I also expect that the manufacturers will, and indeed may have already
submitted thousands of pages of data/studies that they feel show there will
be "no problems." Because EPA rules prohibit the agency from publicly
disclosing this and other data until after a decision has been reached,
there could be essentially no time between government review/approval and
widespread marketing. I am sure the grower, land grant and NGO communities
will press Dow and Pioneer to be much more forthcoming with data than they
have to be under EPA regulations. Since both companies are trying to not
follow in Monsanto's footsteps, maybe they will open up the process. If
they do not, they will be asking for trouble.
My gut feeling is that the scope/degree of change in the soil profile from
the new corns could be very different from the experimental conditions in
which past work was carried out. I think many soil ecologists and students
of soil health feel the same way. Extrapolating safety from past work that
involved low levels of foliar Bts mixed in soil, to the much higher levels
of probably partially truncated-activated Bts exuded through roots for
continuous, extended periods is a huge leap. Stotsky's new work adds a new
reason to "look before thousands of corn farmers leap,'' as it were.
What might it take for the U.S. EPA to review and act upon this critical
new GMO technology "correctly" from the perspective of those advocating
adherence to the precautionary principle? As part of my work with the
Science and Environmental Network (SEHN) and IATP, I am among a group of
people working toward at least a preliminary answer to this question.
Some early thinking follows; we welcome people's reactions and further
suggestions and dialogue.
The first key goal would be to characterize potential risks (both in the
soil system and animal/human health, of course) and to establish baselines
from which potential risk/adverse consequences can be objectively
monitored. This step entails both the qualitative description of potential
adverse risk outcomes, and the identification of what amounts to
mechanisms of action through which bad outcomes might arise, including
identification of "worst case" combinations of factors that would seemingly
increase the odds of problems occurring. This later step is key in
targeting monitoring efforts and to rapidly build confidence that the
review/approval did cover all the bases.
Next, science/data submitted that supports a prediction that possible
risks will not amount to much must be critically evaluated. EPA's approval
will depend largely on whether the agency, and scientists asked to review
the decision and underlying data, conclude that a persuasive and solid case
has, in fact, been made.
Last, the agency must insist on there being a credible monitoring system
and an incremental series of field research activities. It is not
realistic to expect science to completely foresee the impacts of such a
technology given the lack of knowledge of what really goes on in soil.
Accordingly, much greater weight must be assigned to actual infield
monitoring in the first few years of approval, to make sure the initial
risk assessment did not completely miss some complex multi-tiered effect.
The approval also needs to have appropriate "easy out" clauses (i.e.
conditions) -- if x, y, or z is found in early field research (or other
required monitoring), the approval is rescinded, period, without EPA having
to go through a 7 year, multi-million debate with the registrant, as often
the case with federal pesticide law (under which biotech approvals are
made). When the registrant/developer has new data showing the problem has
been fixed, they can always resubmit the technology for a new review.
Both a resistance management and non-target impacts monitoring program
should be developed and in place, with appropriate safeguards, BEFORE wide
scale planting. The conditional approval of the new varieties should
depend upon annual field research/monitoring confirming the projected
performance of the resistance management plan and lack of "meaningful"
impacts on non-targets. Increased plantings should lag by a year or two
the confidence scientists have in the data/knowledge supporting the "no big
impacts" conclusion.
The EPA's Scientific Advisory panel meets 12/8 to discuss the type of
research and data needed to project the ecological impacts of Bt-transgenic
crops on non-target Lepidopterans, soil microbial communities, and other
non-targets. I hope they spend at least some time considering below the
ground impacts, and am sure they will given the timely release of the new
work by Stotsky and colleagues.
chuck
Charles Benbrook CU FQPA site www.ecologic-ipm.com
Benbrook Consulting Services Ag BioTech InfoNet www.biotech-info.net
5085 Upper Pack River Road IPM site www.pmac.net
Sandpoint, Idaho 83864
208-263-5236 (Voice) 208-263-7342 (Fax)
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