide product to be used on specific crops.

At that time, Edward Allen was the regulatory action leader who attended to the details of AuxiGro approvals -- including approvals of AuxiGro's active ingredients.  Allen reported to Janet Andersen, Ph.D., who was (and still is) Director of the Biopesticides and Pollution Prevention Division (BPPD).

We first made Andersen's acquaintance in 1998 after we found out that the EPA had approved spraying processed free glutamic acid (MSG) on food commodities when applied as a plant growth and crop yield enhancer.  She first came to our attention when friends of the Truth in Labeling Campaign shared copies of e-mails sent to them in which Andersen made excuses for the EPA's approval of processed free glutamic acid (MSG) for limited use on growing food crops, spewing out a number of bold faced lies.

How did Andersen excuse (defend, justify, rationalize, explain) the fact that the EPA had approved processed free glutamic acid for use in an EPA approved spray? First, said Andersen, the free glutamic acid used in the spray is naturally occurring. In addition, said Andersen, it is 99.3 per cent pure pharmaceutical grade L-glutamic acid.  It never seemed to bother Andersen that in admitting that the free glutamic acid in AuxiGro is only 99.3 per cent pure, not 100 per cent pure L-glutamic acid (as found in nature), Andersen contradicted herself.  For if the free glutamic acid used in AuxiGro were truly naturally occurring, it would be 100 per cent pure, not 99.3 per cent pure L-glutamic acid.  The fact that the free glutamic acid used in the spray is pharmaceutical grade only means that when it was manufactured, Ajinomoto or whomever else manufactured the free glutamic acid used, controlled its manufacturing process to make sure that the contaminants in the processed free glutamic acid did not exceed 0.7 per cent.

Andersen said other things that were very interesting. She said that the EPA is well aware of the fact that MSG causes adverse reactions. However, when Andersen used the term "MSG" she was referring to the one food ingredient called "monosodium glutamate," and not to the free glutamic acid in "monosodium glutamate" that causes adverse reactions. Failure to define terms, as Anderson did (and still does), is both deceptive and misleading.

Andersen must surely have psychic powers, for she made all sorts of claims for the safety of processed free glutamic acid (MSG) for which there were (and still are) no data.  Andersen claimed that the little bit of processed free glutamic acid (MSG) that might be left as a residue on crops treated with it could not cause adverse reactions.  But Andersen wouldn't tell us how much residue there might be on crops treated with AuxiGro and its processed free glutamic acid (MSG), or how much processed free glutamic acid (MSG) left on the surface of crops would be needed to cause an adverse reaction in an acutely sensitive person.  Moreover, Andersen wouldn't tell us how much processed free glutamic acid (MSG) would be taken up into various crops (russet potatoes, for example) and remain as such in those crops when brought to market; or how much processed free glutamic acid (MSG) taken up into various crops would be needed to cause an adverse reaction in an acutely sensitive person.

Andersen also told us that most of the residue left on crops from AuxiGro would wash off.  But, again, Andersen had no data.  Neither did she tell us that Auxein/Emerald BioAgriculture suggested to users of their product that a surfactant be used with the AuxiGro so the AuxiGro would be sure not to wash off.

Over all, what Andersen did was very clever. First, she said some words that at first sounded meaningful, but if considered carefully, made no sense. For example, no one ever claimed that the processed free glutamic acid (MSG) in AuxiGro came out of a box labeled "monosodium glutamate." So for Andersen to say it didn't, was meaningless.

When that tactic wasn't good enough,  Andersen simply ignored questions, comments, and or criticisms which, if answered, would have demonstrated that use of processed free glutamic acid (MSG) in products regulated by the EPA would place consumers at risk.  The claim has been made, for example, that the free glutamic acid in AuxiGro will cause the same brain lesions, neuroendocrine disorders, adverse reactions and other diverse disease conditions that are caused by the free glutamic acid in "monosodium glutamate" and the other food additives that contain processed free glutamic acid (MSG). That claim is true, but Andersen ignored it and did not address it.

Clever?  Yes, clever.  How do you refute someone who ignores legitimate questions and spews out irrelevant statements as though they pertained to your legitimate questions? You don't when that "someone" representing a government agency serves simultaneously as expert, witness, judge, and jury. The EPA defense of its approval of use of processed free glutamic acid in plant "growth enhancers" and its registration of AuxiGro has three parts to it: 1) ignoring those who question EPA actions; 2) making irrelevant statements such as "AuxiGro does not contain MSG (monosodium glutamate);" and 3) serving simultaneously as witness, expert, judge, and jury.

Neither Andersen nor anyone else at the EPA ever addressed the criticism that approvals given by the EPA to allow the use of free glutamic acid and the product AuxiGro were inappropriate.

At the end of June, 2001, we learned of the Auxein/Emerald BioAgriculture application to allow use of processed free glutamic acid (MSG) on growing food crops without restriction, and we learned that on June 21, 2001, the EPA had approved the Auxein/Emerald BioAgriculture application.  This opened a window of opportunity, for by law the EPA is required to take comment on such approvals.  To do the best job possible, we decided to ask the EPA's Carol Frazer, Ph.D. for a list of the material submitted to the EPA in 1997 and 1998 when processed free glutamic acid (MSG) was first proposed for limited use on growing food crops. Originally, Edward Allen, Regulatory Action Leader, Biopesticides and Pollution Prevention Division, Office of Pesticide Programs, EPA, was the person with whom we communicated about detail of the EPA's approvals of processed free glutamic acid (MSG) and AuxiGro.  (The EPA now refers to the processed free glutamic acid [MSG] that they have approved for unrestricted use as "L-glutamic acid.")  Allen moved on, however, and eventually Frazer took his place.

When we spoke to Dr. Frazer, we explained that knowing what material had been submitted to the EPA in 1997 and 1998 might help us write an Objection to the June 21, 2001 approval -- an Objection that we were planning to submit on behalf of the Truth in Labeling Campaign.  The June 21, 2001 approval appeared to be based on little or nothing more than the material submitted to the EPA by Auxein Corporation in 1997 and 1998.

For the next seven weeks, Frazer made excuses for not placing material from 1997 and 1998 in the 1998 Docket--which, conveniently, had never been opened by the EPA. (If placed in the docket, the information from 1997-1998 might have been available to us if we had flown to Washington to review it.)  Frazer even made excuses for not sending us a list -- a simple list -- of the 1997-1998 material that she had in her office relevant to the proposal and approval of processed free glutamic acid (MSG) for limited use on growing food crops.  But after seven weeks of listening to Frazer's lame, and often contradictory excuses, we challenged her, asking Frazer on whose authority she was withholding this information from us.  It was at that time that Frazer told us--she actually told us--that it was on orders from someone in her department that she was not making material available to us.

After that, Frazer stopped answering our phone calls, letters, and e-mail.  But her boss, Dr. Janet Andersen (who claimed to pride herself on returning phone calls) returned the calls that we made to her. Andersen also answered letters that were sent to her.  But in what we have grown to understand to be typical EPA fashion, Andersen did not answer questions when honest answers might have been interpreted as admissions that the EPA was, or is, representing the interests of Auxein Corporation, Emerald BioAgriculture, or Ajinomoto, Company, Inc., all corporations that had (and still have) a great deal to gain from the EPA's approvals.  Andersen did not answer questions when honest answers might have been interpreted as admissions that the neurotoxic amino acid approved by the EPA for use on food crops was approved in violation of the Federal Food, Drug, and Cosmetic Act.

Objections to the EPA's Final Rule allowing processed free glutamic acid (MSG) to be applied to growing food crops without restriction were filed by August 20, 2001, as required by the EPA.  (We have included a copy of the Truth in Labeling Campaign Objection on this Web site.) Fascinated to know how the EPA would process the objections and comments and respond to them, the Truth in Labeling Campaign pushed Andersen for an outline of the procedure to be followed.

The following is what Andersen told us in September, 2001 about how the Objection of the Truth in Labeling Campaign would be handled.

"Subj: Your email and fax of September 4
Date: 9/21/2001
From: Andersen.Janet@epamail.epa.gov (Janet Andersen)
To: Adrienne Samuels

"I am pleased I had the chance to talk to you on Friday, September 14....

"...The Biopesticides and Pollution Prevention Division has never had a timely and correctly submitted objection to any of its tolerances or tolerance exemptions so I was unfamiliar with the process....

"The law does require that EPA send a copy of any and all objections to the petitioner [Auxein Corporation (now Emerald BioAgriculture)]....There is no indication that the registrant is required to respond to the EPA or the objections.  EPA does have an obligation to respond to the objections by producing a Final Order.

"In a previous matter involving objections to a chemical pesticide tolerance, EPA first published a draft Final Order.  This proposed Order (or draft Final Order) would allow for public comment before EPA issues its Final Order.  I strongly prefer the option of allowing public comment on the proposed Order and my upper management agreed with my recommendation on September 19th.

"....I am estimating it will take us 6 to 8 months to develop the proposed Order.  We would then announce the availability of this proposed Order in the Federal Register and have all of the documents on the public docket before the Federal Register is published.  I anticipate giving a 60 day comment period on the proposed Order.  Once the comment period is closed, EPA would review all of the comments and produce a Final Order."

"Subj:  Re: L-Glutamic Acid and Gamma Aminobutyric Acid; Exemptions from the Requirement ...
Date:  8/6/2002 1:09:31 PM Central Daylight Time
From:    Andersen.Janet@epamail.epa.gov
To:    AdieOnly@aol.com

"I'm sorry that it has taken a few days to get back to you on your email
note regarding the petition on the L-Glutamic acid and GABA tolerance
amendment.  I was on travel most of last week.

"We are working on the petition response although we have been slowed by
some other actions.  I will let you know as soon as we have a draft
document for distribution and comment.  Please feel free to stay in
contact with me."

The details are laid out in the Objection filed by the Truth in Labeling Campaign in August, 2001.  The essentials are as follows:

1. Ignore the applicant's:

Errors

Omissions

Failures to define terms

Use of ambiguous words and phrases

Half-truths

Misrepresentations

Out and out lies

2. Repeat the applicant's Errors, Omissions, Failures to define terms, Use of ambiguous words and phrases, Half-truths, Misrepresentations, and Out and out lies to those who question the product in question.

3. Add unsupported and unsupportable assumptions about the safety of the applicant's product.

4. Draw unsupported and unsupportable conclusions about the safety of the applicant's product.

5. Serve simultaneously as witness, expert, judge, and jury if and when challenged.

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The content on this page was last updated on March 3, 2008