At a workshop in Washington, D.C., July 17-18, the EPA restated that it seeks to regulate substances that plants produce to protect themselves against pests and diseases according to the definition of the Federal Insecticide, Fungicide, and Rodencide Act (FIFRA) section 2 (if they are "...intended for preventing, destroying, repelling, or mitigating any pest" or "...intended for use as a plant regulator, defoliant, or desiccant").
The 11-society consortium, which issued a report in July 1996 called "Appropriate Oversight for Traits in Plants That Make Them Resistant to Pests," finds EPA's proposed policy "scientifically indefensible." All plants produce traits to protect themselves against pests and diseases, and in many cases, the mechanisms of resistance in plants are unknown, said Roger N. Beachy, Ph.D., of Scripps Research Institute. Regulating these traits would be like trying to regulate the human immune system without knowledge of the genetic information involved.
Since all plants are resistant to some pests, the term "plant-pesticide" implies that all plants contain pesticides and therefore, so does food made from plants, Beachy added. This implication will not serve American exporters well in trying to ship crops overseas, where many countries have sought to ban GMOs or called for mandatory labeling of them.
If the EPA's policy is finalized, "plant-pesticide" labeling will be required for all GMOs regulated under FIFRA. According to the EPA's Nov. 23, 1994 Federal Register, "Labeling includes both written material accompanying the pesticide and labels on or attached to the pesticide, its container, or wrapper," such as a sack of seeds.
The EPA said during the workshop that the public's trust must be earned through policies that ensure no more than a negligible risk. As GMOs do not pose any greater risks to human health or the environment than plants that are crossbred through traditional techniques, the EPA's plant-pesticide policy is unnecessary, Beachy noted. In fact, it will only reduce U.S. public confidence in GMOs, such as strawberries, corn, and wheat, by implying that fruits, vegetables, and grains contain pesticides.
"Are these products safe? Some of the best science in the world has determined yes," stated U.S. Secretary of Agriculture Dan Glickman in a July 17 speech. "As long as these products prove safe, we will not tolerate their segregation... The stakes for the world are simply too high."
Moreover, by imposing regulatory costs of $60,000 to $1 million per registration, the EPA's policy will hinder small to mid-sized companies and publicly-funded institutions such as the USDA's Agricultural Research Service (ARS) from developing alternatives to chemical pesticides.
Wheat production, for example, depends heavily on pest-resistant varieties developed by state agricultural experiment stations and the USDA-ARS. In 1996, it accounted for the largest acreage of crops (76 million) in the U.S. and more than 550 varieties.
"In the U.S., wheat varieties are selected for the highest yield without chemical pesticides," said R. James Cook, Ph.D., research plant pathologist of USDA-ARS. "There are probably more pests and diseases controlled by breeding in wheat than in any other crop."
However, the economic and regulatory burdens of EPA's policy will greatly discourage the use of genetic alternatives to develop pest-resistant varieties of wheat. This will leave wheat farmers more dependent on chemical pesticides to deal with pests that cannot be controlled through conventional breeding, Cook noted.
"This policy creates a major disincentive for all but a few companies, and will force most companies to abandon efforts to develop genetic alternatives to chemical pesticides," stated John Sanford, Ph.D., president of Sanford Scientific, Inc. (SSI), during the workshop. SSI is a small biotech company that develops pest-resistant ornamental plants such as roses and turf grass.
The EPA plans to regulate all pest-resistant plants and create broad categories of exemptions under FIFRA and the Federal Food, Drug, and Cosmetic Act (FFDCA). Scientists, however, feel that the policy should be structured in the reverseóall plants should be exempt from regulation except those whose pest- resistant substances can be extracted and are toxic when reapplied, like Bacillus thuringiensis (Bt) and pyrethrins.
"To safeguard the public, transgenic plants should be regulated as is already being done via the FDA and the USDA," Sanford stated. "However, EPA's policy does not seem designed to protect the public from pesticides, but seems only to serve the combined interests of the EPA bureaucracy and the major chemical companies, who are the producers of real pesticides. The consequence of this policy will, without question, be greater public exposure to synthetic chemical pesticides in the coming decades."
"If it can't be supported by the economics, if it isn't supported by the science, and if it doesn't address a specific risk, what is the basis for the rule?," concluded Daniel Haley, president of Haley & Associates law firm, during the EPA workshop.
Despite these grave concerns, the EPA intends to finalize its plant- pesticides policy by the end of 1997.
Founded in 1939, IFT is a non-profit scientific society with 28,000 members working in food science, technology and related professions in industry, academia and government. As the society for food science and technology, IFT brings sound science to the public discussion of food issues.
Members of the 11-society consortium include the American Institute of Biological Sciences, American Phytopathological Society, American Society for Horticultural Science, American Society for Microbiology, American Society of Agronomy, American Society of Plant Physiologists, Crop Science Society of America, Entomological Society of America, Institute of Food Technologists, Society of Nematologists, and Weed Science Society of America.