Biotechnology Project
Center for Science in the Public Interest
National Agricultural Biotechnology Conference
Agricultural Biotechnology: Savior or Scourge?
Chicago, Illinois
May 22, 2001

Michael F. Jacobson, Ph.D., Executive Director
Center for Science in the Public Interest

     Thank you very much for the opportunity to participate in this important meeting. It comes at a time of great controversy over biotechnology, and I hope that the discussions will lead to some constructive ideas.

     For those of you who are not familiar with my organization, the Center for Science in the Public Interest is a nonprofit consumer-advocacy organization that since 1971 has focused on food safety and nutrition. In 1990 we led the efforts to win passage of laws mandating the Nutrition Facts food label and defining "organically grown" foods. We are supported largely by the 900,000 subscribers to our Nutrition Action Healthletter, along with foundation grants. We do not accept funding from government or industry.

     Though CSPI sometimes has been accused of being anti-everything in the world of food, from fettucine Alfredo to olestra, we have a decidedly middle position on genetically engineered foods. If used properly, engineered crops could greatly benefit farmers, consumers, and the environment. But, if misused, they could cause great harm.

     Biotechnology is reaching a crossroads, where public opposition may become so great that no farmer, food manufacturer, or retailer will want to market a food with biotech ingredients. The biotech industry, by and large, has insisted that genetically engineered foods are sufficiently regulated and perfectly safe. That posture simply isn’t flying in the age of StarLink corn, Mad Cow Disease, and the Internet.

     Critics are asking many questions about biotechnology — ranging from accusations of potential ecological catastrophes to monopolization of the seed industry by a few companies. The current crops are benefiting primarily the seed and chemical companies and farmers, not consumers. When benefits are enjoyed by one party, but possible risks are borne by another, that’s a formula for suspicion. In such an environment, it behooves supporters of biotechnology to address valid concerns, debunk red herrings, and build long-term public confidence by establishing strict rules to protect the environment and ensure safety and choice to consumers.

Slide 1 Before I address the concerns, though, let me emphasize that everyone — including environmentalists — should draw satisfaction from the fact that the current engineered crops appear to have been safe and have yielded environmental benefits.

     * According to the National Center for Food and Agriculture Policy, in 1999 Bt cotton enabled farmers to cut their insecticide use by 2.7 million pounds and increase their net revenues by about $100 million. That’s a tremendous boon to farmers and presumably to non-target species.

     * In 1999, herbicide-tolerant soybeans reduced weed-control costs by $216 million and led to 19 million fewer herbicide applications. The no-till farming that herbicide-tolerant crops encourage also should reduce soil erosion. While overall herbicide usage has remained about the same, glyphosate herbicides appear to be much safer than some of the herbicides that they replaced

     * Bt corn, according to the National Center for Food and Agriculture Policy, saved an estimated 66 million bushels of corn from the European corn borer in 1999. Also, Bt corn should have lower levels of insect damage and some mycotoxins.

     * Finally, genetically engineered papayas provide Hawaiian farmers an effective new means of coping with the devastating papaya ringspot virus.

     Genetically engineered versions of sweet corn, potatoes, sugar beets, apples, and other crops have been developed and could be providing similar benefits, but farmers and processors won’t plant them for fear of a consumer backlash.

Safety Concerns

     From the consumer’s point of view, the key question about biotech foods is, "Are they safe?" To date, of course, biotech foods have not caused any known health problems whatsoever. That record of safety is reassuring. To be honest, though, it probably would be impossible to identify many long-term problems, such as carcinogenicity or neurotoxicity, with current testing procedures.

Slide 2 One of the obvious concerns is whether engineered foods might cause allergic reactions. Known allergens are easy to test for. However, if a protein to which people have had only limited exposure were introduced into foods, one could not state definitively whether that protein could cause allergic reactions.

     Another concern is that levels of naturally occurring toxins in plants might be increased. Again, known toxins are easy to test for. But it is not inconceivable that a genetically engineered food would display a novel toxicity, such as by activating a "silent" gene or altering normal metabolic pathways. While speculative, those concerns indicate the need for a rigorous, but not suffocating, regulatory scheme, including appropriate testing standards.

Ecological Concerns

Slide 3 While consumers may focus on safety, environmental problems may be likelier. Whether it’s the effect of Bt corn on non-target organisms, or the spread of genetically engineered characteristics to wild relatives, or the development of pesticide resistance in insects or weeds, GM crops deserve the closest scrutiny. After all, the self-propagating nature of living organisms - be they fish or wheat - means that once a problem occurs, it might be uncontrollable. While the U.S. Department of Agriculture and the Environmental Protection Agency claim to be doing an effective job of anticipating and preventing environmental problems caused by GM crops, last year a committee of the National Academy of Sciences identified numerous ways in which the system should be strengthened. And last March an EPA Science Advisory Panel concluded that data requirements for the effects of Bt corn on non-target insects were not complete, leading the EPA to ask companies for new studies.

Regulation - Safety

     Most Americans, I believe, are open to biotechnology, but want assurances that the foods are safe and that crops won’t adversely affect the environment. We need to upgrade our regulatory system to minimize those concerns.

     The FDA has long relied upon a voluntary consultation process to address any safety problems. That process did not result in any health concerns, but it takes place behind closed doors and does not result in a formal approval. In contrast, the FDA has a mandatory, albeit secret, process for approving transgenic animals — such as fish — and the EPA has a mandatory, relatively open process for evaluating transgenic pest-protected plants, such as Bt-corn.

Slide 4 The FDA recently proposed a mandatory review process to replace its current voluntary system for evaluating GM crops. Importantly, the new process would ensure that all new food crops were scrutinized. Also, the new process would be open to public scrutiny, with most company documents being placed on the public record. However, the review process still does not result in a formal approval. Instead, the FDA would say "we have no further questions." While that approach might not result in any harmful mistakes, it would still invite the accurate criticism that transgenic crops are not formally approved in the United States.

     Because the FDA has not been willing to formally approve all biotech foods, Congress should mandate that it does so. New legislation should distinguish transgenic organisms from existing categories, such as Generally Recognized As Safe substances or food additives, and establish a formal approval process. Such a new law should ban common or severe allergens from biotech foods, phase out antibiotic-resistance marker genes, and have the National Academy of Science’s Institute of Medicine evaluate FDA’s standards for biotech foods.

     The StarLink episode revealed an additional problem. Farmers and seed producers apparently can’t ensure that corn — or other crops — grown for feed will not end up in food. Hence, the FDA and EPA should be prohibited from approving biotech crops for animal feed if they are not also approved for human food.

     Those all are simple, sensible measures that the biotech and food-manufacturing industries should be able to accept. Passage of a law that included such measures would significantly enhance public confidence in bioengineered foods.

Regulation - Labeling

Slide 5 The second component of an improved regulatory scheme concerns the labeling of genetically engineered foods. Labeling could respond to concerns ranging from allergies to ethics to environment.

     In response to environmental groups, the European Union, Australia, and several other countries are requiring labeling of foods containing engineered ingredients. The FDA has not done so. Instead, the FDA recently announced a voluntary labeling scheme that it believes will be useful to consumers. It has described situations in which terms like "does not contain genetically engineered ingredients" may be used on labels. Consumers concerned about GM foods could then choose non-GM products. The FDA’s labeling guidance represents a very small advance, and even the FDA admits that very few foods, other than those grown organically, will sprout labels.

     Some critics hope that GM labeling would be the kiss of death for engineered foods and agricultural biotechnology. But it may be that the public is simply not going to have confidence in biotechnology if companies are not more open about their use of transgenic ingredients.

     To better understand the public’s interest in biotech labeling and how consumers might react to such labeling, CSPI recently commissioned a national telephone survey. I’d like to describe some of our findings.

     First, 62% to 70% of people said they would like engineered foods to be labeled. Those percentages are similar to many previous surveys and indicate fairly broad support for biotech labeling.

     We wanted to get beyond that first question and understand consumer attitudes in greater detail.

Slide 6 The survey found that as the amount of the engineered ingredients in a food decreased, so did the desire for labeling. If labeling were required, 61% of those surveyed said that a whole food, such as a tomato, should be labeled. If a major ingredient, such as the wheat in Wheaties, was engineered, 53% said that that should be labeled. The percentage favoring labeling dropped to 42% for a minor ingredient, such as corn starch in a frozen dinner and to 38% for a food like soy oil that does not contain any engineered material. Thus, if labeling were required, well under half of people wanted labeling when only small amounts of, or no, genetically modified material was present.

Slide 7 We found that people indicate a desire not just for biotech labeling, but for just about any information about food production. Thus, 76% wanted labels to disclose the spraying of pesticides, and 66% wanted information on genetic engineering. But 43% wanted label statements on foods grown with practices that cause soil erosion, and 40% wanted the use of hybrid corn to be disclosed. It could be that most Americans don’t know much about food production and are suspicious of any process or term they don’t understand. One could interpret such findings as indicating that 40%, not 0%, should be considered the baseline when asking people if they want something on labels about growing practices.

Slide 8 Several questions indicate that support for labeling is not as deep as appears at first glance. We asked people how much extra they would pay for their family’s food to have labels declare that foods were genetically engineered. About 60% of the people said they would pay either nothing or only $10 per year for that labeling. One in four respondents said they would pay $50 per year or more for labeling, and a small group of consumers, 12%, said they would pay $250 a year or more to get labeling. Those are the hard-core proponents of labeling. Interestingly, even among those people who said that labeling should be required, half said they would pay nothing or only $10 per year. Thus, although most consumers may desire labeling of GE foods, relatively few appear willing to pay additional costs for that information. Of course, some people might want labeling, but want someone else — namely the food and seed industries — to bear the costs.

Slide 9 We next explored how people interpreted label statements. We found that about one-third of respondents believed that foods labeled "contains genetically engineered ingredients" were not as safe as, or not as good as, foods without labels.

Slide 10 Conversely, about one-third of respondents believed that foods labeled "does not contain genetically engineered ingredients" were better than foods without such a label. Thus, if, as appears to be the case, there is no difference in safety or quality between conventional and GM crops, many consumers apparently would be deceived by labels that stated "genetically engineered" or "not genetically engineered."

Slide 11 Those perceptions about safety, quality, or other matters carried over into questions about buying behavior. Only about 40% of respondents said they would buy foods made with genetically engineered ingredients. It didn’t matter whether the foods were transgenic fruits and vegetables or processed foods that contained only minor ingredients that came from engineered crops. Clearly, considering the public’s current views, no food manufacturer would market foods containing engineered ingredients if they had to put a statement on the label.

     We also asked people if they would buy foods bearing other labels. Interestingly, while only 43% of the respondents said they would buy foods labeled "genetically engineered, only about the same percentage said that they would buy foods labeled as having been sprayed with pesticides, treated with plant hormones, or made from cross-bred corn. Apparently, people have apprehensions about any unusual and suspicious-sounding statements made on labels.

     We did not explore consumers’ reactions to different kinds of labels. We left to the imagination of the respondents the prominence of the GM label on food packages. It would be worth exploring how differently people might perceive the term "contains genetically ingredients" on the front of the package, the term "genetically engineered" embedded within the ingredient statement, and a little "GM" symbol somewhere on the front of the package.

     If foods are labeled to indicate that they contain, or don’t contain, engineered ingredients, the FDA should ensure that labeling does not lead consumers to think that an engineered food is inferior, and that a food made without genetically engineered ingredients is superior.

     Considering how negatively the public views genetically engineered foods, I think industry needs to play catch-up and be candid with consumers about the benefits and pitfalls of the technology. The seed industry’s current expensive ad campaign probably is too vague to have much impact on public thinking. The food industry might be in a position to do a better job. It could mount an advertising campaign depicting hundreds of familiar packaged and restaurant foods that contain ingredients from engineered crops. Those ads could explain the apparent safety and the environmental benefits, while acknowledging that the safety of any food — engineered or not — can never be assured with absolute certainty.

Regulation - Environment

Slide 12 Let me now turn to environmental issues. One major concern is that while the EPA stipulates that certain crops, such as Bt corn, be accompanied by refuges of conventional crops, no agency polices and enforces such important requirements. That must be corrected. Also, the NAS report on pest-protected plants made numerous specific recommendations, ranging from regulating viral coat proteins under FIFRA to improving inter-agency coordination. All of those recommendations should be implemented.

     Over at USDA, despite the millions of acres planted with GM crops, APHIS has never prepared a full Environmental Impact Statement for any of the crops that it approved. Full EISs would have led to better analysis and mitigation for any remaining questions.

     To summarize, now is the time, while agricultural biotechnology is still young, for Congress and the regulatory agencies to create the framework that will maximize the safe use of these products.

Other Concerns about Agricultural Biotechnology

     Aside from effects on the public’s health and the ecosystem, agricultural biotechnology raises many other concerns.

     Underlying much of the attacks on biotechnology is the critical question of whether a handful of giant companies — and universities — will end up controlling the world’s major crops and the technology itself. The briar patch of patent rights that affected Golden Rice exemplifies the problem. Also, for obvious reason, companies focus on the largest crops in the developed world — and then only on applications that are profitable, rather than ones whose primary purpose is to protect the environment or benefit consumers.

Slide 13 To bring the greatest benefits to the most people, it is essential that government sponsor more basic and applied research to ensure that new methods and products are in the public domain. Government-sponsored research also should address the needs of small farmers, the consumers, and the environment, as well as so-called minor crops. We need creative ways to prevent a thicket of patents from strangling innovation, especially in developing nations. And we need to expand aid programs to train scientists in developing countries, fund research stations, and help those nations build a regulatory structure to anticipate and prevent possible problems.

     Organic farmers in the United States have justifiable fears that pollen from biotech farms will pollute their crops, possibly rendering them non-organic, under the law. Organic farmers also fear that insects will develop resistance to Bt toxin. While that concern was always present due to organic farmers’ own use of Bt sprays, the widespread planting of Bt corn and cotton increases tremendously the possibility that pests will develop resistance. I don’t pretend to have the solutions to those thorny problems, but they deserve careful attention. Buffer zones, compensation by seed companies, and other measures should be developed to protect the integrity of organic foods.

Beyond biotechnology

Slide 14 Let me conclude by noting that many critics of biotechnology are opposed to any and all applications of biotechnology, apparently regardless of its benefits. Advocates of biotechnology should not fall into a similar trap of thinking that biotechnology is the answer, regardless of the question. Genetic engineering is not the only tool in the agricultural tool box. Conventional breeding and non-transgenic applications of biotechnology offer tremendous opportunity. We should also note that production agriculture, biotech or not, suffers from real problems. Many farmers are going broke — any more would, were it not for huge government bailouts. Both advocates and critics of genetic engineering should recognize that the wisest course of action would be simultaneously to follow several paths to satisfy our food needs, making use of genetic engineering, conventional farming, and sustainable approaches. Many farmers are discovering that sustainable agriculture, including organic farming — based on smaller farms, diverse crops, crop rotation, and natural means of pest control — may be just as, or even more, profitable, especially at a time of soaring energy costs. Their input costs may be lower, while their crops may command premium prices in the marketplace.

     No big chemical or seed companies, no government subsidies support sustainable agriculture. Hence, my final recommendation would be for ag schools, state departments of agriculture, and USDA to conduct more research and provide greater technical and financial assistance to farmers who want to get off the agribusiness treadmill.


Thank you.

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