Since, approximately, November 2012, Legacy Food Storage has promoted that they are 100% GMO Free. That may be the case but, the details behind the certification are worth reviewing. Below you will find information that is publicly available about Legacy and the certifying organization called the Food Quality Council. Legacy Food Storage is sold Online by sites that are owned or are affiliates of Legacy Food Storage. They aggressively market food storage by comparative analysis between Legacy and competitors. The Legacy site is critical many of the major competitors. Legacy Food Storage has an official certification document declaring that they are “100% GMO FREE.” That document is signed by a person named Roger Mickelsen with a title of “Certified Quality Manager.” This document has a date of 12-4-12. An image of the certificate can be found below but the certificate can also be found on the Legacy site here: http://www.legacyfoodstorage.com/index.php/features.html# Legacy Food Storage creates various sites; many of them have, at some point, referenced a single PO Box address (PO Box 2070. Salt Lake City, UT 84110). When pushed, the Legacy team will explain that all of the entities are separate and different (see an example of how they explain it here: http://www.survivalistboards.com/showthread.php?p=4294557 ). A Google search of the terms [PO "Box 2070" Salt Lake City, UT "84110" "Food"] will generate a resulting search of six web domains that have referenced the above address. They are: Freelegacyfood.com Preparewise.com Buyemergencyfoods.com Legacypremiumfoods.com Legacyfoodstorage.com Wisefoodinsurance.com Food Quality Council in Salt Lake City Utah. Who is behind the Food Quality Council? The Legal entity under the name of “Food Quality Council, LLC” was filed in Salt Lake City Utah by Brian L Twede on November 2nd, 2012; that was four weeks before Legacy received Certification as being “100% GMO Free” (see images from State of Utah with date and name of registrant). The Food Quality Council domain was registered on October 31st, 2012, which is 43 days before the 100% GMO Free certification was given to Legacy. Information on the domain registry for FoodQualityCouncil.org can be found here:

http://whois.net/whois/foodqualitycouncil.org . (also see screenshot of the whois information on the registrant at the time of publishing of this document to be Brian L Twede.) The address of record for the Food Quality Council (840 West 1700 South) is also the address for Twede Photography (see screenshot of contact address for twede.com along with screenshot of state of Utah registration details). On the surface, The FoodQualityCouncil.org website reports to be independent and non-biased with a devotion to enforcing industry standards. The site is registered to Brian Twede of Salt Lake who is a Professional Photographer. His website and some of his work can be found at www.twede.com. Under his gallery of work, one will find a food section. In that food section, there are images that were, presumably, taken by Brian Twede, but are also used by the Legacy Food Storage Company to promote their product (see side-by-side images of pancakes on both the Twede.com website as well as the Legacy website). If the individual that owns the organization that “certified” the Legacy product line as being 100% GMO FREE is the same person who is either affiliated, engaged, or employed by Legacy as a photographer, it would call into serious question Food Quality Council’s claim of independence. Even though the Food Quality Council gave their approval to the Legacy product over 7 months ago (at time of research), they do not promote the certification of any other organization other than Legacy. This is somewhat surprising since the charter style statement of the Food Quality Council states on their website that:

“The Food Quality Council is an organization that is impartial. Our group doesn't make food, or sell food. We are the people who will test your food, evaluate it, rate it, and publish our findings.” And

“As the time go by, more companies will be added to the ranks and earn the Food That Stores™ seal of approval.” (link: http://foodqualitycouncil.org/Food_Quality_Council/About_Us.html ) See screenshot of the “A Little About Us” page of the Food Quality Council website.

GMO testing: When asked directly about the GMO testing process, the NON GMO Project (http://www.nongmoproject.org) stated that their testing period takes a minimum of 6 weeks and can last as long as 6 months. Seeing that the Food Quality Council was a legal entity for only 4 weeks before Legacy received “Certification,” it creates concern that the process was “Independent,” or from a “3rd party” or that it was thorough. Relative to the process, the NON GMO Project states on their website that certain “High-risk Crops must be tested every time prior to use in Non-GMO Project Verified Projects.” This is a very rigorous standard but their certification comes with high level of certainty that consumers will not be consuming products that have been genetically modified. GMO is a hot button issue and one that is very important to a segment of the population who are determined to not consume anything except NON-GMO goods. For the NON GMO Project, the High-Risk Crops include some of the ingredients that Legacy uses. The NON GMO Project states that 88% of the Corn and 94% of the Soy grown in 2011 were “High Risk.” Legacy includes on their various sites, on their product packaging, and on their adverts in a very prominent fashion that they are “Certified 100% GMO FREE” (see image of promotional banner with an arrow to the Certified badge). Some industry experts talk about the extremely cost prohibitive and invasive process of becoming certified as NON-GMO. The expense and rigors create a high barrier to entry for those who would like to earn certification. With a GMO Free certification, one company could gather a high percentage of the business from people who want food storage and want it to be 100% GMO Free. Again, Legacy might have a product that truly is 100% GMO FREE. The “Certificate” on the Legacy site from the Food Quality Council certifies with 100% certainty that the product is GMO FREE. Here is the wording that was transcribed from the certificate: “The Food Quality Council is aware of increased public concern over the use of Genetically Modified Organisms (GMO’s) in our food supply. To that end, Food Quality Council has conducted a review of each ingredient used in the formulation of Legacy Premium Food Storage products. During this review process, Food Quality Council has requested, compiled, and examined documents provided by the manufacturers of each ingredient used in the manufacturing of Legacy Premium products – specifically regarding each suppliers’ position related to the use of Non-GMP

and GMO-Free components in formulation of the ingredients which are used in the Legacy Premium products. After careful review of over two hundred original documents, covering each ingredient used in the production of Legacy Premium Food Storage products, we are able to certify this line of products GMO Free.” It appears that the analysis by the Food Quality Council required for certification of “100% GMO Free” was completed by a review of documentation from the manufacturer of the ingredients with out a reference to the types of tests that performed by organizations like NON GMO Project. Summary points:

Legacy Food owns or affiliates with the owners of various websites. Legacy states that they are “Certified 100% GMO FREE.” Industry experts question the possibility that the products are Certified as

being 100% GMO FREE in the same way that other product are certified by other certifying agencies.

A certification of Legacy offering a product that is 100% GMO FREE is documented to come from the Food Quality Council in Salt Lake City and Legacy appears to have no other validation referenced.

Brian Twede created the Food Quality Council as a legal entity in the State of Utah on November 2nd, 2012.

December 4th, 2012 is the date of signature of the 100% GMO FREE certificate for Legacy Food; that is 4 weeks after the legal entity was formed.

Even though the NON GMO Project stated that their testing process takes a minimum of 6 weeks and can last up to 6 months, The Food Quality Council Certified Legacy as 100% GMO FREE 4 weeks after opening their doors.

Brian Twede who is a photographer in Salt Lake City with experience in food photography and some of the Food photos profiled on Brian Twede’s website are also on the Legacy website to promote the Legacy product.

If there were a professional or financial relationship between the Food Quality Council and Legacy, it would contradict the claim of independence.

The GMO Free certificate suggests that the certification was based on a review of documentation and not a test of the individual ingredients for Genetic Modification.

This is an important issue. In the Food Quality Councils own words: “The Food Quality Council is aware of increased public concern over the use of Genetically Modified Organisms (GMO’s) in our food supply.”

The relationship between Legacy and the Food Quality Council appears convenient in its timing, its connections, and potentially its standards for independence and certification.

The analysis by the Food Quality Council appears to be exclusive to the Legacy product.

Certification from the Food Quality Council to Legacy Premium Food Storage:

Google search of PO Box 2070 and the 84110 and the term “Food”

Food Quality Council Registered Agent from the State of Utah Agent Address. Both the Registered address and the address of Twede Photography are the same.

Whois information at the time of research on the Food Quality Council:

Food images of the Legacy product can also be found on the Twede.com website:

Closer look at the Pancakes- looks identical.

Claim of impartiality of the Food Quality Council and charter style comments about purpose to impartially review other products even though Legacy has the only product that is profiled.

Certified 100% GMO FREE badge found with the legacy product on a website along with a promotional image showing the GMO badge on the packet of Legacy food.