Charles Benbrook wrote:
> Mike -- In response to your question -- Yes, different Bt crystals target
> different insects. They also no doubt will behave differently in the soil.
> I doubt anyone outside the companies working on the technology has much of
> an idea what the consequences will be for soil microbial communities of the
> new corn hybrids with Bt expressed through roots at high levels. How could
> they? There is little or no information in the public arena re the
> engineered Bt toxin that will be in the new hybrids, its exact form, and
> levels of expression over time.
> 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.
> 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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