Editor’s Note: This article is intended for information purposes only. Because state and municipal laws vary greatly, as do the circumstances of individual cases, readers are advised to contact an attorney for specific legal advice. The views and opinions expressed here are those of the author(s) and contributor(s) and do not necessarily reflect those of the publisher and editors of WholeFoods Magazine.

After two years of Zoom meetings in place of live, in-person meetings, the Codex Alimentarius Commission (CAC) finally met in-person once again in Rome, Italy during the week of November 21, 2022. Well, not quite. In deference to the on-going COVID-19 fear-mongering, it was actually a “hybrid” meeting where delegates could attend either in-person or by Zoom. But social distancing was to be enforced in the FAO main room where the meeting was to take place, which meant that all of the INGOs (such as the National Health Federation) would have to be seated in a separate, adjacent room where they would participate via a Zoom connection. So, for NHF the choice was clear—save the wear-and-tear, and expense, of travel and attend instead from the relative comfort of a home office.

On Monday morning, November 21st, the CAC Chairman, Steve Wearne, opened the meeting with about 340 participants attending either in person or online. There were the usual obligatory opening speeches extolling the many great deeds of Codex, with hearty pats on the back all around, and announcing plans for celebrating Codex’s 60th anniversary in 2023, but the Chairman quickly got down to business.

Malnourished Third-World Children

One of Codex’s noble goals is to establish guidelines for healthy Ready-to-Use Therapeutic Foods (RUTF), which are used to feed severely malnourished children (usually under the age of five). RUTF are energy-dense, micronutrient-enriched pastes (similar in consistency to peanut butter) that are nutritionally similar to the traditional milk-based diet used in inpatient therapeutic feeding programs. Often, RUTF consist of peanuts, oil, sugar, and milk powder. Some of the ingredients are not what we would consider healthy (certain oils and sugar), but the RUTF do give immediate sustenance to children who might otherwise die.

Codex observer-delegate UNICEF, a keen proponent of RUTF, has stated that, “[p]roperly used, RUTF is safe, cost effective, and has saved hundreds of thousands of children’s lives in recent years. Severe acute malnutrition is a major killer of children under five, accounting for approximately 1 million deaths annually. Around 20 million children worldwide are estimated to be suffering from this condition, of which only approximately 10-15 per cent currently receive treatment using RUTF.” Codex wants to expand the availability of RUTF by creating an internationally accepted guideline; and this guideline was adopted at the final Step 8 at this meeting.

But, before that happened, I expressed NHF’s concern to the Commission over the high ratio of calcium to magnesium (55 mg to 15), reminding everyone that extensive science supported higher levels than those present in RUTF and that calcium and magnesium are twin minerals, and their intake ratio is important nutritionally. In fact, the paleolithic diet typically had a ratio of calcium to magnesium of 1:1, while the RUTF ratio was 4 or 5:1!

In a last-ditch effort, I then proposed that the levels for magnesium be doubled so that they would at least be closer to a proper ratio with calcium. But my arguments fell on deaf ears, unsupported by any member states, and the magnesium levels in the RUTF guidelines were left unchanged, to the harm of malnourished children everywhere.

Both Elisabeth Sterken of the International Baby Foods Action Network (IBFAN) and Patti Rundall of the European Network of Childbirth Associations (ENCA) argued strongly again this year for appropriately designed programs to support continued breastfeeding and re-lactation, and that the use of RUTF should not preclude the use of culturally appropriate, home-based foods. As with NHF, they, too, received nothing more for their trouble than a passing reference in the final report of the meeting.

Nobody Is Thinking

Next up of importance, the Commission considered moisture standards for dates—of little concern to NHF but of great concern to producers of dates. Too strict a standard would kill many of their export markets. The debate over this droned on, but what made me perk up and pay much closer attention was when the member state objections kept piling up and yet the Chairman was still trying to push the standard to the near-final Step 5/8. I spoke up for NHF at this point and said, “Mr. Chairman there is sustained opposition to advancing this standard to Step 5/8.  You only have consensus on Step 5, so you really have no choice but to take it to that Step so that this standard may be considered more fully.” The Chairman then correctly ruled the date standard could only go to Step 5.

This seemed to be the theme for this year’s Commission meeting: Push the envelope for advancing every harmful standard under consideration, often while disregarding Codex’s own established procedures. At one point, the Chairman quite strangely stated, “Those who don’t speak out [at this meeting] support advancement.” Note to Chairman: No, they don’t. They essentially abstain and their voices don’t count. It shouldn’t take my legal expertise to point out that there could be any number of reasons why a member state has not spoken out!

The Chairman displayed his Machiavellian expertise in other ways as well. He was especially adept at getting delegates who opposed a standard from advancing to simply state their “reservations” to it. This is a Codex position that essentially says, “We don’t accept this standard for our country, but we are not opposed to it advancing in the Codex 8-step process.” It is easy to trick new delegates into thinking that by expressing a “reservation” to a standard, they are truly opposing it, when they are not. The correct answer to the Chairman for these delegates should have been, “No, Mr. Chairman, we are steadfastly opposed to this standard advancing.” Save your “reservation” for the very final moment when all is lost and the standard is actually adopted at Step 8!

This problem was highlighted best in the emotionally charged atmosphere surrounding the debate on aflatoxin levels for various grains and cereal-based food standards. Once again, the Chairman very cleverly maneuvered some 40 countries into simply expressing their “reservations” to the standards instead of them taking a firm position opposing the standards. I have never seen this before in my 23 years of attending Codex meetings where 40 countries steadfastly opposed to a Codex standard being adopted are swept up instead into a toothless category of just expressing their “reservations.” I must say that this Chairman is one of the most wickedly masterful whom I have ever seen.

When finally given a chance to speak, I said, among other things, “We disagree with Uruguay that making a reservation is the only way to express disagreement with a standard, guideline, or code of practice. One can oppose a standard completely.” To which the Chairman, to his credit, replied, “Excellent point, NHF.” Unfortunately, NHF’s comment was at the end of the debate and well after some 40 countries had already caved in to pressure and meekly made their reservations. A lot of African and other delegations were visibly upset with the fact that they had been tricked.

To U.S. General George Patton, Jr’s way of thought, “When everyone is thinking the same way, nobody is thinking.” Sadly, and too often at this meeting, very few delegates struck a path different from the mainstream thinking.

The Most Pretentious Word of the Year

“Robust.” If I heard it once, I heard it a million times at this meeting. It was almost everyone’s favorite buzz word in describing the “absolutely marvelous” job they said JECFA had done in evaluating the safety risks of zilpaterol hydrochloride residues in slaughtered animals that end up on consumer dinner tables. JECFA is the acronym for the Joint FAO/WHO Expert Committee on Food Additives and, at Codex meetings, is about as close to being considered a God on scientific matters as anything I have ever seen anywhere else. Most Codex delegates hang on every word uttered by the Codex science officer and woe be to anyone—such as NHF—who disagrees with those official pronouncements!

So, on Tuesday, November 22nd, when the CAC delegates took up Agenda Item No. 4.8 (Zilpaterol residues in food) and started their discussion, “robust JECFA risk assessment” might not have been the first words uttered, but they were certainly among the first, much to my annoyance. That annoyance morphed into disgust as the word “robust” kept being used time and again to describe how wonderful the JECFA risk assessment was. Keep in mind that JECFA has three times declared zilpaterol residues in food to be safe for humans to consume, and Merck and its minions have repeatedly built their case for Codex to approve the standard upon that foundation.

For those who don’t already know, zilpaterol is Merck’s special steroid-like veterinary drug for cattle, pigs, and poultry that unnaturally forces them to make more muscle and less fat. It harms the animals who get the drug, and it further harms the humans who in turn eat the drugged animals. There is no therapeutic benefit whatsoever to the poor animals, only financial benefit to the vet-drug companies and ranchers. And, yet, you should have seen some of thefierceemotions on display at this Codex meeting when country proponents of Zilpaterol pleaded with the Commission to push the Codex standard further up the 8-step approval process at Codex just so that Merck and others could make more dollars around the World. With such passion, you would have thought they were trying to save lives; but, no, it was only about the money.


During the debate on this issue I spoke for NHF, having to endure the Chairman imperiously interrupting the start of my argument to tell me that I couldn’t say that half of the delegates would adopt a standard for “cow patties” simply because otherwise “Codex would look bad.” Another time, the Chairman refused to let NHF and another INGO (IBFAN) speak at all. But when allowed to speak for my allotted two minutes, I gave a succinct summary of the arguments in NHF’s CRD 16, to be found athttps://thenhf.com/comments-of-nhf-on-zilpaterol-hydrochloride/.

Among other arguments made by NHF during the course of the debate, I told the Commission delegates that:

  • Growth-promoting substances do not belong in animal husbandry and that many food companies—including Tyson and Merck itself—have had concerns about zilpaterol causing health and behavioral problems with cattle (and Merck even pulled the product off the market after reports exposed the abuse to animals associated with its use);
  • The residues in food can impact humans even at the levels currently determined by JECFA to be safe, causing tremors, heart palpitations, and other health issues;
  • Many countries around the World have wisely banned this class of vet drugs;
  • Zilpaterol’s use in horses has already been banned, so why are we trying to use it in cattle?;
  • Being a catecholamine, zilpaterol has been implicated as a contributory cause for increased bacterial problems coming off commercial feedlots these days;
  • Far from being “robust,” the JECFA risk assessment of this dangerous chemical was not done in combination with other vet drugs, medicated feeds, toxins, endocrine disruptors, and EMFs, so there is no information on the cumulative and synergistic effects on humans or animals from the drug residues of zilpaterol and other factors acting together, directly violating the requirements of the Codex Procedural Manual; and
  • Codex is the sole Risk Manager here, so it’s entirely appropriate for it to accept or reject any risk assessment, for any reason whatsoever.
Arguing in favor of the zilpaterol standard and its use worldwide were the entire Western Hemisphere countries, most of Africa (including NHF’s former ally South Africa), Australia, New Zealand, and the postage-stamp-sized southwestern Pacific Island states specially flown in for this very reason. Most disgusting, though, were those 25 countries that either prohibit zilpaterol use in their own countries or else simply do not use it domestically but who both argued and voted for the zilpaterol standard to advance. Traitors to their own country’s laws and citizens is probably the nicest way that I could describe them. And, yet, some of the other pro-zilpaterol countries saluted these 25 traitors as sterling examples of Codex fidelity.

After two days of discussion and debate, the European Union, Russia, China, Norway, Switzerland, Iran, India, Thailand, ENCA, IBFAN, and the National Health Federation finally lost the battle to hold back the barbarians from breaching our defenses—which had held so well for 10 years, to keep this toxic vet drug that is added to animal feed for its “Arnold Schwarzenegger” effect on the animals—from advancing beyond Step 4 in the Codex 8-step process of adoption. NHF and others had successfully blocked any zilpaterol standard from advancing in several previous Codex meetings because we could correctly argue that there was no consensus. However, in an in-person (not wholly online) meeting at the Commission level, any member country may call for a vote on the question to force the issue, and that is exactly what they did this time in order to win.

In an obviously well-choreographed series of moves to rival any Broadway musical, and aided by the CAC Chairman Steve Wearne, the pro-zilpaterol countries forced a vote on the issue that they then won 87-48 to advance the zilpaterol standard from Step 4 to Step 5. However, in a second vote taken to brazenly suspend the Codex Procedural Manual so that they could advance the standard to Step 5/8—inches away from the goal line—they failed.

Amazingly, most of the delegates care more about how Codex might appear by not adopting a standard than they care about consumer health. Plus, they don’t appear to listen to our counter-arguments at all. While Austria was giving several excellent arguments on this issue, I could see the Australian delegate seated next to her was thumbing through her phone. And curiously, the Merck front group called “Health for Animals,” which has vocally pushed zilpaterol for years, was silent nearly the entire debate. It was almost as if they knew that the outcome was already sewn up in their favor.

With this article is a screenshot that I took of the Codex voting board showing the votes cast for, against, and in abstention by the member states on the issue of advancing the zilpaterol standard to Step 5. INGOs, such as NHF, may not vote. At the very next Commission meeting, you can be assured that Merck and its captured Codex Offices in the U.S., Australia, New Zealand, South Africa, Argentina, Chile, Cuba, Mexico, Brazil, the Middle East, and elsewhere will shove this standard across the finish line at Step 8 so they can chalk up yet another victory for poisoning the World—unless they are stopped or else consumers boycott Merck-meat in favor of their local ranchers’ production.

The Last Rung on the Ladder to Hell

Codex appears to be systematically destroying animals, insects, and the environment—and therefore Humanity—with its standard making. Nowhere was that more apparent than in the Commission’s discussion of the long list of pesticides sent up to it from the Codex Committee on Pesticide Residues for approval.

The EU argued that the Maximum Residue Levels (MRLs) for clothianidin, quinoxyfen, and thiamethoxam be adopted at Step 5 and not the near-final Step 5/8 because, among other reasons, Codex must consider environmental factors in setting MRLs. These particularly nasty pesticides have been implicated in the death of bees and other pollinators. Norway supported the EU, stating that “there has been a worldwide decline in pollinators and human health does not succeed in a vacuum.” France, Switzerland, Kazakhstan, North Macedonia, Finland, Germany, Sweden, the NHF, ENCA, and IBFAN all spoke up, agreeing with the EU position.

When NHF had its chance to speak, I essentially said, “NHF supports the comments made by the EU, Norway, France, Germany, North Macedonia, Switzerland, Kazakhstan, Finland, Sweden, and others on this pesticide issue. NHF, as a consumer organization with members around the World, would especially like to express its appreciation to them for working to protect the health of its members and consumers in general.

“As for the other delegations, NHF would like to make the following points:

  • Pollination is vital for the reproduction of 80% of all plant species and 35% of all global crops.

  • Without pollinators, the human race would suffer a catastrophic drop in its food supply, leading to widespread starvation. Albert Einstein even said, ‘our extinction.’

  • There has already been a precipitous decline in pollinators around the World with a loss of 60% of native bee pollinators.

  • Over 90% of pesticides do not reach their target, and they cumulate in the environment, so the toxicity problem is growing, not shrinking.

  • So, the protection of consumer health by not killing off our pollinators is clearly appropriate and our responsibility!”

NHF then reminded the delegates, especially those who said that the environment was of no concern to Codex, that “By the way, if the environment is of no concern to Codex, or outside its mandate, then why was an EWG [Electronic Working Group] established by CCPR53 [Codex Committee on Pesticide Residues] promoting environmental inhibitors and none of you objected then? Indeed, you congratulated the co-chairs of the EWG! You cannot have it both ways. Mr. Chairman, there is no urgency to advance these MRLs to Step 5/8. Adopt at Step 5.”

But the United States, Japan, China, Egypt, Canada, Chile, Ecuador, Costa Rica, Brazil, South Africa, Argentina, Australia, New Zealand, and the pesticide-industry front-group CropLife all argued that these pesticides were safe and should be adopted at the near-final Step 5/8. Australia tried to pretend that it had concerns for the environment while New Zealand lamented that, “It’s tempting to consider the World as we might want it to be, but we do not believe that the environmental concerns are legitimate factors.”

After much debate, the pesticide industry got its way and these dangerous pesticides were adopted at Step 5/8, which means that at the very next Codex Alimentarius Commission meeting in one year they can be adopted at the final Step 8. This may very well sound the death knell for bees and other pollinators, and of course then for humans.

These things are clear: They don’t care about people. They don’t care about animals. They don’t care about the environment. Health is never a consideration as they only think about their own rules and standards and with a mindless obsession of adopting yet one more standard, or guideline, or code of conduct, they press on until, finally, the object of their blind obsession has been adopted and enshrined in the panoply of standards, guidelines, and codes of conduct. Then, inexorably, this monster turns its focus upon the next standard and the relentless march towards adoption begins anew. Little stands in its way. Codex is nothing but a factory on auto-pilot churning out industry-orderedtoxicitystandards with little to no discernment. Like a breath of death through dry leaves, Paul Mayers, the former chairman of the Codex Committee on Food Labeling, admitted, “Codex is adjusting to industry practices.” Yes, I would say that it is.

There is a French saying, very applicable here, “Nous n’irons plus aux bois, les lauriers sont coupés,” which in English means, “We’ll go to the woods no more, the laurel trees are cut.” Codex is blindly or maybe not so blindly cutting down all of the “trees,” killing the bees, poisoning the populace, and turning our beautiful Planet into a wasteland.And is calling it “global warming” or “climate change”!But the devastators will have their money; let them eat that, while they hatch their sordid plans for all of the rest of us survivors to subsist on vermin.

“Let Them Eat Crickets!”

On the morning of Day Four of the meeting, the Codex Commission took the torch passed to it by the Codex Committee on Pesticide Residues and addressed the subject of new food categories, including crickets, spiders, lice, and earwigs, all charmingly relabeled as “Micro-Livestock.” Both the FAO and WHO are pushing to create new food sources for humans from insects. To my great surprise, the EU—and Denmark especially—were enthusiastic supporters, with Denmark opining that, “There is an urgent need to transform the World’s food systems.” On the other hand, and much to my surprise, the United States, Canada, Argentina, and even Australia and New Zealand urged that the Commission exercise caution and conduct any work on this matter through already existing Codex committees.

Among other things, the Canadian delegate said, “We may be taking too many steps ahead of ourselves.” When the National Health Federation spoke up, I agreed and said further that the Dominican Republic’s earlier comments were shared equally by NHF, where it had said, “Codex should control food waste before establishing new food sources.” NHF agreed and directed the Codex delegates’ attention to an FAO Report that showed 1.6billiontons of food are wasted globally every year! (Seehttps://www.fao.org/news/story/en/item/196402/icode/.) I also pointed out that most insects are contaminated with parasites, are a health hazard, and should not be consumed.

After much discussion, the Commission was not able to reach any consensus “on the way forward,” as Codex likes to put it. So, the European and other pro-insect-food delegates did not get the electronic working group that they wished established to move this project forward. Instead, members were encouraged to bring up this issue within existing Codex committees.

Somewhere Between Right and Wrong Is Still Wrong

The 13th-century Persian poet Rumi is often quoted as saying, “Somewhere between right and wrong is a garden. I will meet you there.” Lovely sentiments, but if Rumi were referring to compromise, how does one compromise between, say, clean and dirty? Less dirty? Well, that is still unclean. There can be no compromise between certain kinds of positions without the higher moral side losing. Maybe in family arguments there might be a garden to meet someone in, but how about between freedom and slavery? Less free? That’s still a form of slavery.

Codex ostensibly operates on consensus, a form of compromise, reached by its members. It is not a bad system, considered on its own. And many good standards and guidelines have been created by Codex. The Codex Secretariat has always been fair, to us and others, just as I believe that CAC Chairman Steve Wearne has overall strived to negotiate a very difficult path as chairman and be polite and fair to all.

Still, empirical evidence is information acquired by observation or experimentation. What I observed at this most recent Codex meeting as well as over the more than two decades of my attendance at these meetings is that all of the Anglophone member delegations (U.S., UK, Canada, Australia, New Zealand) are clearly controlled by the pesticide and drug industries. The ferocity and intensity with which they protect the pesticides, vet drugs, and other corporate toxins at Codex meetings make this crystal clear. No other smoking gun is needed to know that these government agencies, supposedly in existence to protect the public health, are nothing but corporate branch offices for industry and the public be damned.

As Anton Chigurh asked in the 2007 film No Country for Old Men, “If the rule you followed brought you to this, of what use was the rule?” Codex needs to reexamine its rules and principles. With a world drowning in pesticides and other endocrine disruptors, oceans awash with plastics both macro and micro, vitamin and mineral levels in foods dropping like a stone, people becoming sicker not healthier, and bees dying aplenty while animal herds and poultry flocks are culled for imagined infections simply so that we can all be forced to eat bugs instead, then the World is on the path to death with Codex leading the march. If we don’t change our principles and practices soon, then there can be no return from this path.WF­

Editor’s Note: This article is intended for information purposes only. Because state and municipal laws vary greatly, as do the circumstances of individual cases, readers are advised to contact an attorney for specific legal advice. ©Scott C. Tips 2023

Note: The views and opinions expressed here are those of the author(s) and contributor(s) and do not necessarily reflect those of the publisher and editors of WholeFoods Magazine.