National Agricultural Biotechnology Conference|
Agricultural Biotechnology: Savior or Scourge?
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 isnt 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,
thats 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. Thats a tremendous boon to farmers and presumably to non-target
* 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
* 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
wont plant them for fear of a consumer backlash.
From the consumers 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.
Slide 3 While consumers may focus on safety, environmental problems may be likelier.
Whether its 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 wont 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 Sciences Institute of Medicine evaluate FDAs standards for biotech foods.
The StarLink episode revealed an additional problem. Farmers and seed producers
apparently cant 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 FDAs 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 publics interest in biotech labeling and how consumers might
react to such labeling, CSPI recently commissioned a national telephone survey. Id 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
We wanted to get beyond that first question and understand consumer attitudes in greater
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 dont know much about food
production and are suspicious of any process or term they dont 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 familys 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 didnt 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 publics 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 dont 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 industrys 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
Other Concerns about Agricultural Biotechnology
Aside from effects on the publics 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 worlds 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
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 dont 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.
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.