August 9, 1996
Union of Concerned Scientists Action Alert:
Urge U.S. EPA to Issue Biotechnology Regulations
For over a decade, the U.S. Environmental Protection Agency
(EPA) has been working on two regulations that would give the
Agency authority to oversee biotechnology products used in
the environment. One, under the Toxic Substances Control Act
(TSCA), would allow EPA to regulate genetically engineered
microorganisms, such as those developed for pollution
cleanup. The other, under the Federal Insecticide, Fungicide
and Rodenticide Act (FIFRA), would regulate "plant
pesticides" -- plants genetically engineered to contain
pesticides, such as the Bt insecticidal crops. These rules
are a critical part of the federal regulatory framework for
biotechnology.
Almost two years ago, the Agency issued the two rules as
proposals for public comment. EPA received and analyzed the
comments and revised the regulations. But now the revised
rules are stuck in the Agency review process. Action is
needed to get the rules published as final regulations by the
end of the year.
** Your Support Is Needed Now. The FIFRA Rule Is Under
Attack.**
Recently, a coalition of food and agriculture scientists
released a report and held a Congressional briefing to
denounce the FIFRA biotechnology rule. Coordinated by the
Institute for Food Technologists, eleven societies
representing food and agricultural scientists have endorsed
the report. Though its recommendations are vaguely worded,
the coalition appears to be calling on EPA to abdicate
responsibility for genetically engineered pesticidal plants
under FIFRA. The coalition asserts that the EPA rule unfairly
singles out genetic engineering for regulatory oversight and
will retard the development of agricultural biotechnology.
Letters are needed to counter the pressure on EPA that this
report may generate. The Union of Concerned Scientists (UCS)
requests that you write to the EPA administrator and tell her
that it is important for EPA to finalize these rules this
year.
** The TSCA rule protects against the environmental risks of
nonpesticidal genetically engineered microorganisms. Without
these rules, developers could test genetically engineered
microorganisms in the environment without federal review or
oversight.
** The FIFRA or "plant pesticide" rule regulates the
commercial uses of crops genetically engineered to produce
their own pesticides. This rule is critical in the regulation
of the Bt insecticidal crops. Without these rules, EPA will
not have authority in the future to oversee Bt crops and
require resistance management plans as a condition of
commercialization. Currently, companies voluntarily submit to
EPA to obtain registrations for Bt crops.
The need for EPA's authority over pesticidal plants became
clear this summer -- the first growing season after
commercialization of Bt crops. Last month, thousands of acres
of Bt cotton were damaged by cotton bollworms, one of the
three insects the genetically engineered cotton was supposed
to control. That great numbers of bollworms escaped the
lethal effects of Bt cotton means that the plan to delay the
development of resistance in the bollworm is failing.
Effective resistance management plans are crucial to
preserving Bt. If an insect develops resistance to Bt in
engineered crops, it will also be resistant to Bt sprays,
thereby threatening the effectiveness of one of organic and
sustainable agriculture's most valuable tools to control
insects. To gain registration of Bt cotton, Monsanto agreed
to implement a resistance management plan which relied on the
crop's ability to produce high doses of Bt that would kill
virtually all cotton bollworms. The damage reports from the
Cotton Belt create serious doubts that the resistance
management plan will work. EPA must evaluate the situation
and decide whether to suspend Bt cotton sales to keep the
cotton bollworm from developing resistance.
If the FIFRA biotechnology rule is not finalized, EPA will
not have the power to require resistance management plans or
to intervene in future uses of Bt crops.
Send letters to:
Carol Browner, Administrator
Environmental Protection Agency (Mail code 1101)
401 M St., SW
Washington, DC 20460
fax (202) 260-0279
Letters should refer to OPPTS, docket control numbers OPP
300369 and OPP 300370.
Source/contact: Jane Rissler, Margaret Mellon, Agriculture
and Biotechnology Program, Union of Concerned Scientists,
Suite 310, 1616 P St., NW, Washington DC 20036; fax (202)
332-0905; email jrissler@ucsusa.org, mmellon@ucsusa.org.
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