Does the Steel Industry Perform Differently Than the Basic Materials Sector?

Does the Steel Industry Perform Differently Than the Basic Materials Sector?

By C. Michael Carty, Edward Matluck, Ph.D., and Andrea Psoras  (authored in late 2006, early 2007)

  1. Executive Summary

The purpose of this paper is to present the results of research that compares the steel industry and basic materials sector.  In the past, investors wishing to manage their exposure to the steel industry have had to either purchase steel stocks, basic materials exchange-traded funds and/or mutual funds.  Recently, Van Eck’s Market Vectors – Steel ETF (SLX) was launched which eases this task.  We find that this ETF performs differently from those based on basic materials indices.  More specifically, a steel index consisting of domestic stocks and foreign ADRs and ADSs is found to possess distinct characteristics relative to broader basic materials indices. Although these sectors can move together, they often diverge from each other. An investment tied specifically to a steel industry index therefore offers more direct ways of gaining or reducing portfolio exposure to that industry, giving professional and private investors greater flexibility in separating economic and market trends specific to it from those influencing other sectors and the overall market.

In order to demonstrate the existence of these distinguishing characteristics, this study investigates the historical stock market performance of the Amex Steel Index (STEEL) used in the Market Vectors – Steel ETF, the Dow Jones US Basic Materials Index (DJUSBM) underlying the iShares Dow Jones US Basic Materials Sector Index Fund (IYM) and the S&P Materials Index (IXB) underlying the Materials Select Sector SPDR Fund (XLB). Since historical data for the indices are not of sufficient length to encompass several economic and market cycles, they were reconstructed using their rules of construction as closely as possible going back nearly 30 years. Standard statistical tests were conducted to determine their monthly and annual returns, standard deviations, correlations, betas, maximum draw-downs, draw-down durations, tracking errors relative to the S&P 500 index, and relationships to macroeconomic data and cyclical patterns.

On the basis of this evidence, we conclude that the Amex Steel Index underlying the Market Vectors – Steel Fund is distinguishable to a statistically significant degree from the basic materials indices underlying the iShares Dow Jones US Basic Materials Sector Index Fund and the Materials Select Sector SPDR Fund.  The primary implication of this conclusion is that broad basic materials indices, by being diversified across a number of basic materials industries, obscures the steel industry’s unique performance characteristics.  Therefore, investors interested in gaining or reducing exposure to the steel industry should do so directly by using an ETF based on a steel index instead of one based on a basic materials index, all other things being equal.

 

  1. Background

The common stocks of the steel industry and basic materials sector trade differently and are not proxies for one another. One reason is that they diverge somewhat in the underlying fundamentals that govern supply and demand.  Key drivers or end markets of steel include autos and parts, oil services, commercial construction, capital goods production, and defense related expenditures.  Other basic industries are tied to different end product markets; e.g., aluminum is tied very closely to aerospace, chemicals to processing markets, forest products to residential construction, and paper throughout the economy.

In addition, union and labor issues differ completely as do many of the sources of profitability.  Marketing and sales strategies also differ as do seasonal patterns.  On the other hand, both steel and the basic materials sector overall are sensitive to economic activity and demand patterns are often similar.

Because capital intensity as well as manufacturing capacity differs among these industries, their component companies sell at different price-to-earnings multiples and betas, and trade with different cyclical patterns.  Including all these companies in the same index obscures the movements of their individual industries and thus fails to identify various profit opportunities.  For example, when steel stocks are cheap, other basic materials’ stocks may be relatively expensive.

Starting in July 2003, operating margins in steel went from around 7% to 20% in September 2005. Since then, they have begun to recede and are now around 15%. Over the same period, basic materials’ operating margins have fluctuated in a narrow range, between 13% and 18% and are now about 17.5%.  It is likely that higher steel operating margins resulted from higher prices related to import quotas and tariffs to which basic materials’ operating margins did not respond. Subsequently, lower steel prices related to eliminating quotas and tariffs caused operating margins to recede. On-again off-again protectionist measures by the government over the past 50 years further contributed to differentiating the steel industry’s performance from that of basic materials.

 

III. Trading Opportunities with ETFs

ETFs have become a generally accepted tool for specific investment strategies, sector rotation, hedging and risk control.  Despite the popularity of sector ETFs, many are little more than aggregates of a number of industries having different characteristics.  For example, a number of ETFs already exist for the basic materials sector, i.e., iShares Dow Jones US Basic Materials Sector Index Fund, Materials Select Sector SPDR Fund, PowerShares Dynamic Basic Materials Sector Portfolio (PYZ), PowerShares FTSE RAFI Basic Materials Sector Portfolio (PRFM), streetTracks SPDR Metals and Mining (XME), and Vanguard Materials ETF (VAW).  However, SLX is the only ETF specializing in the steel industry.

Different industries within a sector may be cheap or expensive at different times. Investors can take advantages of some of these relationships using the steel industry ETF.  For example, steel may become ‘cheap’ compared to non-ferrous metals which are subject to commodity market booms.  The ETF provides a way to buy the industry against those stocks and short it when things move the other way.  The basic materials sector which contains non-ferrous metals, chemicals and other non-metals based industries is too broad to allow this.

Commodities booms and busts in the steel industry have caused their stock prices to be more volatile than basic materials’. Steel industry stock prices rose 57.6% in 1980, 67.3% in 1987 and 63.0% in 2004, significantly in excess of basic materials’ stock prices. These spreads provided an opportunity for investors expecting steel stock prices to revert to the mean to liquidate their long positions, or adopt short positions.  Conversely, when steel stock prices were significantly below basic materials’ in 1982, 1984, 1986 and 2000, investors had the opportunity to either cover their short sales or acquire long positions.

The preferred investment at those times would be a diversified portfolio of steel stocks afforded by an index, not individual stocks which are subject to the specific risk associated with a single company.  Van Eck’s Market Vectors – Steel ETF provides a simple low cost means of acquiring or shorting the steel industry in a single trade.

In addition, investors often have a need to hedge their steel stock holdings. A well-diversified steel ETF is a valuable tool for such hedging.  Further, as trading in the ETF grows, futures and options based on the index could be offered, giving participants the opportunity to play spreads and hedge with limited risk instruments. (Currently, the Philadelphia Stock Exchange trades options on their steel index. However, this index contains only domestic stocks and may not be appropriate as a hedge for SLX.)

 

  1. Comparing the Steel Industry, Basic Materials Sector and the S&P 500

The Market Vectors – Steel ETF is based on the Amex Steel Index (STEEL), which is a modified capitalization-weighted index of common stocks or ADRs of publicly traded companies involved primarily in steel production. The number of constituents in STEEL and hence SLX will vary depending on a number of factors including trading volume and market cap.  There were 39 constituents in the index as of December 22, 2006.  Since there is no readily available long term history for most of the foreign issuers, prior history of the steel industry index had to be constructed without them.  However, one to two years of pricing data are available. The steel index was reconstructed using equal-weights for the constituents, as was the surrogate for both the Dow Jones US Basic Materials Index and S&P Materials Index.  The reconstructed is apparently a suitable surrogate for STEEL with a high 0.92 correlation to its monthly changes and a 0.98 correlation to DJUSST.

As of December 22, 2006, the iShares Dow Jones U.S. Materials Sector Index Fund is based on the Dow Jones U.S. Basic Materials Index, a float-weighted index containing 80 publicly traded companies involved in the diverse basic industries such as chemicals, forestry and paper, industrial metals and mining. The Materials Select Sector SPDR is based on the S&P Materials Index which is float-weighted index of 29 publicly traded companies involved primarily in such diverse basic industries as chemicals, forestry and paper, mining, non-ferrous metals, paper and steel.

Table 1 contains summary statistics related to the Steel, reconstructed Basic Materials and the S&P 500 Indices.  Over the period from January 1977 to August 2006, the Steel Index has a compound annual return of 12.32% versus 16.31% for the Basic Materials Index and 8.78% for the S&P 500. As one might expect, both the Steel Index’s 28.92% standard deviation and the Basic Materials’ 20.01% indicate their greater volatility than the S&P 500’s 8.78%.  Their betas, also a measure of volatility, are consistent with their standard deviations.  The Steel Index’s 1.27 beta is greater than the Basic Materials Index’s 1.08, and both are greater than the S&P 500’s 1.00. Somewhat surprising is the fact that the Steel Index has lower annual returns and higher volatility than the Basic Materials Index over the nearly 30-year period, which seems somewhat inconsistent with capital asset pricing theory, where one expects greater, not lesser, returns to be consistent with greater risk.

Table 1. Summary of the Statistical Results, January 1977 to August 2006

 

Steel Basic S&P 500
Index Materials  
Compound Annual Return (%) 12.32% 16.31% 8.78%
Annual Standard Deviation (%) 28.92% 20.01% 14.79%
Beta 1.27 1.08 1.00
Maximum Draw-down (%) -65.08% -28.16% -46.28%
Max Draw-down/Avg. Return. (Years) 5.3 1.7 5.27

Source: QED International Associates, Inc.

 

Further evidence of their unique characteristics lies in their maximum draw-downs over the period, and the times expected to overcome these draw-downs based on their average returns.  The Steel Index’s maximum draw-down is 65.08%, and would require 5.3 years to recover to its previous level given its average annual return. The Basic Materials Index’s 28.16% maximum draw-down is less than half of Steel’s and would require 1.7 years to recover on average.  The S&P 500’s unusually large maximum draw-down of 46.28% theoretically would require 5.27 years to recover, but it still has not achieved its former highest level.

The Indices’ compound annual returns since January 1977 and over 1, 3, 5, and 10 year periods ended August 2006 are shown in Table 2.  The annual returns of the Steel Index differ from those of the Basic Materials and S&P 500 Indices, further indicating a degree of independence between them. The individual annual returns for the indices are contained in the Appendix.

Table 2. Comparative Annual Returns of the Indices

Over 1, 3, 5, and 10 Years and Since January 1977

 

  Steel Basic Materials S&P 500
  Returns Returns Returns
1 Year 49.99% 25.71% 6.84%
3 Years 57.81% 21.38% 8.96%
5 Years 28.45% 18.08% 4.61%
10 Years 20.11% 24.20% 14.87%
Since Jan ’77 12.32% 16.31% 8.78%

Source: QED International Associates, Inc.

 

Chart 1. Growth in the Value of $100 Invested in the Steel, Materials, Basic Materials and S&P 500 Indices, January 1977 to August 2006

Source: QED International Associates, Inc.

Assuming initial investment of $100 is made in each of the three indices in January 1977, the terminal values of those investments at the end of August 2006 would be $3,136.83 in Steel, $8,842.85 in Basic Materials and $1.213.31 in the S&P 500.  These results clearly indicate the Steel, Basic Materials and S&P 500 Indices perform differently with regards to returns.

The results in Chart 1 indicate significant differences regarding terminal and intermediate values in returns of the Steel, Basic Materials and S&P 500 Indices. For example, in April of 1998 both the Steel and Basic Materials Indices peaked, while the broad market as measured buy the S&P 500 continued to climb. The Basic Materials Index bottomed out in September 1998, while the Steel Index continued to falter.   After finding ‘bottom’ in February 2003, it rose more rapidly than both the Basic Materials and S&P 500 Indices.

Chart 2. Annual Returns in the Steel, Basic Materials and

S&P 500 Indices, January 1977 to August 2006

 

Source: QED International Associates, Inc.

The results in Chart 2 further substantiate significant differences in the Steel, Basic Materials and S&P 500 Indices.  At times their returns move together, often catching the same turning points, but occasionally moving in different directions. Steel outperformed Basic Materials in 13 of the 30 years, and the S&P 500 in 17 years.  In some years, such as 1982, 1986, 1994 and 1996 the Steel Index had negative returns while the Basic Materials Index had positive returns. In all but six cases, the returns between the two indices differed in magnitude.

The simple correlation of annual returns and tracking errors also indicates a statistical independence between the returns of these two indices.  Table 3 contains these statistics calculated over the nearly 30-year period, illustrating the existence of less than perfect correlations and significant tracking errors between the monthly returns of the Steel and Basic Materials Indices.  The evidence is all the more compelling when one recognizes steel, as a subset of the basic materials sector, is correlated perfectly with itself, having zero tracking error against its own index.

Table 3.  Correlation Coefficients and Tracking Errors for the Steel, Basic

Materials and S&P 500, January 1977 through August 2006

 

Correlation Steel Basic Mat’ls S&P 500
Steel 100.0%
Basic Materials 74.9% 100.0%
S&P 500 23.8% 54.0% 100.0%
Tracking Errors Steel Basic Mat’ls S&P 500
Steel 0.0%
Basic Materials 18.4% 0.0%
S&P 500 27.3% 14.3% 0.0%

Source: QED International Associates, Inc.

One might question whether the nearly 30-year steel index we constructed (QEDI Steel) is a proper surrogate for the Amex Steel Index (STEEL), or any other steel indices. Table 4 provides correlation and tracking error statistics comparing the reconstructed index with STEEL, the Dow Jones US Steel Index (DJUSST) and the S&P 500 between March 2001 and August 2006, a period common to all three. (S&P does not publish a steel index.) As evident in the table, the STEEL is highly correlated to the DJUSST and QEDI Steel with comparable tracking errors. In sum, the QEDI Steel Index appears to be a suitable proxy over the period common to STEEL and DJUSST. If STEEL had been computed back to January 1997, it would probably still be highly correlated to QEDI Steel.

Table 4.  Correlation Coefficients and Tracking Errors for Three

Steel Indices, March 2001 through August 2006

 

Correlation STEEL DJUSST QEDI Steel
STEEL 1.000
DJUSST 0.926 1.000
QEDI Steel 0.919 0.980 1.000
Tracking Error STEEL DJUSST QEDI Steel
STEEL 0.0%
DJUSST 16.5% 0.0%
QEDI Steel 17.9% 8.1% 0.0%

Source: QED International Associates, Inc.

 

  1. Summary and Conclusions

Although the steel industry is traditionally considered a subset of the basic materials sector, there are fundamental cyclical, economic and performance differences between it and other industries also considered to be basic industries. The end markets for the steel industry include autos and parts, oil services, commercial construction, capital goods and defense. Other basic industries serve other product markets. In addition, factor inputs differ substantially, iron ore and coke in steel, trees in forestry, wood and fiber in paper, etc. Even union and labor issues differ completely as do many of the sources of profitability.  Marketing and sales strategies also differ.

Because capital intensity as well as manufacturing capacity differs among these industries, their component companies sell at different price-to-earnings multiples and betas, and trade with different cyclical patterns.  Including all these companies in the same index obscures the performances of their individual industries and thus fails to identify various profit opportunities.  For example, when steel stocks are cheap, other basic materials’ stocks may be relatively expensive.

This study investigated the historical price performance of the Amex Steel Index underlying Van Eck’s Market Vectors – Steel ETF and the basic industry indices underlying the iShares Dow Jones US Basic Materials Sector Index Fund and the Materials Select Sector SPDR Fund.  Since historical data for the indices are not of sufficient length to encompass several economical and market cycles, they were reconstructed using their rules of construction going back nearly 30 years. Standard statistical tests were conducted to determine their monthly and annual returns, standard deviations, correlations, betas, maximum draw-downs, draw-down durations, tracking errors relative to the S&P 500 index, and relationships to macroeconomic data and cyclical patterns.

On the basis of this evidence, we conclude that the performance of the steel index underlying Van Eck’s Market Vectors – Steel Fund is distinguishable to a statistically significant degree from the basic materials indices underlying the iShares Dow Jones US Basic Materials Sector Index Fund and the Materials Select Sector SPDR Fund.  The primary implication of this conclusion is that a basic materials index, by being diversified across a number of industries, obscures the steel industry’s unique performance characteristics.  Therefore, investors wishing to gain or reduce exposure to the steel industry should do so directly with a vehicle such as Van Eck’s Market Vectors – Steel ETF instead of using basic materials ETFs.

January 4, 2007.

Appendix A.  Annual Returns to the Steel,

Basic Materials and S&P 500 Indices

 

       
Year Steel Basic Materials S&P 500
       
1977 1.23% 1.17% -11.50%
1978 28.88% 18.62% 1.06%
1979 41.08% 43.10% 12.31%
1980 57.63% 29.38% 25.77%
1981 7.31% 2.05% -9.73%
1982 -14.00% 16.85% 14.76%
1983 45.09% 40.98% 17.27%
1984 -25.06% -2.47% 1.40%
1985 13.30% 34.51% 26.33%
1986 -16.30% 19.81% 14.62%
1987 67.28% 37.36% 2.03%
1988 27.31% 28.54% 12.40%
1989 14.63% 22.69% 27.25%
1990 -10.50% -9.45% -6.56%
1991 37.76% 35.38% 26.31%
1992 31.85% 18.68% 4.46%
1993 28.23% 19.68% 7.06%
1994 -1.64% 8.00% -1.54%
1995 0.60% 16.23% 34.11%
1996 -3.71% 16.18% 20.26%
1997 1.12% 11.21% 31.01%
1998 -8.72% -2.40% 26.67%
1999 11.42% 17.89% 19.53%
2000 -35.04% -6.03% -10.14%
2001 23.13% 17.05% -13.04%
2002 -23.24% -5.01% -23.37%
2003 38.51% 39.71% 26.38%
2004 62.97% 22.18% 8.99%
2005 30.67% 7.48% 3.00%
2006* 25.82% 11.61% 4.45%

 

Source: QED International Associates, Inc.

* Data through August 2006

Appendix B. ETFs and Indices Discussed in this Study

  

Exchange-traded Funds Ticker
iShares Dow Jones US Basic Materials Sector Index Fund IYM
Market Vectors – Steel ETF SLX
Materials Select Sector SPDR Fund XLB
PowerShares Dynamic Basic Materials Sector Portfolio PYZ
PowerShares FTSE RAFI Basic Materials Sector Portfolio PRFM
streetTracks SPDR Metals and Mining XME
Vanguard Materials ETF VAW
Source: QED International Associates, Inc
Sector/Industry Indices Ticker
Amex Steel Index STEEL
Dow Jones US Basic Materials Index DJUSBM
Dow Jones US Steel Index DJUSST
S&P Materials Index IXB
Source: QED International Associates, Inc

  About QED International Associates, Inc (the firm was shut down just before the Lehman Brothers shut down in 2008).

Founded by Herbert Blank in 1997, QED International Associates, Inc. (QEDI) is a network of experienced quantitative investment professionals, who provide consulting services to the global investment community.

QEDI draws on its collective expertise to compose research studies and papers, development investment products, provide marketing advice, and design conference programs.  The QEDI focus includes asset allocation, exchange-traded funds, indexes, and risk management.  Recognized as a pioneer in ETF development, QEDI has played a key role in launching more than fifty ETFs traded across the globe.

About the Authors

  1. Michael Carty is Special Consultant to QEDI and is a recognized expert on exchange-traded funds and their strategic application, speaking frequently at major industry conferences about exchange-traded funds as lifetime financial planning tools and optimal ETF portfolio strategies. He has authored several articles on designing, understanding, and creating ETF investment programs, as well as developing and evaluating indexes for potential use as ETFs. He is also a principal of New Millennium Advisors, an investment advisory firm. Prior to that, he was Director of Closed-end Funds Research and Strategy at Prudential Securities, researching CEFs and evaluating potential IPOs. His academic background includes a Bachelor of Science degree in Industrial Engineering from the New Jersey Institute of Technology and a Master’s degree in Business Administration from Columbia University, where he also pursued doctoral studies

 

Edward Matluck, Ph.D. is Chief Executive Officer of QEDI in addition to serving as President of Hedgemetrics.  His work includes quantitative investing techniques, product development, and portfolio risk control modeling. He has 20 years experience in creating, developing, and marketing quantitative investment products and tools. Ed has significant experience in developing international and domestic equity indexes and creating index-based synthetic investment vehicles. Other specialties include economic forecasting and securities analysis.  Prominent firms in Ed’s career history include: APT, Inc.; DRI; Mosley Securities; Chase Manhattan: and Zacks Investment Research. His Ph.D. in Economics and Finance and a strong background in financial analysis and product development

Andrea Psoras, Senior Vice President for QEDI, is an established financial institutions and financial sector analyst, who has worked as an M&A (combinations, divestitures and related, private equity, “recaps”-bailouts engagements) investment banker on the execution side as well as an analyst on the counter-party credit risk side covering North American based financial institutions while consulting for one of the world’s largest banks.  Skilled in a variety of analytical disciplines-strengths, she is well informed (and on a number of commercial/industrial sectors) and knowledgeable of domestic as well as global economic and political subjects. Some of her former employers include KPMG, UBS Warburg, and Advest, and is Principal of her own consulting firm, Strategic Advisory. She also serves on 3 committees at the New York Society of Security Analysts and had earned her B.A. from Franklin & Marshall College.

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GMO Opposition September 11, 2012 Psoras to USDA for Public Due Process Comment Period

(also posted here by the USDA as a part of the public due process comment period letters opposing deregulation of herbicides and associated gmo grains – according to each Docket Number http://www.regulations.gov/#!documentDetail;D=APHIS-2010-0103-4699 )

11 September 2012

Via website post:  http Go to http://www.regulations.gov/#!documentDetail;D=APHIS-2012-0046-0001  

Via email: biotechquery@aphis.usda.gov

Biotech Query

United States Department of Agriculture/ Animal and Plant Health Inspection Service (“APHIS”)

Docket No. APHIS-2012-0046

Regulatory Analysis and Development, PPD, APHIS, Station 3A-03.8,

4700 River Road Unit 118,

Riverdale, MD 20737-1238

Cc: Dr. John Turner, Director, Environmental Risk Analysis Programs, Biotechnology Regulatory Services, APHIS, 4700 River Road Unit 147, Riverdale, MD 20737-1236;

(301) 851-3954, email: john.t.turner@aphis.usda.gov

cc: Ms. Cindy Eck, APHIS

(301) 734-0667/cynthia.a.eck@aphis.usda.gov

 

DOCUMENT ORGANIZATION                                                                                         Page   Opening remarks                                                                                                                      1

Petition Item List                                                                                                                      5

Preface                                                                                                                                         5

Physiological damage  in people and animals, pollinating insects                         7

Environmental damage caused by Monsanto GM agri products, herbicides, etc                                                                                                                                                   8

Body of the Discussion of Contentious Issues                                                              9

Deceitful FDA – USDA trials practices yielding flawed test results                     10

Anticompetitive and abusive corporate practices by Monsanto, Dow and biotech cartel of players which are the actual beneficiaries vs. alleged beneficiaries such as the organic farmers, the non gmo farmers, and society which trust and expect a non contaminated food supply that is neutral and benign.                Et al

Dear Sir(s)/Ma’am(s):

I learned only yesterday about the USDA request for comment closing today on the petitions by herbicide and GMO –GE organizations.  Please accept my comment which exists in much of the same form and substance that I had submitted in 27 February 12, to apply as my comment as a concerned citizen who opposes deregulation of, and any sort of taint and DANGER AT ALL in our food supply and in our environment-biosphere, by way of  crops such as the following and associated herbicides(Roundup and 2,4D)  to which they’re tolerant:  Dow such as “ENLIST”, 1) DAS-40278-9 (aka GMO), which has been genetically engineered for increased resistance to broadleaf herbicides in the 1a) phenoxy auxin group (such as the herbicide 2,4-D) and resistance to grass herbicides in the 1b) aryloxyphenoxypropionate acetyl coenzyme A carboxylase inhibitor group (such as quizalofop herbicides  thus, all inclusive in my opposition I label as 2,4D (dioxin and related contaminants) by DOW Agriscience LLC as well as:

[Docket No. APHIS–2012–0046] GENECTIVE SA- Petition for Determination of Nonregulated Status of Maize Genetically Engineered for Herbicide Tolerance;

[Docket No. APHIS–2012–0032] Dow AgroSciences LLC – Petition for Determination of Nonregulated Status of Soybean Genetically Engineered for Herbicide Tolerance; [Docket No. APHIS–2012–0020] Monsanto Co.– Petition for Determination of  Nonregulated Status of Soybean Genetically Engineered for Increased Yield

[Docket No. APHIS–2012–0035] Monsanto Co.– Petition for Determination of Nonregulated Status of Canola Genetically Engineered for Herbicide Tolerance;

[Docket No. APHIS–2012–0031] Pioneer Hi-Bred International, Inc,- Petition for Determination of Nonregulated Status of Canola Genetically Engineered for Herbicide Tolerance;

[Docket No. APHIS–2012–0027] Monsanto Co.- Petition for Determination of Nonregulated Status of Maize Genetically Engineered With Tissue-Selective Glyphosate Tolerance Facilitating the Production of Hybrid Maize Seed;

[Docket No. APHIS–2012–0047] Monsanto Co.- Petition for Determination of Nonregulated Status of Soybean Genetically Engineered for Herbicide Tolerance; [Docket No. APHIS–2012–0025] Okanagan Specialty Fruits, Inc.- Petition for Determination of Nonregulated Status of Apples Genetically Engineered To Resist Browning;

[Docket No. APHIS–2012–0028] BASF Plant Science, LP – Petition for Determination of Nonregulated Status of Soybean Genetically Engineered for Herbicide Tolerance; [Docket No. APHIS–2012–0024] Syngenta Biotechnology, Inc. – Petition, Plant Pest Risk Assessment, and Environmental Assessment for Determination of Nonregulated Status of Corn Genetically Engineered for Insect Resistance;

[Docket No. APHIS–2012–0019] Dow AgroSciences LLC – Petition, Plant Pest Risk Assessment, and Environmental Assessment for Determination of Nonregulated Status of Soybean Genetically Engineered for Herbicide Tolerance;

[Docket No. APHIS–2012–0029] Bayer CropScience LP – Petition, Plant Pest Risk Assessment, and Environmental Assessment for Determination of Nonregulated Status of Soybean Genetically Engineered for Herbicide Tolerance.  Please where throughout the document where I condemn and urge rejection of the Petition by Dow or Monsanto for their use of additional herbicides and their GMO tolerant and terminator grains, substitute the list I provided beginning with

[Docket No. APHIS–2012–0046] and ending with [Docket No. APHIS–2012–0029]

I also urge re-regulation and actually ban-prohibit-cease and desist  ALL GMO.  THE  USDA leaves itself open for mockery, ridicule and Department of Justice legal review or Court system rules against itself related to how it recently de-regulated GMO – Per Mother Jones’ Tom Philpott, “It’s a hoary bureaucratic trick, making a controversial announcement on the Friday afternoon before a long weekend, when most people are daydreaming about what beer to buy on the way home from work, or are checking movie times online. But that’s precisely what the US Department of Agriculture pulled last Friday.

In an innocuous-sounding press release titled “USDA Responds to Regulation Requests Regarding Kentucky Bluegrass,” agency officials announced their decision not to regulate a “Roundup Ready” strain of Kentucky bluegrass—that is, a strain genetically engineered to withstand glyphosate, Monsanto’s widely used herbicide, which we know as Roundup. The maker of the novel grass seed, Scotts Miracle Gro, is now free to sell it far and wide. So you’ll no doubt be seeing Roundup Ready bluegrass blanketing lawns and golf courses near you—and watching anal neighbors and groundskeepers literally dousing the grass in weed killer without fear of harming a single precious blade.

Which is worrisome enough. But even more worrisome is the way this particular product was approved. According to Doug Gurian-Sherman, senior scientist at the Union of Concerned Scientists’ Food and Environment Program, the documents released by the USDA’s Animal and Plant Health Inspection Service (APHIS) along with the announcement portend a major change in how the feds will deal with genetically modified crops.

Notably, given the already-lax regulatory regime governing GMOs (genetically modified organisms, click here for a primer), APHIS seems to be ramping down oversight to the point where it is essentially meaningless. The new regime corresponding with the bluegrass announcement would “drastically weaken USDA’s regulation,” Gurian-Sherman told me. “This is perhaps the most serious change in US regs for [genetically modified] crops for many years.” (Wait, Did the USDA Just Deregulate All New Genetically Modified Crops?, In a surprise move, the agency green-lights Roundup Ready lawn grass—and perhaps much, much more. http://motherjones.com/environment/2011/07/usda-deregulate-roundup-gmo-tom-philpott)

“Not at all surprisingly, weeds are becoming increasingly resistant to Roundup, creating “superweeds” which are “galloping through the Midwest.” So Dow AgroScience created a strain of corn that has been genetically engineered to withstand a different class of herbicides—those containing 2,4-D, a known carcinogen. Dow is now seeking to freely use this 2,4-D-resistant corn. GE modification to create resistance means they will be free to use ever-increasing amounts of the herbicide, with no limits whatsoever. These new herbicide-resistant crops will be planted alongside conventional and organic crops. This increases the potential for cross-contamination, and for the spillover of toxic herbicides into the groundwater and neighboring farms. The manufacturer of this seed will of course reject our use of the term “Agent Orange Ready” seed. But don’t be deceived. 2,4-D was a principal ingredient of Agent Orange—and it is the toxic pesticide that these new seeds are designed to survive. Three million people had health effects and 150,000 were born with birth defects as result of Agent Orange’s use during the Vietnam War. The US Department of Veterans Affairs has a shocking list of the diseases related to Agent Orange exposure, including leukemia, diabetes, Hodgkin’s lymphoma, heart disease, Parkinson’s, and numerous different cancers. ( Do We Want to Spray More Agent Orange on Our Crops? Are We at War with Ourselves (and Our Children)? February 7, 2012  http://www.anh-usa.org/agent-orange-on-our-crops/   )

Even more disturbing, Monsanto and Dow now seem to be in collusion with one another. In its petition, Dow states that the 2,4-D trait in the GE seeds will be stacked with Monsanto’s Roundup Ready trait so that the seeds are resistant to multiple herbicide tolerances. Soon we’ll be eating food with a whole cocktail of different herbicide traits cooked into the seed—all so they can be sprayed with chemicals that are more toxic than ever before! The real solution here is to stop using GE seeds altogether.  Why (Do We Want to Spray More Agent Orange on Our Crops? Are We at War with Ourselves (and Our Children)? February 7, 2012  http://www.anh-usa.org/agent-orange-on-our-crops/   )

And, apparently farmers, scientists and academics are finding that  “GM Crops Facing Meltdown in the USA” because of herbicide resistance and the flaws generally of GMO. Major crops genetically modified for just two traits – herbicide tolerance and insect resistance – are ravaged by super weeds and secondary pests in the heartland of GMOs as farmers fight a losing battle with more of the same; a fundamental shift to organic farming practices may be the only salvation.  HT crops encouraged the use of herbicides, resulting in herbicide-resistant weeds that demand yet more herbicides. But the increasing use of deadly herbicide and herbicide mixtures has failed to stall the advance of the palmer super weed in HT crops. At the same time, secondary pests such as the tarnished plant bug, against which Bt toxin is powerless, became the single most damaging insect for US cotton.  (Dr. Mae-Wan Ho ISIS Report 01/02/10  http://www.i-sis.org.uk/GMCropsFacingMeltdown.php)

Monster plants that can’t be killed. It is the Day of the Triffidsnot the genetically modified plants themselves as alluded to in John Wyndham’s novel – but “super weeds that can’t be killed” [2], created by the planting of genetically modified HT crops, as seen on ABC TV news. The scene is set at harvest time in Arkansas October 2009. Grim-faced farmers and scientists speak from fields infested with giant pigweed plants that can withstand as much glyphosate herbicide as you can afford to douse on them. One farmer spent US$0.5 million in three months trying to clear the monster weeds in vain; they stop combine harvesters and break hand tools. Already, an estimated one million acres of soybean and cotton crops in Arkansas have become infested.  (Dr. Mae-Wan Ho ISIS Report 01/02/10  http://www.i-sis.org.uk/GMCropsFacingMeltdown.php)

“In effect, given this cocktail below, we’re dealing with “Agent Orange” Ingredient to be Used in GMO Crops

Dow’s new GM product, dubbed “Enlist,” is a three-gene, herbicide-tolerant soybean that has been engineered to be resistant to glyphosate, the active ingredient in Monsanto’s popular Roundup herbicide, along with glufosinate and 2,4-D. The company expects to earn $1.5 billion in additional profit in 2013 by selling these triple herbicide-resistant seeds. As noted by the U.S. Department of Veteran Affairs“The two active ingredients in the Agent Orange herbicide combination were equal amounts of 2,4-dichlorophenoxyacetic acid (2,4-D) and 2,4,5-trichlorophenoxyacetic acid (2,4,5-T), which contained traces of 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD).” 

Ironically, while Dow’s new crops would seriously escalate the use of 2,4-D, Monsanto is currently facing a class-action lawsuit involving the other Agent Orange ingredient, 2,4,5-T. The suit alleges that homes and schools near one of its 2,4,5-T chemical plants are now contaminated with cancer-causing dioxin, a byproduct of the manufacturing process. This should be a wake-up call to those considering widespread application of any toxic Agent Orange ingredient.  (Hidden “Agent Orange” Chemical They Want to Sneak into Your Food Posted By Dr. Mercola | February 12 2012 | 199,114 views http://articles.mercola.com/sites/articles/archive/2012/02/12/dow-agrosciences-developed-new-genetically-modified-crops.aspx )

  • I also oppose this “Arm’s Race in herbicides and GMO alleged, but impossible to defeat the problems, unless those problems were planned across US land under agriculture. That speaks of other problems and as I have observed, none of this sort of herbicide and GMO abuse is happening or permitted in Germany and generally in Europe.
  • Dow’s “Agent Orange” corn will trigger a large increase in 2,4-D use–and our exposure to this toxic herbicide–yet USDA has not assessed how much, nor analyzed the serious harm to human health, the environment, or neighboring farms. This GE corn will foster rapid evolution of resistant weeds that require more toxic pesticides to kill, followed by more resistance and more pesticides–a chemical arms race in which the only winners are pesticide (aka biotechnology) firms.
  • 2,4-D corn is only the first of many new herbicide-resistance crops being developed by the biotechnology industry to usher in a new era of increased chemical use that represents a very significant opportunity for Dow, Monsanto, DuPont, Bayer, and Syngenta. These “biotechnology” companies are actually pesticide firms that have acquired a large portion of the world’s seed supply, and they use biotechnology to create synergies between their seed and pesticide divisions. In short, biotechnology = pesticide + seeds. One indication of this is that nearly two-thirds of GE crops pending approval by our USDA (13 of 20) are herbicide-resistant ” Agent Orange” Corn: Biotech Only Winner in Chemical Arms Race as Herbicide Resistant Crops Fail Andrew Kimbrell Executive Director of the Center for Food Safety, 22 Feb 12, http://www.huffingtonpost.com/andrew-kimbrell/agent-orange-corn-biotech_b_1291295.html

Included also in this my opposition to glyphosate and associated class of herbicides (ie, Roundup) in our food supply and associated GMO by both Dow and Monsanto respectively that are tolerant to those harmful herbicides and harmful to the earth, the biosphere/environment, our food animals and mankind.  Sane people want clean food, clean environment and clean water. GMO and associated terrible herbicides and pesticides are contrary in every way to the aforementioned.

Thank your for including my comment as a factor in your decision with regard to opposing 2,4D and associated dioxin contaminants for any sort of use in the US, and any sort of GMO in the US ah, demanding it and associated GMO be utterly banned completely from the US food supply at any level or at any point. I urge you to follow this link on at least 1 compelling study for landmark ruling, the NZ Commerce Commission tests done by  Dr. Jack Heinemann where people were complaining about the lack of labeling on food which had GMO ingredients of any sort. “Animals Raised on Genetically Engineered Feed Are Different” GM Watch, Jan 10, 2010 1. A LANDMARK RULING NZ Commerce Commission: animals fed on GM components ARE different Comment by GM-Free Cymru http://www.gmfreecymru.org/documents/landmark.html). http://www.comcom.govt.nz/media-releases/detail/2009/inghamswarnedovergmfreechickenclai/

I am supportive to see the better prospects for the Plaintiff OSGATA rather than corporate abuse against that association by the defendant Monsanto in that lawsuit to which I think Dow should be attached.  I have encouraged that lawsuit to proceed against Monsanto, among other things and oppose the use of the terrible Herbicides and insecticides and the GMO.

In Europe these are not used, nor GMO permitted generally in its food supply and their efforts by their agriculture to resist and oppose using our toxic cocktail of herbicides, pesticides and GMO has their farms, farmers, and people more healthy, better land and quality of life, and VASTLY BETTER QUALITY FOOD.

It’s sad and despicable that our food is now a hazard to one’s health, those of the animals in our food supply, and the herbicides and GMO are a hazard to nature and our environment here in the US, as if it’s corporate war against nature, man and our food in the US, but not in Europe especially Germany. BASF may not sell or do GMO over there and as a result GMO and associated contaminants like glyphosate and dioxin herbicides that had been used or proposed to be used here in the US be utterly banned, ceased & desisted, and prohibited.

My concerns are found following and the document’s organization you will find below.  Thank you again for your attention to my concerns on behalf of opposing Dow’s herbicides, its GMO and especially GMO that resists DOW’s and Monsanto’s herbicides and also note my support for  Plaintiff OSGATA against Monsanto. This plaintiff class also has been harmed by DOW, and also should have attached DOW to the Monsanto lawsuit as I said above.

Please consider my comment as a Friend of the OSGATA plaintiffs suing Monsanto in 2nd District Federal Court in Southern Manhattan.  Please Rule against and oppose 2,4D (dioxin and related contaminants) use in the US and Dow being able to vend this anywhere. 

Please Rule against any sort of GMO that is resistant to 2,4D  and GMO resistant to ANY OTHER HERBCIDE including glyphosate, ie, Roundup by Monsanto. Also note I have requested 2nd District Federal Court to over-rule Monsanto’s demand to have the OSGATA case dismissed against it, when in reality Monsanto’s corporate charter (and perhaps Dow’s) should be revoked and its business cease and desisted and required to pay reparation payments to farmers, society harmed by Round-up, Agent Orange and 2,4D (1a) phenoxy auxin group (such as the herbicide 2,4-D) and resistance to grass herbicides in the 1b) aryloxyphenoxypropionate acetyl coenzyme A carboxylase inhibitor group (such as quizalofop herbicides), and GMO including DAS 40278-9 and that commercial and cultural warfare against mankind and the environment.

Notice it’s generally not permitted in Europe and will continue to be rejected going forward based in part on the superior quality, independent research of its agri/bio scientists. Notice it’s not permitted to engage in Fraud in regulatory trains in Europe nor for its abuse and shedding regulator investigation for employee death by dioxin, as in Monsanto’s case.

Please excuse this is a little aggressive and not really the current matter before you in your court however when practicable, I urge ‘CONVICTING’ Dow and Monsanto #GUILTY#!  in its FULL COURT PRESS AGAINST MANKIND  AND NATURE as it is ENGAGING  SLOW  GENOCIDE against mankind and the environment

Respectfully,

Andrea Psoras

NY, NY 10026

(212) 666 2569

http://www.linkedin.com/in/andreapsorashttp://www.bankinnovation.net/profile/AndreaPsorashttp://www.bankinnovation.net/profile/AndreaPsoras

Petition Item List

I URGE YOU TO – AND A NUMBER OF YOU TO WHOM I ADDRESS THIS ‘PETITION’:

  1. Punish all producers of GMO and the herbicides producers which produce GMO for their environmental hazardous behavior as well as Monsanto for the same; ruling against the use of 2,4-D (and other herbicide) tolerant GMO grains and ruling against ALL GMO GRAINS, as well as those associated herbicides.
  2. Sanction Monsanto for engaging in Fraud against the USDA when it presented its trial materials for the GMO, Bt products, most recently Alfalfa mixing the trial materials while also manipulating the trial comparisons of rats which at GMO rather than a Control group of Rats which ate no GMO while also presenting more robust tests on more rodents over longer periods of time to expose the transfer of genetic harm across proteins which transfers down the generations for increasing still birth and sterility in the test rats, while also failing to respect and acknowledge the transfer of genetic engineering across protein and other physiological/anatomical materials from the sterile seeds in to the livestock fed it and now harmful and damage in the people.

Rather than the EPA  and USDA continuing to disgrace and defile themselves with these repugnant scandalous companies, sanction Monsanto and also DOW of its dioxin abuses and for Monsanto’s environmental disaster and conspiracy to obstruct justice over the period from 1990 -1994 and discussed in the Abuse section (see EPA INVESTIGATES MONSANTO, Reported by RACHEL’S HAZARDOUS WASTE NEWS #400 July 28, 1994,  http://www.ejnet.org/rachel/rhwn400.htm )

3. Rule in favor of Organic Seed Growers Trade Association, aka “OSGATA”, organic farmers, and other plaintiffs against Dow’s and Monsanto’s interests to override the interests for ‘plaintiff’s OSGATA et al like the NRDC for ban on 2.4D and dioxins of every sort in every form that by way of man finds its way into the food supply and the environment.

4. By Ruling against Dow and Monsanto, you’re thwarting anti-social, corporate abusers Monsanto in court to litigate it against any further abuse and monopolistic practices against any and all organic and non-GMO farmers and agricultural commerce by small and family owned farms and agricultural cooperatives growing any and all crops, seeds. I urge attaching Dow to the defendant as a defendant.

5. Require labeling of all food in any form to people, animals and commercial or organizational enterprises that have any and all Dow and Monsanto GMO of any and every sort in any way at any point in the food chain again from barn or lab to manger or dinner table.

6. Cease and desist all corporate or private production and sale or buying of GMO of every, any and all sorts by Monsanto, Dow or otherwise by any and all other perpetrators including also BASF and associated herbicides and pesticides.

7. BAN COMPLETELY IN ANY WAY FROM THE FOOD SUPPLY AT ANY TIME AND AT ANY LEVEL OR FORM – GMO IN ANY FORM AT ALL IN ANY WAY – AND REQUIRE UNWIND-CLEANUP OF ALL SUCH CONTAMINTION IN ANIMALS, THE ENVIROMENT INCLUDING POLLINATORS AND WATER SUPPLY

8. Cease and desist use of all herbicides especially Monsanto’s Roundup and Dow’s 2,4D and its related herbicides, and pesticides,

9. Cease and Desist all further GMO of any and every sort as well as cease and desist all cloning of any and all creation already on the face of the earth and/or in the water or air.

10. http://www.regulations.gov/#!submitComment;D=APHIS-2010-0103-0001 opposition against Dow 2,4D class and Monsanto glyphosate resistant plants and seeds, Roundup resistant plants and seeds and any and all other seeds genetically modified in any way that produce their own insecticides and/or resist herbicide destruction other than for academic or research analysis.

Preface

Over the past few years, little has aroused my deep concern because in a way, I have seen it ‘all’, as a bank analyst who endured a great deal of retaliation and isolation as a whistle blower at the beginning and during the Financial sector’s Enronesque heist that continues to funnel trillions of dollars out of the financial system into the hands of the largest institutional investors, the very wealthy, and the largest global corporate as well as our largest financial institutions which are not ‘profitable’ without their parasitic agency self dealing business of Over the Counter derivatives contracting.

Until a friend had emailed me about the corporate abuse of Dow and Monsanto looking to get their GMO food into the people food supply and use of Dow 2,4D class and associated herbicides (dioxin)  and pesticides, I was only beginning to experience the problems of occasionally eating GMO and herbicide: glyphosate and dioxin polluted food, pork, meat, and dairy, thinking my health problems were related to dairy/livestock pharma I virtually always avoid by avoiding contaminated livestock and dairy however over the holidays strayed with milk chocolate.

Although I am busy with FASB comments and muck-raking of sorts publicly condemning the ISDA financial cartel members, or the German dominated G20 (Transatlantic Union) Agreements, after reading Bob’s commercial-investor newsletter in which he mentions the Agent Orange component 2,4D and Roundup resistant crops ie, GMO, I began to research this issue Bob mentioned. What I found based on what he mentioned about Dow and Monsanto takes on genocidal proportions like using Agent Orange components and crops that are resistant to these toxic substances rather than using responsible land husbandry such as crop rotation. I remembered Agent Orange; I’d grown up during the Vietnam War era. Even if a component of Agent Orange, dioxins are serious contaminants. These are among the most toxic contaminants in our society. The EPA considers Dioxin an environmental contaminant like PCB when a Category III harbor sludge, a serious bio-accumulant (concentration increases up the ‘food chain’) and known health hazard.

As recently as last week 24  Feb 2012, the Natural Resources Defense Council filed in federal court against the US EPA to ban use of dioxin: NRDC Seeks Ban of 2,4-D Herbicide (http://legalnewsgroup.com /2012/02/24/nrdc-seeks -ban-of-24-d-herbicide/6126The EPA itself, admits that “according to a Sept 1994 EPA report, not only does there appear to be NO “safe” level of exposure to dioxin, but levels of dioxin and dioxin-like chemicals have been found in the general US population that are “at or near levels associated with adverse health effects.That draft report released for public comment by the US Environmental Protection Agency clearly describes dioxin as a serious public health threat.  Dioxins and furans are some of the most toxic chemicals known to science; the public health impact of dioxin may rival the impact that DDT had on public health in the 1960’s.”  (http://www.ejnet.org/dioxin/

The EPA document also acknowledges that the newly appreciated hazards of dioxin go far beyond the risk of cancer… the expected non-cancer effects include:

** disruption of endocrine hormone systems, especially those related to sexual development;

** disruption of critical stages of embryonic development, for example of the nervous system;

** damage to the developing immune system, leading to increased susceptibility to infectious diseases. These are intergenerational defects, they are imprinted for life on the developing fetus by the effect of dioxin on the mother and sometimes the father. ( RACHEL’S ENVIRONMENT & HEALTH WEEKLY #405, (formerly RACHEL’s HAZARDOUS WASTE NEWS)  September 1, 1994 Turning point for the Chemical Industry, http://www.ejnet.org/rachel/rehw405.htm )

We’ve known about this since the Vietnam War when not only the soldiers experienced serious health problems from the Agent Orange and Dioxins, but also their dogs were sick and died of for example testicular cancers , as are dogs today sick and dying which role around on the lawns where their masters used Roundup and 2,4-D in some form produced by Dow or Monsanto. (“Turning point for the Chemical Industry” ,RACHEL’S ENVIRONMENT & HEALTH WEEKLY #405, (formerly RACHEL’s HAZARDOUS WASTE NEWS)  September 1, 1994 http://www.ejnet.org/rachel/rehw405.htm; and  “The Dogs of War”, on dioxins – RACHEL’S ENVIRONMENT & HEALTH WEEKLY #436 —April 6, 1995- http://www.ejnet.org/rachel/rehw436.htm )

For example, the 24 Feb 2012 NRDC lawsuit filed in the U.S. Court of Appeals for the District of Columbia  asks the court to intervene in NRDC’s 2008 petition that the EPA ban use  of the chemical that has been used in the United States since the 1940s  The complaint asks the appeals court to compel the EPA to cancel all 2,4-D registrations and revoke all regulatory tolerances   for the chemical within 45 days of the court’s decision.  The compound is one of two ingredients in the neurotoxic herbicide and defoliant Agent Orange, which the U.S. military used in the Vietnam War.

About 46 million pounds of 2,4-D are used in the United States every year, NRDC said. Classified by the EPA as a hazardous air pollutant, exposure to 2,4-D can cause damage to the nervous system, liver and kidneys.”( http://www.jdsupra.com/post/documentViewer.aspx?fid=3eaaa845-ba7a-448a-8cd8-23bc2acdff0e )

I suspect this is why  (Quality Pork Processors Inc. in Austin, Minnesota) employees who worked on the line that blasted hog brains out of the hog skulls for Hormel’s sausage production became ill with neural and motor problems from the aerosole of brain matter of hogs fed GMO and dioxin 2,4D herbicide sprayed grain (AMP).  Nerve damage mentioned from Dioxins would have likewise effects found in the Hormel employees as if they themselves had eaten that dioxin sprayed GMO grain rather than breathing in the aerosole’d hog brain matter. “His legs felt dead, paralyzed…Every test revealed neurological abnormalities, most importantly a severe spinal-cord inflammation, apparently caused by an autoimmune response.”( http://motherjones.com/politics/2011/06/hormel-spam-pig-brains-disease )

As a result since the existence of the EPA, there’s been a body of knowledge about 2,4-D and related dioxin contaminants by corporate and other parties used while corporate and trade association interests which use these as herbicides have taken aggressive steps to attempt to thwart EPA official public disclosure about cancer from dioxin. (http://www.pesticideinfo.org/Detail_Chemical.jsp?Rec_Id=PC33613#Toxicity http://www.wsws.org/articles/1999/jun1999/diox-j01.shtml   US study establishes link between dioxin and cancer By Perla Astudillo 1 June 1999 )

Dr Mercola (note follows) recently posted to his readers that biotech giant Monsanto and Dow Agrisciences have created some of the most dangerous products on the planet, including Agent Orange, dioxin, recombinant bovine growth hormone (rBGH)… and genetically modified seeds. The latter is one of the most pressing concerns because GM crops are now a mainstay of American agriculture which Dow wants similarly to abuse society with its GMO(1).

Mercola: “Ninety percent or more of all US-grown corn, soybeans, canola, and sugar beets are genetically modified versions, which means that virtually all processed food contains at least one or more genetically modified ingredients.  GM foods are, from what I perceive, one of the most significant threats that we have against the very sustainability of the human race. Why? In a nutshell, these toxins are being linked to a growing repertoire of assaults against human health and the environment — and they are already migrating into fetal blood, which means future generations are now at risk.” (1)Banned in Germany, But You’re Probably Still Eating It  Posted By Dr. Mercola | January 31 2012 “Monsanto Named the Worst Company of 2011”)

Deeper digging about the GMO and herbicide/pesticide problems has me concluding that Monsanto and Dow are mad, genocidal, socio-pathic scientists run amok on society.

My next judgment was and is that we NEVER SHOULD HAVE SANCTUARIED NAZI SCIENTISTS AFTER THE MILITARY WAR OF WW2, AND HAVING GIVEN THEM EMPLOYMENT AT DUPONT INCLUDING MONSANTO, DOW and other industrial companies, and institutions such as academic, medical/hospital and think tanks in our society. Now two generations after thinking we’re in the plowshares time, apparently we’re not by way of this war of some bizarro kind that is worse than any nightmare from which one can wake-up AND IS more than likely NOT HAPPENING IN GERMANY, NOR VIRTUALLY ANYWHERE ELSE IN the EU which had had tight regulations.

BASF is not permitted to sell its GMO science and associated products in Germany, however sells those outside Germany. Ask yourself WHY?  The German chemical firm confirmed Monday it plans to move the headquarters of BASF Plant Science from Limburgerhof, Germany, to Raleigh, North Carolina, and to halt all development and commercialization work on products aimed solely at the European market.  “We are convinced that plant biotechnology is a key technology for the 21st century,” BASF board member Stefan Marcinowski said in a release. “However, there is still a lack of acceptance for this technology in many parts of Europe — from the majority of consumers, farmers and politicians.  “BASF to focus plant biotech work on Americas. German firm to halt all Europe-focused projects. (Jan 19, 2012 12:01 AM http://www.grainews.ca/news/basf-to-focus-plant-biotech-work-on-americas/1000833917/ )

Given the damage about which I’m reading in the environment, the pollinating insects, the water and the plants/crops, livestock/poultry/fish i.e. Thanks to the Dairy trade association for the percent of dioxin the EPA estimates is from our food  which the IDFA says the EPA estimates is the source for estimated 95% of dioxins in the livestock and from the herbicide origins (AMP) bio-accumulated up the food chain, we by our ignorance have facilitated those warring scientists’ destruction against us, our trust and typically what our people need while on this earth, and needing to have to eat clean food and drink clean water.

This need apparently has been expropriated or let’s say served as form by which these scientists and their employers (and perhaps other off-the-radar-screen parties) that have decided to extract a feudal toll – aside from the ISDA financial cartel – about as bad as any ‘free’ rider that I have every seen: for their profits, control and power, you’ve risked your life if you eat their food and what they’ve polluted in the environment and those participants in nature like the pollinating insects, the aquatic animals, the water supply, like the sun there to do good for mankind, but now hijacked and in its way, like radio-active or toxicity more robust and harmful, cancer producing than had been acknowledged in the developed world.

For example I site the Dioxin exposure and cancer risk in the Seveso (http://en.wikipedia.org/wiki/Seveso_disaster )  Women’s Health Study found at Environ Health Perspect. 2011 Dec;119(12):1700-5.  Epub 2011 Aug 2 http://www.ncbi.nlm.nih.gov/pubmed/21810551 .  A study and health tracking of people was monitored over decades after a dioxin spill in Seveso, Italy. After 3 decades a robust number of women were found to have Breast Cancer.

We trusted scientists and the regulatory framework to keep the line drawn between corporate interests for profit and a clean environment, clean food and responsible regulators who themselves know where these lines are, rather than allowing themselves to be hijacked by lawless self interests, expedience and other powers that perhaps are beyond their control. I suggest not, however, because that’s why they’re in the jobs, roles and appointments that they are, while those deemed as ‘consumers’ and presumed to be not qualified to be in the roles of regulators, are not. (EPA reassessment of Dioxin –http://www.ejnet.org/dioxin/#reassessment )

Because controlling dioxin is expensive, since 1985 industry has maintained relentless pressure on government to relax dioxin standards. Some animal studies showed dioxin to be an extremely potent toxin in some species; other studies showed it to be weaker in other species. EPA established a Workgroup to review the data and conclusions of its 1985 assessment.( RACHEL’S ENVIRONMENT & HEALTH WEEKLY #405, (formerly RACHEL’s HAZARDOUS WASTE NEWS)  September 1, 1994 Turning point for the Chemical Industry, http://www.ejnet.org/rachel/rehw405.htm ]

Meanwhile, trade association interests have been attempting to thwart EPA public reports on dioxin contamination such as the dairy association and chemical companies like Dow and Monsanto; November 2, 2011 IDFA Requests Agency Coordination to Fix Flawed Dioxin Assessment  (http://www.idfa.org/key-issues/details/6584/ ) and IDFA, Others Urge White House to Intervene on Dioxin Reassessment ( http://www.idfa.org/key-issues/category/food-safety–defense/details/6721/ ); December 20, 2011: American Chemistry Council (ACC) requests EPA delay the release of the dioxin reassessment ( http://www.americanchemistry.com/Policy/Regulatory-Reform/Cal-Dooley-Letter-to-Administrator-Jackson-Fix-Dioxin-Reassessment.pdf )

Dow and Monsanto seem to be hankering for that sort of ‘crisis’ situation and associated damage, unless thwarted by hands more powerful than its own social genocide drives and suicidal behaviors.

As a bank analyst and an expert of sorts on the financial sector, however a long time ago the blush was off that rose and knowing what trade associations’ and sectors’ lobbying, and those campaign contributions can buy and has bought in Washington and elsewhere. As a result I was not ignorant about the facile – lack of guard – and thus with associated co-optability – in those responsible for making law, regulating and administrating that regulatory framework, whether it is the intelligence apparatus, the financial regulators, the White House or elected public servants at the federal and state levels, and even the courts.

Although I am not isolating and blaming any single party or regulator, I am shocked however at the swift decay of the environment, the quality of food in the US while other countries in Europe, Australia have held the line generally against this class of glyphosate and 2,4-D herbicides, pesticides and GMO and Genetic engineering at all of any sort, at any level of the food supply and its production from barn or in the case of the defendants – the lab – to the livestock feeding trough or dinner table. The decay I mention doesn’t seem to be unconnected with how the regulatory and legislative environment in the US seems to think it is fraudster Monsanto’s and Dow’s best friend, while those corporate malefactors are attempting and arguably perpetrating mass -slow- annihilation of mankind and the environment in the US, while Europe and its people have been able to remain largely unharmed.

My father reminded me of Rachel Carson and “Silent Spring”. Apparently the US EPA and the shock of environmental/ biosphere contamination didn’t stop the USDA and/or FDA and/or EPA from again giving a pass to corporate criminals of the most despicable sort; Enronesque malefactors in the Food and Agricultural and Environmental sectors.

Current dioxin regulations are based on old and outdated science,” says Mike Schade, a campaign coordinator at the Center for Health and Environmental Justice.  “Once EPA’s health report is finalized, agencies can develop new regulations that are responsive to dioxin’s toxicity.” Dioxins get spewed into the air, where they eventually settle into soil, water, and plants. Animals ingest dioxins as they graze, and the chemicals build up in the creatures’ fatty tissues.   t

  • Dow Chemical and the American Chemistry Council (ACC), a chemical and plastics industry group, are leading the charge against the EPA’s dioxin study. In December, the ACC requested[PDF] that the EPA delay the release of its long-awaited study.
  • Major food producers are also pressuring the EPA to turn a blind eye to dioxins, citing concerns that consumers will unnecessarily fear their food. The Food Industry Dioxin Working Group [PDF]—which is made up of industry groups like the International Dairy Foods Association, American Frozen Food Institute, and the National Chicken Council—recently wrote to the White House, urging officials to block the EPA’s study. “Since the agency contends the primary route of human exposure to dioxin is through food, this could not only mislead and frighten consumers about the safety of their diets, but could have a significant negative economic impact on all U.S. food producers,” the group wrote.
  • “Dow and the chemical industry are following the tobacco industry’s strategies to keep information from the public and delay release of the report,” says Schade. “In recent months, the chemical industry and Big Ag have been working behind closed doors to hide and distort the truth about the dangers of dioxin. EPA nor the USDA shouldn’t cave in to chemical industry dollars and interests over public health.” Why the U.S. Government Won’t Protect Us From Toxic Chemicals In Our Food Supply Sarah Parsons February 7, 2012 11:00 am PST http://www.good.is/post/why-the-u-s-government-won-t-protect-us-from-toxic-chemicals-in-our-food-supply/

Given the fact that dioxins are about as common as salt on the American dinner table, you’d think the EPA—whose sole purpose is to protect public health and the environment—would prioritize studying dioxins’ safe limits. Why the years of delay? As Sass explains, “the delay has been political, not scientific.” The EPA faces major pressure from the chemical and food industries not to release its dioxin study—not now, and, if lobbyists get their way, not ever.  Why the U.S. Government Won’t Protect Us From Toxic Chemicals In Our Food Supply, Sarah Parsons food columnis Lifestyle  February 7, 2012 • 11:00 am PST  http://www.good.is/post/why-the-u-s-government-won-t-protect-us-from-toxic-chemicals-in-our-food-supply/

How are we exposed to dioxin? The major sources of dioxin are in our diet. Since dioxin is fat-soluble, it bioaccumulates, climbing up the food chain. Dioxins & Furans: The Most Toxic Chemicals Known to Science  http://www.ejnet.org/dioxin/

According to May 2001 “INTAKE OF DIOXINS AND RELATED COMPOUNDS FROM FOOD IN THE U.S. POPULATION”, The efforts of environmental agencies to set and enforce regulations to decrease dioxin formation and spread into the environment should further reduce food contamination. Generally, however, government regulations and enforcement of standards for dioxin levels in food appear not to be in effect in the United States. Given both the uncertainty about the long-term health effects of various levels of exposure to dioxin-like chemicals and the progress apparently made so far in some European countries in reducing levels of exposure, it seems reasonable to continue periodic surveillance of populations’ exposures to dioxins through the food supply (INTAKE OF DIOXINS AND RELATED COMPOUNDS FROM FOOD IN THE U.S. POPULATION Schecter, Arnold, et al. Journal of Toxicology and Environmental Health, Part A, 63:1–18, 2001 Copyright© 2001 Taylor & Francis)

“. The new attempt to downgrade the dioxin hazard, like all the earlier ones, has failed. But in failing, it has not simply confirmed the important but narrow result of the 1985 risk assessment that dioxin is an enormously potent carcinogen. It has also greatly expanded the range and biological impact of dioxin’s effects, at levels of exposure already experienced by the entire U.S. population.

… Apparently Americans are sufficiently exposed to some very general source of dioxin to put us all well above the “acceptable” cancer risk of one in a million, and within range of its numerous other harmful effects. That source, according to the forthcoming EPA report, is chiefly food [meat and dairy products]….

Stated more simply, the situation is this: The general spread of dioxin and dioxin-like chemicals in the U.S. environment has already exposed the entire population to levels of these extremely toxic substances that are expected to cause a number of serious health effects. These include an average risk of cancer of 100 or more per million in the entire U.S. population –100 times greater than the risk standard that has triggered EPA remedial action, for example at Times Beach near St Louis, MO. (RACHEL’S ENVIRONMENT & HEALTH WEEKLY #405, (formerly RACHEL’s HAZARDOUS WASTE NEWS)  September 1, 1994 Turning point for the Chemical Industry, http://www.ejnet.org/rachel/rehw405.htm ])

BODY OF DISCUSSION OF CONTENTIOUS ISSUES AGAINST DOW AND MONSANTO

Physiological damage to people, pollinating insects, lab animals and food supply animals 

Released last week as a deflection against heavy criticism for having delayed its report on Dioxin damage to health and cancer links, the EPA stated, “Most Americans have low-level exposure to dioxins. Non-cancer effects of exposure to large amounts of dioxin include chloracne, developmental and reproductive effects, damage to the immune system, interference with hormones, skin rashes, skin discoloration, excessive body hair, and possibly mild liver damage (1)” and nerve damage although Vietnam War vets have a robust manifestation of cancers. (1) EPA Updates Science Assessment for Dioxins / Air emissions of dioxins have decreased by 90 percent since the 1980s, 02/17/2012.

(http://yosemite.epa.gov/opa/admpress.nsf/d0cf6618525a9efb85257359003fb69d/33bcba60ed25a9b1852579a700604ed7!OpenDocument )

“Scientists have known since the mid-1960s that dioxin is an extremely powerful promoter of cancer in laboratory animals, but industry researchers have recently been claiming that humans somehow are exempt from the dioxin danger. The question of dioxin’s hazard to humans took on real urgency in the early ’80s when 15,000 veterans sued Dow chemical and other producers of Agent Orange (a dioxin-contaminated herbicide widely used to defoliate the jungle in Vietnam from 1962 to 1971); the vets sought money damages for health effects (cancer, defective offspring, and so forth) they said they were experiencing. Lawyers for the Vietnam vets offered documentary evidence that Dow chemists convened a private meeting of their competitors in 1965 to share new information that impurities [dioxins] in the herbicide 2,4,5-T (principal component of Agent Orange) caused severe liver damage in rabbits. According to court records, a chemist at Hercules Powder Company who attended the private Dow meeting in 1965, received a phone call from a Dow executive who “warned him to keep the findings away from the federal government,” according to a reporter for Nature, the British science journal. [2] If this is true, it would not be the first time, nor the last, that money has influenced the outcomes, and the uses, of scientific studies. (see RHWN #171, #173, #175). (RACHEL’S HAZARDOUS WASTE NEWS #219—February 6, 1991. “New Study Links Dioxin to Cancer” http://www.ejnet.org/rachel/rhwn219.htm)

Dow AgriScience’s variety of corn up for USDA approval, DAS-40278-9, is tolerant to ACCase inhibitor herbicides (including quizalofop, which is not registered for use on corn) as well as 2,4-D. The chemical 2,4-Dichlorophenol (2,4-D) once made up half of the herbicide mix known as Agent Orange. Corn with 2,4-D tolerance could be dangerous to eat because a metabolite of 2,4-D is known to cause skin sores, liver damage and sometimes death in animals. 2,4-D is a potential endocrine disruptor and can affect development. Rats exposed to 2,4-D exhibited depressed thyroid hormone levels, which can affect normal metabolism and brain functioning. Studies found that men who applied 2,4-D had lower sperm counts and more sperm abnormalities than those unexposed to the herbicide. Moreover, The chemical treadmill model cannot be continued indefinitely. Weed resistance to these chemicals will continue to abound and the application of more noxious herbicides will increase exponentially. This new corn variety is not only unsafe and inefficient, but it is a completely unsustainable solution to the broader problem of high-input production agriculture and associated environmental pressures. (No Date or Author. “Agent Orange Ready Corn. Food & Water Watch. http://www.foodandwaterwatch.org/food/genetically-engineered-foods/24-d-corn/ )

“A 1986 National Cancer Institute (NCI) study found that famers in Kansas exposed to 2,4-D for 20 or more days per year had a six-fold higher risk of developing non-Hodgkins Lymphoma than non-farmers (note). The risk of cancer was higher for farmers who mixed or applied the pesticide themselves. Another study done in 1990 found a 50% increase in non-Hodgkin’s Lymphoma in farmers who handle 2,4-D (note)  (2,4-D, chemicalWatch Factsheet/BEYOND PESTICIDES-2004, Washington DC, http://www.beyondpesticides.org/gateway/pesticide/24d.htm  )

Carcinogenic effects: 2,4-D fed to rats for 2 years caused an increase in malignant tumors [7]. Female mice given a single injection of 2,4-D developed cancer (reticulum-cell sarcomas) [7]. Another study in rodents shows a low incidence of brain tumors at moderate exposure levels (45 mg/kg/day) over a lifetime [1,7]. However, a number of questions have been raised about the validity of this evidence and thus about the carcinogenic potential of 2,4-D. In humans, a variety of studies give conflicting results. Several studies suggest an association of 2,4-D exposure with cancer. An increased occurrence of non-Hodgkin’s lymphoma was found among a Kansas and Nebraska farm population associated with the spraying of 2,4-D [25,27]. Other studies done in New Zealand, Washington, New York, Australia, and on Vietnam veterans from the U.S. were all negative. There remains considerable controversy about the methods used in the various studies and their results [“Note  28”]. Thus, the carcinogenic status of 2,4-D is not clear. [“Note 28”] U.S. Environmental Protection Agency. Proposed Rules. Fed. Regist. 55: 24116-17, 1990.7-29 http://extoxnet.orst.edu/pips/reflist7.htm  Clearly this is grossly out of date and there is more  recent research that refutes this seeming conundrum.  Agricultural pesticide use and risk of t(14;18)-defined subtypes of non-Hodgkin lymphoma.

A population based, case control study in Nebraska looking at different molecular subtypes of NHL discovered that the risk of t(14;18)-positive NHL subtype is significantly elevated among farmers who used animal insecticides (OR 2.6), crop insecticides (OR 3.0), herbicides (OR 2.9) and fumigants (5.0 OR) and that there was no increased risk of t(14;18)-negative NHL subtype for these pesticides, which may explain some of the inconsistencies in epidemiological study of NHL and pesticide exposure. They also find that the risk increases with longer duration of use. This abstract shows however, that in that era, and perhaps there wasn’t as wide use of the dioxins however other herbicides were more likely over the long term to spur NHL and it also appears that what one may breath also more likely would spur NHL and shown in Table 4 (herbicides) http://www.ncbi.nlm.nih.gov/pmc/articles/PMC1566872/?tool=pubmed. and [Chiu, B., et al. 2006. Blood 108(4):1363-1369] http://www.ncbi.nlm.nih.gov/pubmed/16621961 Blood. 2006 Aug 15;108(4):1363-9. Epub 2006 Apr 18  Chiu BC, Dave BJ, Blair A, Gapstur SM, Zahm SH, Weisenburger DD. Source Department of Preventive Medicine, Feinberg School of Medicine, Northwestern University, Chicago, IL 60611-4402, USA. bchiu@northwestern.edu

“The latest study is not by industry researchers but by Dr. Marilyn Fingerhut of the federal National Institute for Occupational Safety and Health (NIOSH); Fingerhut looked at the health of 5172 workers at 12 chemical plants that manufacture (or formerly manufactured) products contaminated with dioxin such as the herbicides 2,4,5-T, Silvex, Ronnel, Erbon, and pentachlorophenol (which has also been used as a fungicide, algicide, and wood preservative for telephone poles and pilings), and the bacterial cleansing agent, hexachlorophene–until the 1970s, a leading bactericide in hospitals.

Among the entire cohort of 5172 men, the occurrence of all cancers was significantly increased, by 15%; in the high-exposure group of 1520 men, the “all cancers combined” increase was even more pronounced–46%; furthermore “all cancers combined” were increased among workers at nine of the 12 plants studied. Even when cancers of the respiratory tract were omitted in an attempt to eliminate smoking as a possible the cause, “all cancers combined” was increased among the 5172 and even more so among the high-exposure 1520.

Dr. Fingerhut says correctly that her results do not prove that dioxin causes cancer in exposed workers. The workers she studied were exposed to many other chemicals, in addition to dioxin, on the job, and these other chemicals could explain the cancer increases she observed.

Nevertheless, the Fingerhut study makes it ever more difficult for the purveyors of dioxin-creating machines (such as incinerators for solid waste, hazardous waste, or sewage sludge) to claim that their dioxin emissions are negligible or harmless.  Because dioxin accumulates in the food chain, even small amounts can build up to significant levels as time passes (AMP). (see RHWN #171, #173, #175). RACHEL’S HAZARDOUS WASTE NEWS #219—February 6, 1991. “New Study Links Dioxin to Cancer” http://www.ejnet.org/rachel/rhwn219.htm;

Meanwhile, Monsanto has engaged in Fraud and the EPA was investigating it over several years. Monsanto Corporation Criminal Investigation Cover-up of Dioxin Contamination in Products Falsification of Dioxin Health Studies  Citing a UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON D.C. 20460 OFFICE OF SOLID WASTE AND EMERGENCY RESPONSEMEMORANDUM  DATE: November 15, 1990. (Below)

SUBJECT: Criminal Investigation of Monsanto Corporation – Cover-up of Dioxin Contamination in Products – Falsification of Dioxin Health Studies.
FROM: Cate Jenkins, Ph.D., Chemist Regulatory Development Branch (OS 332) Characterization and Assessment Division.
TO: John West, Special Agent in Charge Office of Criminal Investigations Center U.S. Environmental Protection Agency Building 53, Box 25227 (303) 236-5100 Kevin Guarino, Special Agent Office of Criminal Investigations National Enforcement Investigations Center, EPA

As per our meeting yesterday, I am summarizing information available to me supporting allegations of a long pattern of fraud by Monsanto Corporation. The fraud concerns 2,3,7,7-tetrachlorodibenzodi (dioxin) contamination of Monsanto’s dioxin-exposed workers. You indicated that you would contact me regarding the specific documents which would be useful to your investigation. ( http://www.vetshome.com/monsanto_cover_up_agent_orange.htm)

“A new study of Vietnam veterans, conducted by Air Force physicians, links dioxin exposure to increases in cancer, birth defects, psychological damage, liver damage, cardiovascular deterioration, and degeneration of the endocrine system. The new work stops short of saying dioxin exposures CAUSED the observable health damage among dioxin-exposed vets, but it explicitly reverses the conclusions of a 1984 Air Force study which said dioxin exposures had been shown to be harmless.

Cancer : The study found that 4.59% of the Ranch Hands have some kind of cancer, compared to 2.33% of the unexposed group. Thus the overall risk of cancer among the dioxin-exposed group is doubled (risk increased by a factor of 1.97). The greatest risk increase is for skin cancers (where the risk is increased by a factor of 2.6), whereas the risk of “systemic cancers” (non-skin cancers) is increased by a factor of 1.2; in other words, the dioxin-exposed group has a 20% greater chance of getting a non-skin cancer.

Birth Defects : Analyzing for birth defects, the study looked at children born before the Vietnam experience and children born after Vietnam. Prior to Vietnam, the dioxin-exposed group had born 85% as many children with birth defects as the non-exposed group; after Vietnam, the exposed group bore 139% as many children with birth defects. The earlier Air Force study had said birth defects among dioxin-exposed families were limited to “minor skin lesions” but the new study reverses that conclusion; 32 children with severe defects were born to families in the exposed group, vs. 18 in the nonexposed group. The total number of birth defects in the two groups was: 80 with defects out of 917 total births in the exposed group vs. 48 with defects out of 744 total births in the non-exposed group.

Psychological Damage : Psychological testing revealed significant increases in fatigue, anger, anxiety, and isolation among the dioxin-exposed group compared to the non-exposed group.

Liver Functions : The new study looked at nine chemical measures of liver function and in three categories the dioxin-exposed group showed reduced liver functions, compared to the non-exposed group. In addition, among the exposed group, 16 showed enlarged livers, vs. six among the non-exposed group. Furthermore, 13 among the exposed group had a verifiable medical history of liver disorder other than hepatitis, jaundice, or cirrhosis, vs. only two with such histories among the non-exposed group.

Cardiovascular system : Heart disease rates and heart attack rates did not differ among the two groups. However, during physical examination, 10 different heart pulse measurements were taken in the extremities (e.g., the ankle), and statistically significant abnormalities were found in one or more pulses in 12.8% of the exposed group vs. 9.4% of the nonexposed group. Abnormal pulses in the extremities are evidence of blood circulation problems.

Endocrine system : The endocrine system is a body control system composed of a group of glands that maintain a stable internal environment by producing chemical regulatory substances called hormones. Glands that participate in the endocrine system include the pituitary, thyroid, parathyroid and adrenal glands, as well as the pancreas, ovaries and testicles. The new study looked at five chemical measures of endocrine system functions. In three of the five measures, the dioxin-exposed group showed abnormal functioning of the endocrine system, compared to the non-exposed group. Functioning of the endocrine system reduces with age, but the new study showed that, among the dioxin exposed group, functioning of the endocrine system is being reduced much faster than among the non-exposed group.

Thus the new study shows that, in six out of 11 areas of suspected dioxin effects, exposed Vietnam veterans have health problems in greater proportion than the comparison group. (STUDY OF DIOXIN-EXPOSED HUMANS REVEALS CANCER, BIRTH DEFECTS, LIVER AND CARDIOVASCULAR DAMAGE RACHEL’S HAZARDOUS WASTE NEWS #73 —April 18, 1988—)

“2,3,7,8-tetrachlordibenzo-p-doxin (TCDD) would not have been designated as a Group 1 carcinogen by IARC had there not been a change in the criteria used for inclusion in this category. The exposure-response meta-analysis of TCDD and cancer developed by the United States Environmental Protection Agency (USEPA) is seriously compromised by its failure to adequately fit the data. The studies used by the USEPA also likely underestimate TCDD body burdens and may be confounded by smoking and other occupational exposures. Furthermore, the use of a linear dose-response model by the USEPA is scientifically unjustified since the underlying model of TCDD as a human carcinogen is based primarily on its supposed receptor-mediated, non-genotoxic (or promotional) mode of action. Authors suggest that “The long-term accumulation of negative, weak, and inconsistent findings suggests that TCDD eventually will be recognized as not carcinogenic for humans, however bio-accumulation of those who come into frequent contact and/or larger concentrations I suggest to the contrary of the authors’ suggestion. “(Dioxin and cancer: a critical review” . Cole P, Trichopoulos D, Pastides H, Starr T, Mandel JSRegul Toxicol Pharmacol. 2003 Dec;38(3):378-88., Source Department of Epidemiology, School of Public Health, University of Alabama at Birmingham, USA. jsmande@sph.emory.edu http://www.ncbi.nlm.nih.gov/pubmed/14623487 )

Moreover, biotech firms like Dow and Monsanto claim they offer a genetically modified, pest-resistant crop. Pest-resistant in this context actually means the crops are genetically modified to contain their own built-in pesticide. These seeds are ‘tolerant’ to herbicides and are sterile, largely so that the farmer has to again purchase seed or not have seed usable from the previous year’s crop which is monopolistic and an abusive corporate practice of control the seed producer sector.  Moreover, the GMO seeds genetically modified to not replicate, thus for seed to be sterile seems  to be passing on corrupted properties that are producing damage in the ingesting subject(s), regardless of that ‘target’ as well as moving up whatever food chain into which the GMO is introduced.

Moreover, eating a GM plant i.e., from GM seeds, whether you’re a bug or a human, means you’re ingesting toxic pesticides (that are created by the seeds that are engineered to be herbicide resistant). These herbicides include Monsanto’s Roundup and an herbicide pari-pasu, if not a form of Agent Orange which is produced by Dow Chemical.   (2)More information is found at “Everything You HAVE TO KNOW about Dangerous Genetically Modified Foods”  http://www.naturalhealthstrategies.com/dangerous-genetically-modified-foods.html

Dow’s and Monsanto’s GMO products are causing protein corruption that also has been found to cause protein damage in cells that would happen in people who eat GMO products and/or livestock fed GMO products including the vegetarian ‘grains’ and alfalfa.  Damage is proven  to happen in test animals such as rats although Monsanto only tested  rats over a 90 day period rather than a longer time, and also failed to test other mammals whereas other organizations and scientific groups also tested over longer periods of time other mammals and academic studies on pollinating insects are showing patterns of severe damage in those fauna   Findings on Monsanto’s Roundup herbicide also show this product is lethal to frogs and toxic to human placental and embryonic cells. It is used on more than 80 percent of all GM crops planted in the world. (2 Everything You HAVE TO KNOW about Dangerous Genetically Modified Foods”) http://www.naturalhealthstrategies.com/dangerous-genetically-modified-foods.html “ and  http://foodfreedom.wordpress.com/2010/01/01/three-approved-gmos-linked-to-organ-damage/

“When testing for drug or pesticide safety, the standard protocol uses three mammalian species. The subject studies (by Monsanto) only used rats, yet won GMO approval in more than a dozen nations. Tests other than those by Monsanto showed, “Chronic problems are rarely discovered in 90 days; most often such tests run for up to two years. Tests “lasting longer than three months give more chances to reveal metabolic, nervous, immune, hormonal or cancer diseases,” wrote Seralini, et al. in their Doull rebuttal. [See “How Subchronic and Chronic Health Effects can be Neglected for GMOs, Pesticides or Chemicals.” IJBS; 2009; 5(5):438-443. http://www.biolsci.org/v05p0706.htm]

In Bees, “it is certain that the digestive shutdown (found in bees dead in hives) is due to hard material in the digestive tract that compromises the immune system. Circulatory problems would (occur) without doubt. Could it be that humans are going through the same process with the rise of Colon Cancer? As seen below in the comparison of the healthy Bee and the unhealthy bee, it is obvious that the bees that are ingesting GMO pollen are having severe digestive problems, so severe that the disease is terminal.”  (Death of the Bees. Genetically Modified Crops and the Decline of Bee Colonies in North America by Brit Amos – Global Research, 9Aug11, March 2008 article http://globalresearch.ca/index.php?context=va&aid=25950)

Poultry fed GMO soy is causing damage in those fowl.  The genetic engineering in the soy, scientists found residual effects in the poultry that resulting in ‘consumers’ demanding labeling of GM foods and concerns over safety has consumers demanding truth in labeling and transparency.  Jack Heinemann, Professor of Genetics and Molecular biology at Canterbury University (was commissioned) to research and report on the question of whether animals exposed to feed containing genetically modified material (GM Feed) do in fact contain ‘no GM ingredients’.  In his report, a copy of which is available on the Commission’s website, Professor Heinemann concluded, “The cumulative strength of the positive detections reviewed  (referring to GMO in feed)…leave me in no reasonable uncertainty that GM plant material can transfer to animals exposed to GM feed in their diets or environment, and that there can be a residual difference in animals or animal-products as a result of exposure to GM feed  (Inghams warned over GM free chicken claims. Nov 18, 2009 Press release Commerce Commission from New Zealand). http://www.comcom.govt.nz/media-releases/detail/2009/inghamswarnedovergmfreechickenclai/ )

Dr Don Huber, a retired military Colonel, contacted USDA Secretary Vilsack by imploring the government to commit the resources necessary to find definitive answers (regarding GMO and related issues). Dr Huber, at the time of this article, was a professor emeritus at Purdue University, believes the appearance and prevalence of the unnamed organism may be related to the nation’s over reliance on the weed killer known as Roundup (here and  paragraphs following until cite).

In a letter to Secretary of Agriculture Tom Vilsack, obtained by SafeLawns, the Dr Huber is calling on the federal government to immediately rescind the Jan. 27, 2010 decision to allow genetically modified alfalfa to be released to farmers this spring.  “A team of senior plant and animal scientists have recently brought to my attention the discovery of an electron microscopic pathogen that appears to significantly impact the health of plants, animals and probably human beings,” wrote Huber in the letter (from “Safe Lawns”). “Based on a review of the data, it is widespread, very serious, and is in much higher concentrations in Roundup Ready (RR) soybeans and corn — suggesting a link with the RR gene, or more likely the presence of Roundup. This organism appears NEW to science!” In a Safe Lawns phone interview, Huber said he was assured that the United States Department of Agriculture was taking his letter seriously — yet he remained deeply pessimistic that his warnings would ultimately lead to affirmative action.

“I believe we’ve reached the tipping point toward a potential disaster with the safety of our food supply,” he said. “The abuse, or call it over use if you will, of Roundup, is having profoundly bad consequences in the soil. We’ve seen that for years. The appearance of this new pathogen may be a signal that we’ve gone too far.” This man’s research and associated experience with this body of data reputes that. ( through to note) 

Laboratory tests have confirmed the presence of this organism in a wide variety of livestock that have experienced spontaneous abortions and infertility.  Preliminary results from ongoing research have also been able to reproduce abortions in a clinical setting.” “It is urgent to examine whether the side effects of Round-up’s active ingredient, glyphosate use may have facilitated the growth of this pathogen, or allowed it to cause greater harm to weakened plant and animal hosts. It is well documented that glyphosate promotes soil pathogens and is already implicated with the increase of more than 40 plant diseases; it dismantles plant defenses by chelating vital nutrients; and it reduces the bioavailability of nutrients in feed, which in turn can cause animal disorders.  (The pathogen) deserves immediate attention with significant resources to avoid a general collapse of our critical agricultural infrastructure.”

http://www.safelawns.org/blog/index.php/2011/02/researcher-roundup-may-be-causing-miscarriages-in-cattle-humans/  http://www.safelawns.org/blog/  Wed, Feb 16, 2011

Researchers in France at CRIIGEN, Universities of Rouen and Caen, for the first time find cell level damage in mammals’ organs by way of chemical interaction with GMO (through this material to note). “The most fundamental point to bear in mind from the outset is that a sample size of 10 for biochemical parameters (referring to Monsanto’s trial it provided for approval by the FDA or USDA) measured two times in 90 days is largely insufficient to ensure an acceptable degree of power to the statistical analysis performed and presented by Monsanto. For example, concerning the statistical power in a t test at 5%, with the comparison of 2 samples of 10 rats, there is 44% chance to miss a significant effect of 1 standard deviation (SD; power 56%). In this case to have a power of 80% would necessitate a sample size of 17 rats” ( begun at opening of this section through to cite de Vendemois et al).

MONSANTO ALSO ENGAGED IN FRAUD AND ITS TRIAL IT PRESENTED TO THE REGULATORS AND THE RETRIAL/MORE THOROUGH TRIAL BY EUROPEAN SCIENTISTS EXPLAINS WHAT MONSANTO DID AND USED IT  WITH THE US REGULATORS. With regard to the Statistical power related to the experimental designs used by Monsanto versus these researchers “in reality, in their (Monsanto’s) report containing the raw data and statistical analysis, Monsanto did not apply in any case their chosen and described statistical methods. Only parametric tests (one-way ANOVA under homoscedasticity hypothesis and Student t tests on contrasts) were employed. Moreover, to select significant results, they only contrasted the data sets from the 33% GM maize feeding groups (for NK 603 and MON 810) with all reference groups

–( which seems to be that Monsanto attempted to manipulate the perception of the Regulators by using a data set from those fed a partial diet of GMO maize and what damage there is there, serves as that to which all groups are compared. Whatever may be marginal damage in the partially fed GMO group looks only slightly worse than the normal and not as bad as those fed only GMO, but the fed only GMO wasn’t the group used and over a longer time, but also in which more damage became evident over time, as if diluting the findings and attempting to obscure this from the Regulators. AMP)

Per deVednemois moreover, their biological interpretation of statistically significant results differs from case to case. In particular, sex differences were frequently used to reject pathological significance, despite the fact that this was without measuring effects on sex hormone levels. They also used the lack of linear dose-related effects, which is almost inevitable given that only two feeding doses were measured, to declare the diet as safe, as proposed for MON 863 GM maize [4 site’s footnote]. In the MON 863 experiments, the authors still failed to apply their declared methodology, which was slightly different. The ANOVA and contrast analysis (33% GM feeding dose versus controls) were in this case the determining criteria for evaluation of statistical significance, but only if the mean of the 33% GM feeding group was outside the range of the mean of the reference cohorts. All this increases noticeably the risks of false negative results.

Consequently, based on the clear inadequacy of the statistical power (in how Monsanto crafted its trial and reported what it’s used to refute toxic effects for instance the unquestionable large size effects in this study), knowing also that billions of people and animals can consume these products prior to the performance of appropriate in vivo safety evaluation, we applied an appropriate, experimentally validated statistical analytical methodology [5 cite’s footnote], elements of which are described below. (deVednemois)

Monsanto’s tests were found to be flawed and its results bogus and erroneous that it had provided to oversight bodies.   

In “a comparative analysis of blood and organ system data from trials … rats (were) fed three main commercialized genetically modified (GM) maize (NK 603, MON 810, MON 863), which are present in food and feed in the world,”  “Maize type NK 603 has been modified to be tolerant to the broad spectrum herbicide Roundup and thus contains residues of this formulation.  MON 810 and MON 863 are engineered to synthesize two different Bt toxins used as insecticides. Approximately 60 different biochemical parameters were classified per organ and measured in serum and urine after 5 and 14 weeks of feeding. GM maize-fed rats were compared first to their respective isogenic or parental non-GM equivalent control groups. This was followed by comparison to six reference groups, which had consumed various other non-GM maize varieties. We applied nonparametric methods, including multiple pair-wise comparisons with a False Discovery Rate approach. Principal Component Analysis allowed the investigation of scattering of different factors (sex, weeks of feeding, diet, dose and group).

The analysis by De Vendomais, et al clearly reveals for the 3 GMOs new side effects linked with GM maize consumption, which were sex- (affects worse on males than females) and often dose-dependent. Effects were mostly associated with the kidney and liver, the dietary detoxifying organs, although different between the 3 GMOs. Other effects were also noticed in the heart, adrenal glands, spleen and haematopoietic system. We conclude that these data highlight signs of hepatorenal toxicity, possibly due to the new pesticides specific to each GM corn. In addition, unintended indirect metabolic consequences of the genetic modification cannot be excluded.” de Vendômois JS, Roullier F, Cellier D, Séralini GE. A Comparison of the Effects of Three GM Corn Varieties on Mammalian Health. Int J Biol Sci 2009; 5(7):706-726. Available from http://www.biolsci.org/v05p0706.htm )

(Moreover, if the regulators were ignorant they were being defrauded, as it were, they’re still accessories before and after the fact to the criminal acts/actions of Monsanto and its damage perpetrated in the food supply and the environment. If the regulators were aware they were being defrauded by Monsanto, then they’re co-conspirators, and aided and abetted Monsanto in its criminal actions against the food supply, mankind and the environment for which it then needs to be punished and the regulators sued by the victims of which there are very many. The dead bees and pollinators, and bats and other insect eating creatures and some of the quality of life of the environment has been murdered and silenced and unable to represent itself in court, and against the regulators which in one way or another atrociously failed in their duty to cease and desist and ban Monsanto’s products and corporate abuse and crimes. Whatever mechanism that needs to punish Monsanto and the beneficiaries of its criminal acts must be put into action AMP).

Suppressed report shows cancer link to GM potatoes ( through until cite until note). The Independent in the UK reported “that campaigners against genetically modified crops in Britain are calling for trials of GM potatoes this spring to be halted after releasing more evidence of links with cancers in laboratory rats.  UK Greenpeace activists said the findings, obtained from Russian trials after an eight-year court battle with the biotech industry, vindicated research by Dr Arpad Pusztai, whose work was criticized by the Royal Society and the Netherlands State Institute for Quality Control.

The disclosure last night of the Russian study on the GM Watch website led to calls for David Miliband, the Secretary of State for Environment, Food and Rural Affairs, to withdraw permission for new trials on GM potatoes to go ahead at secret sites in the UK this spring. Alan Simpson, a Labour MP and green campaigner, said: “These trials should be stopped. The research backs up the work of Arpad Pusztai and it shows that he was the victim of a smear campaign by the biotech industry. There has been a cover-up over these findings and the Government should not be a party to that.”

Mr. Simpson said the findings, which showed that lab rats developed tumors, were released by anti-GM campaigners in Wales.  Dr Pusztai and a colleague used potatoes that had been genetically modified to produce a protein, lectin. They found cell damage in the rats’ stomachs, and in parts of their intestines. The research is likely to spark a fresh row about GM crops in Britain. Graham Thompson, a Greenpeace campaigner, said: “It is important because it backs up the research by Pusztai, which was smeared at the time by the industry.”

Brian John of GM Free Cymru, who released the findings, said the research was conducted in 1998 by the Institute of Nutrition of the Russian Academy of Medical Sciences and has been suppressed for eight years…Irina Ermakova, a consultant for Greenpeace, said she had conducted her own animal feeding experiments with GM materials. “The GM potatoes were the most dangerous of the feeds used in the trials … and on the basis of this evidence they cannot be used in the nourishment of people.”  Greenpeace said the Russian trials were also badly flawed. Half of the rats in the trial died, and results were taken from those that survived, in breach of normal scientific practice. ( Suppressed report shows cancer link to GM potatoes  The Independent: By Colin Brown , Deputy Political Editor /Saturday 17 February 2007 http://www.independent.co.uk/life-style/health-and-families/health-news/suppressed-report-shows-cancer-link-to-gm-potatoes-436673.htmlhttp://www.independent.co.uk/life-style/health-and-families/health-news/suppressed-report-shows-cancer-link-to-gm-potatoes-436673.html and  http://www.responsibletechnology.org/article-gmo-soy-linked-to-sterility )

“Before the FDA decided to allow GMOs into food without labeling, FDA scientists had repeatedly warned that GM foods can create unpredictable, hard-to-detect side effects, including allergies, toxins, new diseases, and nutritional problems. They urged long-term safety studies, but were ignored.  Since then, findings include (through cite to note):

  • Thousands of sheep, buffalo, and goats in India died after grazing on Bt cotton plants
  • Mice eating GM corn for the long term had fewer, and smaller, babies
  • More than half the babies of mother rats fed GM soy died within three weeks, and were smaller
  • Testicle cells of mice and rats on a GM soy change- shrink – significantly
  • By the third generation, most GM soy-fed hamsters lost the ability to have babies
  • Rodents fed GM corn and soy showed immune system responses and signs of toxicity
  • Cooked GM soy contains as much as 7-times the amount of a known soy allergen
  • Soy allergies skyrocketed by 50% in the UK, soon after GM soy was introduced
  • The stomach lining of rats fed GM potatoes showed excessive cell growth, a condition that may lead to cancer.
  • Studies showed organ lesions, altered liver and pancreas cells, changed enzyme levels, etc.

Unlike safety evaluations for drugs, there are no human clinical trials of GM foods. The only published human feeding experiment revealed that the genetic material inserted into GM soy transfers into bacteria living inside our intestines and continues to function. This means that long after we stop eating GM foods, we may still have their GM proteins produced continuously inside us. This could mean:

  • If the antibiotic gene inserted into most GM crops were to transfer, it could create super diseases, resistant to antibiotics
  • If the gene that creates Bt-toxin in GM corn were to transfer, it might turn our intestinal bacteria into living pesticide factories. Although no studies have evaluated if antibiotic or Bt-toxin genes transfer, that is one of the key problems. The safety assessments are too superficial to even identify most of the potential dangers from GMOs. (Genetically Modified Soy is Linked to Sterility, Infant Mortality See our Health Risks brochure and State of the Science report for more details and citations. http://www.responsibletechnology.org/

Please see the sub paragraph in the article on the Institute for Responsible Technology: “Denial, Attack and Canceled Follow-up”   Scientists who discover adverse findings from GMOs are regularly attacked, ridiculed, denied funding, and even fired.

When Ermakova reported the high infant mortality among GM soy fed offspring, for example, she appealed to the scientific community to repeat and verify her preliminary results. She also sought additional funds to analyze preserved organs. Instead, she was attacked and vilified. Samples were stolen from her lab, papers were burnt on her desk, and she said that her boss, under pressure from his boss, told her to stop doing any more GMO research. No one has yet repeated Ermakova’s simple, inexpensive studies. In an attempt to offer her sympathy, one of her colleagues suggested that maybe the GM soy will solve the over population problem! ( “Denial, Attack and Canceled Follow-up”  http://www.responsibletechnology.org/article-gmo-soy-linked-to-sterility)

Pesticides associated to genetically modified foods (PAGMF), are engineered to tolerate herbicides such as glyphosate (GLYP) and gluphosinate (GLUF) or insecticides such as the bacterial toxin bacillus thuringiensis (Bt). The aim of this study was to evaluate the correlation between maternal and fetal exposure, and to determine exposure levels of GLYP and its metabolite aminomethylphosphoric acid (AMPA), GLUF and its metabolite 3-methylphosphinicopropionic acid (3-MPPA) and Cry1Ab protein (a Bt toxin) in Eastern Townships of Quebec, Canada. Blood of thirty pregnant women (PW) and thirty-nine non-pregnant women (NPW) were studied. Serum GLYP and GLUF were detected in NPW and not detected in PW. Serum 3-MPPA and CryAb1 toxin were detected in PW, their fetuses and NPW. This is the first study to reveal the presence of circulating PAGMF in women with and without pregnancy, paving the way for a new field in reproductive toxicology including nutrition and utero-placental toxicities. (Aris, A. and S. Leblanc (2011). “Maternal and fetal exposure to pesticides associated to genetically modified foods in EasternTownships of Quebec, Canada.”Reproductive Toxicology 31(4).)

“Direct causal links between pesticide exposure and subsequent long-term illness are extremely difficult to establish. However, the evidence is mounting (through cite to note). Out of 426 chemicals named in 1988 by the Ministry of Agriculture, Fisheries, and Food as ingredients in pesticides cleared for use in England, 164 had been implicated in causing cancer, genetic mutations, irritant reactions, or reproductive problems ranging from impotency to birth defects. A 1986 National Cancer Institute study reported that farmers exposed to herbicides – especially 2,4-D – for more than twenty days per year were six times as likely to develop non-Hodgkins lymphoma, a cancer of the lymphatic system. In the prime agricultural region of the San Joaquin Valley of California, where 35% of the wells are contaminated with DPCP (DBCP?), the State Department of Health Services found an increased mortality rate for stomach cancer, the primary site for tumor induction in animals used in testing DPCP (DBCP?). In the small farm community of McFarland, California, thirteen children have developed cancer since 1981, and six have died; miscarriages, fetal deaths and low birth weights are common. A definitive causal link has not been established, but pesticide contamination in the region is a likely factor. Other recent studies link agricultural chemicals to an increase in birth defects.

Scientists are finding higher and higher levels of pesticides in people throughout the world. The effects are poorly understood, but the increased use of pesticides and other industrial chemicals has been followed by increased cancer rates. Since chronic health problems are usually slow in developing, it may well be that the most serious effects of pesticide contamination are yet to come. Pesticides and other chemicals are stored mainly in body fat and tend to concentrate in breast milk fat. They can thus be passed on to children during breast feeding, or to unborn babies through the placenta. (From the Ground Up, Rethinking Industrial Agriculture, p. 23. Pesticides, and You http://www.celsias.com/article/pesticides-and-you/)

Human health, of course, is of primary import to us, but ecological effects are also in play. Ninety-nine percent of GMO crops either tolerate or produce insecticide. (http://globalresearch.ca/index.php?context=va&aid=25950 http://www.ucsusa.org/food_and_agriculture/science_and_impacts/impacts_genetic_engineering/environmental-effects-of.html#monarch)  This may be the reason we see bee colony collapse disorder and massive butterfly deaths. If GMOs are wiping out Earth’s pollinators, they are far more disastrous than the threat they pose to humans and other mammals. (http://foodfreedom.wordpress.com/2010/01/01/three-approved-gmos-linked-to-organ-damage/ )

Children of agriculture families are likely to be exposed to agricultural chemicals, even if they are not involved in farm activities. Although four organophosphorous (OP) insecticides commonly used on tree fruit were targeted for analysis: azinphosmethyl, chlorpyrifos, parathion, and phosmet.  “Pesticides in household dust and soil: exposure pathways for children of agricultural families National Institute of Environmental Health Sciences: Enviornmental Health Perspectives. 1 Dec 95 N J. Simcox, R A. Fenske, S A. Wolz, I C. Lee, D A. Kalman Department of Environmental Health, University of Washington, / http://ehp03.niehs.nih.gov/article/fetchArticle.action?articleURI=info%3Adoi%2F10.1289%2Fehp.951031126  and http://dx.doi.org/10.1289/ehp.951031126

The corn, dubbed “Agent Orange Corn,” is being developed by Dow AgroSciences, a subsidiary of Dow Chemical, one of two companies that manufactured Agent Orange (the other was Monsanto).  “This novel corn will foster resistant weeds that require more toxic pesticides to kill, followed by more resistance and more pesticides—a chemical arms race in which the only winners are pesticide/biotechnology firms,” Andrew

Kimbrell, director of the anti-GMO nonprofit Center for Food Safety, said in a statement. If approved, the crop could be planted as early as next year, bringing with it all the health problems of 2,4-D exposure, including Parkinson’s disease, nerve damage, and hormone disruption—to say nothing of the birth defects and cancers caused by dioxin, a potential contaminant. Studies by the Environmental Protection Agency have also found that, in countries with high rates of 2,4-D use on farms, birth defect rates are as much as 60 to 90 percent higher than in other countries.

What’s threatening to farmers of non-genetically modified crops is that 2,4-D damages neighboring crops more so than any other weed killer, according to the Center for Food Safety. It can kill wheat before the grain has had a chance to sprout, and can kill as much as 82 percent of sunflowers in a field, just by drifting in from a nearby farm.

In 2008, the Natural Resources Defense Council (NRDC) petitioned the Environmental Protection Agency to ban 2,4-D entirely. On February 23rd, the environmental nonprofit sued the agency for failing to respond to that petition. Citing the chemical’s toxic effects on people and water, NRDC scientists warn that, if 2,4-D-resistant corn gains USDA approval, use of the herbicide could increase by 50-fold or more.

Genetically modified crops, the Center for Food Safety has said, are a failed technology. Repeated field trials by the United Nations Food and Agriculture Organization and at the Pennsylvania-based Rodale Institute have shown that they produce no better yields than non-genetically modified and organic varieties, and often, according to the UN, under certain circumstances, perform worse than their organic counterparts, rendering new genetically modified varieties as providing “no public benefit,” Kimbrell said in his statement.  Emily Main 2012-02-22 15:34  Speak Up Now to Stop ‘Agent Orange Corn’!   http://www.rodale.com/research-feed/gmo-corn

Environmental damage caused by Dow and Monsanto GM agri products, and associated  herbicides such a 2,4D and related dioxin and glyphosate, etc

Last week (17Feb12) the US EPA released EPA’s Science Plan for Activities Related to Dioxins in the Environment in which the US EPA website states: “This document provides hazard identification and dose-response information on 2,3,7,8- tetrachlorodibenzo-p-dioxin (TCDD) and the most up-to-date analysis of non-cancer health effects from TCDD exposure. The report also include a reference dose (RfD) and a detailed and transparent description of the underlying data and analyses. EPA will complete Reanalysis, Volume 2, containing the full dioxin cancer assessment, as expeditiously as possible. In Volume 2, EPA will complete the evaluation of the available cancer mode-of-action data, and will augment the cancer dose-response modeling, including justification of the approaches used for dose response modeling of the cancer endpoints, and an associated quantitative uncertainty analysis. The U.S. Environmental Protection Agency is currently addressing several issues related to dioxins and dioxin-like chemicals in the environment. These include the comprehensive human health and exposure assessment for dioxin, commonly called the dioxin reassessment and a review of dioxin soil clean-up levels currently in use across the United States. To move forward with both of these efforts, as well as other dioxin related activities, a plan with interim milestones has been developed and it is outlined below.

 It made the following DISCLAIMERS however, that again serve to thwart accountability by corporate polluters and BigAg abusers like Dow and Monsanto, which continue to produce herbicides and GMO tolerant to those that harm the environment including the soil and water as well as insect, acquatic live, animal  and food supply quality and people physiology.

Volume 1 (noncancer) of the Reanalysis contains some descriptive cancer information. The cancer information in Volume 1 should not be used for regulatory or risk management decision-making.  Volumes 1 and 2 of the Reanalysis will supersede the 2003 draft dioxin Reassessment.

The 2003 draft dioxin Reassessment includes a disclaimer that the document should not be cited or quoted. As such, information in this draft document should not be used for regulatory or risk management decision-making. “ EPA Updates Science Assessment for Dioxins / Air emissions of dioxins have decreased by 90 percent since the 1980s, 02/17/2012, Latisha Petteway, petteway.latisha@epa.gov, 202-564-3191 Notice http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=209690

  • Mother Jones reported in Feb 2007, “In a ruling that could make it more difficult for the USDA to speed through permits for the testing of genetically engineered crops, a federal judge halted field trials of several controversial GMOs yesterday pending a more detailed review of their potential environmental hazards. It was the first time a field trial of a GE crop has been stopped by a U.S. court. Judge Harold Kennedy found the USDA should have required environmental impact statements before approving field trials of pesticide-resistant creeping bentgrass and Kentucky bluegrass in Oregon. Last year, pollen from the grasses escaped from the test area and fertilized plants several miles away in a national grassland.
  • The ruling was a rebuke to a common practice at the USDA of approving GMO field trials under a “categorical exclusion”–basically, an argument that field trials are too environmentally insignificant to merit detailed oversight. Although the judicial pounding has by no means driven a nail in the coffin of GMOs, it’s certainly a sign that the USDA is starting to face rebukes for years of lax policies on a very poorly understood area of science. (For the First Time Ever, a U.S. Court Halts a GMO Field Trial, Josh Harkinson, | Tue Feb. 6, 2007 4:26 PM PST http://motherjones.com/blue-marble/2007/02/first-time-ever-us-court-halts-gmo-field-trial )

“EPA Updates Science Assessment for Dioxins / Air emissions of dioxins have decreased by 90 percent since the 1980s” although most of the dioxins contaminating food is from herbicides.

http://yosemite.epa.gov/opa/admpress.nsf/d0cf6618525a9efb85257359003fb69d/33bcba60ed25a9b1852579a700604ed7!OpenDocument

“In any case, as a result of these lawsuits, during the 1980s the question of dioxin’s effects on humans became subject of bitter controversy–with enormous sums of money riding on the outcome of the debate. As the 1980s drew to a close and it became known that all incinerators create and release dioxin into the local environment, industry felt enormous pressure to “prove” that dioxin was harmless to humans. From 1980 onward, industry researchers published several studies of dioxin-exposed workers, claiming to show that they suffered no more cancer than the general public. Last year, however, evidence began to accumulate indicating that the industry-funded studies of dioxin dangers to humans were badly flawed or were simply fraudulent (see RHWN #171, #173, #175)”.( RACHEL’S HAZARDOUS WASTE NEWS #219—February 6, 1991. “New Study Links Dioxin to Cancer” http://www.ejnet.org/rachel/rhwn219.htm  )

Despite claims that genetically modified organisms (GMOs) will lower the levels of chemicals (pesticides and herbicides) used, quite the opposite has occurred, with 1.6 billion pounds of glyphosate (the active in ingredient in Roundup) being applied to American soil in 2007 alone ( through cite to note). This is of great concern both because of the negative impacts of these chemicals on ecosystems and humans, and because there is the danger that increased chemical use will cause pests and weeds to develop resistance, requiring even more chemicals in order to manage them.

Monsanto has been claiming that through genetic engineering it can breed crops for drought tolerance and other climate-resilient traits. This is a false promise. (“Banned in Germany, But You’re Probably Still Eating It Posted By Dr. Mercola | January 31 2012,  Dr. Mercola – “Monsanto Named the Worst Company of 2011”)

Pesticides associated to genetically modified foods (PAGMF), are engineered to tolerate herbicides such as Round-up, chemically known as glyphosate (GLYP) and gluphosinate (GLUF) or insecticides such as the bacterial toxin bacillus thuringiensis (Bt). Glyphosate [N-(phosphonomethyl) glycine] is an herbicide used widely throughout the world in the production of many crops and is heavily used on soybeans, corn and cotton. Glyphosate is used in almost all agricultural areas of the United States, and the agricultural use of glyphosate has increased from less than 10 000 Mg in 1992 to more than 80 000 Mg in 2007.

  • Thanks to glyphosate that is sprayed on massive acreages of GM Roundup Ready soybeans, cotton, and corn grown in the United States each and every year, super weeds are growing at an alarming rate. It’s estimated that more than 130 types of weeds spanning 40 U.S. states are now herbicide-resistant, and the super weeds are showing no signs of stopping. In fact, the situation is getting progressively worse.
  • Extremely hardy Roundup-resistant weeds are already boosting costs and cutting crop yields for U.S. farmers. And with world food stores already strained, diminished crop production is a serious problem. In addition, the creation of these super weeds is leading farmers to douse their fields with ever increasing amounts of herbicides in a desperate attempt to stop their spread.
  • Along with the environmental devastation, research published in 2010 showed that
  • The greatest intensity of glyphosate (Round-up) use is in the Midwestern United States, where applications are predominantly to genetically modified corn and soybeans (through cite to note). As well as being used increasingly widely in food production, glyphosate/Round-up-based weed-killers often also get sprayed onto railway lines, urban pavements and roadsides. According to an article in German in the Ithaca journal, a German university study has found significant concentrations of glyphosate/Round-up in the urine samples of city dwellers. Last year also saw the publication of two US Geological Survey studies which consistently found glyphosate in streams, rain and even air in agricultural areas of the US. In spite of the increase in usage across the United States, the characterization of the transport of glyphosate and its depredate aminomethylphosphonic acid (AMPA) on a watershed scale is lacking. Because of significant pressure by agrochemical representatives and the fear that the work of the lab could be influenced, the complete analytical data will only be published in the course of this year.”  (Now glyphosate is found in people’s urine

 

  • Bio-magnification: the higher up the food chain the poison travelled, the more Herbicides accumulated (although here referring to glyphosate, however dioxins also do the same), or ‘magnified’ it becomes, and this magnification can be exponential. We’re at the top of most food chains (through cite to note). Moreover, the United States produces between 100 and 150 million pounds of pesticides which are considered too dangerous for use within the country’s borders. These chemicals are exported for use in other nations with less stringent environmental safeguards. ( From the Ground Up, Rethinking Industrial Agriculture, p. 23. Pesticides, and You http://www.celsias.com/article/pesticides-and-you/ )

Summary of Remarks by Pesticide Research Team – Queen’s Park News Conference, April 23, 2004 (21)

BACKGROUND ONLY — NOT TO BE USED AS ATTRIBUTED QUOTES

Our review has found evidence of serious harmful effects in several areas including cancer, reproductive effects and impacts on the nervous system. These effects are found in both occupational and home and garden exposures. (21 http://www.ocfp.on.ca/communications/public-policy-documents Pesticides Literature Review  Dr. Margaret Sanbord, Dr. Donald Cole, Dr. Kathleen Kerr, Dr. Cathy Vakil, Dr. Luz Helena Sanin, Dr. Kate Bassil / Published: 4/23/2004 12:00:00 AM

Although I was not able to quickly find if dioxin based herbicides chelated trace elements out of the soil as well as render the plants with little or inferior nutritional value like “wimpy” milk and butter from cows administered rBHT and similar bovine stimulant hormones and pharma, and the USDA probably already knows this and PROBABLY already understands this, however,

“The same nutrients that glyphosate chelates and deprives plants of – essential minerals such as iron, zinc, copper, manganese, magnesium, calcium, and boron – are also critical for animal and human health. One example is manganese, a mineral whose losses can be severe. The nutrient not only is chelated by glyphosate but also is reduced in Roundup Ready plants. Recently veterinarians have found low levels of manganese and sometimes no detectible levels in livestock that they’ve tested. Veterinarians also report much sicker animals since GM foods started to dominate animal feed, and when livestock is switched from GMO to non-GMO feed, the animals experience dramatic improvement in health. Minerals are simpler in chemical form and are tiny in comparison to vitamins, but they are one of six groups of nutrients we need for healthy function each and every day. With depleted levels of minerals, failure to thrive develops, then deficiency diseases with severe health consequences, and eventually death. This occurs not only in humans, but also in animals and plants.

This loss is something we simply can’t afford. We’re already suffering from progressive nutrient deprivation even without Roundup. In a UK study, for example, they found between 16-76% less nutrients in 1991, compared to levels in the same foods in 1940. ” (Herbicide Used on GM Corn & Other Crops a Mineral Chelator  by Melissa Diane Smith  http://www.againstthegrainnutrition.com/newsandnotes/2011/01/23/herbicide-used-on-gm-corn-other-crops-a-mineral-chelator/)

This is their (Dow’s and Monsanto’s) job to understand *and be responsible about* plant and soil nutrition and quality. Yet they and the FDA and USDA permitted and had permitted BigAg-BioTech and BigDairy to produce and plant GMO seeds/crops into the environment that have been eroding the environment and food quality; meanwhile it’s disgraceful corruption to see the erosion in the quality of the environment and the plant and livestock/diary/poultry-eggs food supply and feeds to those that has continued to go forward in our agriculture/land ‘husbandry’ and livestock dairy and poultry production without ANY efforts on the part of the USDA, the FDA, and the EPA to professionally assess food and environmental quality.  (AMP)

Although not directly related to Monsanto’s GMO environmental and physiological harm, the similar abuses and contaminations exist in other related contexts: Meanwhile, the meat industry built a multi-billion dollar business based on stuffing animals by the thousands into tight spaces amid their own waste. To keep them alive and growing to slaughter amid such conditions, feedlot operators give their animals daily doses of antibiotics and other of Monsanto’s pharma. The FDA recently revealed that factory animal farms now burn through fully 80 percent of all antibiotics consumed in the United States. (http://motherjones.com/tom-philpott/2012/01/monsanto-gmo-drought-tolerant-corn  Mother Jones: Tom Philpott,  Mon Jan. 23, 2012 12:15 PM PST USDA Greenlights Monsanto’s Utterly Useless New GMO Corn)

And deceitful trial practices to obtain regulator approval yielding flawed test results not to mention support by wealthy and influential players like Bill Gates**

See also Page 13,14 deVednemois Study for the fraud in its trials it presented to the US regulators.  Monsanto knew in presenting the materials in the way that it did for the trial, it would minimize what would be observed by the Regulators, who are complicit with the fraud if they knew that Monsanto not only mixed its trial materials but also in the manner of what it also presented in the trial, limiting the number of lab rats as well as limiting its trials to only rats rather than also using other mammals it used and over too short a time frame failed to reveal the damage caused by those rats eating Monsanto GMO feed.

MONSANTO ENGAGED IN FRAUD, MEANWHILE  IT also mixed/OBSCURED its trial subject matter and presented results of this corrupted trial to the USDA and/or FDA for approval ”Further, Monsanto’s analysis compared unrelated feeding groups, muddying the results. The June 2009 rebuttal explains, “In order to isolate the effect of the GM transformation process from other variables, it is only valid to compare the GMO … with its isogenic non-GM equivalent.” (through cite to note)

(Moreover, if the regulators were ignorant they were being defrauded, as it were, they’re still accessories before and after the fact to the criminal acts/actions of Monsanto and its damage perpetrated in the food supply and the environment. If the regulators were aware they were being defrauded by Monsanto, then they’re co-conspirators, and aided and abetted Monsanto in its criminal actions against the food supply, mankind and the environment for which it then needs to be punished and the regulators sued by the victims of which there are very many. The dead bees and pollinators, and bats and other insect eating creatures and some of the quality of life of the environment has been murdered and silenced and unable to represent itself in court, and against the regulators which in one way or another atrociously failed in their duty to cease and desist and ban Monsanto’s products and corporate abuse and crimes. Whatever mechanism that needs to punish Monsanto and the beneficiaries of its criminal acts must be put into action AMP).

The researchers which conducted this excellent review of Monsanto’s trial it used with the ‘appropriate’ regulators, as well as responsible research for the efforts in their own countries on whether or not to permit GMO in their food supply and environment as well as the use of the herbicides and pesticides used in the US but banned in Europe because of their toxicity to the environment have provided us robust information. These researchers have concluded that the raw (Monsanto as well as their own research) data from all three GMO studies reveal novel pesticide residues will be present in food and feed and may pose grave health risks to those consuming them.” They have called for “an immediate ban on the import and cultivation of these GMOs and strongly recommend additional long-term (up to two years) and multi-generational animal feeding studies on at least three species to provide true scientifically valid data on the acute and chronic toxic effects of GM crops, feed and foods.” (http://foodfreedom.wordpress.com/2010/01/01/three-approved-gmos-linked-to-organ-damage/; **http://www.takepart.com/article/2012/02/02/the-flip-side-what-bill-gates-doesnt-know-about-gmos

The Examiner.com reports that Rep Kucinich introduced, H.R. 3554 The Genetically Engineered Safety Act, which aims to protect the food supply from Monsanto and GMOs, the use of which largely has been unrestricted in part because it has presented findings from flawed tests in order to deceive the regulators. His HR is looking to attempt to prevent biological contamination of the food supply. (http://www.examiner.com/democrat-in-national/kucinich-bill-aims-to-protect-food-supply-from-monsanto-gmos

In order to prevent further harm in the environment, the food supply, the insect and animal wildlife, the domestic livestock food supply, the people who eat the livestock, poultry/egg and dairy industries’ production from its deceitful representations to the FDA and USDA, Kucinich’s HR would prohibit open air cultivation of GE pharmaceutical and industrial crops  (through cite to note). The ‘bill’ also would prohibit the use of common human food or animal feed as the host plant for a GE pharma or industrial chemical. If passed the legislation would establish a tracking system to regulate the growing handling, transport, and disposal of pharma and industrial crops, and protect native ecosystems and traditional farms from the poorly studied or misrepresented dangers of growing GE organisms. Kucinich rightfully so is concerned about irreversible damage to our food supply…. Many Americans are unaware that crops that are GE to produce experimental pharma are being grown in this country in the open, allowing them to contaminate conventional crops without detection. We cannot rely on industry to prevent the undetected spread of GE organisms. We have taken few steps to ensure that our own genetic experiments are kept in check: (sounds similar to what the nazis did in the concentration camps). He is attempting to have what would be legislation that ensures that cloning and GE do not disrupt our traditional food supply. The USDA has allowed outdoor field trials of more than 300 outdoor field plants to produce experimental pharma, industrial enzymes, and novel proteins. Those GE substances are not intended to be incorporated into food or to be spread into the environment or our food supply. The potential for already significant contamination introduces risks of grand scale destructive consequences. (Examiner.com/ Michael Stone, 12Dec11 http://www.examiner.com/democrat-in-national/kucinich-bill-aims-to-protect-food-supply-from-monsanto-gmos )

Anti-competitive/Monopolistic and Corporate abusive practices so that Monsanto, Dow and this cartel of biotech players are those who are the Actual Beneficiaries versus those alleged to Benefit from the use of GMO. The Non GM Agriculture- the every day non gmo and organic farmers and society which expect and trust the system for clean, uncontaminated, undamaging food have been harmed by Monsanto, Dow and the biotech cartel.

Monsanto and Dow are probably colluding and engaging in abusive anti-monopolistic practices, as well as harmful, abusive practices to society and the environment; Even scarier, Monsanto and Dow now seem to be in collusion with one another. In its petition, Dow states that the 2,4-D trait in the GE seeds will be stacked with Monsanto’s Roundup Ready trait so that the seeds are resistant to multiple herbicide tolerances. Soon we’ll be eating food with a whole cocktail of different herbicide traits cooked into the seed—all so they can be sprayed with chemicals that are more toxic than ever before! The real solution here is to stop using GE seeds altogether.( http://www.anh-usa.org/agent-orange-on-our-crops/

Per Mother Jones SEC Investigates Monsanto’s Roundup Biz —By Tom Philpott The SEC is investigating Monsanto’s tactics for defending the market for its herbicide, Roundup. The news emerged just before the July 4 holiday weekend, during Monsanto’s press conference about its quarterly financial earnings. Company execs boasted of a 77 percent increase in profit before dropping a mini-bombshell, The Wall Street Journal reported: Monsanto said it was cooperating with a previously undisclosed US Securities and Exchange Commission probe into its customer incentive programs for herbicides in fiscal years 2009 and 2010, and had received a subpoena to provide related documents.

Neither the SEC nor Monsanto will comment on the ongoing investigation. But Monsanto did issue a terse press release after the earnings call explaining that the probe “relates to financial incentives Monsanto offered to distributors who carry its glyphosate products and the financial reporting of those incentives.”

Glyphosate is the active ingredient in Monsanto’s flagship Roundup herbicide, and “distributors” refers to the seed industry’s middlemen, the companies that buy seeds and agrichemcals from suppliers like Monsanto and sell them to farmers. So what the company is saying its that it gave “financial incentives”—presumably, discounts—to somehow promote Roundup sales in 2009 and ’10.

Here’s the context. For years, the company minted profits by selling farmers seeds engineered to withstand that potent weed killer, and also selling them copious amounts of the weed killer itself. But its patent on glyphosate expired in 2000. By the late 2000s, Chinese competitors selling cheap generic glyphosate had stormed into the market, eating away at Monsanto’s Roundup sales. In response, according to Bloomberg, Monsanto announced in early 2010 that it would spend up to $150 million on “incremental price concessions or trade incentives” to boost its Roundup brand.

Did Monsanto essentially bribe agrichemical dealers to promote Roundup and squeeze out competitors? That, I suspect, is the question SEC investigators are asking. Monsanto certainly has a history of using its heft to manipulate the markets it dominates. Here’s what AP’s Christopher Leonard concluded after digging into Monsanto’s business practices for an an excellent 2009 investigative report: “The world’s biggest seed developer is squeezing competitors, controlling smaller seed companies, and protecting its dominance over the multibillion-dollar market for genetically altered crops.” And as the SEC investigation suggests, it may be resorting to illegal tactics to maintain its Roundup cash cow. (SEC Investigates Monsanto’s Roundup Biz —By Tom Philpott | Tue Jul. 19, 2011 2:00 AM PDT,  http://motherjones.com/tom-philpott/2011/07/roundup-sec-investigates-monsanto )

 Meanwhile, Reported by RACHEL’S HAZARDOUS WASTE NEWS #400 July 28, 1994 EPA INVESTIGATED MONSANTO,  an internal memorandum by an official of the U.S. Environmental Protection Agency [EPA], has accused EPA of conducting a “fraudulent” criminal investigation of Monsanto, the St. Louis chemical corporation. [1  William Sanjour, EPA Office of Solid Waste and Emergency Response, “Memorandum: The Monsanto Investigation” to David Bussard, Director, EPA Characterization and Assessment Branch, dated July 20, 1994. Available for $5.00 from Citizens Clearinghouse for Hazardous Waste, P.O. Box 6806, Falls Church, VA 22040; phone (703) 237-2249.]

  • The 30-page memo, from William Sanjour to his supervisor, David Bussard, dated July 20, 1994, describes a two-year-long criminal investigation of Monsanto by EPA’s Office of Criminal Investigation (OCI). The Sanjour memo says EPA opened its investigation on August 20, 1990 and formally closed it on August 7, 1992. “However, the investigation itself and the basis for closing the investigation were fraudulent,” the Sanjour memo says.
  • According to the Sanjour memo:
  • ** EPA’s investigation of Monsanto was precipitated by a memo dated February 23, 1990, from EPA’s Dr. Cate Jenkins to Raymond Loehr, head of EPA’s Science Advisory Board.
  • ** The Jenkins memo said that EPA had set dioxin standards relying on flawed Monsanto-sponsored studies of Monsanto workers exposed to dioxin, studies that had showed no cancer increases among heavily exposed workers.
  • ** Attached to the Jenkins memo was a portion of a legal brief filed by the plaintiffs as part of a trial known as Kemner v. Monsanto, in which a group of citizens in Sturgeon, Missouri had sued Monsanto for alleged injuries they had suffered during a chemical spill caused by a train derailment in 1979.
  • ** The Jenkins memo had not requested a criminal investigation; instead Jenkins had suggested the need for a scientific investigation of Monsanto’s dioxin studies. But in August 1990, EPA’s Office of Criminal Investigation (OCI) wrote a 7-page memo recommending that a “full field criminal investigation be initiated by OCI.”
  • ** Plaintiffs in the Kemner suit made the following kinds of allegations (which we quote verbatim from the Sanjour memo):
  • “* Monsanto failed to notify and lied to its workers about the presence and danger of dioxin in its chlorophenol plant, so that it would not have to bear the expense of changing its manufacturing process or lose customers;…
  • “* Monsanto knowingly dumped 30 to 40 pounds of dioxin a day into the Mississippi River between 1970 and 1977 which could enter the St. Louis food chain;
  • “* Monsanto lied to EPA that it had no knowledge that its plant effluent contained dioxin;
  • “* Monsanto secretly tested the corpses of people killed by accident in St. Louis for the presence of dioxin and found it in every case;…
  • “* Lysol, a product made from Monsanto’s Santophen, was contaminated with dioxin with Monsanto’s knowledge.” [The Sanjour memo says that, at the time of the contamination, “Lysol (was) recommended for cleaning babies’ toys and for other cleaning activities involving human contact.”]
  • “* The manufacturer of Lysol was not told about the dioxin by Monsanto for fear of losing his business;
  • “* Other companies using Santophen, who specifically asked about the presence of dioxin, were lied to by Monsanto;…
  • “* Shortly after a spill in the Monsanto chlorophenol plant, OSHA measured dioxin on the plant walls. Monsanto conducted its own measurements, which were higher than OSHA’s, but they issued a press release to the public and they lied to OSHA and their workers saying they had failed to confirm OSHA’s findings;
  • “* Exposed Monsanto workers were not told of the presence of dioxin and were not given protective clothing even though the company was aware of the dangers of dioxin;
  • “* Even though the Toxic Substances Control Act requires chemical companies to report the presence of hazardous substances in their products to EPA, Monsanto never gave notice and lied to EPA in reports;
  • “* At one time Monsanto lied to EPA saying that it could not test its products for dioxin because dioxin was too toxic to handle in its labs.”…
  • OCI’s August memo alleged that “Monsanto did, in fact, produce ‘research’ to defend its position. ‘The Record however, shows a deliberate course of conduct designed to convince its employees and the world that Dioxin is harmless,'” the OCI memo said. [2] Memorandum from [name redacted] in EPA Office of Criminal Investigation to [name redacted] in EPA Office of Criminal Investigation dated August 16, 1990. A copy of this memo was sent to us by EPA’s Freedom of Information Officer in Washington, D.C.]
  • OCI’s memo concluded, “Based upon review of the available information submitted to the EPA-OCI by the Office of Enforcement, it is recommended that a full field criminal investigation be initiated by OCI.

“Information in the plaintiff’s brief indicate a potential conspiracy, between Monsanto and its officers and employees, exists or has existed to defraud the US EPA, in violation of 18 USC 371. The means of the conspiracy appears to be by (1) providing misleading information to the EPA; (2) intentional failure by Monsanto to fully disclose all pertinent TSCA [Toxic Substances Control Act] related information to the EPA; (3) false statements in notices and reports to EPA; (4) the use of allegedly fraudulent research to erroneously convince the EPA, and the scientific community, that Dioxin is less harmful to health and the environment.” (“EPA Investigates Monsanto” RACHEL’S HAZARDOUS WASTE NEWS #400—July 28, 1994— http://www.ejnet.org/rachel/rhwn400.htm )

The public ‘record’ provides robust information about relationships between Dioxin causing cancer however the corporate record is reported to alter or control or defraud ‘official’ reports and tests by the US regulators on which upgrading environmental and agricultural standards rely.  For example studies in which Monsanto and BASF of Dioxins engaged in fraud and similar miscreant activity such as conspiracy have diminished the regulatory ‘official’ record that would force the regulators to require indsutray and agriculture to comport themselves in more responsible and less reckless ways in the environment, agriculture and in their science, rather than presume teir science is absolute and without accountability. (Dioxins and Cancer: Fraudulent Studies. RACHEL’S HAZARDOUS WASTE NEWS #171 —March 7, 1990—http://www.ejnet.org/rachel/rhwn171.htm)

The following leaked memo to the US Environmental Protection Agency, summarised by The Ecologist, shows how Monsanto lied to the US authorities about its dioxin production, and deliberately falsified data to prevent compensation claims or the tightening of regulations. (Monsanto’s Dioxin Fraud, http://www.lightparty.com/Economic/MonsantoDioxinFraud.html)

“Marie-Monque Robin reports that following Monsanto’s long history of manufacturing hazardous chemicals and lethal herbicides, it is now marketing itself as a “life sciences” company, seemingly convinced about the virtues of sustainable development ( through cite to note) (although ‘sustainable development means to shrink the world’s population by 8/9s using any means to achieve that in different geographies AMP). However, Monsanto now controls the majority of the yield of the world’s genetically modified corn and soy–ingredients found in more than 95 percent of American households–and its alarming legal and political tactics to maintain this monopoly are the subject of worldwide concern. The author’s documentary is the result of a three-year-long investigation that took across four continents (North and South America, Europe, and Asia), The World According to Monsanto tells the little-known yet shocking story of this agribusiness giant–the world’s leading producer of GMOs (genetically modified organisms)–and how its new “green” face is no less malign than its PCB- and Agent Orange-soaked past…”  (The World According to Monsanto: Pollution, Corruption, and the Control of the World’s Food Supply [Hardcover] Marie-Monique Robin, http://www.amazon.com/gp/product/1595584269/ref=cm_cr_dpvoterdr?ie=UTF8&isSRAdmin=#RVI73YD1JL5P5.2115.Helpful.Reviews )

Monsanto wants you to simply trust them because they’re “experts” and because their industry-funded studies “prove” their GM foods are safe (through cite to note). But these same experts also told you PCB’s, Agent Orange, and DDT was safe, and we now know those claims were far from accurate.  Of course, in terms of reliability, there’s a big difference between corporate science, which tends to primarily favor and support corporate interests, and independent science, performed without preconceived bias.  (Monsanto Named the Worst Company of 2011.htm by Dr. Mercola Jan 31, 2012 “Banned in Germany but you’re probably still eating it”)

What appears to be is the aggressive and prolific use of herbicides and insecticides which already caused environmental and nature blowback, has served as a reason for Monsanto and Dow to produce GM seeds and crops that actually ENCOURAGE MORE use of yet more and more powerful herbicides and pesticides.  In Feb 2008, Friends of the Earth published its Media Advisory entitled: “NEW REPORT: GM CROPS INCREASE PESTICIDE USE”. It reported “In 2007 GM crops still failed to tackle hunger and poverty in developing countries” (through cite to note).

A new report released on February 13th (2008) shows that planting genetically modified (GM) crops are causing an increased use of harmful pesticides in major biotech crop producing countries. A new report released (by Friends of the Earth) on February 13th shows that planting genetically modified (GM) crops is causing an increased use of harmful pesticides in major biotech crop producing countries.  GM crops are not ‘green’. The adoption of Roundup Ready (RR) crops, the most extensively grown GM crop today, has led to an increase in pesticide use:

– In the United States, data from the U.S. Department of Agriculture (USDA) shows that RR crops drove a more than 15-fold increase in the use of glyphosate –the herbicide associated with RR crops- on major field crops from 1994 to 2005. In 2006, the last year for which data is available, glyphosate use on soybeans jumped a substantial 28%. The intensity of glyphosate use has also risen dramatically. From 1994 to 2006, the amount of glyphosate applied per acre of soya rose by more than 150%.  The increase in glyphosate herbicide is no longer displacing other herbicides in the US. From 2002 to 2006 the use of 2,4-D –one of the most widely used herbicide in the world- on soybeans more than doubled, and the use of atrazine (an herbicide banned in Europe due to links to health problems) on corn increased by 12 per cent from 2002 to 2005.

– In major RR soybean producer countries, like Brazil and Argentina, glyphosate use and weed resistance have risen. A 2007 study by a Brazilian governmental agency shows that the use of glyphosate increased 79.6% between 2000 to 2005,  much faster than the expansion in area planted with RR soya. In 2007 a glyphosate-resistant weed called Johnson Grass infested over 120,000 ha in Argentina. An estimated 25 million litres of herbicides other than glyphosate will be needed, resulting in increasing production costs of between $160 to 950 million per year. In India, a 2007 study from Andhra University concluded that Bt cotton uses the same amount of pesticides as conventional cotton.

The 2008 edition of the Friends of the Earth International “Who Benefits from GM crops?” report series is titled “The Rise in Pesticide Use” and concludes that GM crops on the market today have on the whole caused an increase rather than a decrease in toxic pesticides use, and have failed to tackle hunger and poverty.  GM crops do not tackle hunger or poverty. Most GM crops commercialized so far are destined for animal feed, not for food, and none have been introduced to address hunger and poverty issues. GM crops are not providing help to small farmers in developing countries. In South Africa, for example since the adoption of Bt cotton, the number of small cotton farmers have plummeted from 3229 in 2001/02 to just 853 in 2006/07.

“The biotech industry is telling Africans that we need GM crops to tackle the food needs of our population. But how can we believe such statements when the majority of GM crops are used to feed the animals of rich countries, produce industrial products like agrofuels, and overall don’t yield more than conventional crops?”, said Nnimmo Bassey of Friends of the Earth Nigeria/ERA.   As it were, “GM crops still fail to deliver the long-promised benefits. They are not good for the environment, as they are increasing pesticide use. In addition, they do not benefit small farmers or consumers in terms of quality or price,” added Bassey. (28 MEDIA ADVISORY- Friends of the Earth International, February 13, 2008, BRUSSELS (BELGIUM), LAGOS (NIGERIA), KUALA LUMPUR (MALAYSIA) – February 13, 2008 –: NEW REPORT: GM CROPS INCREASE PESTICIDE USE  http://www.foei.org/en/media/archive/2008/gm-crops-increase-pesticides/  )

Moreover, regarding criticism of its trials and its products and ‘science’ Monsanto’s rebuttal to its opponents was disingenuous and vague. Damage also was experienced by live stock producers and bt alfalfa which Monsanto sloughed off and ridiculed.  “Genetically modified seeds are produced and distributed by powerful biotech conglomerates (29 through cite to note). The latter manipulate government agricultural policy with a view to supporting their agenda of dominance in the agricultural industry. American conglomerates such as Monsanto, Pioneer Hybrid and others, have created seeds that reproduce only under certain conditions, often linked to the use of their own brands of fertilizer and/or insecticide and obtain this capability to engage in this abuse by regulatory approval.“ (29 http://globalresearch.ca/index.php?context=va&aid=25950 Death of the Bees. Genetically Modified Crops and the Decline of Bee Colonies in North America by Brit Amos – Global Research, 9Aug11, based on  March 2008 article)

OSGATA v Monsanto. Since March, 82 other plaintiffs representing over 300,000 organic farmers, seed companies and food associations have joined the case (30 through cite to note). “The trajectory from the past fifteen years, which been increasing in recent years, is that organic farmers will be forced out of business because the extended contamination will become so extensive because of its increasing acreage,” Gerritsen said when Lekas Miller asked what inspired him to file a lawsuit. “So either we stand up and fight now, or we’re going to lose our options.”

(30 Tuesday 1/30/12, Gerritsen and over 50 plaintiff representatives, New York City,  Public Patent Foundation lawyer Dan Ravicher

*http://www.alternet.org/health/153982/occupy_vs._monsanto:_activists,_farmers_fight_the_corporation_they_fear_will_take_over_all_america’s_crops?page=entire)

Monsanto begin to purchase as many seeds as possible—spending $8 billion and acquiring over 20 seed companies over the past decade alone. Today, Monsanto controls 93 percent of soybean crops, 86 percent of corn crops, 93 percent of cotton crops, and 93 percent of canola seed crops in the United States alone (31 through cite to note).

Monsanto is far from finished. To continue its corporate monopoly and push more seeds off the market, Monsanto specifically targets organic farmers, often testing their crops without permission. If the crops are resistant to RoundUp, Monsanto’s signature pesticide, Monsanto sues the farmer for patent infringement.

 In many instances, pollen from a neighboring farm growing Monsanto’s genetically modified crops can migrate to an organic farm, contaminating its crops. In addition to losing these crops and losing important organic buyers due to this genetic trespass, many organic farmers face undeserved, crippling lawsuits from Monsanto that force them into debt, bankruptcy, and often out of business entirely.

“Family scale farmers are the most in danger; all of us are hanging on by our fingertips,” Jim Gerritsen, an organic potato farmer from Northern Maine and president of the Organic Seed Growers and Trade Association (OSGATA), told Lekas Miller. “The thought of having to fight off a monster like Monsanto under false charges—and in this country, as wonderful as it is, anybody can sue anybody for anything—having to defend ourselves from a frivolous lawsuit could bankrupt any of us.” ( http://www.alternet.org/health/153982/occupy_vs._monsanto:_activists,_farmers_fight_the_corporation_they_fear_will_take_over_all_america’s_crops?page=entire Alternet/Personal Health – Anna Lekas Miller: Occupy vs. Monsanto: Activists, Farmers Fight the Corporation They Fear Will Take Over All America’s Crops, 6Feb12)

  “The U.S. Is Behind the Curve in Rejecting GM Foods” (through cite to note)

People around the world have joined forces to refuse GM foods and crops because of the dangers they present to biosphere and physiology and the future of the food supply. Europe, for example, eliminated GMOs from their food supply 10 years ago.

In the United States, however, because there is no labeling for GMO in the food, many are still not even aware they’re eating GM foods every day.

That’s because an estimated 75 percent of foods in U.S. grocery stores contain GM ingredients. About seven out of every 10 items in the average grocery cart have been genetically modified. And don’t bother reading labels to see if you’re buying a GM product, because no labeling is required.

 Why Genetically Modified Food in the First Place? The stated purpose for the development of GMOs is to increase crop yields, reduce costs for farmers, and to use less herbicide.

 Actual results?

  • No increase in yields: GM soy decreased yields by up to 20 percent compared with non-GM soy, and up to 100 percent failures of GM cotton have been recorded in India.
  • Increase in costs to farmers: “Terminator technology” is being used to create seeds that self-destruct. The seeds (and subsequent crops) are sterile, which means farmers must buy them again each year instead of using the seeds from their harvest to replant the following year, which is the traditional way.

This means bigger profits for the food companies that are patenting GM seeds, and more money shelled out from farmers. Worse still, this practice could actually threaten the entire food supply because the sterile seeds may spread to nearby fields.

  • No reduction in pesticide use: USDA data showed that GM crops increased pesticide use by 50 million pounds from 1996 to 2003 in the United States
  • Biotech firms claim they offer a genetically modified pest-resistant crop. Pest-resistant in this context actually means the crops contain their own built-in pesticide. So eating a GM plant, whether you’re a bug or a human, means you’re ingesting toxic pesticides.

The fact is genetic engineering is crude, imprecise and insidious. The process itself alters DNA and mutates genes. It’s a game of genetic roulette that can’t be won, and is ultimately dangerous. (http://www.celsias.com/article/who-benefits-from-gm-crops/

It has been proven GM crops do not fulfill their stated purpose. They have not influenced the escalating rates of hunger, poverty, food prices and environmental disasters” (http://www.naturalhealthstrategies.com/dangerous-genetically-modified-foods.html “ Everything You HAVE TO KNOW about Dangerous Genetically Modified Foods”)

“Jeffrey M. Smith, author of Seeds of Deception, and Genetic Roulette, asserts that genetically modified (GM) soy has decreased yields by nearly 20 percent compared with non-GM soy, and failures of GM cotton have been as high as 100 percent in some cases.  The irony is that supporters of GMOs originally claimed that they would increase crop yields, and would reduce both the costs for farmers and the necessity for herbicides. But the use of GMOs has proven to have exactly the opposite effects. Likewise, the use of GMOs has resulted in cost increases to farmers. Smith explains that “terminator technology” — which creates seeds that self-destruct — forces farmers to purchase more of the same seeds each year, instead of using the seeds from their harvest in the following year. As noted by Smith, this situation also results in larger profits for the food companies which patent GM seeds. Those seeds could pose threats to the food supply because the sterile seeds may spread to nearby fields.

Meanwhile, there has been no reduction in the use of pesticide. In fact, data from the USDA reveal that the rise of GM crops in the United States increased pesticide use by 50 million pounds from 1996 to 2003 (34 through to note). Smith pointed out that Roundup herbicide, which is said to be poisonous to frogs as well as placental and embryonic cells, has been used on 80 percent of GM crops around the world. In other words, what was once offered as a solution to a problem has created yet more problems.” (34 http://www.thenewamerican.com/usnews/politics/10731-kucinich-bills-would-control-gmos-good-intent-bad-policy  http://globalresearch.ca/books/SoD.html)

William Engdahl has research “Seeds of Destruction: The Hidden Agenda of Genetic Manipulation”. The  book focuses on how a small socio-political American elite seeks to establish control over the very basis of human survival: the provision of our daily bread (35 through to note). “Control the food and you control the people.” Engdahl takes the reader inside the corridors of power, into the backrooms of the science labs, behind closed doors in the corporate boardrooms. The author cogently reveals a diabolical World of profit-driven political intrigue, government corruption and coercion, where genetic manipulation and the patenting of life forms are used to gain worldwide control over food production. If the book often reads as a crime story, that should come as no surprise. For that is what it is.

Engdahl’s carefully argued critique goes far beyond the familiar controversies surrounding the practice of genetic modification as a scientific technique.  (35 http://globalresearch.ca/books/SoD.html, http://www.alternet.org/health/153982/occupy_vs._monsanto:_activists,_farmers_fight_the_corporation_they_fear_will_take_over_all_america’s_crops?page=entire

  • Herbicides and insecticides are potent environmental toxins. Where GE crops cannot deliver meaningful reductions in reliance on pesticides, policy makers need to look elsewhere. In addition to toxic pollution, agriculture faces the twin challenges of climate change and burgeoning world populations (36 through to note). The biotechnology industry’s current advertising campaigns promise to solve those problems, just as the industry once promised to reduce the chemical footprint of agriculture. Before we embrace GE crops as solution to these new challenges, we need a sober, data-driven appraisal of its track record on earlier pledges. THIS HONEST PROCESS HAS BEEN DEFRAUDED BY BOTH MONSANTO AND THE REGULATORY FRAMEWORK.
  • The government has the capability, and we would argue a responsibility, to conduct periodic surveys of sufficient depth to track and accurately quantify the impacts of GE crops on major performance parameters, including pesticide use. While the USDA continued to collect farm-level data on pesticide applications during most of the 13 years covered in this report, the Department has been essentially silent on the impacts of GE crops on pesticide use for almost a decade. This is why the groups listed in the Acknowledgements commissioned this study by Dr. Benbrook, the third he has done on this topic since 2002.

Authors of this report hope that it will help trigger new government and academic assessments of the performance, costs, and risks associated with today’s GE crops. Without such assessments, American agriculture is likely to continue down the road preferred by the biotechnology industry, a path that promises to maximize their profits by capturing a larger share of farm income, and limit the ability of plant breeders and other agricultural scientists to address other pressing goals of wider importance to society as a whole. (36 Dr. Margaret Mellon, Director, Food and Environment Program Union of Concerned Scientists; Mr. Mark Retzloff, Board Chair, The Organic Center, President, Aurora Organic Dairy. “Impacts of Genetically Engineered Crops on Pesticide Use in the United States: The First Thirteen Years”. November 2009 by Charles Benbrook, Ph.D. Chief Scientist, The Organic Center: Critical Issue Report: The First Thirteen Years The Organic Center.  Access the Supplemental Tables on The Organic Center’s website at: http://www.organic-center.org/reportfi les/ Supplmental%20Tables.pdf Access the October, 2004 report, Ag BioTech InfoNet Technical Paper Number 7, at http://www.organic-center.org/science.latest.php?action=view&report_id=158 )

Thank you again for taking my concerns into account on behalf of OSGATA against corporate criminal Monsanto.

“The earth is the Lord’s and the fullness thereof; the world and they that dwell therein. Ps 24:1

“ For as many as are led by the Spirit of God, they are the sons of God. For ye have not received the spirit of bondage again to fear; but ye have received the Spirit of adoption, whereby we cry, Abba, Father. The Spirit itself beareth witness with our spirit, that we are the children of God: And if children, then heirs; heirs of God, and joint-heirs with Christ; if so be that we suffer with [him], that we may be also glorified together.  For I reckon that the sufferings of this present time [are] not worthy [to be compared] with the glory which shall be revealed in us. For the earnest expectation of the creature waiteth for the manifestation of the sons of God.  For the creature was made subject to vanity, not willingly, but by reason of him who hath subjected [the same] in hope, Because the creature itself also shall be delivered from the bondage of corruption into the glorious liberty of the children of God.  For we know that the whole creation groaneth and travaileth in pain together until now.” Rom 8:14-22

I do not want to see the earth and creation on it have to travail more because of miscreant activities by Monsanto and its corporate chums that had been permitted by our society’s crippled framework.

Respectfully,

Andrea Psoras,

New York, NY 10026,

apsoras@gmail.com (212) 666 2569

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Psoras, Andrea: Structured, Thermogenic Diet or “The Diet”

Psoras, Andrea: Structured, Thermogenic Diet or “The Diet” (apsoras@gmail.com)

Note – to Bob Chapman (RIP) I am somewhat indebted for alerting me about Agent Orange soy and Agent Orange corn*

Subject: diet and antioxidants includes list on what to go ORGANIC vrs what not to because of the expense except for the pesticides on those veg/fruit not going organic. ‘Herbal’ list at the ‘end’ of the doc.

Introduction: With or without exercise, it is relatively easy to loose weight and/or enjoy better quality of life with this structured diet which uses a sequencing strategy starting first with liquids then eating food groups especially excluding/AVOIDING any gmo grain product coated with herbicides and animal product having Genetically Modified Organism(s) or ingredients, also known as “GMO” and associated herbicides (mainly Round-up, a high phosphorous herbicide and 2,4D, a dioxin ingredient herbicide).

WE NEED to rid our food supply and environment and thus OUR DIETS of GMO and associated herbicides*: http://www.regulations.gov/#!documentDetail;D=APHIS-2010-0103-4699 and live-stock pharma (bio-engineered product and associated herbicides) of any sort in the source animals.

Although this is not a comprehensive list of gmo ‘crops’, the main items and derivatives of these ‘crops’ are all chemical and biological warfare in the food supply, on your fork, your plate and for which you paid money at the supermarket, at the restaurant, etc, for them (policy ‘makers’ and a level above them who have contempt for you and your life, liberty and pursuit of happiness) to diminish the quality of your life and health and it is for these reasons that the regulatory framework was pummeled to let these dastardly items and ‘ingredients’ into your food to harm your earthen vesel and shorten your life, while sleazying your money from you.

Avoid: GMO -this list captures the main gmos in the US food supply – ‘processed’ food and environment:

  1. Soy and that includes soy lecithin as well as any meat, poultry, turkey, pork that would be fed this ‘grain’ because the herbicide and gmo engineering remain robust in some degree to hurt the livestock and you after you eat it as soy or in the BBQ pork ribs, – unless these were organic, and/or completely grass fed. “Free” range can be fed gmo grains, and “natural” both are labels which misrepresent safety and quality. Paper is ‘natural’ but you wouldn’t think to eat it even though it is safer for you to eat paper than gmo soy, which also has formaldehyde in it. Formaldehyde is a class 1 carcinogen and nothing you need in your diet.

  2. Corn and all derivatives unless either certified non -gmo or white corn, which is a small crop, short growing season, and doesnt have the ‘dent’ in the kernel. “Dent” corn is the gmo; it’s the ‘meal’ corn that is used in your Kelloggs corn flakes, et al as well as fed to your livestock you find in your supermarkets, aka, ‘grain’ fed. Avoid this food.

  1. Sugar-beets and the sugar in your candy, cereal, drinks of all sorts not labeled CANE SUGAR. Thank God, that Cane sugar is not GMO’d.

  1. Cotton seed – often among the vegetable oils and fed to hogs. States that grow gmo cotton have the highest obesity rates, the highest birth defect rates, infertility rates and lowest life expectancy in the 50 states of the US.

  1. Rapeseed and canola, also are ‘vegetable oils’ alleged to have low or no ‘transfats’. It’s idiotic to have issues over transfats when the herbicides and gmo will cause more harm and make hydrogenated fats a problem.

  2. Papaya, and zucchini and yellow summer squash and now also some apples and some potatoes are now allowed into the food supply. Again, go organic on these items.

Again – GMO foods/grains and associated permutations in processed foods: corn, soy, alfalfa, rapeseed, canola, sugar beets and sugar beet sugar (papaya, and zucchini and summer yellow squash) as this is used in virtually all juices, candy, and other similar sweeteners. Cane sugar actually is not GMO and is safer than GMO. SAFE NON GMO foods – all the greens, most of the fruit except papaya, avocado and yellow apples, some granny smith, sugar beet sugar. Look for the 4 digit tag or the 5 digit tag starting w/9.

On root vegetables anyway one should go organic.

This also is a low phosphorus diet (see bot of pg 1, top of pg 2) which attempts to avoid heavily herbicided/insecticided foods although that’s another body of knowledge for another time.

This food and strategy endeavors to achieve this while providing better nutrition, and killing candida Albicans – a yeast related, opportunistic and competing organism that lives parasitically in the bodies/digestive tracts, lungs, mouths, etc, of most people. The Diet promotes thermogenics. Thermogenics is when the metabolism is increased using foods that lead the body -contribute to burning body fat and/or where the food itself needs more energy to burn than the calories the food gives back to the body.

One will find this nutritious diet effective for youthful vigor, weight loss -if one wishes to use it for that purpose as the diet is a modified Fit-for-Life with Atkins**’ higher protein, lower carbohydrate, low phosphorus diet. Atkins however has little fruit and virtually no carbohydrates, while “fit-for-life” suggests eating fruit AT BREAKFAST ONLY before 12pm, but at lunch and dinner eating vegetables while at the same meal avoiding eating proteins with carbohydrates. For example, eat vegs + starch at one meal, while at next meal eating vegs + protein such as meat or fish or poultry or eggs), and suggests to avoiding eating after 7pm.

Including a faster metabolism and well-being, benefits are improved blood flow to the brain when one avoids eating proteins and carbohydrates at the same meal. The calorie burn also is far better by eating starches at a different meal than meats/proteins, etc and eating vegetables FIRST at both lunch and dinner – before one eats the more complex food such as a carb OR meat.

Again avoid all YEAST, including that in beer. Atkins’ book has an entire chapter on yeast (although Atkins writes about this when cattle became feed-lotted with steroids and pharma-antibiotics, and candida which flares when people eat feed lot cattle with that pharma /antibiotic and steroid contamination and thus the sugar-comfort food cravings) and its negative impact on the body, mind and emotions. Stumbling on both his insights and mine may be liberating for the user of this diet and/or supplements. People became more yeast sensitive with pharma in the feedlot livestock meat. Avoid this and go to grass fed and organic on meat, poultry, milk, eggs etc.

Candida Albicans and its pathology

The yeast family organism by the name of candida albicans causes many health problems often passed off as other problems. As a bane of the contemporary world and civilized life, Candida Albicans, or “c Albicans” is a living organism that will compete with you for the nutrition that you put into your body, while also competing for squatting space in your brain, lungs, stomach, mouth, lower digestive tract – anywhere in your body that is soft, damp dark tissue. It will circulate through your blood and will root in the liver. Rooting in the Liver, candida will cause the liver to produce, thicker, gunkier, dirtier blood. While depriving and killing the candida, perhaps parasites and other negative bacteria, the point of this structured food strategy using superior quality calories is optimal nutrition for one’s body and soul, and sense of well-being.

Heavy proliferation of candida may be a precursor to liver cirrhosis, lung problems, colon & stomach problems, perhaps even melanosis coli stubborn weight gain which also probably is a by-product of gmo+herbicides which foul with the digestive tract’s enzymes. This fouls with the digestive process that also can contribute to weight gain. The Candida’s chemistry ie, its ‘pathology’ in people usually are the physiological root of most cravings (as well as perhaps feeling fatigued, sleepy, depressed, depression, irritable and habits such as eating for ‘comfort’ or eating when depressed or nervous, lack of concentration/mental focus, cigarette smoking, craving for alcohol. When detoxing, sometimes I’ve gotten that skin-crawling-listlessness and occasional nausea which passes after up to a few hours, but is quite annoying while enduring it).

Candida is related to other spores such as molds, mushrooms, etc. THESE ORGANISMS WHILE DYING OFF will produce cramps and gas and WILL AND DO HAVE THEIR OWN CRAVINGS, WHERE WHILE DYING THE CANDIDA ORGANISMS WILL IMPART ‘HUNGER’ FOR THAT WHICH THEY ARE HUNGRY – COMFORT FOOD (any of the above that has ingredients such as sugar that usually help proliferate their life cycle) – THEY WILL IMPART THAT HUNGER CHEMISTRY TO THE ‘HOSTS’ Who is YOU! Your BRAIN, LUNGS, AS WELL AS IMPART THEIR PATHOLOGICAL CHEMISTRY TO OUR MINDS (AS THE ORGANISMS’ DEATH CHEMISTRY exists, AND IMPARTS that chemistry TO US) which produces THAT ‘FEELING’ DEPRESSED*, ANXIOUS, REJECTED, DEJECTED, WORTHLESS, NEGATIVE, EMOTIONALLY VULNERABLE. These sorts of ’emotions’ also can be from the wifi pollution that baths us undetectable to the naked eye, but has communication in it that only at higher band widths can the ear hear. At lower band widths, the wifi will carry communication that is inaudible however because those waves operate at roughly the same wave length as brain waves, the brain receives this wifi communication and processes it, whereby the person thinks it is oneself, rather than realizing it is independent of one’s mind. This Diet isn’t quite the forum for explaining what else is going on with society that the individual is encountering and can influence one’s reasoning including diet choices and even influence what happens in one’s body or exacerbates the clean up process from candida albicans and transitioning to a clean, thermogenic diet.

Candida organisms cause cravings for, and the desire to ‘taste “Comfort food” such as bread/yeast, dairy, sweets, alcohol*, tobacco, drugs. As I’d mentioned above, some of their chemical blow back signs are depression, PMS and cramps, phlegm, slow colon (even organic soy will slow the colon in some people, but gmo soy is a terrible addative and it and candida probably also spur melanosis coli in some people’s colons, sinus headaches and migraines (although regular migraines and bi-polar are from a parasite which has positioned itself on the hypothalamus and imparted its own chemical interference with one’s brain chemistry). (NOTE TO alcoholics – Alcoholics frequently have poor diets and often have severe candida problems. Getting them immediately to optimal, anti-candida nutrition will give you better traction against the alcoholism). Poor diet with antibiotic polluted dairy and livestock (ie, ‘treated livestock, poultry, eggs, cheese, etc) and red meat from feed lot livestock and/or livestock fed grains, devoid of B-12, excessive amounts of beer and alcohol, and insufficient exercise, sleep, sunshine all together or abundance alone promote candida proliferation colon, uterus lungs, brain and mouth.

The glyphosate ie, the high phosphorus herbicide by monsanto ie Roundup (and high sweets-comfort food diet) fertilizes the Candida Albicans which are ‘opportunistic’ organisms, which means they plume when the body’s run-down condition permits their proliferation. These organisms are negative and dysfunctional in the body, and will reduce one’s vitality when simultaneously competing for proper nutrition against the beneficial bacteria in our bodies. The candida generally will proliferate over the good bacteria in one’s digestive tracts, UNLESS one takes proper nutrition and life style steps, as well as a separate supplement first thing in the morning and before meals, such as a lacto bacillus supplement. Lacto bacillus “LB” products such as All Flora (use if possible one without soy), or Daily Dophilius by Country Life (although the flax seed in this is a problem for people coming out of phosphorous problems), or Kyodophilous, and Primadophilus bifidum, are effective. LB are important organisms although from foods such as yogurt, beets, carrots, radicchio one can find natural lacto bacillus. Enzymes too are key. Rainbow Light has a good enzyme product except for the tumeric, which is another high phosphorous herb.

GMO and herbicides such as dioxin (2,4D), glyphosate (Round-up), and high phosphorous aggravate-flair the yeast and candida. And the bio-tech of the feed-lot growth hormones and associated animal (and people) antibiotics also spur the candida/yeast problems. Actually going organic significantly lessens the problems of phosphorous blowback, because going organic minimizes the gmo and Roundup (glyphosate, which is high phosphorous) in the body. Foods such as organic poultry or quinoa or kasha/ buckwheat or organic peanuts or nuts are less aggravating and less likely to cause fluid retention after a period of time. Otherwise the Round-up and any additional phosphorous load contributes to fluid retention, sciatica, bloat, numb limbs, feet, hands, and other build-up of phosphorous in the capillaries, even sore teeth roots. Cycle out of all foods with gmo ingredients & herbicide contamination and do large doses of dandelion in any form, black raspberry (battery of OPCs), vits E, C, and fish oils and evening primrose oil caps ALL from non gmo origins.

Other Physiological blow back from yeast Remember yeast is a living organism and spore. GMO and herbicides which themselves make gunky blood and harm the liver, but the GMO and herbicides contribute to Yeast gunking up-fouling up the liver with its own root system, interfering with the proper functioning of the liver to cleanse the blood, causing the liver to pass along dirtier, thicker blood, while causing body odor and the other candida problems, etc. Eliminating GMO/herbicides, yeast and most white refined sugar (especially GMO beet sugar) and/or dirty dairy (antibiotic and stimulant hormone laced, and full of parasites such as shigella and e-coli causes gas and PMS like chemistry and thus those moods and emotions in men and women.

On Children, Babies and their taste buds/desire for ‘sweets’ picky eating and colic:

If you ate sweets, bread and a great deal of dairy and eggs from antibiotic and hormone treated and feedlot/gmo grain fed dairy cows and chickens, and indulged your Candida while you were pregnant, your children usually will be born with Candida Albicans. You can remedy this with cleaning up your diet while breast feeding although babies will be sensitive to the garlic and other quality anti-oxidant Candida killing upgrades in your diet. This will cause them some gas until their Candida are killed.

I am not certain if this takes a day, a week or a month, however avoid giving them formula from soy and other grains from gmo crops, and avoid formula from milk with the dairy from cows treated with stimulant hormones and antibiotics especially if you are avoiding this yourself, avoid also using soy based formulas as well as BigPharma formulas in general. If you are getting proper nutrition and vits/anti-oxidants, that will pass into breast milk. While they are growing, avoid foods with white refined sugar, sodas and other ‘juices’. Clean water and clean milk from non-antibiotic polluted, non-gmo alfalfa fed livestock will be the better beverages for them with limited amounts of quality pure, non sweetened, juices not from concentrates. And if they’ve been given vaccines, make certain they get sufficient B vitamins, using baby vitamins that one can find at the better health food stores. Or Go to vacuum packed organic such as Parmalat’s vacuum packed milk OR TRADER JOES GALLON ORGANIC MILK- I FREEZE THIS AND IT CAN BE THAWED AND REUSED – AND I BOIL IT) from the diet, generally eliminates body and scalp odor and the ‘garlic on the breath’ after used as a liver cleanse or cold remedy won’t be so bad, but several cloves of chopped garlic in kefir (drinkable yoghurt of dairy from untreated animals – home made kefir from boiled non-pharma milk is best) and taken at night or first thing on an empty stomach is good for the liver and to get rid of colds.

Diet suggestions and tips – avoid all GMO grains and foods with GMO ingredients from those grains that also are polluted with the herbicides* and unwind from the GMO insecticide characteristic -which is an e coli like behavior. THERE IS virtually NO PROCESSED FOOD ON THIS STRATEGY by going to a diet that is: yeast free, processed food free, white sugar -free, bleached-bromated white refined flour free strategy, ie eliminating all foods with yeast, and all processed foods. This includes no bullion cubes, no lipton packaged soups. No fruit juices except 100% pure fruit juice so to avoid the gmo sugar beet sugar.

There are Non Yeast breads sold at the better health food stores found in their freezer cases. One needs to read ingredients in any processed carbohydrate as yeast is found in saltines, most crackers and virtually all pretzels, so low fat or low sugar isn’t always the issue, it’s also a yeast issue and what feeds the yeast spores for reasons I explained. Then there are the GMO vegetable oils in many foods. Those also carry the herbicide load and are toxic to health and slow the metabolism.

On this diet there is no yeast bread, or other yeast products, refined white sugar, or things made with white or brown sugar, or in general processed food, except matzo or similar cracker such as Ryevita. Further, eliminating virtually all white refined flour and white refined sugar mitigates cholesterol build-up and plaque in the circulatory system. Bleached and bromated white flour – this and white refined sugar gunk up the liver, and reduce efficiency in proper fat digestion and cholesterol ‘development’/use.

As a result – use breads without yeast, sometimes, although even some slow rise and natural rise are with yeast, however, ask – known as ‘slow rise’ or ‘natural sour’ found in the better health food and sometimes better super markets. I would not recommend this and I have suffered when taking the risk on bakery ‘slow rise’ or natural sour bread. Plain Matzo and pasta are safer.

This Diet recommends dairy and meat from grass ONLY-fed livestock, while avoiding feed lot cattle (most red meat and pork at this point unless labeling states otherwise – this generally is the meat found in the supermarket meat section and will not state it is ‘feedlot’ although it may say ‘corn fed’ or grain-fed or even black angus, unless it is labeled ‘grass-fed’. Even “natural is a bogus label which doesn’t mean the meat was from livestock raised eating grass its entire lifetime.

These too have been fed GMO grains, gmo alfalfa, gmo beets and are contaminated with that and dangerous herbicides) processed meats, etc, hot dogs, sausages, and meat w/livestock medicines such as antibiotics or growth hormones and processed/artificial smoked fish, farmed fish, or pharmaceutically treated fish, poultry, livestock, or hogs and all also excluding artificially smoked meats. Avoid ‘pulled’ beef and pork, both which have vinegar and often also are from feedlot livestock and hogs.

Similar to Atkins, The Diet recommends fresh fruits/vegs/ organic kefir, and organic eggs, and perhaps some occasional whole grains such as buckwheat or river rice, but NOWHERE NEAR THE CARBS AND/OR YEAST CURRENTLY FOUND IN MOST DIETS.

*LIST OF WHAT TO BUY THAT’S ORGANIC in this list: milk, eggs, grass fed meat only, poultry, US cheese.

NON GMO here ARE OK in this group-list: olive oil, palm, coconut, peanut, sunflower, VEGS green leafy, avoid iceberg lettuce because of all the insecticides on it. Use escarole, dandelion, green chard, mustard and turnip greens; European cheese as long as it is from grass fed only live stock and that is difficult to know unless organic which in most cheese from the UK one shouldnt assume is grass fed only, and wild fish only.

Ecoli – the insecticide characteristic contributes to eating at soft tissue – liver, colon-sigmoid colon, perhaps also the heart, however what was genetically engineerered into the grains to eat at larvae eating at roots of gmo crops, this characteristic remains robust across the ‘kingdom’ boundaries, up through the food chain. It will eat at the soft tissue of livestock and people, and people eating livestock which have eaten the gmo, after a delayed period of time will encounter colon or other organ problems that the medical profession has made spurious correlations to other roots, rather than properly attributed to gmo the tissue eating problems playing out in the organs, digestive tracts, circulatory systems of people.

On Cholesterol, and lipid issues such as sciatica

This diet has virtually no white refined sugar or bleached white flour both, nor processed foods with GMO/herbicides all which gunk up the liver and foul with clean cholesterol production that the body needs for itself for nervous system and proper brain nerve/chemistry function. Without what are clean fats and lipids that the body and nerves produces for itself, the body by way of the nerves will ‘electrocute’ itself. Sciatica and cramps are an example of this. The nerves in the muscles and brain need the proper cholesterol and clean fats (omega 3,9, vit e, unsaturated fats), so small amount of clean cholesterol one ingests via organic eggs and organic milk given the other foods , greens, and vits like the Deva Vit E, the Oil of Evening Primrose, the Fish oil, and the Astaxanthin on this diet deters bad cholesterol buildup.

The diet includes many fresh fruit and vegetables – grapefruit, including other items for metabolic increase and cruciferous vegetables, fat burners, grass fed livestock while avoiding feed lot, hormone fed dairy and livestock, all which counter any negative effects of clean cholesterol in the diet. REMEMBER this diet avoids all processed food, food with gmo and herbicide ingredients, and triglycerides are found in ALL OF THAT. Chicken and Eggs from poultry raised on organic grains and without antibiotics or other pharma used on poultry on this diet are ok and perhaps the clean milk, which naturally have ‘cholesterol’ but from clean livestock, will be safe for one’s circulatory system.

Avoid food cooked in or cooking in metal pots, pans – unless enamel or ceramic lined. Cook in oven/stove Pyrex or ceramic, or enamel lined cookware – Martha Stewart, corning, Pyrex, a French brand for enamel lined all are very good. AVOID ALUMINUM FOIL OR ALUMINUM OF ANY SORT NONE, NOT EVEN FAST FOOD CONTAINERS…. ASK FOR THE PLASTIC or paper take-out containers on this structured eating plan.

Avoid sweets and products of beet sugar – as this is gmo, (and cane white sugar minimize although cane isn’t gmo), processed food, yeast/bread, items with baking power especially those with include aluminum or phosphates**. If possible avoid leavenings and also IF POSSIBLE, substitute YOGHURT OR MOLASSES FOR THE ACID TO ACTIVATE if one is using baking SODA. I’ve done a great deal of baking however and actually one can avoid any leavening agents except cream of tarter or organic egg whites beaten stiff, unless the recipe doesn’t call for eggs. Most cookies and baked goods however call for leavening which can be eliminated from the recipe with very little negative impact and taste difference. Baking times may be a little longer depending on how dense the batter is.

** DANDELION (and enzymes) HELPS ADDRESS THE HIGH PHOSPHOROUS MATTER – DANDELION TEA, GREENS, CAPSULES, ROOT – Note on phosphorus, phosphates and oxalic acid/phytic acid foods foul the circulatory system, liver, kidneys. AVOID or at least LIMIT concentrations of these which one finds in baking powder, oats, fonio (an African grain) Quinoa, buckwheat, soy, peanuts, nuts in general, cheese, poultry, colas and naturally carbonated beverages are bad for oxygen flow in the muscles, spinach (raw is worse than cooked), coffee, chocolate, ‘black’ and ‘green’ tea, chocolate.

The candida love certain chemicals and the “inflammation” – the swelling is their allergic reaction as well as the phosphorus blow-back on the body perhaps acting as fertilizer to the candida. I also get this reaction from nitrates and nitrates in most smoked foods, smoked fish but not from naturally salty foods such as celery. I also suggest higher use of dandelion tea, dandelion herbal capsules, dandelion root and dandelion greens which are effective in mitigating phosphorus concentrations. And go organic, ie free of gmo and herbicides!

This diet will generally fix circulation problems and high blood pressure, with the use of the L-carnitine to deal with fat buildup in the body, perhaps blood vessels. Generally, the diet will also eliminate fluid retention if one avoids the high phosphorous, high phosphate, and refined foods/refined sugars, vinegars, and avoids yeast/bread products generally avoiding what flares the candida albicans, when aggravated will produce fluid retention and stiffness in the joints due to the fluid retention.

Use some sea salt and/or ‘fish’ sauce, an Asian condiment found in Asian food stores. Avoid sodas-carbonated beverages, or coffee/tea as these will impair the proper function of the kidneys. Sometimes I chew bitter cola one can buy sometimes at West African stores but a ginseng supplement is also ok.

Switch to Yerba Mate, a South American beverage found in many of the Latin and South American bodegas in New York and perhaps elsewhere. One also on the web find Yerba Mate and can mail order it. Put yerba mate in a search engine and that should produce sites from which one may order the beverage. Mate has vits B5, B6, potassium and magnesium.

Boil all milk (organic) although most people can handle any negative bacteria in organic dairy. Boil Dairy in stove top capable ceramic, Pyrex, Corningware or enamel lined stainless steel or enamel lined cast iron. Boil or cook all dairy before eating accept yogurt –organic stonyfield is ok – plain is best, however home made kefir is better and easy to make… Switch to ORGANIC (TRADER JOES and Whole Foods 1 GALLON CONTAINERS WHICH CAN BE FROZEN) or any other that says it does not use the PbST or the rBST hormone in the milk ie from ‘untreated’, grass fed only cows, or is organic. Typically if farmers are avoiding using stimulant hormones, they also will avoid using/abusing their cows dairy pharma/antibiotics.

The dairy antibiotics cause serious problems such as disruption in the liver, and gut chemistry, and skin lesions as a result from their impact on the physiology as well as the eventual candida and parasitic build up in the digestive tract that will cause skin lesions and other deleterious conditions in the body, scalp/skin. If they’re using gmo grains however the cows will get sick and will need pharma unless the cows go grass fed and hay only/NON GMO-non gmo alfalfa.

To make ones own kefir (drinkable yogurt): boil the milk (to kill the bacteria – watch it, however it shouldn’t boil over unless it’s been cut with water) half gallon milk using better names such as organic or vacuum packed Parmalat Organic which does not have to be boiled because it already has the bacteria killed. Neither have the Pbst or rBst Hormone) in an enamel lined pot or boil in ceramic bowl in oven. Let cool to room temperature or refrigerate.

And unless in a half gallon plastic, capable container – already having a previous mixture and one is replenishing, otherwise open 4 lacto bacillus capsules into cooled mixture and cap and shake, or if still in large bowl – stir in and let sit overnight in a warm place to ‘yog’…. It will thicken and will get even thicker when cold. Have this with fruit, alone before in the mornings with the capsules, with other gut cleanse products when mixed with filtered water… or at night with chopped garlic or for tzatziki… It is a loose yogurt and can be used in place of butter milk, kefir! (or replace (clabbered) milk /use baking soda in baked goods and back with either milled dried cane juice, but no white refined sugar, and perhaps turbanado, molasses, organic honey ( on from hives far away from gmo crops), maple syrup, rice syrup (rice too now often is contaminated with arsenic), corn syrup – but this isn’t the best thing to use as corn virtually always now is Genetically modified.

Condiments, Vinegar, and Legumes

Avoid these in as much as possible if one is very candida- craves pizza, bread, other similar comfort foods, sweets of any sort even diet sweeteners, diet sodas and obsessions with any of this, habitually indulging in any sort of this, rationalizing it, feeling it is necessary to taste or have SWEET – unless it is a piece of fruit at breakfast or before some sort of fitness, an afternoon lift or after dinner break.

While beginning and on this diet, one is killing the candida and other bad bacteria which actually cause the cravings (and one must eliminate the use of ) for sweet, vinegar, soy sauce, alcohol, etc as candida dwells in one’s body and circulates through the blood stream: ears, nasal cavities, nose, mouth, brain and lungs (for cigarette smoke, which has the sugar from the tobacco leaves, and the brain and lungs crave it and the nicotine). So these negative organisms in their life cycle will die anyway, and as a result their life cycle will crave sweets and the above listed things that promotes their thriving which to you is headaches, sinus problems, depression, foggy mindedness, anxiety, poor circulation, gas and gastrointestinal problems.

This Diet also excludes all SOY in any form. Soy is a legume on which the candida feed. I suggest also utterly avoiding GMO foods such as non-organic corn, soybeans; virtually all corn and soybean product, canola, rapeseed, cotton seed, beet sugar are from GMO. Moreover, Soy is not native to the ‘western’ diet. And, given its amino acid profile because of its glutamine content beyond that of normal-meat protein, as a protein Soy is inferior to wild fish or meat from grass fed livestock, and or organic poultry, however, if one eats those grains and legumes, go organic. Even organic soy can slow the colon, so I suggest for those who are legume sensitive, to avoidd even organic soy.

Avoid vinegar in general as the candida thrive on it. Vinegar gives me three or more days of fluid retention, and gurgling gut. One finds vinegar in most condiments. So avoid those and make your own mayonnaise and mustard. There are recipes for these and one can substitute lemon juice for vinegar. One will find Vinegar in virtually all ricotta and cottage cheeses, and of course in many cured and pickled foods, olives and yes without question virtually all bottled salad dressings. As a general diet clean-up, the diet avoids use of commercial mayonnaise (unless home made with lemon juice and olive oil), soy sauce, vinegar, mustard, catsup. And if you use them, you may have a swelling, fluid retention reaction.

The candida in the mouth are craving to taste sweet. Understand this and avoid letting this/these spores manipulate you. So deny the spores their lust to proliferate their lifestyle at your expense, and bless yourself in the process. The more powerful and greater proliferation of their chemistry and pathology of these negative organisms in the body, mouth, tissues such as digestive tract, that chemistry’s signal in our minds and mouths is to crave, feel sleepy, grouchy, PMS, depression, a number of different manifestations at different times…while the candida want to live and steal nutrition from the beneficial organisms and our bodies’ needs.

Sequential eating At a meal, first have hot beverages such as herb tea or soups. Then if you’re inclined to drink things like tomato juice, something like tomato juice have these after the hot beverage or soup – no hard and fast rule about hot before cold, but I do hot first. Then have the vegetables and/or fruit ( I GENERALLY do fruit AT BREAKFAST ONLY), but after any capsule supplements that one takes. The new info on the capsules is that when from commercial cow bone gelatin, these have pollutants, MSG and gmo in them, optional – break open the capsules and put into kefir or vegetable juice before the meal.

After eating the fruit at breakfast, then if you want vegetables, celery or cabbage, etc have these and then after that, one would eat their carbohydrates or proteins. At breakfast last – eat hard boiled organic eggs, as there is nothing in this diet to promote problems with the cholesterol in the eggs, one can eat as many organic eggs as one wants, although one should increase the use of garlic and dandelion in any/all forms in the diet to cleanse the liver… On this diet I suggest using only organic when eating root vegetables … where the most pesticides and polluting fertilizers are used. At one point I was avoiding produce from Texas, where I’d heard there farms use human effluent for fertilizer. Human effluent, ie, human sewage is very polluted. I phoned the farmer however and spoke with the manager to drill down on the accusation; I was told that no such thing was used by that ag enterprise of which I was finding that produce in my NYC supermarkets.

Avoid eating carbohydrates and proteins at the same meal: proteins and carbohydrates, such as pasta or potatoes are not had at the same meal. Eat meat or proteins with vegetables and eat starches with vegetables.

OK: spices, herbs, fresh ground pepper, sea salt, are all fine, even ‘fish sauce’, olive, palm, peanut are OK. Supposedly cider vinegar doesn’t cause inflammation however I haven’t experimented with this.

OK Carbohydrates eaten occasionally and sequenced after vegetables: buckwheat (although this is a high phosphorus grain), organic polenta or cracked (organic or non gmo) corn, other whole grains such as millet, river rice, brown rice although the later 2 are high in phosphorus.

Avoid margarine unless nongmo – although I suggest also avoiding soy even organic or non gmo soy. Use olive oil and organic butter if possible. I also generally avoiding anything from cans, although I will eat canned WILD salmon – you can tell by the date on the can the farther away the expiration date, the fresher the salmon. Or wild, white fleshed fish is also good.

Use grass fed meat, organic poultry or game and fowl

Breakfast. It is better for the metabolism to have a decent morning meal. Start with hot Yerba mate beverage (or Wisdom of the Ancients ‘tea’ bags/boiled water) first. Even Dandelion teas and other like (although I avoid green tea. It gives me inflamation and that’s nothing anyone needs.) KEFIR (home made and organic) or organic yogurt also are important. Then fresh fruit – Green apples -peeled/cored unless organic but wash with soap and water and dry the surface of all fruit whether or not one is paring the fruit, citrus. And/or other fruit… option to include but not necessary although one will feel less hungry for longer and eggs are thermogenic: Hard boiled organic eggs, OR organic oat meal (a high phosphorus grain), or hot cereal or non gmo grits that are unrefined with no white sugar (especially no beet sugar or artificial sweeteners or rice syrup as that also often is from gmo rice) or brown sugar.

Lunch: perhaps fruit first but rather veg juice before then steamed or raw, well washed with a vegetable wash then rinse to eliminate the pesticides unless organic (then washed anyway) fresh vegetables, either more clean protein such as plain yogurt of roasted goat or another sort of grass fed organic meat or – but not at the same meal with pasta, brown rice, or another whole grained boiled/steamed like rice. Perhaps a baked potato not baked in foil AVOID ALUMINUM FOIL. AVOID STAINLESS STEEL AND ALUMINUM POTS AND PANS. For cooking, baking – PREFER ENAMEL LINED, cast iron OR CERAMIC.

Remember avoiding carbohydrates and proteins at the same meal after your vegetables will give you more energy and help your brain/mental activity after your body has somewhat detoxed from candida.

Dinner: – perhaps veg juice before, then raw, steamed or sautéed vegetables, and clean protein, OR complex carbohydrate. Meat or poultry from organic and/or grass fed livestock/poultry or Nuts from the shell or raw nuts from the bulk bins are fine. Avoid dry roasted or when a non-gmo oil is used to coat the nut so that the salt sticks. Nuts and seeds between meals is ok although if dealing with phosphorus buildups, balance with dandelion  in any or all forms. Again, meat and carbohydrates are not eaten at the same meal.

Other product tips, suggestions

Switch to glycerin soap or tea-tree oil and/or Grandpas pine tar soap when you can for face/scalp, and avoid detergents on your skin, etc. I also have begun to use Ivory Soap which is actually very effective to kill bacteria without additives and Kirks coconut-soap, or olive oil soap. Ammonia will cut the film on the bathtub and sink surfaces.

Herbal/superfoods

A special supplement for enzymes (Rainbow Light Advanced Enzyme System) is key to improve the digestive process to extract complete nutrition in the food where the enzymes promote improved bio-availability for the body, head … Go with the Vits first, and if purchased all at one time, the entire group can run between $400-$500. Additionally, good vitamins often will have enzymes. My brand is “SuperNutrition”

NOTE: herb capsules sadly often are gmo. Via Amazon and some good enterprises that sell empty non gmo gel caps, I suggest and although time consuming, if bottle says NO GMOs in the product, then the capsules are probably fine. IF however there is no labeling about gmo and the manufacturer’s customer service either confirms no attention to non gmo or fails to respond to at least a couple of attempts for information, then you’ve got gmo capsules. I suggest in the list at the end of this doc, when ordering through amazon, confirm if the product is labeled for NO GMO ingredients. If the manufacturer cared to have no gmo gel caps, often this is labeled and is worth the marginal difference in expense. At some point I will get around to indicating which are non gmo and which are gmo gel caps.

Anti-parasitics and colon products – although all are good for the colon

1) Parazyme made by Renew Life for digestive enzymes, which makes the anti-parasitic I use. And any good anti parasitic as above, Paragone, Parasitin, and any other good herbal anti parasitic will kill candida albicans, although there are also supplements to kill candida albicans. Parasites thrive in a chemistry of contamination…I have suffered from parasites at least Twice – a ruptured appendix (appendicitis is caused by a microscopic parasite behind the appendix), and at another point I passed an enteric parasite. So a diet low in processed foods, most hormone/antibiotic laced commercial dairy with is teaming with shigella and ecoli ( for that reason even organic milk, but generally organic is a little better), sweets, but high in garlic, onions, cruciferous vegetables food from untreated animals diminish parasite aggravation.

The GMO has e-coli also engineered into the grains to serve as an insecticide the monsanto and dow? Scientists designed to ‘kill’ the larvae that eat at the roots of the gmo grains. This insecticide/E-coli characteristic remains robust across physiological boundaries and continues to do harm regardless of the physiological turf: people, insect larvae, hog or cattle gut. This is difficult to remedy using conventional anti-parasitic methods and 1 time use of anti-parasitics, and limited use of herbals, vits and high quality diet.

IT takes AGGRESSIVE STEPS IF ONE IS ENCOUNTERING COLON ‘ISSUES’ WHICH ARE WHAT ARE NOW CAUSED BY THE GMO AND HERBICIDES IN THE FOOD, AS WELL AS THE PHARMA IN THE LIVESTOCK, DAIRY AND PARASITES IN THE DIRTY DAIRY. THIS BAD COMBINATION HAS MOST PEOPLE IN THEIR DOCTORS’ OFFICES AND UNDER THE SURGEON’S KNIFE.

THE NSA, THE HENCHMAN THAT CONTROLS THE MEDICAL PROFESSION AND IN GENERAL MOST OF SOCIETY, HATES THAT YOU CAN REMAIN OUT OF THE MEDICAL SYSTEM AND PERHAPS EVEN YOUR DOCTOR’S AND DOCTORS OFFICES THROUGH ABIDING IN AND RESPECTING THE LORD’S GRACE, ASK FOR HELP FROM (AND HAVE RELATIONSHIP WITH) HIM FOR COURAGE, AND WHAT I’VE PROVIDED HERE TO SAVE YOUR HEALTH, COLON AND IMPROVE YOUR STRENGTH IN THE LORD YESHUA! AND BY HIS GRACE WITHOUT THE DOCTORS, DRUGS, AND MISERY. ROM 8; 1JOHN 3:1,2; HEBREWS 12.

2)Grapefruit seed extract +other astringent herbals- Nutribiotics

3)Cloves and Wormwood extract – both made by Q-W & Company. the wormwood herbal has cascara. this is good, but to be used cautiously. Perhaps 1 cap at a time and see the effect. One also can make their own capsules of these and buy the empty caps and bulk powders or herbs at a local store or Amazon, or on-line. Wormwood however is a high phosphorous item so i had to go off it.

4)Bentonite or montmorilinite liquid by Sonnes’ No7 treatment or Great Plaines (Sonnes hasn’t gone gmo free on its other items so I stopped using Sonnes) – that helps keep down negative bacteria in the lower digestive tract and very effective if interested on detox efforts and when fighting candida albicans. Very effective although I don’t use every day as others may and do. I use Sonnes’ No. 7 occasionally when I am having blowback from ecoli/shigella. Another capsule known as “Perfect 7” also includes montmorilinite. With regard to other Sonnes products I have encountered misrepresentation with regard to it calling itself an Organic food company, but using GMO soy in its Vitamin C product and GMO papaya seed in its enzyme product, which uses organic beets but has failed to disclose origin of the Papaya as well as the soy. Failure on producer’s part to be willing to disclose ingredient quality or origin often means it’s gmo and/or or risky, or questionable origin like from China were production and agriculture are from a highly polluted environment.

5) Everyday Fiber System Powder – by Rainbow Light (at this time out of production) and has not been put back onto the market. My conversation with Rainow Light management has found it wanting and unprofessional in its fecklessness, or targetted by the NSA to give up ground to restore availability of this effective product. It also has an enzyme product – Rainbow Light Advanced Enzyme System, which is fairly good except for the tumeric, a high phosphorous root. I also use Zoganic’s enzyme product, which has no inflammatory ingredients. 

6)Cleanse Smart by Renew Life, any other gut scrape/gut cleanse product such as the except for the corn silk which concerns me if gmo. Renew Life also has another colon product which has flax seed, a high phosphorous product and unnecessary in this mix to achieve good/better colon health.

6A) Naturalax 1 or 2 or 3. By Nature’s Way. Combinations in various mixes of cascara or aloe vera plus other herbs effective for the colon although none of the Naturalax indicated here include Senna, which is a legume. I avoid Senna in all forms. Naturalax products have laxative properties and will kill candida which if one has a dirty diet or recently cheated, that will cause gas. As these capsules were gmo, I twist apart the cap and pour some of the powder into water with dandelion drops and powdered dandelion root as well also as Great Plaines montmorilinite, and digestive bitters such as “Organic Digest Maple Bitters by Urban Moonshine, which I buy through Amazon.

Naturalax IS A VERY POWERFUL GROUP OF HERBALS. USE THESE ONLY IF ONE IS ENCOUNTERING NERDLING AND/or CONSTIPATION FROM GMO and soy MISHAPS. IF ONE NEEDS TO USE, USE THESE IN THE BEGINNING WITH SIGNIFICANT CAUTION AS THEY ARE QUITE POWERFUL UNLESS ONE IS HAVING COLON ISSUES FROM THE GMO. FEEL FREE TO EMAIL ME ABOUT DEALING WITH THESE MATTERS AND THESE PARTICULAR HERBALS.

7) lacto- bacilius supplement often found in the refrigeration case or on the shelf in PB8 or Kyodophilus or All Flora or Country Life’s Daily Dophilus without the soy. Excellent reasonably priced product. I use another Country Life product as well as NOW’s Probiotic -10 (for 10 probiotic strains), “25 Billion”

8a)Dandelion tea (Alvita or Traditional Medicinals), dandelion capsules, dandelion root by Starwest (which I grind to fine powder in my Bullet) and other herb teas like cranberry tea in form more pure than Celestial Seasons and cranberry and raspberry teas are very good for the liver and kidneys. Even the roasted dandelion root, ground up and added to food, water, taken off the spoon works but isnt then focused to do work in the colon that putting it into capsules will do. Also Dandelion root in 1lb bags roasted or dried (Starwest or others which one may find in bulk on Amazon).

I also began using 8b) Olive leaf powder and one can make their own capsules. This is said to be a good blood/liver product. Too soon to tell if it’s effective like dandelion products. Actually however Olive Leaf powder and 8c) Oregano oil caps have made my bowel movements more ‘frequent’?, softer and probably is attacking candida.

9) Tumeric – I make my own 1000 mg caps from the bottled powder fairly easily found and empty gel caps sold in most sophisticated health food stores (see Health and Harmony contact info below) or Amazon. I’ve been off this for a while because tumeric is a high phosphorous herbal.

10)OPC- pycnogenol 100mgs or Pynogenol or French Maritime Pine Bark Extract (by Vitamins Because although this company more than tripled its price for its product which in the past was a great buy and I would buy more and use more), an excellent supplement but I am very sensitive to the green tea extract in it in one of these products that makes a combination of Pycnogenol and green tea…. however, I am sensitive to the green tea extract in anything, so I generally avoid all supplements with green tea and anything with additional phosphate bonded elements such as calcium which is used to add ‘calcium’ unnecessarily while attempting to keep the anti-oxidant ingredients in the body for longer so the green tea acts to slow the function of the kidneys. I also purchased 90x300mg Caps, 100% Pine Bark Extract, 95% Proanthocyanidins, FREE SHIPPING by Lifeline Nutrients

One should take the tablet supplements after food and be certain to take enzymes to promote optimal digestive function to extract optimal nutrition from the supplements for the body’s and brain’s use.

11)OPC –Grape Seed Extract 100mgs, or bilberry (by Natures’ Way); and/or or black raspberry (by Genesis Today), and/or Red Raspberry caps by “Natures Answer

12)Green drink/tablets of spirulina and chlorella – Green Energy by Super Nutrition. or Earthrise Spirulina Greens blend Or E3AFA is another good green product. I’ve purchased Allied Life Spirulina and Chlorella, and E3AFA Blue green algae. Or Earthrise, Supergreens and more as mentioned above. Best Earthrise product in this type, but now gone was its “Ultra Energy Plus”. This was an outstanding product that sadly I suspect the NSA gooned because it was so amazing in terms of welll-being and energy.

13) Germanium Sequioxide (by Jarrow) however, I haven’t used or purchased this in years because I haven’t had the funds.

14)CoEnzyme Q10 at least 100 mcg daily. 300mg-400mg +if fighting tooth aches, tooth root issues

Vitamins

15)Multi Vitamins- SuperNutrition– I buy Men’s Blend which doesn’t have the green tea however has an Iron or a no iron alternative. Its Women’s Blend recently began to include hawthorne berry, flax seed and green tea I had to stop using that line because of those new inflammatory additives, but the company has other multis that it didn’t foul with the ingredients to that same degree, such as the Men’s Blend. I buy with Iron, that given the amount of Vit C I use, there is no gunky blood issues with more iron than my body may need. Suddenly after eating a great deal of the ‘junk’ items while at a conference, and that junk of course was seriously contaminated with gmo+herbicides, my menstral cycle VANISHED nearly immediately after that particular stumble and it never returned. For a number of months afterwards, I also had joint problems and without question, given how careful my diet is, it was the gmo from all that junk that I’d eaten that afternoon while at that conference.

16)Vit C American Health and Rainbow Light 1000 mg tablets or capsules. I take at least 6000 mgs-10,000 mgs daily. With the Rainbow Light brand you have to wash off the gmo soy lecithin coating the vit. High dosages of Vit C will kill problems in the teeth and teeth roots. I suggest avoiding the commercial toothpastes with fluoride. Switch to the natural nonfluoride. Also Ester C is a good Vit C product – by American Health

17)Vit E – Deva brand (non gmo) at least 400mgs daily at least unless very active and then in THAT case take 1200mgs, on a low fat diet and on fat burners such as L-Carnitine, then use 800mgc to 1200mgs. Go non GMO.

18)Vit B complex Solgar Megasorb use if without soy lecithin or other gmo ingredients

19) Gentle Iron + vits C, B-12, Folic Acid. Nature’s Bounty – not bad for a plebe brand.

I now also take a Vit D NatureWise Vitamin D3 in organic olive oil (5,000 IU) product, and went non-gmo on this.

Oils

20)Oil of evening primrose, (Sports Research) is better than borage or flax seed which aren’t bad. Sports Research is non gmo

21)fish oil capsules –Krill or Nordic Naturals Complete Omega 3-6-9

22) Astaxanthin – by Sports Research –a fish oil family superfood for nerves, muscles, joints

Other superfoods

23)royal bee jelly and bee pollen. YS and Burts, Shiloh Farms are very good, however go organic to be gmo and herbicide free.

24)a good garlic supplement – Garlicin and any of the others are fine or a garlic w/selenium supplement

25)Kyolic “108” and “106”. Very good garlic supplement although one of them has Hawthorne, which is high phosphorus and I avoid that.

26)Colostrum and permutations of colostrums although this has phosphotodyl choline, and can tend to contribute to inflammation if detoxing from Round-up

27)Cayenne – and other thermogenic herb products; any good name to also kill negative bacteria in digestive tract and heart cavity. It/these also is/are good for metabolism. Some people are sensitive to ‘nightshade’ including all hot peppers, green peppers, eggplant (take out the seed/pulp core of this), cherries, tomatoes, potatoes (peel the skin of these).

28)Nature’s Way Urinary Plus Cranberry or any good pure cranberry herbal and other Nature’s Way herbal combinations are very good. Nature’s Way also has Dandelion capsules and other combinations with dandelion such as Leg Veins although this combination has horse chestnut which is hard on people very sensitive to high phosphorus foods. I also purchased Whole Fruit Cranberry powder in 1lb bulk form by Nubeleaf through Amazon.

29)fat burner such as L-carnitine a safe supplement, although you will need to take extra Vit E which is the nerve cushion/fat soluble vitamin… if on fat burners and low fat diet, you will need more Vit E (and other fat soluable vits) to protect the nerves and prevent ‘self-electrocution’ when the nerves emit electro chemicals in order to make the muscles function and if that process is impaired by ‘free radical’ build up and nerve cushion problems from insufficient E, then in the tissues that remains and muscles are further polluted with more body and environmental pollution.

30)Super Lysine Plus (this is the name of the product) made by Quantum\ except for the Tri-calcium phosphate in this, which I find a problem and as a result, I infrequently use this product

References:

Linda R. PageHealthy Healing; Hulda R. ClarkThe Cure for All Diseases.

Health and Harmony (listed with information in New York, NY on Hudson Street below Grove in the West Village By phone: 212 691 3036/fax 212 691 0855) in Manhattan. One can order via phone.  The Proprietor is Ramsey or other management such as Tarique will take your order and ship I think UPS or USPS, and tell them if you order from them that I recommended the store to you. If you order a fair amount, he probably will give you some sort of discount although I cannot promise that. His prices are reasonable however, and if you shop there regularly and in abundance, he sometimes omits charge for some small items.

I also shop at Westerly Market on 8th Ave, at W. 54th. One may order by phone or web.

The antioxidant/supplements are not a cheap part of the strategy, however, the food part of the strategy is generally inexpensive – processed food usually costs more than unprocessed food so in the short and long run, even if one is switching in some cases to organic, one is spending a better quality dollar than for what was previously spent for and wasted on processed food.

Read the Gospels for the interaction of the Lord Yeshua and the people when they needed healing and wholeness. Notice that the Levitical diet in that time was what people used. Food in that era was either ‘clean’ adhering to Levitical law or unclean. There was no processed food or BigPharma antibiotics and other BigPharma drugs used on the people today. Although people are sick and infirmed from sin and iniquity/sins of the fathers and lawlessness then as well as today, today people make their lives worse via sedentary life style, processed food and bigPharma, medtech/mengele medical profession corruption and pollution.

The US medical system is a volume based revenue model. This means that the more people ignorated to fall in and remain in it are the way the system makes money and self-enriches by parasiting off of the peoples’ ignorance.

The Lord is a rewarder of them who diligently seek Him. And in seeking Him one gains wisdom and understanding. One also gains faith to trust Him for better quality of life and health, however one also can avoid the medtech system and its operating strategy with the Lord and better nutrition and life style choices.

I have only gotten ‘flu’ when I have had some sort of infection or had eaten junk food and came into contact with cold germs. Once I’d gotten flu when I had a bad tooth infection that later needed root canal, which happened after my dentist had forgotten to deal with a bad cavity and my diet had trended into junk during the holidays and insufficient exercise, not enough antioxidants. Everyone else with that flu, however lost a week of work in bed while in my case with my constitution generally better, I only had the ‘bad cold’/cough.

This diet will prevent (assuming clean personal habits, not living near or on a toxic waste dump or major polluter, and no pets – pets often have parasites and in general make it more difficult to prevent in ones environment bacteria from pet fecal matter), reverse cavities and with the coQ10 in large amounts; fix gall bladder problems – as long as one doesn’t overeat or eat food from animals polluted with antibiotics and Bigpharma livestock pharma, do polluted dairy and put pressure on a problemed gall bladder, generally my diet strategy will also prevent gout. It will hinder if not prevent arthritis (the strategy uses clean fats and avoids the heavy metals from the cookware, other sources which the negative bacteria in the body and joints find useful for thriving in the anaerobic environment) and other auto immune illnesses.

Bless the Lord!

Clean, grass fed livestock and cooking things such as goat meat (from goats not treated with any sort of pharma or fed gmo grains

Roasted Goat or any other game or grass fed livestock- clean, grass fed meat… unless using organic (pure and free of any sort of pharm or gmo grains): US cattle, US lamb, US pork, buffalo, ‘hacked’ or goat shoulder the shank cut in half, or whole is one is going to roast it on a spit or in a large oven but otherwise cut to fit the cookware. Rinse, bake w/lid on the pot at 350F approx 1 hr 50 min to 2 hours depending on the amount of meat in the pot.

Avoid cloned cows/cattle for milk and meat. We’ve got plenty of animals. Why clone something God made just fine? If one takes responsible care of their livestock they can breed the good ones without the problems, but they inbreed, give them hormones, make them sick, give them anti-biotics, and this is the pathetic food supply they attempt to feed to us.

*The US Government is “out there” as death merchants, so if it’s not military hardware, then it’s something like GMO food and associated herbicides. GMO and the associated herbicides are for population reduction and contaminating the environment. Policy going by the name of ‘Sustainability” are pawned off on the people, sleazily destroying them, slowly exterminating them one forkful at a time, while yielding an annuity to nazi part of the medical system and bigPharma. If people trust their life and health to the medical system and bigPharma, it surely will kill them sooner or later. The medical system also will say people have some illness or disease because some people are targets or if perhaps is too ignorant to stand up to the system.  People need to be responsible for their own health and lives, if not by the Lord, even by wisdom that trickles down into the world about food quality and quality of life and other ways of interacting with society and its disorder. This includes in what way you interact with medical system and bigPharma. Using its services and products vs believing it is life-giver and maintainer when it is neither, puts the user at risk for its vanity. This vanity grows by the day as the Day of the Lord is here.

**Atkins authored his diet long before any prolific use of early versions of gmo such as steroids, growth hormones, pharma in the animals and fish and ‘fisheries’. Feedlot cattle became in vogue about that time, but the use of steroids, and other contaminants in their feed has been perhaps only over the last 40 or so years, although feed-lotting also now has been including gmo grains and gmo seeds, and garbage such as processed food. Live stock pollution of such a nature became the reason our Olympic athletes and those involved in professional athletics in which the athletes are tested for performance hormones, the athletes had to go to grass/organic livestock, dairy, poultry and eggs, wild fish, any animal product pure and without contamination of any sort of animal/livestock or fishery pharma so as to not test positive in the athletes’ bodies.

Moreover, dairy pharma: stimulant hormones and dairy antibiotics are known to be a contributing factor in increasing incidence of breast cancer in women. I urge complete elimination of any of these sorts of contaminated animal products and by products from one’s diet.

There also are other problems such as the high-powered, electro-magnetic (ie, ‘directed energy’, Microwave or radio wave) /extremely low frequency wave, and the interference with one’s brain chemistry and now prolific in the environment by way of space based and earth based science/tech, that there are challenges to mankind with regard to the manner in which these technologies present hurdles to the quality of life. Technologies such as HAARP and SQID are neither benefit nor benign to mankind.

Furthermore, the danger in the environment to the gmo and associated herbicides now including war crime chemicals such as “Agent Orange” are not only serious toxins to man, animals and their associated food supply, the natural balance between the environment and fauna and insects that support agriculture and the beautiful environment with which God blessed us all is at risk by the evil schemes of science hijacked and co-opted for the policy of ‘Sustainability’ or that which is the policy interested to see the world’s population reduced by 8/9s. “The Earth is the Lord’s and the fullness thereof, and they that dwell therein.”

*http://theinternationalforecaster.com/page/bob_chapman

http://www.quantumhealing.co.za/roundup-and-glyphosate.html

https://www.globalhealingcenter.com/natural-health/top-20-gmo-foods-and-ingredients-to-avoid/

https://www.globalhealingcenter.com/natural-health/top-10-gmo-foods-to-avoid/

http://podcast.drpompa.com/episodes/95-gmos-with-special-guest-dr-stephanie-seneff

https://www.globalhealingcenter.com/natural-health/remedies-for-kidney-stones/

http://dharmanutritionhealing.com/driving-gmos-and-monsantos-roundup-off-the-market-3/

https://jeffagostinelli.com/podcast/zachbush/

https://www.gentechvrij.nl/2017/11/19/healing-from-gmos-and-roundup/

 

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M&A: Current Issues and Trends Affecting the Banking Sector. ABA Journal White Paper 2Q94

In 1994 when I first joined KPMG working with Rich Lashley , John Palmer, Chuck Walker, Mike Turillo, Jr, Don Rondblum (God rest his soul) with Rich and Mike, I co-authored “Mergers & Acquisitions: Current Issues and Trends Affecting the Banking Sector”. Prior to Sarbanes Oxley, KPMG partner money was establishing a boutique investment bank with a Broker/Dealer license. KPMG itself was not permitted by law to obtain a Broker/Dealer license and engage in Investment banking activity because public accounting firms are to remain independent of conflicts of interests with the firms they provide assurance and related consulting and tax advisory services. This new independent unit however, at that time going by the name of the “Global Capital Group” was engaging in M&A Advisory work. I was employed from the ‘outside’, ie, not from within KPMG, to bring in M&A skills and experience, with most of my work have dealt with depository (and other financial) institutions. The ABA Banking Journal invited my KPMG group to provide an article (White Paper) which until I have posted it, to my knowledge has not existed nor appeared on line. Moreover in that particular ABA Banking Journal, other professional colleagues also provided articles; Oliver Sarkozy, Michael Martin, and Alex Sheshunoff are among the other contributors.  Saved at that time as a pdf, for some reason, it wouldn’t convert to a document file for beautification.   Notwithstanding, one may see the Table of Contents and article’s original text.

https://www.linkedin.com/messaging/thread/6270256454750601216/ is this same comment with the article in pdf format.

 

 

 

 

 

 

 

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Andrea Psoras Resume for Financial Sector Mergers/Acquisitions

Andrea M. Psoras

201 W117th Str #2B  NY, NY 10026 ; (212) 666-2569; andreapsoras@yahoo.com  apsoras@gmail.com

PROFILE:

  • Financial Analyst/Financial Sector with strong strategic thought leadership skills: experience consulting to, analyzing predominantly depository and financial institutions. Strong skills in: Financial analysis, research, quantitative analysis with strong commercial intuition and reasoning/problem solving, abilities and experience for M&A-investment banking (combinations/divestitures), credit/counter-party risk, stock or Private equity portfolio investments (industry/macro, credit analysis) using 10Q, 10K, Y9-C, “Call”, TFR, Focus; FR Y-14/“Stress Tests: DFAST, CCAR; Dodd Frank (Resolution Plan) related, consulting business development.
  • Member: NYSSA since 1990 (in process-2016). Passed CFA I.
  • International Bank Credit Trained – formal credit training; 24 credits specific to Accounting. Jul’14 NYC Exam for Staff Analyst Trainee: 78%; Jun15 NYC Civil Service exams score 76% for Analyst, 80% for Assoc Staff Analyst
  • Strong software skills including (spreadsheet) forecasts, strong modeling, building models: MS Office: Excel, Word, Access, Powerpoint, MS Project; Lotus 123, Amipro; FoxPro; dBase; WordPerfect; Bloomberg API spreadsheet building; FactSet product use; QuickBooks; STATA; Sybase; WordPress-website development; some SAS JMP; data mining, data analysis; transactions-projects with multiple stakeholder collaboration.

 

EMPLOYMENT/CONSULTING: (see also Transactions/Projects/Activities List in WordPress)

    • PLLC Family office/ Independent Consulting (“PLLC”)  Analyst/Consultant                                           (8/08 — Pres)
    • QED International Associates, Inc. (“QEDI”)  Senior Vice President                                  (10/05 – 8/08)
    • Strategic Advisory (“SA”)                 Principal/Analyst                                                            (6/95 – 9/05)
    • KPMG Peat Marwick, LLP (“KPMG”)  Senior Banking Analyst                         
    • Ryan Beck (now part of Stifel Nicolas); Consulting (“IC”)   AVP; Consultant; Contractor
    • Lyons, Zomback & Ostrowski (Advest Group) (“LZO”)       Associate/M&A consulting                                                               

EMPLOYMENT INCLUDING CONSULTING HISTORY (see also Transactions/Projects/Activities List)

PLLC Family office/ Independent Consulting ( PLLC). NY, NY (2008-present): Financial services/related consulting for client and ad hoc projects using Financial Reports: 10Q, 10K, A/R, Y9-C, Call, TFR, Focus and related to these. Public Due Process Comments Letters to FASB, SEC, Fed/BoG, FDIC, OCC, CFTC, USDA, Amicus letters

Capital Markets Advisors, LLC. NY, NY (CMA), Senior Manager (5/12-7/13): Financial services, related consulting, business development.

  • Co-authoring service contracts-agreements with banks,
  • Co-authoring/writing CMA’s business, operating plans, presentations in PowerPoint,
  • Resolution Plans Consulting- foundation/organized/developed presentation, website, website materials for Resolution Plans consulting
  • QED International Associates, Inc. NY (QEDI) Senior Vice President (2005 – 2008): Quantitative consulting
    • Design and developed strategies of: Indexes, quantitative, fundamental analysis; Exchange Traded Funds; trading, investment strategy consulting to asset management, investment, pension, and related communities, Risk/Credit/Portfolio Management product development.
    • Co-authored white papers. Co-authored with Herbert Blank: “When Vice is Nice”, Financial Advisor,” When Sin is Superior”, April 2006 Co-Authored with Michael Carty and Ed Matluck, PhD, “Does the Steel Industry Perform Differently than the Basic Materials Sector?” for Van Eck
    • Strategic Advisory (SA)- Principal. NY, NY Provided strategy consulting to clients, affiliations. Also see following-client engagements (Transactions-Projects List)
  • KPMG Peat Marwick, LLP, (KPMG) Senior Banking (M&A and related; execution side) Analyst, NY, NY. For the Global Capital/Capital Strategies Group promoted in less than a year from Senior Research Analyst. Co-authored ABA Banking Journal White Paper– “Mergers & Acquisitions: Current Issues and Trends Affecting the Banking Sector” https://wordpress.com/post/apsoras1.wordpress.com/220 .
  • Lyons, Zomback & Ostrowski ((LZO).part of Advest Group), NY, NY. Associate. Fulfilling M&A, strategic advice (execution side) roles. Please see below: “Professional Experience and Skills” for skills, experience; “Transactions List

Prior Professional Experience in the Maritime sector: Norton Lilly Intl, Maersk Line/Moller Steamship

EXPERIENCE: Financial Sector, Related (Also see Transactions-List www.apsoras1.wordpress.com):

M&A and Related Consulting (mostly “Execution” side):

  • LZO, KPMG, SA I co-authored M&A, recap, strategy/strategic plans-strategic planning, business-capital plans (these were predecessors to ‘Resolutions’ Plans) for regulator, client purposes.
  • LZO, KPMG, SA I created, constructed, developed complex, scenario driven interactive Excel, Lotus spreadsheet models with stress testing/scenarios, pro-forma forecasts for business combinations, divestitures, capital planning,/capital adequacy/recapitalizations, private placements, financial and/or credit analysis; modeled mostly retail, (some) commercial, industrial, SNC/‘participations’ loan portfolios – to accompany co-authored materials.
  • LZO, KPMG, SA For execution side of transactions/projects: I engaged in strategic planning consulting, strategic economic and financial analysis collaborating between external, internal stakeholders: senior partners/investment bankers, analysts, clients and/or external parties such as the regulators; “turn-around” work. I also was involved in some business development.
  • LZO, KPMG, QEDI, IC While laws, regulations have been designed to diminish the number of ‘mouths’ feeding at the table of the US economy, for stakeholders – clients, regulators (external) and MDs (internal) I researched/surveyed/co-authored: industry trends, economic/demographic trends, sub-sectors; fairness opinions, regulatory assisted transactions/FDIC resolutions-Resolution plans, Open Bank Assistance Requests/Applications; D’Oenche Doctrine. I also analyzed deposit franchise/branch networks, market/trade areas, calculated Herfindahl (deposit concentration, anti-competition/anti-competitive) analysis; associated scenario driven spread complex interactive sheet models.
  • LZO, KPMG, SA, PLLC Used/analyzed, dealt with definitions, data changes in
  • “TRF”, “Call” reports, UBPRs, BHCPRs (“RAP”) including Examiners/Exam Reports, and GAAP data on North American based financial institutions, other public and private enterprises –
  • understanding, comfortable with data and those definitions that role up into these reports
  • LZO For clients, internal use I worked on the development of the LZO Bank & Thrift Directory, and from regulator data in dBase form I built, I contributed to developing a credit scoring model that quality-rated banks and thrifts as a proxy for rating their CDs
  • Financial Analyst – Credit Analysis/Counter-party Credit Risk (and project-contract-temporary, etc):
  • Used/analyzed GAAP; RAP data: “Call”, Y9-C reports, Focus Reports for broker/dealers, North American based financial institutions, credit card banks, financial service cos, broker/dealers, ETNs, also analyzing US subsidiaries (“subs”) and foreign subs in Europe, Asia of US based financial institutions (some translating from French, Spanish)
  • Reviewed Y2K, operations/IT compliance, some editing of Counterparty ISDA docs used for adjusting global exposures to credit counterparties
  • Provided credit analysis using internal credit utility software on Global 1000 cos. at a global bank for Senior Management
  • For Treasury, Controller, determined profits and losses from trading: derivatives – options, swaps, hedges; forward rate agreements, FX; A/L gap analysis in Sybase, G/L work for CFO of large European bank US sub
  • For dealing with, solving systems issues and reporting differences in at a global bank’s Global Asset Management, I reconciled portfolio performance of large private wealth clients’ portfolios to Custody’s reports
  • Medium Term Notes: Transactions and Collateral Due Diligence, coordination with Traders/Trading Banks
  • Other Related Experience­ Full CV, Transactions List) https://apsoras1.wordpress.com/2016/11/30/psoras-transactionsprojectsactivities-list-2q16/
  • Financial Services consulting: Dodd Frank Resolution Plan/PMO business development, related consulting
  • Financial analysis, transactions, and product development on other sectors: CFTC public due process comment on Event driven commodity contracts; “Stress” Tests public due process comment
  • Analysis of Accounting/Financial Reporting; Risk Management, Regulation and Legislation
  • Basel III Public due process comment; Basel II macro/micro (some policy) Analysis
  • Analysis of mortgage products, mortgage equity products and associated companies

EDUCATION and OTHER: ATTRIBUTES, ACTIVITIES; (Transactions , References List Provided Upon Request)

Franklin & Marshall College, Lancaster, PA, Degree: B. A.  Major/minor: Business Management/Economics, “Finance”. Advanced research in Money & Banking: “Capital Adequacy in Commercial Banking”; Accounting: “Barter revenue as a component in Revenue Recognition”; Additional 24 credits in Accounting and Economics/Econometrics (F&M) 2004/Feb-May; Econometric/quantitative review of Gramm Leach Bliley mandated study of the profitability of lending under the Community Reinvestment Act, in process. Extracurricular activities: varsity field hockey& lacrosse (de facto regionally, nationally ranked).

Other:

Columbia University, NY, NY. Public Economics with research: ‘Shadow Pricing of Foreign Exchange”; Spanish.

Baruch College: Accounting Certificate, Budgeting and QuickBooks, Audit 

Memberships.

Present: New York Society of Security Analysts “NYSSA” Committees: –Financial Reporting and Analysis, Corporate Governance/Shareholder Rights; Sustainable Investing.

Former: Professional Risk Managers’ Investment Association “PRMIA”; Quantitative Work Alliance For Applied Finance Economics and Wisdom “QWAFAFEW”. New York State Society of Certified Public Accountants; Foreign Policy Assn.; American Assn for the Advancement of Science (AAAS).

Community/Civic/Social memberships, endeavors have included:: The Penn Club of New York; Greenwich Field Hockey Club VP-88/90; 93 Empire State Games gold medal winning field hockey team. Whitehall Club; Downtown A/C-Audit Committee, Instructor w/Sons & Daughters Program; Computer instructor at Fountain House.

President’s Council on Physical Fitness Award, 2 years.

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Andrea Psoras – M&A Resume

Andrea M. Psoras

201 W117th Str #2B  NY, NY 10026 ; (212) 666-2569; andreapsoras@yahoo.com apsoras@gmail.com

PROFILE:

  • Financial Analyst/Financial Sector with strong strategic thought leadership skills: experience consulting to, analyzing predominantly depository and financial institutions. Strong skills in: Financial analysis, research, quantitative analysis with strong commercial intuition and reasoning/problem solving, abilities and experience for M&A-investment banking (combinations/divestitures), credit/counter-party risk, stock or Private equity portfolio investments (industry/macro, credit analysis) using 10Q, 10K, Y9-C, “Call”, TFR, Focus; FR Y-14/“Stress Tests: DFAST, CCAR; Dodd Frank (Resolution Plan) related, consulting business development.
  • Member: NYSSA since 1990 (in process-2016). Passed CFA I. 
  • International Bank Credit Trained – formal credit training; 24 credits specific to Accounting. Jul’14 NYC Exam for Staff Analyst Trainee: 78%; Jun15 NYC Civil Service exams score 76% for Analyst, 80% for Assoc Staff Analyst
  • Strong software skills including (spreadsheet) forecasts, strong modeling, building models: MS Office: Excel, Word, Access, Powerpoint, MS Project; Lotus  123, Amipro; FoxPro; dBase; WordPerfect; Bloomberg API spreadsheet building; FactSet product use; QuickBooks; STATA; Sybase; WordPress-website development; some SAS JMP; data mining, data analysis; transactions-projects with multiple stakeholder collaboration
    • EMPLOYMENT/CONSULTING: (see also Transactions/Projects/ Activities List )
    • Independent Consulting/PLLC Family office (“PLLC”) Analyst – “Contractor”                                                                                                   (8/08 – Pres)
    • QED International Associates, Inc. (“QEDI”)  Senior Vice President (10/05-8/08)
    • Strategic Advisory (“SA”)  Principal/Analyst                                            (6/95-9/05)
    • KPMG Peat Marwick, LLP (“KPMG”)                               Senior Banking Analyst 
    • Ryan Beck (now part of Stifel Nicolas)                               Associate Vice President
    • Lyons, Zomback & Ostrowski (Advest Group) (“LZO”)   Associate/M&A consulting

EMPLOYMENT INCLUDING CONSULTING HISTORY (see also Transactions/Projects/Activities List)

PLLC Family office/ Independent Consulting ( PLLC). NY, NY (2008-present): Financial services/related consulting for client and ad hoc projects using Financial Reports: 10Q, 10K, A/R, Y9-C, Call, TFR, Focus and related to these. Public Due Process Comments Letters to FASB, SEC, Fed/BoG, FDIC, OCC, CFTC, USDA, Amicus letters

Capital Markets Advisors, LLC. NY, NY (CMA), Senior Manager (5/12-7/13): Financial services, related consulting, business development.

  • Co-authoring service contracts-agreements with banks,
  • Co-authoring/writing CMA’s business, operating plans, presentations in PowerPoint,
  • Resolution Plans Consulting- foundation/ organized/developed presentation, website, website materials for Resolution Plans consulting

QED International Associates, Inc. NY (QEDI) Senior Vice President (2005 – 2008): Quantitative consulting

  • Design and developed strategies of: Indexes, quantitative, fundamental analysis; Exchange Traded Funds; trading, investment strategy consulting to asset management, investment, pension, and related communities, Risk/Credit/Portfolio Management product development.
  • Co-authored white papers. Co-authored with Herbert Blank: “When Vice is Nice”, Financial Advisor,” When Sin is Superior”, April 2006 Co-Authored with Michael Carty and Ed Matluck, PhD, “Does the Steel Industry Perform Differently than the Basic Materials Sector?” for Van Eck

Strategic Advisory (SA)- Principal. NY, NY Provided strategy consulting to clients, affiliations. Also see following-client engagements (Transactions-Projects List)

KPMG Peat Marwick, LLP, (KPMG) Senior Banking (M&A and related; execution side) Analyst, NY, NY. For the Global Capital/Capital Strategies Group promoted in less than a year from Senior Research Analyst. Co-authored ABA Banking Journal White Paper- “Mergers & Acquisitions: Current Issues and Trends Affecting the Banking Sector”.

Lyons, Zomback & Ostrowski ((LZO).part of Advest Group), NY, NY. Associate. Fulfilling M&A, strategic advice (execution side) roles. Please see below: “Professional Experience and Skills” for skills, experience; “Transactions List

Prior Professional Experience in the Maritime sector: Norton Lilly Intl, Maersk Line/Moller Steamship

EXPERIENCE: Financial Sector, Related (Also see Transactions-List www.apsoras1.wordpress.com):

M&A and Related Consulting (mostly “Execution” side):

  • LZO, KPMG, SA I co-authored M&A, recap, strategy/strategic plans-strategic planning, business-capital plans (these were predecessors to ‘Resolutions’ Plans) for regulator, client purposes.
  • LZO, KPMG, SA I created, constructed, developed complex, scenario driven interactive Excel, Lotus spreadsheet models-forecasts with stress testing/scenarios, pro-forma forecasts for business combinations, divestitures, capital planning,/capital adequacy/recapitalizations, private placements, financial and/or credit analysis; modeled mostly retail, (some) commercial, industrial, SNC/‘participations’ loan portfolios – to accompany co-authored materials.
  • LZO, KPMG, SA For execution side of transactions/projects: I engaged in strategic planning consulting, strategic economic and financial analysis collaborating between external, internal stakeholders: senior partners/investment bankers, analysts, clients and/or external parties such as the regulators; “turn-around” work. I also was involved in some business development.
  • LZO, KPMG, QEDI, IC While laws, regulations have been designed to diminish the number of ‘mouths’ feeding at the table of the US economy, for stakeholders – clients, regulators (external) and MDs (internal) I researched/surveyed/co-authored: industry trends, economic/demographic trends, sub-sectors; fairness opinions, regulatory assisted transactions/FDIC resolutions-Resolution plans, Open Bank Assistance Requests/Applications; D’Oenche Doctrine. I also analyzed deposit franchise/branch networks, market/trade areas, calculated Herfindahl (deposit concentration, anti-competition/anti-competitive) analysis; associated scenario driven spread complex interactive sheet models.
  • LZO, KPMG, SA, PLLC Used/analyzed, dealt with definitions, data changes in “TRF”, “Call” reports, UBPRs, BHCPRs (“RAP”) including Examiners/Exam Reports, and GAAP data on North American based financial institutions, other public and private enterprises – understanding, comfortable with data and those definitions that role up into these reports
  • LZO, KPMG Worked on structured pricing/bids, strategies for acquiring, selling branches; also for failing/failed financial institutions.
  • LZO For clients, internal use I worked on the development of the LZO Bank & Thrift Directory, and from regulator data in dBase form I built, I contributed to developing a credit scoring model that quality-rated banks and thrifts as a proxy for rating their CDs

Financial Analyst – Credit Analysis/Counter-party Credit Risk (and project-contract-temporary, etc):

  • Used/analyzed GAAP; RAP data: “Call”, Y9-C reports, Focus Reports for broker/dealers, North American based financial institutions, credit card banks, financial service cos, broker/dealers, ETNs, also analyzing US subsidiaries (“subs”) and foreign subs in Europe, Asia of US based financial institutions (some translating from French, Spanish)
  • Reviewed Y2K, operations/IT compliance, some editing of Counterparty ISDA docs used for adjusting global exposures to credit counterparties
  • Provided credit analysis using internal credit utility software on Global 1000 cos. at a global bank for Senior Management
  • For Treasury, Controller, determined profits and losses from trading: derivatives – options, swaps, hedges; forward rate agreements, FX; A/L gap analysis in Sybase, G/L work for CFO of large European bank US sub
  • For dealing with, solving systems issues and reporting differences in at a global bank’s Global Asset Management, I reconciled portfolio performance of large private wealth clients’ portfolios to Custody’s reports
  • Medium Term Notes: Transactions and Collateral Due Diligence, coordination with Traders/Trading Banks

Other Related Experience­ Full CV, Transactions List) https://apsoras1.wordpress.com/2016/11/30/psoras-transactionsprojectsactivities-list-2q16/

  • Financial Services consulting: Dodd Frank Resolution Plan/PMO business development, related consulting
  • Financial analysis, transactions, and product development on other sectors: CFTC public due process comment on Event driven commodity contracts; “Stress” Tests public due process comment
  • Analysis of Accounting/Financial Reporting; Risk Management, Regulation and Legislation
  • Basel III Public due process comment; Basel II macro/micro (some policy) Analysis
  • Analysis of mortgage products, mortgage equity products and associated companies

EDUCATION and OTHER: ATTRIBUTES, ACTIVITIES; (Transactions , References List Provided Upon Request)

Franklin & Marshall College, Lancaster, PA, Degree: B. A.  Major/minor: Business Management/Economics, “Finance”. Advanced research in Money & Banking: “Capital Adequacy in Commercial Banking”; Accounting: “Barter revenue as a component in Revenue Recognition”; Additional 24 credits in Accounting and Economics/Econometrics (F&M) 2004/Feb-May; Econometric/quantitative review of Gramm Leach Bliley mandated study of the profitability of lending under the Community Reinvestment Act, in process. Extracurricular activities: varsity field hockey& lacrosse (de facto regionally, nationally ranked).

Other:

Columbia University, NY, NY. Public Economics with research: ‘Shadow Pricing of Foreign Exchange”; Spanish.

Baruch College: Accounting Certificate, Budgeting and QuickBooks, Audit.

Memberships.

New York Society of Security Analysts “NYSSA” Committees: –Financial Reporting and Analysis, Corporate Governance/Shareholder Rights; Sustainable Investing (1990-16).

Former: Professional Risk Managers’ Investment Association “PRMIA”; Quantitative Work Alliance For Applied Finance Economics and Wisdom “QWAFAFEW”. New York State Society of Certified Public Accountants; Foreign Policy Assn.; American Assn for the Advancement of Science (AAAS).

Community/Civic/Social memberships, endeavors have included:: The Penn Club of New York; Greenwich Field Hockey Club VP-88/90; 93 Empire State Games gold medal winning field hockey team. Whitehall Club; Downtown A/C-Audit Committee, Instructor w/Sons & Daughters Program; Computer instructor at Fountain House.

President’s Council on Physical Fitness Award, 2 years.

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Andrea Psoras TRANSACTIONS/PROJECTS/ENGAGEMENTS/ACTIVITIES LIST 2Q16

ANDREA M. PSORAS

201 W. 117th Street #2B  NY, NY 10026 (212) 666-2569 andreapsoras@yahoo.com  apsoras@gmail.com

TRANSACTIONS/PROJECTS/ACTIVITIES LIST*

2011/2012/2013/2014/2015/2016

Public Due Process Comment Letter – FDIC Notice and Request for Comment: Guidelines for Appeals of Material Supervisory Determinations: Federal Register Vol 81, No. 150 (Aug 4, 2016, pps 51441-6.) in process.

Policy-Legal Analysis of New York Bankers Association v. The Cty of New York , et al.  Analysis of and comment to the New York City Banking Commission regarding the 2105 law suit by New York Bankers (Trade ) Assocation against New York City Counci’s  2012 “Responsible Banking Act” and associated programs administrated by the Community Investment Advisory Board.

Public Due Process Comment Letter  (letter #01) FDIC:  Company-Run Annual Stress Test Reporting Template and Documentation for Covered Institutions with Total Consolidated Assets of $50 Billion or More under the Dodd-Frank Wall Street Reform and Consumer Protection Act OMB Control Number 3064–0189 / 75152-75155 Federal Register / Vol. 79, No. 242 / Wednesday, Dec 17, 2014 https://www.fdic.gov/regulations/laws/federal/2014/2014-stress_test_reporting_dodd_frank_3064–0189.html 2014-stress_test_reporting_dodd-frank_3064–0189-c_01.pdf

Public Due Process Comment Letter (letter #29) FDIC: Single Point of Entry / 77614-76624 Federal Register / Vol. 78, No. 243 / Wednesday, Dec 18, 2013 http://www.fdic.gov/regulations/laws/federal/2013/2013-single-point-entry.html

Public Due Process Comment Letter (letter#40): FASB Project: 2012-260 Financial Instruments—Credit Losses (Subtopic 825-15) comment letter for Public Due Process. 2 May 2013

http://www.fasb.org/jsp/FASB/CommentLetter_C/CommentLetterPage&cid=1218220137090&project_id=2012-260

Public Due Process Comment Letter: Fed, FDIC, OCC, SEC Comment regarding opposition to Basel III adoption, analysis, in narrative style http://www.federalreserve.gov/SECRS/2012/December/20121206/R-1442/R-1442_113012_110903_367981921547_1.pdf

Director on Board: Occupy Financial (OWS’ financial company established to do financial services, payment cards). Worked on organization’s development-establishment, business plan, financial (interactive spreadsheet) model.

Public Due Process Comment Letter (letter#167): FASB Project: 2011-230- Revenue Recognition (Topic 605): Revenue from Contracts with Customers Updated Exposure Draft comment letter for Public Due Process. 13 March 2012

http://www.fasb.org/jsp/FASB/CommentLetter_C/CommentLetterPage&cid=1218220137090&project_id=2011-230&page_number=2

Public Due Process Comment Letter: US Department of Agriculture –Comment letter against deregulating Dow Agri Group GMO 2,4-D (dioxin) tolerant soy, and supporting banning GMO in the US food supply and agriculture; Amicus Letter: OSGATA v Monsanto- Friend of the Court Letter on behalf of Organic Seed companies and Organic Farmers Trade Association in anti-competitiveness/corporate abuse lawsuit against Monsanto. http://www.regulations.gov/#!documentDetail;D=APHIS-2010-0103-4699

Public Due Process Comment Letter: Fed, FDIC, OCC, SEC: Comment for public due process regarding “Restrictions on Proprietary Trading and Certain Interests in, and Relationships with, Hedge Funds and Private Equity Funds”  et al, aka “Volcker Rule” http://www.sec.gov/comments/s7-41-11/s74111-332.pdf; http://www.federalreserve.gov/SECRS/2012/March/20120305/R-1432/R-1432_021312_104969_451639007701_1.pdf

Comment Letters and Analysis: Financial Crisis Inquiry Commission: Attended and analyzed hearings/testimonies while FCIC conducted its Due Process on Capitol Hill, 2010 and 2011

2009/2010

Financial Crisis and Financial Crisis Inquiry Commission: Forensics/post-mortem on root with associated prospered causes of the financial ‘crisis’ from late 2005 through the present and regular input to the Financial Crisis Inquiry Commission related to its hearings and analyses. (1/2010-1/2011)

Public Due Process Comment Letter (#440 10-22-10): FASB – Revenue Recognition (Topic 605): Revenue from Contracts with Customers http://www.fasb.org/jsp/FASB/CommentLetter_C/CommentLetterPage&cid=1218220137090&project_id=1820-100  Letter #440. 10/2010

Bank/financial sector small cap Stock Indexes– Selected a universe (27 names; bench of 71 names) of under-covered smaller (market) cap financial companies including banks, thrifts. Produced an index of their stock market returns from 2005 -2010. Back-tested/compared portfolio return in top 10% against 41 ETFs, CEFs, indexes used for comparison. (10/09-5/10)

FASB “Blue-Ribbon” Panel convened on “fair value” impact in Financial Crisis“ Impact of use of Fair Value as the basis if measure in US financial reporting model, ie, US GAAP. Reviewed and attended US hearings, without public comment letter to FASB – 2010

Public Due Process Comment Letter (#81): FASB – Project: Fair Value Measurements and Disclosures (Topic 820) Reference Number: 1830 100 Amendments for Common Fair Value Measurement and Disclosure Requirements in U.S. GAAP and IFRS http://www.fasb.org/jsp/FASB/CommentLetter_C/CommentLetterPage&cid=1218220137090&project_id=1830-100 10/09

Public Due Process Comment Letter to the Securities and Exchange Commission (‘SEC”): Roadmap for the Potential Use of Financial Statements Prepared in Accordance with International Financial Reporting Standards by U.S. Issuers [Release No. 33-8982; File No. s7-27-08] http://sec.gov/comments/s7-27-08/s72708.shtml aka opposition of “Adoption of IFRS” (2009)

Capital Link Inc Maritime Indexes: Developed/constructed Capital Link Maritime Index for the Capital Link website tracking its maritime clients’ stock movement, with oversight by expert, former co-worker Herb Blank.

Board of Governors of the Federal Reserve System Comment on data robustness/improvement for data used in revenue reported in Y-9C, 1/12/09 and to FFIEC and FDIC regarding data improvements desired in the Y-9C, ‘Call” Reports.

2007/2008

2008 Presidential Campaign – Vice President on the Independent Ticket with Jeffrey Boss for President

FDIC Comment Letter on Capital Adequacy http://www.fdic.gov/regulations/laws/federal/2008/08comAD32.html

 Public Due Process Comment Letters on 8May 08 RE Commodity Futures Trading Commission: Agricultural Forum, April 22, 2008: comment www.cftc.gov/PressRoom/Events/Events2008/event042208_c049; 5May08 related to Agri-commodities “CFTC Requests Public Input on Possible Regulation of “Event Contracts”ETFs, ETNs, ETCs  tracking commodities and associated indexes – public opposition to these equity market tradable vehicles submitted the Commodities Futures Trading Commission and Securities and Exchange Commission on May 8-9, 2008 towards its public comment on the recent problems in the agricultural commodities.

HedgeMetrics, Haugen Custom Financial Systems Sales of these QEDI clients’ products; engaged in portfolio management business development sales on behalf of both clients

XShares Advisors, Index Administrators for 19 Healthshares Indexes and associated Exchange Traded Funds “ETFs” Monitoring index members and selecting new bio/health members for index representation.

Enterprise Development Partners, LLC “PLASMARC”: Project development, capital infusion, merger/acquisition, site strategy $500MM-$1.5Billion (on-going); capital search for $250K-$25MM.

DiscoverScreenS: Capital infusion and strategic roll-up$3MM to $10MM.

OREnterprise: Risk Management company providing software for Sarbanes Oxley Sections 404, 302 Compliance; capital search $5MM

Van Eck Global, “Does the Steel Industry Perform Differently Than the Basic Materials Sector” Co –author with C. Michael Carty and Ed Matluck, PhD.

Rapid Ratings™: Sales and Consulting. Rapid Ratings™ screens portfolios for banks, lenders, large creditors and insurance companies to identify counterparty risk exposures to high vs low-risk credits investigate the creditworthiness of potential new credits; monitors creditworthiness trends of existing credits; also for compliance with BASEL II requirements.

Blue Ridge Motion Pictures  Capital Search, real estate sale of properties, $10MM – $20MM.

2006

Rapid Ratings™: Sales and Consulting. Rapid Ratings™ screens portfolios for banks, lenders, large creditors and insurance companies to identify counterparty risk exposures to high vs low-risk credits investigate the creditworthiness of potential new credits; monitors creditworthiness trends of existing credits; also for compliance with BASEL II requirements.

Strategic Shareholder effort – Shareholder/corporate governance opposition to regulatory filings of the Sovereign Bancorp for acquisition of Independence Bancorp combined with opposition of regulatory filings by Banco Santander Application acquisition/change in control for Sovereign Bancorp; for regulatory submission, legal battle, amicus brief submission on behalf of shareholders https://apsoras1.wordpress.com/2013/05/06/2feb06-amicus-brief-to-u-s-district-courtsouthern-district-ny-relational-investors-llc-sovereign-bancorp-banco-santander-s-a/; Relational Investors, I reviewed Santander application with Federal Reserve Bank of New York, New York State Department of Banking and Sovereign Bancorp application with the Office of Thrift Supervision for Independence.

Co-Author Blank, Herb, and Andrea Psoras. “When Sin Is Superior”, Financial Advisor, April 2006. Co-author on a white paper analyzing period from 1985 through 3Q2005 the divestiture and use of shunned ‘vice’ sectors to tweak investment portfolios (http://www.fa-mag.com/news/article-1368.html ). The SPADE Index refers to this research.

2005

Rapid Ratings™: Sales and Consulting while at QED International. Rapid Ratings™ screens portfolios for banks, lenders, large creditors and insurance companies to identify counterparty risk exposures to high vs low-risk credits investigate the creditworthiness of potential new credits; monitor the creditworthiness trends of existing credits; and comply with BASEL II requirements.

(2005-September from 11 September 2001) Whistle-blower years – over time period while the major financial players were using the financial ‘engineering’ aka ‘financial innovation’ to pump fees through the income statement and structure off-balance sheet securitizations to hide non-performing assets), I was a Financial sector analyst who went to the New York Fed, SEC on another investment banker engaging in corporate espionage and fraud.

Forming a new unit/repositioning of Strategic Advisory to Strategic Well-Being, to provide well-being and ‘retail’ financial advice to groups and individuals, adjusting business plan, preparing to Incorporate, building website, taking advocacy role against medtech/big pharma self-dealing – Spring/Summer 2005

Freelance writing and analyses of (Spring, Summer 2005): 1. The Google auction IPO; 2. Reporting Intangibles and the Knowledge Economy; 3. The ‘Catch-up’ Provision in 401(K) Plan Sponsor, Participant Adoption, discussing Vanguard experience as of 2004; 4. “Free” Trade = FRAUD TRADE, “Free” Trade: The British Crown Colonial Form of Commerce

Grass roots campaign for candidate for Manhattan Borough President, Summer 2005.

2003/2004

Stock Market related research on a trading model in targeted industries, Fall 2004

Re-matriculated Franklin & Marshall College – Accounting and Economics with ‘cutting edge’ research/ analysis on Revenue Recognition writing about/analyzing Barter Revenue in the Income Statement http://benfranklinrepublican-gmail.blogspot.com/2010/10/no-barter-in-revenue-especially-for.html , and beginning an Econometric review of the Board of Governors study of Community Reinvestment Act lending. Spring 2004

Reviewed, opposed merger proposal between Bank of America and Fleet Boston on Concentrations of Power issues. Testified before the Committee at the Federal Reserve Bank of Boston with written statement introduced as support, however not read in entirety at the hearing: Public Hearing Regarding Bank of America Corporation, and FleetBoston Financial Corporation – Held on Wednesday, Jan 14, 2004, at the Federal Reserve Bank of Boston: Unedited Transcript. Vol I, Pgs 1 – 423, line . 0263 beginning 23 http://www.federalreserve.gov/events/publicmeeting/20040114/20040114.htm.

Reviewed provided feedback on Senate, House drafts on ‘Economic Stimulus’ and other Congressional/legislative efforts

New York Society of Security Analysts – Corporate Governance Handbook – research/analysis – drafts on Transparency, Management and Board Quality, and Independence; for the Corporate Governance/ Shareholder Rights Committee and used by the New York Society of Security Analysts, then by the CFA Institute for its own Corporate Governance Handbook.

Baruch College-Accounting Program/Accounting Certificate, 2003.

2001/2002 STRATEGIC ADVISORY:

Reviewed provided feedback on Senate, House drafts on ‘Economic Stimulus’ and other Congressional/ legislative efforts

Client: Joint Equity Development Corp (“JEDCO”) a mortgage product startup founded in Connecticut/search for $5mm private equity. Advisor role: first became acquainted with the founder while at KPMG, where my role for this transaction began as Senior Analyst along with the transaction management/execution efforts.

Client: Julie Research Labs (NY) Strategic Advisor to Trident Project ($2.5B non-nuclear naval rocketry). Project impacted by policies of US nuclear arms strategy. Private equity search for firm while it was/is involved in lobbying for change in nuclear arms policy.

Client: Sageworks, Inc. and Sageworksinc.com (CT/NC)– Strategic advisor/marketing for founder, Brian Hamilton on behalf of SageWorks, Inc. – an Internet based artificial intelligence tool/product that advises and provides an analytical model for ‘small’ business and other entrepreneurs to improve their business decisions, business performance.

Client: Alternative Power (NY) In negotiations to provide Advisor/Manager/Analyst to find strategic partners and with private equity, client development for this green energy/alternative energy, photo voltaic company – the September 11 catastrophe derailed the engagement (contract size difficult to estimate- $500k to $mm+).

Client: Enterprise Development Partners (NY) corporate strategy change for “green” steel/”green” power from waste.   Private Equity/Advisor role for this enterprise with operating strategies including scrap steel refining, waste pyrolsis and with strategies for profitable ‘community’ economic development (private equity $25mm-to open end project size).

Client engagement: UBS For 5 months in 1999 and again in 2001, I worked for UBS Warburg as a Counter-party credit risk analyst in its North American Financial Institutions department. Not an officer who could approve enlarging credit line exposures and approving trades that exceeded credit limits, I analyzed financial condition and relationships with UBS North American counter-parties. This group included: SunTrust, BBT (Branch Bank & Trust), Wachovia, National City (OH), Fifth Third, Citibank’s subs in Spain (whose financial statements were in Spanish), the Bahamas, its Credit Card Banks in UT and SD, its Asset Management Bank in Japan, BAC’s Institutional/Investment bank units in Canada and Chicago, Pacific Century Bankshares (BOH), Morgan Stanley’s Paris Broker/Dealer, whose financial statements were in French, Providian, The Dime (NY), Wilmington Trust Company, Fiduciary Trust Company, Shelby Collum Davis, Legg Mason, Spear Leeds Kellogg, Archipelago ECN, Jeffries, Raymond James, Advest, the Canadian banks, the US Farm Credit System, the FHLB, the Federal Reserve Bank of New York.

2000 Client engagement/subcontractor –

BLAYLOCK & PARTNERS- Combinations, financial modeling, strategic consulting for and with its endeavors including:

UPS (Transport/Fulfillment Sector) activities – Modeling and Buy-side M&A search for freight forwarders/customs house brokers; other types of fulfillment related companies and other potentially appealing companies to UPS. Transactions totaled approximately $100mm, and role was largely as analyst, but included some advisory and transaction management.

ChevronTexaco (CA) petroleum/consumer finance – Gas Credit Card specialty purpose entity/vehicle engagement on which I was among the group of advisors reviewing this investment/Joint Venture for Blaylock ($15mm) private equity opportunity.

TIAA-CREF (Fixed income investment organization)- $300mm-$500mm Collateralized Debt Obligations structured finance transaction on which I was an advisor, manager, analyst.

Southern Cos. (power/utilities) – business development/Private Equity opportunities to present Southern with suitable partners, targets.

Williams Family Investments Real estate/commerce on St. Thomas – Private Equity, M&A ‘services’ where I acted as Advisor/Manager as well as Analyst for insurance underwriting and brokerage.

Verizon Wireless (Telecom) $10B Initial Public Offering where I was included on a (syndicate company) Management/analyst team.

1995-2000* STRATEGIC ADVISORY (Overlapping in 2000 with Blaylock & Partners) Private Equity Activity log:

Client: SAGEWORKS   Strategic Advisor including Research for and Sale of the $10mm-$15mm company, a web-based small business artificial intelligence analytical tool

Client: The Archivum (NY/CA) – $3mm Advisor/manager/research engagement for this startup media content company.

Client: Julie Research Laboratories – $1.5mm Advisor role for this operating defense sub-contractor company

1998-2000 

Client: Enterprise Development Partners/in conjunction with PLASMARC:          MTN and Medium Term Debentures financings – research, Habib Tariq, Developing market banks, investments in Latin/South America, Asia, former Soviet Block and Warsaw pact countries (while providing research/Due diligence efforts I conducted due diligence, encountered foreign paper, the complex global financial ‘grid’, “3rd World Debt, tax evasion, money laundering, and correspondent banking complexities)

1996 Client: Wit Capital now ETrade (NY/CA) $6mm private equity search for this on-line broker/dealer startup

1995 Client: Depthograpy  (NY) $3mm-$5mm Advisor/Manager/Research for this operating depth lenticular photography company

1994 + Client: JEDCO, LLC

1994-95 KPMG PEAT MARWICK LLP Capital Strategies/Global Capital Group a department created to compete directly with the major investment banks for financial services M&A transactions.

1994-95 General Electric Capital Corp (CT)Strategic Financial Advisor/manager for bid for $12B ITT Consumer leasing/lending division; Advisor/manager search for buyer of $3.5B ITT thrift, AND other Buy side engagements for its activities on which I was manager/analyst for these $multi-million transactions.

1994-95 Joint Equity Development Corp “JEDCO” (CT) Advisor/manager/analyst for $5mm Venture capital/private equity search activity as well as senior strategic analyst for unique mortgage equity product enterprise.

1994-95 Union Savings Bank of Danbury (CT) – Strategic Financial Advisor/manager/analyst for Merger/acquisition strategy to buy branch network, bank or thrift – estimated $80mm.

1995 First Fidelity National Bank (OK) – Strategic Financial Advisor/manager/analyst on growth/acquisition strategy and bank/thrift acquisition targets in its market area estimated net worth $25mm.

1994-95 Fingerhut (MN) Strategic Advisor/manager/analyst for M&A buy side target search thrift/consumer finance sub estimated net worth would be $100 mm.

1994-95 RMBI (NY)- Strategic Financial Advisor/manager on this mortgage bank’s estimated $15mm sale to Roslyn Savings Bank (NY)

1994-95 Pooled Asset Auction (NY) partnership to acquire an sell Real Estate Assets owned by CalFed – $350mm on which I was among the Advisor/manager team.

1994 KPMG – Development of its Derivatives Initiative with KPMG national lead partner for financial services practice Group Analyst consulting/business development.

1994 KPMG European Rating Project Survey and Initiative (NY) analyst for intelligence related to survey and dialogue with European/French banks/bankers after these began to be rated by US rating agencies.

1994 Webster Financial (CT) – Firm’s role as Strategic financial advisor. My role would be eventually manager/analyst on acquisition plans/synergy with competitor for a merger of equals estimated $95mm in net worth.

1994 KeyCorp (OH)Strategic Advisor to develop (estimated) $multi-billion “Consumer” Bank

1994 Carteret Savings Bank (NJ)Strategic Financial Advisor/manager/research (M&A) for minority bid strategy for failed $billion thrift while it was in RTC Conservatorship.

1994 Midlantic (NJ)Strategic Advisor (part of team as an analyst) for Problem Asset workout $100s mm

1994 Penn Federal Savings (NJ)  – Analyst/Manager for Buy-side search for acquisition targets with net worth greater than $10mm

1988-93 ADVEST GROUP – LYONS, ZOMBACK & OSTROWSKI, INC (LZO) Acquired 2000 by the MONY Group (Mutual of NY)

1992 Citizens First National Bank (NJ) with net worth greater than $100mm Strategic Advisor (I was an Analyst) to ‘hostile’ large shareholder attempting to gain board seat with their ‘shareholder activist’ efforts

 1989-90 Manufacturers Hanover Trust (NY) estimated assets in multi $Billions- Strategic Advisor (analyst on Advisor team) prior to acquisition by Chemical Bank (NY); performance evaluations/bench marking/peer comparisons while MHT was a retainer client

 1989-90 Republic National Bank New York (estimated Assets of $25+Bs) – Valuation, fairness opinion for tax purposes of its Uruguay Subsidiary (net worth $mms) with significant precious metals, metals trading operation – Analyst for Advisor

1988-93 Peoples Westchester Savings Bank (NY) Assets greater than $4Billions Strategic Financial Advisor to client while it was acquiring healthy and failing local thrifts transactions on which I was Analyst-research and/or Manager.

1990-92 $10+mm to 100+mm Recapitalization-Private Equity/Rights offerings/Open Bank Assistance filings for the following: 1992 Union Savings Bank (Long Island) ‘Good Bank/Bad Bank’ strategy, 1991-92 Bank for Savings (MA),

1992 Sentry Bank (MA), 1991-92 Brooklyn Savings (CT) among others Strategic Financial /Regulatory Advisor for recaps/private placements which included detailed modeling, due diligence, capital plans – Associate- (execution side).

1992 RiverBank America (East River Savings Bank – Assets greater than $3.5Billions) – Strategic Financial Advisor for Branch Sales with Sales Memorandum and Recap forecasts and documents on which I was Manager/Analyst-research.

1992 Howard Savings Bank (NJ) Assets greater than $1.5BillionsReviewed documentation and valued auto leasing portfolio ($100+mms) prior to FDIC resolution the role of which I was Analyst-Research.

1992 Garden State Bank (NJ) with assets greater than $350mm – Branch Acquisition strategy as well as Strategic/Regulatory Advisor while under a Memorandum of Understanding (“MOU”). Analyst and assisted LZO Partner.

1991-92 House Financial Services Committee: Research while at LZO for Congressman LaFalce (D/New York) on which I was analyst-research.

1991? Old Stone (RI) with assets in $Billions Strategic Financial Advisor (I was the Analyst) to seller, valuation of trust operations while this ‘thrift’ was ‘failing’.  The Sale was part of a strategy for capital raising purposes for Old Stone. I worked on this forecast/model.

1991 Peoples Westchester Savings Bank (NY) Strategic Financial/regulatory Advisor on ‘purchase & assumption’ acquisition of Larchmont S&LA, valuation/fairness opinion and models role of which I was Manager/ Analyst -Research – $5mm capital infusion. I built, worked on the forecast/model as well as parts of application.

 1990-91 Brooklyn Savings Bank, Danielson CT. Recap and Request for Open Bank Assistance for $14MM -20MM savings bank with assets of $300MM, with non-performing real estate/development-construction projects.

 1990 State Bank of Long Island (NY) assets greater than $250mm – Strategic Financial Advisor/Analyst-research for Branch bid strategy for failed thrift deposit franchises and Acquisition targets.  I worked on this forecast/model as well as bid strategy for this client.

 1990 Federal Deposit Insurance Corporation – Division of Liquidation; Research Analytical advice, empirical feedback on development of Brown-Epstein Resolution/ “Loss-on-Assets” model for failed bank/thrift resolutions as well as use of the Bovenzi-Merton Resolution/ “Loss-on-Assets” model – on this project I was an Advisor as well as an analyst-research.

1989 Savings Bank of Rockland Country, (NY) – MOU/Business-capital plan advisory role – $250MM sized thrift required to meet regulatory constraints under a FDIC MOU.  I worked on the business/capital plan, the financial-spreadsheet model and with the LZO ‘team’ which interacted with Bank’s board, management, control/audit staff to improve it’s financial condition and operations for release from MOU.

1988-90 TONE (The One Bancorp) Bancorp/The Maine Savings Bank  M&A engagements and later, recap/private equity search for this $billions thrift.  I worked on the memorandum for this series of engagements.

1988 Sag Harbor Savings Bank (NY) assets $350mm- Strategic Advisor/Analyst on its sale to Apple Savings Bk (NY) I worked on Sag Harbor’s forecast for valuation and M&A purposes before its acquisition.

**1993 RB Cenlar (NJ based mortgage bank sub-servicing operation) Strategic Financial Advisor/Manager/analyst- research for recap, branch sales, and capital plan while under MOU with regulators.

**1993 RB Elmwood Federal, Media, PAStrategic Financial Advisor on which I was Manager/Analyst to seller, valuation of company

**1993 RB Central Pennsylvania Savings – Strategic Financial Advisor on which I was Manager/Analyst to seller in its sale to Meridian

Other Sector Activities and Relationships: – Steel Sector (Integrated, Specialty-Niche, Blast Furnace, Pyrolsis/Electric-Arc Furnace Refining, Scrap/Recycling), Precious Metals refining, Waste Conversion/Bio-remediation, Environmental Engineering, green energy, media content, logistics/fulfillment, maritime/ocean transport and related sectors.

Other relationships/share ownership in: Bethlehem Steel, Baldor, Morgan/Chase, Lehman Brothers, ConAgra, Novis/Stratford Acquisition Corp, Philip Services, L-3Com/(Ayden), Schlumberger (EMR – Drill Tools/Missile Guidance), BlackLight Power

***Notes***.

* In 1999, again in 2001, I worked for UBS Warburg as a Counter-party credit risk analyst in its North American Financial Institutions unit. I analyzed financial condition and relationships with UBS N. American counter-parties. Group included: SunTrust, Wachovia, National City (OH), Fifth Third, Citibank’s subs in Spain (whose financial statements were in Spanish), the Bahamas, its Credit Card Banks in UT and SD, its Asset Management Bank in Japan, BAC’s Institutional/Investment bank units in Canada and Chicago, Pacific Century Bankshares (BOH), Morgan Stanley’s Paris Broker/Dealer, whose financial statements were in French, Providian, The Dime (NY), Wilmington Trust Company, Fiduciary Trust Company, Shelby Collum Davis, Legg Mason, Spear Leeds Kellogg, Jeffries, Raymond James, Advest, the Federal Reserve Bk of NY. http://www.bankinnovation.net/forum/topics/accrual-accounting-and-using

**Indicates the transactions in which I was involved while an Associate VP for 3 months at Ryan, Beck in West Orange NJ.

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