Some terrific stuff here in relation to Food Aid, Food Safety, the WTO case, and the resistant weed problems rapidly emerging as a result of Roundup Ready crops.

Excerpts from "GMOs, Pesticide Use, and Alternatives Lessons from the U.S. Experience" Presented at the Conference on GMOs and Agriculture by Dr. Charles M. Benbrook, Paris, France, June 20, 2003

Full text and slides available from:
http://www.biotech-info.net/lessons_learned.html
---
Food Safety

Most of the reassuring commentary from the U.S., such as "...all Americans have been eating this food for years and are fine..." is misleading and in an important way, not relevant.

GM corn and soybeans are mostly processed and fed to animals: very small volumes are consumed directly by people in relatively unprocessed forms. Essentially zero research has been done on impacts of GM food on pregnant women, infants, and children - the population groups likely to be most vulnerable to adverse impacts, if there indeed are any. It will take large, expensive and sophisticated epidemiological investigations to determine whether people and farm animals (or pets) are, or are not suffering allergic reactions or other problems. These studies have not been undertaken in the U.S. or elsewhere, to my knowledge. Hence, extrapolating from the "lack of evidence of harm" in the U.S. to other countries, cultures, and circumstances where GM food might be consumed differently (for example, in the form of food aid, largely unprocessed, and as a major component of the diet) is basing safety assurances on assumptions, some of which are based on other assumptions.

Many scientific societies on both sides of the Atlantic, and a few in cyberspace, have been asked to look at the issue of GM food safety. When asked if there is evidence of harm, the answer is generally cautiously reassuring. Unfortunately, most reviews do not delve more deeply into the unresolved issues of food safety. The lack of pertinent data to review is one major reason why. Those few scientific assessments that have done so with the benefit of current literature in peer reviewed journals rarely dismiss all concerns and almost always recommend additional public sector research to settle lingering issues. The U.S. position that the current absence of evidence of GM food safety risks is now ample proof of safety, versus the view in Europe that more science should be done before reaching safety judgements that open the whole food supply to GM transformation, will be one of the major debates in the WTO case and the scientific community for the next decade or so.

Comments on GM Food Aid

Developments in Zambia last summer set in motion what has become a far-reaching, high-decibel global debate about the role of GMOs in food aid, and more broadly, over the possible contributions of biotechnology in meeting food security needs in developing countries.

Surprisingly, the U.S. government and biotech advocates have prominently featured the growing opposition among many developing countries to GM crops and food aid as one of the major reasons why the U.S. has initiated a WTO case against the EU. As far as I can tell, three important points have been largely absent from this dimension of the GMO-food safety debate.

First, when the companies advanced Bt corn through the regulatory process in the U.S. and Europe, it was known and understood that 98 percent plus of the corn would be fed to animals or processed. If regulatory authorities believed that a sizable share of the American consumers eating Bt corn would consume it directly and that, moreover, the corn might make up as much as half or two-thirds of daily caloric intake, they would NOT have approved it based on the data presented at the time. Anyone who claims that U.S. regulatory reviews of Bt corn technologies in the early 1990s "proves" safety in the context of food aid to Africa is either unaware of the nuances of risk assessment science or poorly informed of the scientific basis of U.S. regulatory reviews at that time.

Second, people in Africa who are suffering acute or chronic malnutrition, AIDs, and/or other health problems may react to consumption of Bt corn - especially when minimally cooked and processed, and present as a major share of their diet - in different ways than the average American or European has reacted to it. It is known that Bt corn may have adverse impacts on the stomach lining, and that potential food safety/allergenicity impacts are impacted in many ways by gut bacteria and the overall health of the gastro-intestinal tract. It is doubtful that any company or government institution has carried out the research needed to determine whether these differences could translate into risks in Africa among the very hungry that are both qualitatively and quantitatively distinct from those that might be expected in North America and Europe.

Third, food aid can and has had negative impacts on farm prices and production in recipient countries. Solving short-run food insecurity crises in a region by undermining the people and the economic sector that must deliver food security in the long-run strikes many people as less than satisfying. Food aid can both meet the pressing needs of the hungry and build agricultural capacity and support infrastructure development when food aid is provided in cash and used to buy basic foodstuffs in the region. The U.S. could easily switch its current policy of providing food aid in the form of grain (whether GM or not), by selling grain stocks on the market and transferring the cash proceeds in the form of aid.

Of course, such a change in U.S. policy will have some costs associated with it, and will increase the need for accountability regarding how aid funds are spent, but many reputable NGOs can handle the money and purchasing, as they are successfully doing in several countries with food aid cash donations from the EU. This approach would also put an end to conspiratorial assertions that the U.S. is trying to force GM food on poor countries.

Providing Bt corn food aid to hungry people in Africa is certainly better than starvation, if the only near-term option. But shouldn't the world community step back and ask why GM food aid became, for even a short period, the only option?

This question is not uppermost in the minds of U.S. commodity groups and politicians praising the Bush Administration for filing the WTO case. In introducing a Senate resolution urging the President to aggressively pursue the WTO case and raise GM food issues at the June G-8 summit, Senator Bill Talent said -

"To me, the turning point was when the European Union countries not only refused to take the biotech product themselves, which I don't even think is defensible, but then they began trying to convince African countries that are in danger of famine to turn down shipments of safe, nutritious U.S. humanitarian biotech food aid." (Floor statement, U.S. Senate, May 23, 2003)

The WTO Case

The May 13, 2003 filing of the United States WTO case against the European Union's moratorium on GM foods is likely to lead to unintended consequences on both sides of the Atlantic. This step has set in motion a process that will -

Raise the stakes in ongoing confrontations between the U.S. and EU over genetically engineering, trade, developmental assistance, and agricultural policy.

Provide the U.S. and the EU an important new forum in which to debate the safety and environmental impacts of GM crops.

Receive substantial media coverage and attention from all sides of the debate and the general public.

Impact in a variety of ways the attitudes of consumers, the food industry, regulators, and politicians all over the world.

The WTO case will trigger a broadening of scientific and public debate in the U.S. over the costs, benefits, and risks of GM food and agricultural biotechnology. This broadening of debate is long-overdo and will hopefully prove constructive in the long-run.

Most Europeans are unaware that there has been little independent, open scientific focus on the safety and benefits of GM foods in the United States. There has been countless days and millions of person-hours spent by dozens of groups discussing what sort of risk assessment science and policies are needed, but no consensus has yet been reached and very little independent risk assessment research has been done.

In the late-1980s, then Vice-President Dan Quayle led a "Council on Competitiveness" composed of senior political appointees from several agencies. Its mission was to identify hot areas of science and technology where the U.S. might gain a stronger position in international markets through innovation. Biotechnology was among those chosen to promote, a decision that led to several key policies in the late 1980s and early 1990s - substantial equivalence, the coordinated framework, no need for basic safety research.

In the current climate, the U.S. agricultural biotechnology regulatory system and policy framework is both difficult to augment and improve as new challenges emerge (without acknowledging weakness), and difficult to defend as thorough and rigorous relative to contemporary scientific understanding and international food safety norms and testing recommendations.

Another practical reality has limited open, scientific debate on GM food technology in the United States. With exception of those working for or on behalf of the biotechnology industry, very few scientists have had access to company data on GM crop transgenes, the methods used to transform plants, where and how transgenes are expressed, and the stability and expression of transgenes as impacted by biotic and abiotic stresses.

Indeed, I know of not a single independent scientist in the U.S. that has gained access to such data on any current GM crop or food. Furthermore, I am near-certain that no independent scientist or laboratory has received the funding, information, and technical cooperation required to carry out what any team of experts would consider a thorough and independent assessment of GM food safety claims.

A recent Washington Post article (May 30, 2003) on the GM food approval process in the U.S. makes clear that not even government regulatory scientists see full data packages or have access to the same information as the companies seeking approvals:

"The FDA reviews biotech foods for safety, and the agency's action on a new biotech crop is often characterized in press accounts as approval. But legally, it isn't.

"The FDA operates a voluntary system under which biotech companies decide on their own how to test the safety of their products, submit summaries of their data -- not the full data -- to the FDA, and win a letter that says, in so many words, that the agency has reviewed the company's conclusion that its new products are safe and has no further questions. In most cases, the data on which the safety conclusion is based remain secret. It is a much less rigorous system than the FDA procedures for reviewing new drugs or food additives, in which the agency will spend months if not years going over company claims in detail."

The adequacy of past U.S. government reviews of GM food technologies will surely be a part of the WTO case, as will an open-ended assessment of environmental impacts.

Already, a series of U.S. National Academy of Sciences (NAS) reports since 2000 have recommended steps needed to improve the scientific foundation for GM food related food safety and environmental risk judgments. Anyone can compare side-by-side the scientific studies and rigor called for in recent NAS or contemporary Codex recommendations for the evaluation of GM food safety risks, in contrast to the science-base supporting today's GM foods. The conclusions drawn will be obvious, although many people will continue to argue that the preponderance of evidence, and the U.S. experience, proves that GM foods pose no meaningful or measurable food safety risks. I sincerely hope they are proven correct.

...The filing of the WTO case is likely to slow the pace of change in U.S. policies, since it will be difficult for the Bush Administration to defend policies before the WTO as fully adequate at the same time the policies are being reformed in response to recommendations from the NAS and other scientific advisory boards.

Sustainability of Herbicide Tolerant Technology

Herbicide tolerant technology has increased dependence on a single herbicide, glyphosate, to clearly unsustainable levels. The extent of use in the U.S. since about 1997 has triggered shifts in the composition of weed communities and set the stage for the emergence of resistant weeds (Harztler, 1999).

Excessive reliance on any single pest management tool heightens the selection pressure imposed on pest populations and sets in motion evolutionary processes that ultimately will undermine efficacy (Lewis et al., 1997). It is no surprise that Roundup resistant weeds have evolved in the U.S. and are beginning to force farmers to add additional herbicides to their weed management programs.

Earlier this month university scientists reported the first significant breakdown in the efficacy of Roundup Ready technology triggered by a resistant weed. The Associated Press covered the findings in a June 4, 2003 story, "Weed Could Cost Farmers Millions to Fight."

University of Arkansas weed management specialists are projecting that about 600,000 acres in the State will be infested with glyphosate resistant marestail (also known as horseweed) by next crop year. They estimate that farmers will have to spend an additional $8.00 to $15.00 per acre to control the resistant weeds in fields were they are present this year, and on much of the 600,000 acres next year and annually thereafter as long as Roundup Ready crops are planted.

The magnitude and severity of this problem in Arkansas reinforces the urgency of rethinking how RR technology is used, if the efficacy of glyphosate is to be preserved. In recent years in Arkansas, USDA pesticide use data show that about 3.5 million acres of soybeans have been grown, with about three-quarters planted to Roundup Ready varieties. About 970,000 acres are planted to cotton, with perhaps one-quarter Roundup Ready.

Accordingly, Roundup Ready technology has been used on some 2.9 million acres annually for about four years, use that has led to a projected 600,000 acres infested with resistant horseweed. This is already about 20 percent of the 2.9 million acres on which Roundup Ready technology has been used.

Without aggressive measures to control resistant phenotypes, horseweed will spread throughout regions where Roundup crops are common. These measures will markedly increase both grower costs and herbicide use, reduce the acreage that can be planted to RR crops, and will have to be sustained for several years.

The rapid and already broad geographic spread of glyphosate resistant horseweed has occurred because of the intense selection pressure this weed has been subjected to in fields planted to Roundup Ready crops. This unfortunately proves correct the warning issued by many weed scientists that resistance would emerge as a much greater threat if glyphosate tolerance were engineered into agronomic crops and planted widely (Hartzler, 1999).

The longer-run impact of weed shifts and resistance on the viability of herbicide tolerant plants remains to be seen. Weed scientists in the U.S. generally agree that - The Roundup Ready system still works well in most places, although not as well as when it was first adopted.

Resistance is appearing in weed populations somewhat more quickly than anticipated, based on glyphosate's long history of use without resistance prior to the introduction of HT technology.

The pounds of herbicides applied per acre and cost of the RR system are edging upward, despite reductions in the cost of glyphosate, because of incrementally more serious weed shifts and resistance.

In addition, Roundup Ready soybeans have led to other ecological responses with negative consequences. For example, applications of glyphosate on RR Soybeans can retard root development and nitrogen fixation - adverse impacts worsened by drought (King et. al., 2001). Other examples are discussed in Benbrook (2001a).