table of contents€¦ · transgenic crops. it explains what genetic engineering is, and examines...

ATTRA is the national sustainable agriculture information center operated by the National Center forAppropriate Technology under a grant from the Rural Business-Cooperative Service, U.S. Departmentof Agriculture. These organizations do not recommend or endorse products, companies, or individuals.ATTRA is located in the Ozark Mountains at the University of Arkansas in Fayetteville (P.O. Box3657, Fayetteville, AR 72702). ATTRA staff members prefer to receive requests for informationabout sustainable agriculture via the toll-free number 800-346-9140.

By Nancy MathesonNCAT Agriculture SpecialistOctober 2001

AGRONOMY TECHNICAL NOTE

GENETIC ENGINEERING

OF CROP PLANTSWHAT FARMERS NEED TO KNOW ABOUT

TRANSGENIC CROPS

Table of Contents

What Are Transgenic Crops? ................................................................................................................................. 2How Is Gene Transfer Accomplished? ................................................................................................................. 2Commercial Transgenic Crops and Their Traits ................................................................................................. 4Unresolved Issues of Concern ............................................................................................................................... 4

Ecological Issues ................................................................................................................................................ 5 Food Safety .......................................................................................................................................................... 6 Farm Management Issues ................................................................................................................................. 7 Crop Yield, Costs, and Profitability ................................................................................................................. 8 Marketing and Trade ......................................................................................................................................... 9 Liability ............................................................................................................................................................. 11 Influence on Public Research ......................................................................................................................... 12 Industry Concentration and Farmers� Right to Save Seed .......................................................................... 13 Regulation of Transgenic Crops ..................................................................................................................... 13

Implications for Sustainable Agriculture ........................................................................................................... 15Framework for gauging a technology�s impact on agricultural sustainability ........................................ 15

Conclusion ............................................................................................................................................................. 15References .............................................................................................................................................................. 16Further Resources .................................................................................................................................................. 19Appendix 1: GMO Issues Facing Indiana Farmers in 2001 ........................................................................... 24Appendix 2: Wheat Industry Is Cautious on Biotech Introduction ............................................................... 28Appendix 3: On the Implications of the Percy Schmeiser Decision .............................................................. 30Appendix 4: A History of Intellectual Property Rights (IPRs) ....................................................................... 34

Abstract: This publication attempts to define for farmers and ranchers some of the key issues related totransgenic crops. It explains what genetic engineering is, and examines the costs and benefits to farmersof transgenic versus conventional crop varieties. However, this publication cannot provide definitiveanswers or recommendations because independent scientific and socioeconomic analyses of transgeniccrops are limited, with many questions still unanswered. In addition, how well transgenic technologyworks for farmers depends on the characteristics of each specific crop variety, the system in which it isplaced, the skill with which it is managed, and the markets for which it is destined.

//GENETIC ENGINEERING OF CROP PLANTSPAGE 2

What Are Transgenic Crops?

The term biotechnology refers to a broad spectrum of technologiesincludingconventional plant selection and breedinginwhich humans intervene in biologicalprocesses of genetic alteration andimprovement. The focus of this paper is oncrop varieties created through a type ofbiotechnology commonly known asrecombinant DNA, genetic engineering (GE),transgenic modification, or genetic modification(GM). The products of genetic engineering areoften called genetically modified organisms, orGMOs. All these terms refer to methods ofrecombinant DNA technology by whichbiologists splice genes from one or morespecies into the DNA of crop plants to transferchosen genetic traits.

Genes are segments of DNA that containinformation that in part determines thestructure and function of a living organism.Genetic engineers are molecular biologists whomanipulate this information, typically bytaking genes from one species�an animal,plant, bacterium, or virus�and inserting theminto another species, such as an agriculturalcrop.

With the advent of genetic engineering ofplants around 1983, it appeared that this newbiotechnology would benefit and evenrevolutionize agriculture. The transfer ofdesirable genetic traits across species barriershas shown promise for solving problems in themanagement of agricultural crops (1). Potentialbenefits include reduced toxic pesticide use,improved weed control resulting in less tillageand soil erosion, and water conservation.However, �emerging evidence suggests thepromised environmental benefits remain small,uncertain or unrealized in the U.S., and somerisks are real� (2).

How Is Gene TransferAccomplished?

Knowing how gene transfer occurs in thelaboratory is key to understanding how the

desired traits express themselves in theresulting crop plants, and why unintendedeffects, such as the production of allergens,may also be present or develop withsubsequent generations of plants.

Plants have elaborate defense mechanisms fordealing with foreign substances, includingforeign DNA. To overcome these defensemechanisms, genetic engineers includepathological organisms in the complex DNApackages they create to carry the chosen geneinto the host cell.

Generally, there are four parts to a DNApackage (3):

1. Genes for the desired traitthe �payload.�An example of such a trait is crop resistance toa given herbicide.

2. Genes for carrying the package into the hostplant�s DNA. This genetic carrier is called thevector and is usually taken from a bacteriumthat causes tumors in plants, Agrobacteriumtumefaciens. Viruses are also sometimes used asgene carriers. These bacterial or viral vectorsinfect the new host cells, delivering theengineered gene into the DNA of the hostplant.

3. Genes for ensuring that the genetic packagewill express the desired trait persistently(rather than weakly or not at all). These genes�turn on� the desired trait and are calledpromoters. They are usually derived from thecauliflower mosaic virus (CaMV).

4. Genes for helping the biologist find theDNA segment in which the insertion has beensuccessful. These genes are called markers andare resistant to antibiotics (usually neomycin orkanamycin). When the antibiotic is applied tothe new host�s cells, the cells that survive arethe ones carrying the successfully insertedantibiotic-resistant geneindicating alikelihood that the gene carrying the desiredtrait has been successfully inserted as well.Marker genes are usually derived from bacteria(E. coli).

//GENETIC ENGINEERING OF CROP PLANTS PAGE 3

An alternative vector method uses a particlegun to shoot tiny metal particles with the DNApackage attached into the new host cell. Thiseliminates the need for a bacterial vector, butadds to the potential for genetic disruption inthe host cell (4).

How does this process sometimes result inunintended effects?

The current methods of gene transfer are notprecise. While scientists can control withrelative exactness the �trait gene� that isinserted into a host plant genome, they cannotyet control its location, nor the number ofcopies that get inserted. Location of geneticmaterial is important because it controls theexpression of biological traits just as genesthemselves do. Also, inserted DNA frequentlycontains multiple copies, which are oftenscrambled. Multiple copies can �silence� genes,resulting in instability in the introduced genes.Because scientists can control neither thelocation nor copies of the genetic material theyare inserting, they cannot entirely control thetraits the host plant will express, nor can theyguarantee genetic stability in subsequentgenerations (5). This can lead to unpredictableand undesirable effects, examples of whichinclude plant infertility, the production oftoxins, and reductions in yield and plantfitness.

Another characteristic that can result inunintended effects is called pleiotropy.Pleiotropy means that one gene controlsmultiple traits in an organism. In other words,the gene for a desired trait may also controlother traits in the crop plant. Genetic engineershave relied on a simpler model of geneexpression, assuming one gene controls oneparticular trait. But pleiotropy is common, andthe interactions of genes with each other andtheir environment add further complexity. Inshort, it is difficult or impossible to predictwhat the effects of new genetic combinationswill be.

The current marker and promoter genes ofchoice also create new hazards. The antibiotic-resistant marker genes carry the potential to

increase the number of bacteria that areresistant to antibiotics. The viral promotergenes could combine with other infectingviruses to create new viruses. The verypowerful promoter commonly used, thecauliflower mosaic virus, can cause theinserted DNA package to be expressed out ofproportion with the rest of the genetic code.With the particle gun method especially, thispromoter can also jump out of the DNApackage and land somewhere else in the hostgenome, causing disruption. The bacterial andviral vector genes can recombine to form activepathogens once againeither new ones, orold ones with renewed virulence, or withbroader host specificity (3).

Each piece of the gene package describedabove carries with it the potential to disruptnon-target portions of the host plant�s DNA, tocreate instability in the new genetic construct,or to result in unpredictable combinations thatcan create new substances, viruses, or bacteria.What this adds up to is the possibility ofunintended effects, particularly in subsequentgenerations of the engineered plant.

Lessons from the human genome project

Genetic engineering of crops is based upon thenotion that genes alone determine speciestraits. But this assumptionand the resultingidea of simply transferring a single genebetween organisms to achieve a singleresultcontradicts recent discoveries in geneticscience. Inheritance and expression of traits arecontrolled by complex processes involvingcomplicated genetic material that includesmore than simple genes. For example, so-calledjunk DNA is now thought to play a significantrole in determining an organism�s traits.

Mapping of the human genome, completed inearly 2001, revealed that humans contain aboutone-third the number of genes scientistsexpected to find. In fact, the 30,000 humangenes they identified comprise only 1 percentof the total human DNA; they don�t knowwhat much of the other 99 percent is for. Only300 genes in the human genome are not also inthe mouse. �This tells me genes can�t possibly


explain all of what makes us what we are,�said Craig Venter, president of CeleraGenomics, the Maryland firm that led one ofthe mapping teams (6).

Commercial Transgenic Crops andTheir Traits

While increased yields and improvednutritional value are among the promisedbenefits of transgenic crops, most geneticallyengineered crops now planted worldwide aredesigned either to 1) survive exposure tocertain herbicides (called herbicide-tolerantcrops) or 2) kill certain insect pests (calledpesticidal or insecticidal crops).

Genetically engineered herbicide-tolerant cropshave been altered to withstand being sprayedwith broad-spectrum herbicides, with the ideathat one application will take care of mosttypes of weeds without killing the crop.Insecticidal crops contain genes of the soilbacterium Bacillus thuringiensis (Bt). These Btgenes cause the plants to produce a chemicaltoxic to the European corn borer, the cottonbollworm, and other caterpillars. (Caterpillarsare the larvae of insects in the Lepidopteraorder, which includes moths and butterflies).

Herbicide-tolerant crops accounted for 71percent of the acreage planted, worldwide, togenetically engineered crops in 1998 and 1999.Pesticidal crops, or a combination of pesticidaland herbicide-tolerant crops, accounted formost of the remaining acreage (7).

More than 100 million acres of the world�sfarmland were planted with transgenic cropsin the year 2000. The United States, Argentina,and Canada are the world�s leading producersof genetically engineered crops, with the U.S.first at 71 percent of the world�s total acreage.Transgenic crops are being shipped to orexperimented with in many other countries,including China, India, Australia, and SouthAfrica (8).

In 1999, one-quarter of U.S. farmland wasplanted to transgenic crops. To date, soybeansand corn cover the most transgenic acres. In

2001, more than 60 percent of soybeansplanted in the U. S. were estimated to betransgenic�specifically, tolerant toMonsanto�s broad-spectrum herbicide,Roundup� (glyphosate) (9). Transgenic cornplanted in the U.S. offers both insecticidal andherbicide-tolerant traits, though Bt insecticidalcorn predominates.

Other large-acreage transgenic crops includecotton and canola. Most transgenic cotton isherbicide-tolerant, though some varieties havethe Bt trait; transgenic canola is herbicide-tolerant. The first transgenic wheat, plannedfor commercial introduction in 2003, isRoundup-tolerant.

Other traits engineered into commercialtransgenic varieties include disease resistance,high pH tolerance, and several nutritional,taste, texture, and shelf-life characteristics (10).Other transgenic crops currently on the U.S.market include tomatoes, potatoes, sunflowers,peanuts, and sweet mini-peppers. Moretransgenic crops, including rice, are underdevelopment for commercial release in the nextseveral years (10).

However, there is evidence that biotechnologyfirms may be changing course because ofdeepening consumer skepticism and tighterregulation worldwide, which are increasing thecosts and business risks of new transgenic cropintroductions. A Monsanto spokesman wasquoted in the Christian Science Monitor inAugust 2001, saying, �We�re focusing on fourcore crops�corn, oilseeds, cotton, and wheat,�the major crops in North America with themost acreage and profit potential (11). For amore complete list of current and futurecommercial transgenic crops and their traits,see <http://www.bio.org>, the website of theBiotechnology Industry Organization.

Unresolved Issues of Concern

There are many unanswered questions abouttransgenic crops and their potential benefits,costs, and risks. In fact, according to a recentindependent survey of research data ontransgenic crops, conducted by the Winrock


Foundation�s Henry A. Wallace Center forAgricultural and Environmental Policy, �Thevarieties and uses of genetically altered cropshave grown much more rapidly than ourability to understand...them.� The studyrevealed that only four percent of total federalagricultural biotech funding is dedicated toenvironmental assessment (12).

Following is a brief discussion of someprominent transgenic-crop-related issuesfacing farmers and ranchers. Whether aproducer is growing transgenic crops, isconsidering growing them, has fields adjoiningthem, or has markets sensitive to transgeniccrops, these issues are relevant. The purpose ofthe following discussion is not to provide athorough treatment of each issue, but toexplain in summary fashion what farmers andranchers should be aware of, and to help themmake sense of contradictory claims and stories.

1. Ecological Issues

Gene flow to neighboring crops and to related wildspecies

Ecological scientists have little doubt that geneflow from transgenic fields into conventionalcrops and related wild plants will occur. Geneflow from transgenic to conventional crops isof concern to farmers because of its potential tocause herbicide resistance in relatedconventional crops. For example, in westernCanada, three different herbicide-resistantcanola varieties have cross-pollinated to createcanola plants that are resistant to all threetypes of herbicide. Through what is calledgene-stacking, this new triple resistance hasturned volunteer canola into a significant weedproblem (13).

Gene flow from transgenic crops to wildrelatives creates a potential for wild plants orweeds to acquire traits that improve theirfitness, turning them into �super weeds.� Forexample, if jointed goatgrass�a weedy relativeof wheat�acquires the herbicide-tolerant traitof Roundup Ready wheat, it will thrive in cropfields unless applications of other herbicidesare made. There is already evidence of such

outcrossing from herbicide-resistant wheat tojointed goatgrass. Frank Young and hiscolleagues at Washington State Universityfound that imidazolone-resistant wheat (not atransgenic variety) outcrossed to goatgrass inone season (14). Other traits that wild plantscould acquire from transgenic plants thatwould increase their weediness are insect andvirus resistance (2).

Because of their experience with classicallybred plants, few scientists doubt that geneswill move from crops into the wild: seven ofthe world�s thirteen most important cropweeds have been made weedier by genesacquired from classically bred crops (13).Because gene flow has the potential to affectfarmers� crop and pest management, cropmarketability, and liability, more researchneeds to be done to determine the conditionsunder which gene flow from transgenic plantsis likely to be significant.

Pesticide resistance in insect pests

Bt has been widely used as a microbial spraybecause it is toxic only to caterpillars. In fact, itis a pest management tool that organic farmersdepend onone of the few insecticidesacceptable under organic rules. Unlike thecommercial insecticide spray, the Btengineered into crop plants is reproduced inall, or nearly all, the cells of every plant, notjust applied on the plant surface for atemporary toxic effect. As a result, thepossibility that transgenic Bt crops willaccelerate insect pests� development ofresistance to Bt is a serious concern. Pestresistance to Bt would remove this valuableand environmentally benign tool from farmers�and forest managers� pest control toolbox. Formore on Bt pest resistance, see <http://www.pmac.net/ge.htm> (Pest Management atthe Crossroads).

Antibiotic resistance

As described in the earlier section on how genetransfer is accomplished, the use of antibiotic-resistant marker genes for the delivery of agene package into a recipient plant carries the


Allergenicity

StarLink corn, a transgenic variety,contains the Cry9C protein, which protectsthe growing plant from pests. In 1998,federal regulators approved Starlink forlivestock feed and ethanol, but banned it inhuman food because of concerns that theprotein could cause allergic reactions. Yet,by the fall of 2000, StarLink had found itsway into taco shells shipped around theworld. Many people reported allergicreactions after eating foods later discoveredto contain StarLink. However, proving alink to StarLink was difficult because theproducts containing it were not labeled andpeople ate it unknowingly. Aventis, thecompany that developed and patentedStarLink, asked the U.S. EnvironmentalProtection Agency (EPA) to approve it forhuman consumption after the fact in orderto avoid the costs of removing it from theworld�s market. In July 2001, a U.S. scienceadvisory panel recommended to the EPAthat it maintain its ban on StarLink corn inhuman food. The science panel reaffirmedthat the Cry9C protein in StarLink corn islikely to be a human allergen (21).

2. Food Safety

Because food safety is predominantly a concernof consumers, this paper does not include adiscussion of it. However, because food safetyissues do impact marketing and internationaltrade, here is a short list of consumer safetyconcerns about transgenic food:

� possibility of toxins in food� possibility of new pathogens� reduced nutritional value� introduction of human allergens� transfer of antibiotic resistance to humans� unexpected immune-system and genetic

effects from the introduction of novelcompounds

It is in part because of these concerns thatconsumer demand for organically grown cropscontinues to increase.

danger of spreading antibiotic-resistantbacteria. The likely result will be human andanimal health diseases resistant to treatmentwith available antibiotics. Research is neededon antibiotic resistance management intransgenic crops (15). Already the EuropeanCommission�s new rules governing transgeniccrops stipulate phasing out antibiotic-resistantmarker genes by the end of 2004 (5).

Effects on beneficial organisms

Evidence is increasing that transgenic crops�either directly or through practices linked totheir production�are detrimental to beneficialorganisms. New studies are finding that Btcrops exude Bt in concentrations high enoughto be toxic to some beneficial soil organisms(16). In addition, a study by University ofArkansas scientists has shown that �rootdevelopment, nodulation and nitrogen fixationare impaired� in some varieties of RoundupReady soybeans (17). The reason is that thebeneficial rhizobium responsible for nitrogenfixation in soybeans is sensitive to Roundup. Italso appears that disruption of beneficial soilorganisms can interfere with plant uptake ofphosphorus, an essential plant nutrient (18).

Beneficial insects that prey on insect pests canbe affected by insecticidal crops in two ways.First, the Bt in transgenic insecticidal crops hasbeen shown in some laboratory studies to betoxic to ladybird beetles, lacewings, andmonarch butterflies (2). The extent to whichthese beneficials are affected in the field is amatter of further study. Second, because theinsecticidal properties of Bt crops functioneven in the absence of an economic thresholdof pests, Bt crops potentially can reduce pestpopulations to the point that predator speciesare negatively affected (19).

Reduced crop genetic diversity

As fewer and larger firms dominate the rapidlymerging seed and biotechnology market,transgenic crops may continue the trendtoward simplification of cropping systems byreducing the number and type of cropsplanted. In addition, seed-saving, whichpromotes genetic diversity, is restricted fortransgenic crops (20).


3. Farm Management Issues

The most widely planted transgenic crops onthe market today can simplify short-term pestmanagement for farmers and ranchers. In thecase of herbicide-tolerant crops, ideally farmerscan use a single broad-spectrum herbicide forall their crop weeds, though they may needmore than one application in a season. Byplanting insecticidal crops, farmers caneliminate the need to apply pesticides forcaterpillar pests like the European corn boreror the cotton bollworm, though they still haveto contend with other crop pests.

While these crops offer handy pest controlfeatures, they may complicate other areas offarm management. Farmers who are growingboth transgenic and conventional varieties ofthe same crop will need to segregate the twoduring all production, harvesting, storage, andtransportation phases if they are selling intodifferentiated markets or plan to save theirown seed from their conventional crops. Readabout the steps necessary for on-farmsegregation in Appendix 1.

To minimize the risk of gene flow fromtransgenic to adjacent conventional crop fields,federal regulations require buffer strips ofconventional varieties around transgenic fields.Different transgenic crops require differentbuffer widths. Because the buffer strips mustbe managed conventionally, producers have tobe willing to maintain two different farmingsystems on their transgenic fields. Cropsharvested from the buffer strips must behandled and marketed as though they aretransgenic.

Planted refuges�where pest species can liveoutside fields of insecticidal and herbicide-tolerant transgenic crops�are also required toslow the development of weed and insect pestresistance to Bt and broad-spectrum herbicides.These refuges allow some individuals in thepest population to survive and carry on thetraits of pesticide susceptibility. Requirementsgoverning the size of refuges differ accordingto the type of transgenic crop grown.

Farmers growing herbicide-tolerant cropsneed to be aware that volunteer crop plants thefollowing year will be herbicide-resistant. Thisherbicide resistance makes no-till or direct-seed systems difficult because volunteers can�tbe controlled with the same herbicide used onthe rest of the crop. In a no-till system thatrelies on the same broad-spectrum herbicidethat the volunteer plants are resistant to, theseplants will contaminate the harvest of afollowing conventional variety of the samecrop, a situation farmers need to avoid for tworeasons. First, the contamination means afollowing conventional crop will have to besold on the transgenic market. This leads to thesecond reason. If farmers grow and market atransgenic crop for which they do not have atechnology agreement and did not pay royaltyfees, they face possible prosecution by thecompany that owns the transgenic variety.Many farmers have been charged with �theft�of a company�s patented seed as a result ofcontamination in the field (22).

Farmers growing insecticidal crops need torecognize that insect pressure is difficult topredict and may not warrant the planting of aninsecticidal variety every year. In a year whenpest pressure is low, the transgenic seedbecomes expensive insurance against the threatof insect damage (23).

Farmers growing transgenic crops need tocommunicate with their neighbors to avoidcontaminating their fields and to ensure thatbuffers are adequate. In Maine, farmersgrowing transgenic crops are now required bylaw to be listed with the state agriculturedepartment, to help identify possible sources ofcross-contamination when it occurs. The newlaw, L.D. 1266, also �requires manufacturers orseed dealers of genetically engineered plants,plant parts or seeds to provide writteninstructions to all growers on how to plant,grow, and harvest the crops to minimizepotential cross-contamination of non-genetically engineered crops or wild plantpopulations� (24).

Farm management issues common to alltransgenic crops include yield, cost, price,


profitability, management flexibility,sustainability, market acceptance, andliability. Many of these issues are described inAppendix 1an article specific to transgeniccorn and soybean production, but one that allgrowers will find useful. Yield andprofitability, market acceptance, and liabilityare also discussed in separate sections below.

4. Crop Yield, Costs, and Profitability

Some farmers will get higher yields with aparticular transgenic crop variety than withtheir conventional varieties, and some will getlower yields. The same is true for costs. Someproducers will see their overall profitabilityrise, and some will see it drop. If the results ofresearch studies so far on yield, chemical use,costs, crop prices, and profitability of thesecrops seem contradictory, it is because farmersand farms are not all alike. Neither are theconventional varieties used for comparison.

Some yield, cost, and profitability trends doappear to be emerging from the growing bodyof research data for transgenic crops, however.As noted in the Wallace Center report,Roundup Ready soybeans were designedsimply to resist a particular chemical herbicide,not to increase yields. In contrast, Bt corn andcotton, by resisting insect pests, may result inhigher yields from reduced pest pressure (25).

Yield: herbicide-tolerant crops�soybeans, cotton,canola

Herbicide-tolerant soybeans appear to sufferwhat�s referred to as a �yield drag.� Again, insome areas and on some farms this tendency ofRoundup Ready soybean varieties to yield lessthan their comparable, conventionalcounterparts varies, but overall, they appear toaverage yields that are five to ten percent lowerper acre (26). As described earlier, impairedroot development, nodulation, and nitrogenfixation likely account for this yield drag.Drought conditions worsen the effects. Thebacterium that facilitates nodulation andnitrogen fixation in the root zone apparently issensitive to both Roundup and drought (27).

In addition, University of Missouri scientistsreported problems with germination ofRoundup Ready soybeans in the 2001 cropyear (28).

Yields of herbicide-tolerant cotton arereportedly not significantly different fromthose of conventional cotton (29).

Herbicide-resistant transgenic canola varietiesyield less on average than conventional canolavarieties. Transgenic canola costs less thanconventional canola to produce, but because ofits higher yields conventional canola returnsmore profit per acre (30).

Yield: insecticidal crops�corn, cotton

Insecticidal Bt corn and cotton generally yieldhigher �in most years for some regions�according to USDA Economic Research Servicedata from 1996 to 1998. Bt cotton, especially,outpaces yields of conventional cotton by asmuch as 9 to 26 percent in some cases, thoughnot at all in others. Yield increases for Bt cornhave not been as dramatic (31). Time will tellwhether farmers can expect yield increases ordecreases in the long run with these and othertransgenic crop varieties.

Changes in chemical pesticide use

One of the promises of biotechnology is that itwill reduce pesticide use and thereby provideenvironmental benefits and reduce farmers�costs. The herbicide-tolerant and insecticidalvarieties are designed specifically to meet thesegoals.

Studies estimate a two to three percentdecrease in U.S. pesticide use, but the effectsvary widely by crop, region, and year.Increased future pesticide use resulting fromthe buildup of resistance to heavily usedherbicides is a long-term concern (32). Pesticideuse depends on the crop and its specific traits;weather; severity of pest infestations; farmmanagement; geographic location of the farm;and other variables. As a result, conclusionsdrawn by various studies analyzing pesticide


use on transgenic crops remain controversial.According to the Wallace Center report, in areview of the data available up through 2000,crops engineered to contain Bt appear to havedecreased the overall use of insecticidesslightly, while the use of herbicide-resistantcrops has resulted in variable changes inoverall herbicide use, with increases in use ofsome herbicides in some places and decreasesin others (33).

The crop for which studies are showing thelargest decrease in pesticide use is Bt cotton,with Bt corn resulting in only small changes.Herbicide-tolerant cotton has also resulted inlittle change in herbicide use (2).

The data for herbicide-tolerant soybeans seemsharder to sort out. A recent study of herbicideuse data on Roundup Ready soybeans by Dr.Charles Benbrook, former executive director ofthe National Academy of Sciences Committeeon Agriculture and now with the NorthwestScience and Environmental Policy Center,concludes that the use of herbicides hasactually increased because the weeds havebecome resistant to Roundup (34). Whileanother recent study by Netherlands scientistsshows a decrease in herbicide use ontransgenic soybeans, it is clear that weedresistance to Roundup may lead to increasedherbicide use and to the need to shift to moretoxic compounds in the future (2). AmericanSoybean Association president Tony Andersonagrees that the developing resistance of weedsto herbicides such as Roundup is a problem(35).

The Wallace Center report emphasizes theimportance of ongoing monitoring of pesticideuse data. If farmers abandon integrated pestmanagement, which utilizes a variety ofpesticide and cultural control methods, in favorof the simplified control offered by herbicide-resistant and insecticidal transgenic crops, thenearly findings of reduced pesticide quantitiesand toxicity may not hold over the long run(36). Refer to chapter one of the Wallace Centerreport (12) for USDA pesticide use datacomparisons between transgenic andconventional crops, broken down by crop.

Profitability

Farmers need to consider all the factors thatdetermine profitability. No single factor can tellthe whole story. Transgenic crop seeds tend tobe more costly, and farmers have the addedexpense of a substantial per-acre fee chargedby the owners of transgenic varieties. Thesecosts have to be considered along with inputcost changes�whether herbicide or insecticideuse and costs go down, go up, or stay the same.Market price is another factor: Prices for sometransgenic crops in some markets are lowerthan prices for comparable conventional crops,though rarely are they higher. Farmers need towatch the markets. Some buyers will pay apremium for a non-transgenic product, thoughas transgenic seeds find their way intoconventional transportation, storage, andprocessing streams, these premiums maydisappear along with confidence that �GMO-free� products are in fact truly free ofengineered genes.

5. Marketing and Trade

Buyer acceptance is a significant marketingissue for farmers raising transgenic crops.Farmers need to know before they plant whattheir particular markets will or won�t accept.Since most grain handlers cannot effectivelysegregate transgenic from non-transgenic cropsin the same facility, many companies arechanneling transgenic crops into particularwarehouses. Farmers need to know which onesand how far away those are.

Many foreign markets tend to be more leery oftransgenic products than domestic markets,though trade in transgenic livestock feed ismore liberal than trade in transgenic humanfood. The widespread contamination of corn inthe U.S. with the Cry9C Bt transgene(StarLink), which is not approved for humanconsumption, has resulted in even furtherresistance on the part of buyers to purchasingtransgenic products for human food.According to a report in Britain�s The Guardian,�No new transgenic crops have beenapproved by the European Union (EU) since


April 1998, and a defacto moratorium onfurther approvals has been in place since June1999� (37). Some countries have bannedaltogether the production and importation oftransgenic crops and food products (Sri Lankaand Brazil), while many others have put inplace partial bans or mechanisms to slow theirapproval for importation or production.

While the European Union officially lifted itstwo-year moratorium on the introduction ofnew transgenic crops in February 2001, duringthe debate over labeling and traceabilityregulations the moratorium remains in effect.Under the proposed new EU requirements,�all foods and animal feed derived fromGMOs have to be labeled and, in the case ofprocessed goods, records have to be keptthroughout the production chain allowing theGMO to be traced back to the farm� (38). Ifapproved, the new regulations will hamperthe export of U.S. farmers� products to the EUbecause the U.S. does not require traceabilityor labeling of transgenic crops.

While the U.S. does not require mandatorylabeling of processed food containingtransgenic ingredients, the European Union,Russia, Czech Republic, Japan, South Korea,Taiwan, Australia, New Zealand, andEcuador do (39). Because many domesticmerchandisers of agricultural commodities donot segregate transgenic from conventionalcrop varieties, it is impossible for them and thefarmers that supply them to serve these foodmarkets.

Twenty percent of corn and 8 percent ofsoybeans produced in the U.S. are exported,and more than 80 percent of these crops isused in animal feed. Overseas marketrestrictions on transgenic crops in the feedsector are less stringent than those for food(40). In contrast, 48 percent of U.S. wheat isexported, with nearly half of this food cropgoing to countries that are resistant to buyingtransgenic food, particularly Japan andEuropean nations. Because wheat producersare so dependent on exports, they areapproaching the introduction of the firsttransgenic wheat, expected as soon as 2003,with caution. The Japanese milling industryhas made it clear that it does not wanttransgenic products. As a result, Monsantohas promised not to introduce its RoundupReady wheat until Japan gives its approval(41). At least two states, North Dakota andMontana, have considered legislation thatwould place a state moratorium on theintroduction of transgenic wheat. For moreabout the wheat industry�s reaction to theanticipated introduction of Roundup Readywheat, see Appendix 2.

Europe�s Proposed Rules (5)

In July 2001, the European Commissionadoped a new directive regulating therelease of transgenic organisms, includingplants, animals, and microorganisms. Inits main provisions, European Directive2001 / 18 / EC requires the labeling of allproducts containing GMOs�includingprocessed ingredients�and guaranteestraceability from field to plate. Long-termmonitoring of transgenic crops followingtheir release is required, as well asmolecular documentation of their geneticstability. The directive guarantees thepublic�s access to information about therelease and content of GMOs, and theopportunity for comment prior to aproposed release. The directive alsostipulates s phasing-----out of antibiotic-----resistant marker genes by the end of 2004.

If the Commission�s directive is approvedby the member states of the EuropeanUnion, all GMOs will eventually have to

satisfy its requirements before going tomarket. Compliance with therequirement to document genetic stabilitymay be the most difficult provision tomeet, since instability is a commoncharacteristic of current DNA transfermethods (see How Is Gene TransferAccomplished? above). However,approval under the old directive for anytransgenic crop already on the market inthe European Union will be retained.


In addition to national and internationalpolicies on the use and importation oftransgenic crops, many countries� processorsand retailers have set their own corporatepolicies. Major retail chains in Europe and theU.S. have declared their commitment toavoiding the purchase of transgenic products,both feed and food.

For buyers who don�t want transgenicproducts, the likelihood of contamination ofnon-transgenic products with engineeredgenes is troublesome. Since 1997, theEuropean Union has effectively barred U.S.corn imports over the possibility thatgenetically engineered varieties unapprovedin the EU have mixed with sanctioned crops.This has cost American farmers access to a$200 million-a-year market (42).

Organic farmers face even bigger marketingand trade risks, since their buyers can acceptno transgenic contamination. The organicindustry does have a system for segregation,but recent tests for transgenic material inorganic products demonstrate that it is notimmune to contamination from conventionalsystems (43). The markets organic farmers haveenjoyed, and those that producers of non-GEconventional crops could build upon, willlikely disappear if contamination of theirproducts continues to spread.

Until the issues of trade in transgenic cropsand food products, and their labeling andtraceability, are resolved in international tradearenas, the markets for U.S. transgenic cropswill remain uncertain. Changes in what anyparticular country will or won�t accept areoccurring all the time, and producers of cropsfor export are well advised to stay informed ofthese changes.

Segregation of transgenic crops and liabilityfor cross-contamination of conventional andorganic crops are issues that obviously overlapwith those of marketing and trade. Theseissues are discussed further in the followingsection on liability.

6. Liability

The need to separate transgenic crops fromconventional and organic ones opens farmersto liability for their product at every step fromseed to table. Effective systems for segregationdo not exist at present, and will be costly todevelop and put into place (44). Farmers maywell end up bearing the added costs of cropsegregation, traceability, and labeling.

In the meantime, farmers who grow transgenicvarietiesand, ironically, those who donotare liable for transgenic seeds ending upwhere they aren�t wanted: in their own non-transgenic crop fields, in neighbors� fields, intruckloads of grain arriving at the elevator, inprocessed food products on retail shelves, andin ships headed overseas.

Farmers who choose not to grow transgenicvarieties risk finding transgenic plants in theirfields anyway, as a result of cross-pollinationvia wind, insects, and birds, which may bringpollen from transgenic crops planted milesaway. Besides pollen, sources of contaminationinclude contaminated seed and seed brought inby passing trucks or wildlife. Those farmerswhose conventional or organic crops arecontaminated, regardless of the route, risklawsuits filed against them by the companiesthat own the proprietary rights to seed thefarmer didn�t buy. Likewise, farmers who growtransgenic crops risk being sued by neighborsand buyers whose non-transgenic cropsbecome contaminated.

Because contamination by transgenic materialhas become so prevalent in such a short time,all farmers in areas of transgenic cropproduction are at risk. Insurance, the mostcommon recourse for minimizing potentiallosses because of liability, is not available tothe nation�s farmers for this risk becauseinsurance companies do not have enoughinformation to gauge the potential losses.

Most of the farmers who have been accusedby transgenic seed companies of illegally


growing and harvesting their proprietarytransgenic varieties have paid fines to thecompanies rather than go to court to defendthemselves. One Canadian grower of non-transgenic canola, Percy Schmeiser, did go tocourt against Monsanto, and lost in a recentruling that requires him to pay Monsanto theapproximately US$85,000 value of his cropand $13,000 in punitive damages. SeeAppendix 3 for a clear analysis of thisfarmer�s case from the standpoint of thepracticalities of farming, as well as theimplications for other farmers, especially thosewho traditionally save their own seed forplanting next year�s crop.

In another example, a Texas organic farm�scorn, assumed to be GE-free, was purchased bya processor who made it into organic tortillachips. Only after the product had been soldand shipped to European retailers was itdiscovered to be contaminated with transgeniccorn. The processor had to recall its product ata cost of over $150,000. The processor chose notto sue the organic farmer, but could have (42).The retailer, in turn, apparently did not sue theprocessor. Had it done so, the liability for theretailer�s loss could have fallen on both theprocessor and the farmer.

According to a Boston Globe story, no figureson farmers� losses resulting from liability fortransgenic contamination exist, but anecdotalevidence suggests that cases against farmersare becoming �far more common� (42). Untillaws or legal precedent clarify the extent offarmer liability, farmers would do well toavoid making assumptions or claims about thepurity of their non-transgenic products.Furthermore, producers of transgenic cropsneed to take all possible precautions againstspreading pollen and seed to their own andothers� non-transgenic fields and markets.

A full risk assessment and legal clarification ofthe distribution of liability among farmers,seed companies, grain handlers, processors,and retailers is needed before farmers can restassured that transgenic crops won�t result inlawsuits against them. For farmers who haveadopted transgenic technology�and for those

who have not�in the words of Brian Leahy,executive director of California CertifiedOrganic Farmers, �This technology does notrespect property rights� (42). In essence,farmers who grow transgenic crops on someof their fields, and farmers who grow none,risk bearing tremendous liability. Thissituation won�t change until farmers eithergain legal protection or until they all growtransgenic crops on all their fields.

7. Influence on Public Research

While transgenic crop varieties are generallythe property of private corporations, thosecorporations often contract with public-sectoragricultural research institutions for some oftheir development work. In fact, privateinvestment in agricultural research, includinggermplasm development, has surpassed publicinvestment in recent years (45). With this shiftin funding sources, the following questionsbecome important: Is the private sector undulyinfluencing the public research agenda? Arecorporations directing public research in lesssocially valuable directions while research on,for instance, sustainable agriculture goeswanting? Are the outcomes of corporate-funded transgenic research and developmentby our public institutions equitable across thefood and agricultural sectors? Is equity even aconsideration of our public institutions whenthey accept this work?

Because intellectual property rights (patents)apply to living organisms, making themprivate property, the free flow of scientificinformation that has historically characterizedpublic agricultural research is being inhibited.What are the implications for the future ofagriculture and society of the secrecy that nowsurrounds so much of what was formerlyshared public knowledge? For a brief history ofintellectual property rights as they apply toliving organisms, see Appendix 4.

These and other questions need to beaddressed by citizens and their publicinstitutions. These issues are of particularconcern to farmers and consumers who wouldbenefit from research into alternative


technologies that are less costly (in everyway), less risky, and more equitable. Equityrequires that the economic benefits and risksof transgenic technology be fairly distributedamong technology providers, farmers,merchants, and consumers.

For long-term sustainability, farmers needresearch that focuses on farms as systems,with internal elements whose relationshipscan be adjusted to achieve farm managementgoals (46). In contrast, transgenic cropresearch so far has focused on products thatcomplement toxic chemical approaches tocontrol of individual pest species. These areproducts that can be commercialized by largeagribusiness or agri-chemical interests andthat farmers must purchase every year. Thisresearch orientation only perpetuates the cost-price squeeze that continues to drive so manyout of farming.

8. Industry Concentration and Farmers�Right to Save Seed

The broadening of intellectual property rightsin 1980 to cover living organisms, includinggenes, has resulted in a flurry of mergers andacquisitions in the seed and biotech industries.According to the Wallace Center report,�Relatively few firms control the vast majorityof commercial transgenic crop technologies.These firms have strategically developedlinkages among the biotechnology, seed, andagri-chemical sectors to capture as muchmarket value as possible. However, thesetightly controlled linkages of product sectorsraise serious issues of market access, productinnovation, and the flow of public benefitsfrom transgenic crops...� (47).

Unlike Plant Variety Protection�which doesnot allow for the patenting of individualgenes, but only of crop varieties�IntellectualProperty Rights prohibit farmers from savingtheir seed and undertaking their ownbreeding program, and prohibit plantbreeders from using the material to create anew generation of varieties adapted to specificregions or growing conditions (48).

By 2000, agri-chemical giants DuPont andMonsanto together owned 73 percent of thecorn seed producers in the U.S. (49). This kind

of corporate control and concentration raisesthe question of whether there remains enoughcompetition in the seed industry for seedpricing to remain competitive. As additionalconcentration occurs, how affordable willseed�all seed, not just transgenic seed�be forfarmers? This question takes on added gravityas an increasing number of seed varietiesbecome proprietary. Farmers can�t saveproprietary seed for planting and so mustpurchase new seed every year. In addition,farmers choosing transgenic varieties mustsign a contract with the owner of the varietyand pay a substantial per-acre technology fee,or royalty.

The anticipated commercial introduction oftransgenic wheat represents a dramatic shift inan industry in which farmers still widely savetheir own seed. As non-transgenic varietiesbecome contaminated with transgenic ones,even those farmers who choose to stick withconventional varieties will lose the right toreplant their own seed. This loss has alreadyoccurred in Canada�s canola industry, withMonsanto winning its court case againstfarmer Percy Schmeiser for replanting his owncanola variety that had become contaminatedwith Monsanto�s Roundup Ready canola. (SeeAppendix 3 for the story of Percy Schmeiser vs.Monsanto.)

The adoption of transgenic crop varieties hasbrought with it an increasing prevalence ofcontract production. While contract productioncan lead to increased value and reduced riskfor growers, farmers are justified in theirconcern about their loss of control when theysign a contract with a private company. Issuesassociated with contract production oftransgenic crops must be considered within thebroader context of a sustainable agriculture toinclude ownership, control, and social equity.

9. Regulation of Transgenic Crops

Much of the controversy over transgeniccrops, both internationally and in the U.S., isin part a result of how the U.S. regulatestransgenic crops. The federal government hasdetermined that the commercial products of


Precautionary Principle

The principle of precaution was developedspecifically for issues involving ethics andrisk. It is described by Katherine Barrett,project director with the Science andEnvironmental Health Network, as:

�a process for decision-making underconditions of uncertainty. The principlestates that when there is reason tobelieve that our actions will result insignificant harm, we should take activemeasures to prevent such harm, even ifcause-and-effect relationships have notbeen proven conclusively�. It has beeninvoked in many international laws,treaties and declarations on a range ofenvironmental issues including climatechange, marine dumping of pollutants,and general efforts towardssustainability [including the 2000international Cartagena BiosafetyProtocol on the transfer of �livingmodified organisms�]�.there is growingconsensus that the precautionaryprinciple has reached the status ofinternational customary law. (54)

agricultural biotechnology are �substantiallyequivalent� to their conventional counterpartsand that therefore no new regulatory processor structure is needed for their review andapproval.

Currently, three federal agencies regulate therelease of transgenic food crops in the U.S.:the U.S. Department of Agriculture�s Animaland Plant Health Inspection Service (USDA-APHIS), the U.S. Environmental ProtectionAgency (EPA), and the U.S. Food and DrugAdministration (FDA).

USDA-APHIS: The USDA looks at how atransgenic plant behaves in comparison withits unmodified counterpart. Is it as safe togrow? The data it uses are supplied largely bythe companies seeking a permit for release ofthe new crop. Under �fast-track� approval, aprocess in place since 1997, companiesintroducing a crop similar to a previouslyapproved version need give only 30 daysadvance notice prior to releasing it on themarket. According to the Wallace Centerreport, APHIS staff estimate that by 2000, 95to 98 percent of field tests were taking placeunder simple notification rules rather thanthrough permitting (50).

EPA: The EPA regulates the pesticidesproduced by transgenic crops, such as the Btin Bt corn and cotton. It does not regulate thetransgenic crops themselves. In contrast to itsregulation of conventional pesticides, the EPAhas set no tolerance limits for the amount ofBt that transgenic corn, cotton, and potatoesmay contain (51).

FDA: The FDA focuses on the human healthrisks of transgenic crops. However, its rules donot require mandatory pre-market safetytesting or mandatory labeling of transgenicfoods.

Initially, the U.S. regulatory process fortransgenic food crops required product-by-product reviews. Now, however, to simplifyand speed up the process, new products canbe approved based on the experience gainedin reviewing earlier products. According tothe Wallace Center report, the implication isthat �some crops might be approved, ordisapproved, without actual field testing�(52). The regulatory process, in fact, may notanswer most questions about the

environmental and human health risks ofcommercial production of these crops.

Central to the policy of substantialequivalence is the assumption that only theend product of transgenic technology is ofconcern�not the process of geneticmodification. Canada has adopted a similarapproach. Europe and other U.S. tradingpartners, however, have taken a moreconservative approach. They focus on theprocess of genetic modification�the source ofmany of the environmental and human healthrisks of greatest concern.

How these different approaches play out inreality can be summed up simply: The U.S.and Canada assume a product is safe until itis proven to carry significant risk; theEuropean Union, which follows the�precautionary principle,� assumes the sameproduct may carry significant risk until it canbe proven safe. The science used by the twoapproaches is not fundamentally different.The difference is in the level of risk thedifferent societies and political systems arewilling to accept (53).


Implications for SustainableAgriculture

In contrast to the ecological approach ofsustainable agriculture, �the current generationof transgenic crops follows a pest managementmodel like that employed for chemicalpesticides�through interventions that aretoxic to pests,� the Wallace Center reportpoints out. This �single-tool� approach is likelyto fail in the long run because pests willsuccessfully develop resistance that allowsthem to thrive (55).

Standard plant-breeding methods canpotentially solve many of the same problemsin agriculture that genetic engineers areworking on, though there are areas in whichgenetic engineering can enhance traditionalplant breeding. Armed with the map of anorganism�s genetic code, scientists can test

which genes are in a plant to select moreeasily which ones to cross-breed. �Before weknew where the genes were, we were stillbreeding in the dark,� according to StevenBriggs, head of genomics for Syngenta, aSwiss biotechnology giant, as quoted in theNew York Times (56).

Framework for gauging a technology�simpact on agricultural sustainability

The sustainability of any agriculturaltechnology can be gauged in part byanswering a series of questions that emergefrom the principles of sustainable agriculture.Farmers and ranchers can ask themselvesthese questions in the context of their ownoperations to help determine whetheradoption of the technology will move themaway from, or toward, increasedsustainability.

1. Does the technology increase geneticdiversity?2. Does it maintain a positive balance of pestsand predators?3. Does it protect or enhance soil biota?4. Does it decrease the quantity orconcentration of toxins released into theenvironment?5. Does it decrease soil erosion?6. Does it protect non-target organisms?7. Does it help protect natural habitats?8. Does it reduce pest populations andviability?9. Does it increase farmers� yields? Decreasefarmers� costs?10. Does it increase farmers� market control?Management flexibility? Time?11. Does it provide benefits to consumers?Will consumers accept it?12. Does it help citizens globally gain betteraccess to food?13. Does it protect the public�s access toinformation and improve public trust inagriculture?

If the answer to any of the above questions is no, acautious approach to the adoption of thetechnology in question would seem in the interestof agricultural sustainability.

The primary elements of theprecautionary principle are identified byBarrett as:

1. Avoid harms to the environment thatare �irreversible, persistent,bioaccumulative or otherwise serious.�

2. �Anticipate and prevent potentialharms at the source,� rather than relyingon reactive measures of mitigation, clean-up, or compensation.

3. Recognize the limits of scientificknowledge and don�t expect a full andconclusive understanding of potentialconsequences before taking precautionaryaction, especially when the potentialconsequences are long-term, unconfined,and broad-scale.

4. Shift the burden of proof to thedevelopers of potentially hazardoustechnologies.

5. Finally, some versions of theprecautionary principle include analysis ofthe costs and benefits of precautionaryaction, though cost-benefit analysis �is nota sufficiently robust decisionmakingframework to stand alone� (54).


Conclusion

Evelyn Fox Keller, author of The Century of theGene (57), describes the scientificunderstanding of genetics that originatedwith the discovery of DNA in 1953, and onwhich the current generation of transgeniccrops is still based:

For almost fifty years, we lulledourselves into believing that, indiscovering the molecular basis ofgenetic information, we had found the�secret of life;� we were confident that ifwe could only decode the message inDNA�s sequence of nucleotides, wewould understand the �program� thatmakes an organism what it is.

Recent scientific discoveries no longer supportthis theory. Outdated as it has become, theview that each genetic message comes from adistinct gene continues to drive promises offeeding the world and curing incurablediseases�a view Keller calls a now �utterlyfantastic premise� (58).

Keller, a professor of History and Philosophyof Science at Massachusetts Institute ofTechnology, insists that the most recentscientific understanding of genetics has moreto tell us about biological organization thanabout how to modify individual traits. In fact,the new leading-edge biotechnology will striveto capture the benefits of genetic engineeringwithout its costs, risks, and potential geneticinstability.

Molecular biologists and breeders arebeginning to utilize the emerging knowledgeof gene location and function to guide them inthe application of conventional and innovativebreeding techniques that do not rely on atransgene with promoter and marker genes(59). This is good news for sustainableagriculture, which is based on understandinghow natural systems work in order to fithuman enterprises into them. According toFred Kirschenmann, organic farmer anddirector of Iowa State University�s LeopoldCenter for Sustainable Agriculture, ��thereal benefit of genetics seems to be derived not

from the manipulation of a few genes, butfrom our enhanced understanding of hownature works� (58).

Regardless of the future direction of transgenictechnology, one thing remains certain: Many ofthe unresolved issues for farmers, ranchers,and the general public will not be settledthrough the use of biological or naturalsciences alone. Ethical and social issues arecritical components in a meaningful evaluationof this controversial technology (60).

References:

1) Experiment Station and Extension Committeeson Organization and Policy (ESCOP and ECOP).2000. Agricultural Biotechnology: Critical Issuesand Recommended Responses from the Land-Grant Universities. p. 2. <http://www.escop.msstate.edu/committee/agbiotec.pdf>. 20 p. Print copies can be orderedfrom the National Association of State Universitiesand Land Grant Colleges:NASULGC1307 New York Avenue, N.W.Suite 400Washington, D.C. 20005-4722202-478-6040202-478-6046 fax

2) Ervin, David E., Sandra S. Batie, Chantal LineCarpentier, and Rick Welsh. 2001. TransgenicCrops and the Environment: The Economics ofPrecaution. Invited paper, Western AgriculturalEconomics Association. July 10. p. 1-12. Logan,Utah.

3) Adapted from personal email correspondencewith ecologist Jill Davies. Jan. 31, 2001.

4) Physicians and Scientists for ResponsibleApplication of Science and Technology(PSRAST), a global network. GeneticallyEngineered Food Safety Problems, an award-winning educational website. <http://www.psrast.org/intropage.htm>.

5) Ryan, Angela, and Mae-Wan Ho. 2001. Europe�sNew Rules Could Sink All GMOs. A reportfrom the Institute of Science in Society, London.Aug. 28.

<http://www.i-sis.org/EU_Directive.shtml>.


6) Abate, Tom. 2001. Genome discovery shocksscientists. San Francisco Chronicle. Feb. 11.

7) Massey, Rachel. 2001. Biotech: The basics�Part1. In: Rachel�s Environment and Health News.No. 716, Jan. 18. Environmental ResearchFoundation, Annapolis, MD.

<http://www.rachel.org>.

8) Barboza, David. 2001. As biotech cropsmultiply, consumers get little choice. The NewYork Times. June 9.

9) Benbrook, Charles. 2001. Troubled Times AmidCommercial Success for Roundup ReadySoybeans. Northwest Science and EnvironmentPolicy Center. Published on the Web asAgBioTech InfoNet Technical Paper, No. 4.May 3. p. 2.

<http://www.biotech-info.net/troubledtimes.html>.

10) Biotechnology Industry Organization (BIO).2000. Guide to Biotechnology�Ag Products onthe Market, and On the Market in 6 Years.<http://www.bio.org/aboutbio/guide2000/guide_agproducts.html>.

11) Belsie, Laurent. 2001. No bumper crop ofgenetically altered plants. The Christian ScienceMonitor. August 30.

12) Henry A. Wallace Center for Agricultural andEnvironmental Policy, Winrock International.2001. Transgenic Crops: An EnvironmentalAssessment. Policy Studies Report No. 15. p. 52.

An electronic pdf version of this 76-page report(or specific sections of it) is available at <http://www.winrock.org/transgenic.pdf>. For a hardcopy costing $15 contact:

Transgenic Report Order Henry A. Wallace Center/Winrock Intl. 1621 N. Kent St., Ste. 1200 Arlington, VA 22209-2134 Phone 703-525-9430 x672; email

[email protected].

13) Ellstrand, Norman C. 2001. When transgeneswander, should we worry? Plant Physiology.Vol. 125. p. 1543-1545.

14) Personal communication with Dr. DianaRoberts, Washington State University Extension.Feb. 2, 2001.

15) ESCOP/ECOP. op. cit., p. 8-9.

16) Saxena, Deepak, Saul Flores and G. Stotzky.1999. Transgenic plants: Insecticidal toxin inroot exudates from Bt corn. Nature. Vol. 402.p. 480.

17) Benbrook, op. cit., p. 4.

18) Massey, Rachel. 2000. Sustainability and agbiotech. Rachel�s Environment and HealthNews. No. 686, Feb. 10. Environmental ResearchFoundation, Annapolis, MD. Rachel�s is availableon the Web at <http://www.rachel.org>.

19) For more on the effects on beneficial insects, andon pest resistance to Bt, see the website for PestManagement at the Crossroads at <http://www.pmac.net/ge.htm>. This site is about �theart and science of pest management; policy andthe public interest, and forces driving change.�It is sponsored, designed, and managed byBenbrook Consulting Services (BCS) as a publicservice to those working to advance the sciencesand art of biointensive Integrated PestManagement.

20) Altieri, Miguel A. 2000. The ecological impactsof transgenic crops on agroecosystem health.Ecosystem Health. Vol. 6. p. 13-23.

21) Vorman, Julie. 2001. US science panel rejectsStarLink in human food. Reuters. July 27.

22) Rural Updates, June 5, 2001. An electronicnewsletter found at <http://www.familyfarmer.org/>. Site is sponsored by Defenders ofWildlife.

23) Hillyer, Gregg. 1999. Biotechnology offers U.S.farmers promises and problems. AgBioForum.Vol. 2, No. 2. p. 99-102.<http://www.agbioforum.missouri.edu>.

24) Ag BioTech InfoNet, June 4, 2001. Maine GEcross contamination bill signed into law. AgBioTech InfoNet is a website that covers allaspects of the application of biotechnology andgenetic engineering in agricultural productionand food processing and marketing. Ag BioTechInfoNet is sponsored by a consortium ofscientific, environmental and consumerorganizations. It can be found on the Web at<http://www.biotech-info.net>.


25) Wallace Center report, op.cit., p. 20.

26) Benbrook, op. cit., p. 3.

27) Ibid., p. 4.

28) Ho, Mae-Wan. 2001. ISIS in US NationalAcademy of Science Taking Science Seriously inthe GM Debate. Paper delivered to theWorkshop on Agriculture and the DevelopingWorld of the US National Academies StandingCommittee on Agricultural Biotechnology,Health, and the Environment. Washington, DC.April 16. Reprinted on the Web by Ag BioTechInfoNet at <http://www.biotech-info.net>.

29) Wallace Center report, op. cit., p. 21. A summaryof research by Klotz-Ingram, et al. 1999.

30) Fulton, M. and L. Keyowski. 1999. The producerbenefits of herbicide-resistant canola. Universityof Saskatchewan. AgBioForum. Vol 2, No. 2. p.85-93.<http://www.agbioforum.missouri. edu>.

31) Wallace Center report, op. cit., p. 21.

32) Ervin, David E., et al. 2001. Public Research forU.S. Biosafety Regulation of Transgenic Crops.Paper prepared for �Biotechnology, Science andModern Agriculture: A New Industry at theDawn of the Century,� 5th InternationalConference organized by the InternationalConsortium on Agricultural BiotechnologyResearch (ICABR), Ravello, Italy. June 15-18.p 1.

33) Wallace Center report, op. cit., p. 19-20.

34) Benbrook, op. cit., p. 3, 15.

35) Environment News Service (ENS). 2001.Herbicide resistant weeds spring up inbioengineered soy fields. May 4.

36) Wallace Center report, op. cit., p. 15-17.

37) Osborn, Andrew. 2001. GM multinationals arethrown a lifeline with new regulations. TheGuardian (Britain). Feb. 15.

38) Evans, David. 2001. EU presents tough rules ongene labels, tracing. Reuters. July 24.

39) Schrade, Ann and Steve Raabe. 2001. States joinglobal fight over biotech labeling. Denver Post.May 29.

40) From Greenpeace website news, Jan. 2001.<http://www.greenpeace.org/~geneng/>.

41) Hord, Bill. 2001. Wheat industry is cautious onbiotech introduction. World-Herald, May 29.Retrieved from the Web at<http://www. AgriBiz.com>.

42) Shadid, Anthony. 2001. Genetic drift affectsmore than biology: US farmers stand to losemillions. Boston Globe. April 4.

43) Callahan, Patricia. 2001. Laboratory tests beliepromises of some �GMO-free� food labels. WallStreet Journal. April 5.

44) ESCOP/ECOP. op. cit., p. 14.

45) Ibid., p. 10.

46) Union of Concerned Scientists. 2000.Biotechnology and Sustainable Agriculture.From the website of the Union of ConcernedScientists at <http://[email protected]>.Address: 2 Brattle Square, Cambridge, MA02238. Ph. (617) 547-5552.


48) Deppe, Carole. 2000. Breed Your OwnVegetable Varieties: The Gardener�s andFarmer�s Guide to Plant Breeding and SeedSaving. Chelsea Green Publishing. 2nd edition.p. 270.

49) Massey, Rachel. 2000. Sustainability and agbiotech. In: Rachel�s Environment and HealthNews. No. 686, Feb. 10. Environmental ResearchFoundation, Annapolis, MD. Rachel�s isavailable on the Web at<http://www.rachel.org>.


51) Ibid., p. 36-37.

52) Ibid., p. 34.

53) For a good, concise discussion of internationallabeling issues, which are heavily influenced bydifferences in regulatory approaches totransgenic crops, see pages 13-16 of AgriculturalBiotechnology: Critical Issues and RecommendedResponses from the Land-Grant Universities. For afull citation and information on how todownload or order a copy, see citation no. 1above.


54) Barrett, Katherine. 2000. Risk and precaution inagricultural biotechnology: A role for scienceand scientists. Inquiry in Action, the newsletterof the Consortium for Sustainable AgricultureResearch and Education. Special double issueNo. 2627, Spring-Summer 2000. p. 16-19. Centerfor Integrated Ag Systems, University ofWisconsin-Madison, 1450 Linden Drive, Rm.146, Madison, WI 53706. Ph. (608) 265-6483.


56) Pollack, Andrew. 2001. Mapping genes mayhelp breed better food, bypassing geneticengineering. New York Times. March 7.

57) Fox Keller, Evelyn. 2000. The Century of theGene. Harvard University Press. 192 p.

58) Kirschenmann, Fred. 2001. A common groundto discuss genetics. Leopold Letter. Vol. 13, No.2. Summer 2001. p. 6. The Leopold Letter is thenewsletter of the Leopold Center for SustainableAgriculture, 209 Curtiss Hall, Iowa StateUniversity, Ames, IA 50011. Ph. (515) 294-3711.The Leopold Letter is also available on the Web at<http://www.leopold.iastate.edu>.

59) Ag BioTech InfoNet. 2001.<http://www. biotech-info.net/new_era.html>.

60) ESCOP/ECOP. op. cit., p. 4.

Further Resources

The following publications are included as additionsto the excellent resources cited above in theReferences section.

Hubbell, B.J. and R. Welsh. 1998. Transgeniccrops: Engineering a more sustainableagriculture? Agriculture and Human Values15. p. 43−56.

National Research Council (NRC), Board onAgriculture. 2000. Genetically Modified Pest-Protected Plants: Science and Regulation.National Academy Press, Washington, DC.

Rissler, J., and M. Mellon. 1996. EcologicalRisks of Engineered Crops. MIT Press,Cambridge, MA.

Royal Society of Canada. 2001. Elements ofPrecaution: Recommendations for Regulationof Food Biotechnology in Canada. Ottawa.January, 2001.

Most of the sources for this publication wereretrieved from the Internet, an important source ofcurrent news and information about the rapidlychanging field of transgenic technology. Manythanks to the Henry A. Wallace Center forAgricultural and Environmental Policy at WinrockInternational for permission to use the following listof Internet resources from Transgenic Crops: AnEnvironmental Assessment (12). These Web siteURLs were verified and updated Aug. 2001 byWallace Center staff.

Governmental and Quasi-governmentalEntities

Ag-West Biotech, funded by Saskatchewan�sDepartment of Agriculture and Food:http://www.agwest.sk.ca/

• publishes AgBiotech Bulletin,http://www.agwest.sk.ca/e_bulletin.shtml

Australian Department of Health and AgedCare, Office of the Gene Technology Regulator(OGTR):http://www.health.gov.au/ogtr/index.htm


Belgian Service of Biosafety and Biotechnology(SBB)

• Belgian Biosafety Server,http://biosafety.ihe.be/Server.html

Biosafety Information Network and AdvisoryService (BINAS), a service of the UnitedNations Industrial Development Organization(UNIDO)

• BINAS Online,http://binas.unido.org/binas/index.php3

Biotechnology Australia, a collaboration of fiveCommonwealth Government departments:http://www.biotechnology.gov.au/

Canadian Biotechnology Advisory Committee,part of Industry Canada

• Canadian Biotechnology StrategyOnline,http://strategis.ic.gc.ca/SSG/bh00127e.html

Canadian Food Inspection Agency (CFIA), partof Health Canada

• Office of Biotechnology,http://www.inspection.gc.ca/english/ppc/biotech/bioteche.shtml

• Plant Health and Production Division,Plant Biosafety Office,http://www.inspection.gc.ca/english/plaveg/pbo/pbobbve.shtml

Convention on Biological Diversity (CBD)• Cartagena Protocol on Biosafety,

Biosafety Clearing-House (BCH),http://www.biodiv.org/bch

CSIRO Australia (Australia�s CommonwealthScientific and Industrial ResearchOrganisation)

• Gene Technology in Australia,http://genetech.csiro.au/

European Commission, Joint Research Centre(JRC): http://www.jrc.org/

International Centre for Genetic Engineeringand Biotechnology (ICGEB)

• Biosafety Web Pages,http://www.icgeb.trieste.it/~bsafesrv/

Organisation for Economic Co-operation andDevelopment (OECD)

• BioTrack Online (BiotechnologyRegulatory Developments in OECDMember Countries),http://www.oecd.org/ehs/country.htm

• Database of Field Trials,http://www.olis.oecd.org/biotrack.nsf

U.K. Department for Environment, Food &Rural Affairs, Advisory Committee on Releasesto the Environment (ACRE):http://defra.gov.uk/environment/acre/index.htm

U.K. Department of Trade and Industry (DTI),Biotechnology and Pharmaceuticals

• BioGuide (guide to biotechnologysupport and regulations in the U.K.),http://dtiinfo1.dti.gov.uk/sectors/biotechnology.htm

U.N. Environment Programme (UNEP),International Register on Biosafety (IRB):http://www.unep.org/unep/program/natres/biodiv/irb

U.N. Food & Agriculture Organization,Technical Cooperation Network on PlantBiotechnology in Latin America and theCaribbean (REDBIO/FAO):http://rlc.fao.org/redes/redbio/html/home.htm

U.S. Department of Agriculture (USDA),Animal and Plant Health Inspection Service(APHIS)

• Agricultural Biotechnologyinformation,http://www.aphis.usda.gov/biotechnology/

• United States Regulatory Oversight inBiotechnology,http://www.aphis.usda.gov/biotech/OECD/usregs.htm


U.S. Department of Agriculture (USDA),Cooperative State Research, Education, andExtension Service (CSREES), AgriculturalResearch Service (ARS)

• Biotechnology Risk AssessmentResearch Grants Program (BRARGP),http://www.reeusda.gov/crgam/biotechrisk/biotech.htm

U.S. Department of Agriculture (USDA),Cooperative State Research, Education, andExtension Service (CSREES), AgriculturalResearch Service (ARS), National AgriculturalLibrary (NAL)

• Biotechnology Information Resource(BIC), http://www.nal.usda.gov/bic/

U.S. Department of Agriculture (USDA),Cooperative State Research, Education, andExtension (CSREES), Agricultural ResearchService (ARS), Plant Genome ResearchProgram

• GrainGenes (database for small grainsand sugarcane),http://wheat.pw.usda.gov/indexframe.html

U.S. Department of Health and HumanServices (HHS), National Institutes of Health(NIH)

• Bioethics Resources on the Web(including biotechnology),http://www.nih.gov/sigs/bioethics/

U.S. Department of State, Office ofInternational Information Programs

• Biotechnology: Food Security andSafety (thematic issue of EconomicPerspectives Vol. 4, No. 4, October 1999),http://www.usinfo.state.gov/journals/ites/1099/ijee/bio-toc.htm

• Global Issues: Biotechnology,http://www.usinfo.state.gov/topical/global/biotech

U.S. Environmental Protection Agency (EPA),Office of Pollution Prevention and Toxics

• Toxic Substances Control Act (TSCA)Biotechnology Program,http://www.epa.gov/opptintr/biotech/

U.S. Food and Drug Administration (FDA),Center for Food Safety and Applied Nutrition(CFSAN)

• Biotechnology information,http://vm.cfsan.fda.gov/~lrd/biotechm.html

Nonprofit Biotechnology Entities

AgBioTechNet (Online Service for AgriculturalBiotechnology, from CABI Publishing, withsupport from Agricultural BiotechnologySupport Project):http://www.agbiotechnet.com/

Agricultural Biotechnology Support Project(ABSP), formerly Agricultural Biotechnologyfor Sustainable Productivity project (USAID-funded project awarded to Michigan StateUniversity�s Institute of InternationalAgriculture): http://www.iia.msu.edu/absp/

Bioline International• publishes BioSafety Journal,

http://www.bioline.bdt.org.br/by

Consultative Group for InternationalAgricultural Research (CGIAR) ResearchCenters: http://www.cgiar.org:80/centers.htm

European Federation of Biotechnology (EFB):http://efbweb.org/

• Agri-Biotechnology Section,http://www.agbiotech.org/pages/efb/home.html

• EFB Task Group on Public Perceptionsof Biotechnology,http://www.kluyver.stm.tudelft.nl/efb/tgppb/main.htm

Illinois-Missouri Biotechnology Alliance(IMBA): http://www.ssu.missouri.edu/imba/

• publishes AgBioForum magazine,http://www.agbioforum.missouri.edu/


Information Service for National AgriculturalResearch (ISNAR)

• ISNAR Biotechnology Service (IBS),supported by Government of TheNetherlands, Government ofSwitzerland, Government of Japan, andothers,http://www.cgiar.org/isnar/ibs.htm

Information Systems for Biotechnology (ISB),part of the National Biological ImpactAssessment Program (NBIAP) andadministered by USDA/CSREES

• International Field Test Sources,http://www.isb.vt.edu/cfdocs/globalfieldtests.cfm

• publishes ISB News Report,http://www.isb.vt.edu

International Food Information Council (IFIC)• Food Biotechnology information,

http://ific.org/food/biotechnology.vtml

International Service for the Acquisition ofAgri-Biotech Applications (ISAAA):http://www.isaaa.org

National Agricultural Biotechnology Council(NABC), a consortium of 30 leadingagricultural research and teaching universitiesin the U.S. and Canada:http://www.cals.cornell.edu/extension/nabc/

National Biotechnology Information Facility(NBIF), based at New Mexico State University:http://www.nbif.org

University of Guelph, Department of PlantAgriculture (Canada)

• Food Safety Network, GeneticallyEngineered Food/Crops,http://www.plant.uoguelph.ca/safefood/

Nonprofit Consumer and EnvironmentalEntities

Ag BioTech InfoNet (sponsored by aconsortium of scientific, environmental, andconsumer organizations):http://www.biotech-info.net

The Edmonds Institute:http://www.edmonds-institute.org

Genetic Resources Action International(GRAIN): http://www.grain.org/front.cfm

Greenpeace International• Genetic Engineering information,

http://www.greenpeace.org/~geneng/gehome.htm

Rural Advancement Foundation International(RAFI): http://www.rafi.org/

Union of Concerned Scientists (UCS), Food andEnvironment Program

• Biotechnology information,http://www.ucsusa.org/food/0biotechnology.html

• publishes FoodWeb (formerly GeneExchange),http://www.ucsusa.org/agriculture/foodweb.html

Industry Trade Associations and For-profitEntities

AGBIOS (Agriculture & BiotechnologyStrategies, Canada): http://www.agbios.com/

Agricultural Groups Concerned aboutResources and the Environment (AGCare),representing producer groups in Ontario,Canada: http://www.agcare.org

American Crop Protection Association (ACPA)• Issues: Agricultural biotechnology

information, http://www.acpa.org/


BioAbility (formerly Institute forBiotechnology Information, IBI):http://www.biotechinfo.comBIOTECanada:http://www.biotech.ca/EN/index.html

Biotechnology Industry Organization (BIO):http://www.bio.org

Council for Biotechnology Information (CBI):http://www.whybiotech.com/en/default.asp

Food Biotechnology Communications Network(FBCN) (Canada): http://www.foodbiotech.org

By Nancy MathesonATTRA Program SpecialistOctober 2001

The author gratefully acknowledges Montanaecologist Jill Davies and Rick Welsh ofClarkson University for their valuable reviewof earlier drafts of this paper and,along with David Ervin of Portland StateUniversity, for the information sources theyprovided. Thanks also to Suzanne DeMuth ofthe Wallace Center for Agricultural andEnvironmental Policy at WinrockInternational for her help.

The Electronic version of Genetic Engineering ofCrop Plants is located at:HTMLhttp://www.attra.org/attra-pub/geneticeng.htmlPDFhttp://www.attra.org/attra-pub/PDF/geneticeng.pdf


APPENDIX 1

GMO Issues Facing IndianaFarmers in 2001

R.L. (Bob) Nielsen, Agronomy Dept., PurdueUniv., West Lafayette, IN 47907-1150Dirk Maier, Ag. & Biological EngineeringDept., Purdue Univ., West Lafayette, IN 47907-1146

For publication in Purdue Pest Management &Crop Production Newsletter, March 23, 2001

The global debate over genetically modifiedorganisms, specifically transgenic cropvarieties, shows little evidence of slowingdown. Whether you favor transgenic plantbreeding or not, the short term effects onmarket acceptance for transgenic crops ingeneral are impacting corn and soybeanfarmers directly. You only have to look at theuproar caused by the contamination of lastyear�s commercial corn and seed cornproduction by the Cry9C Bt transgene(approved for animal consumption andindustrial use but not human consumption) torealize how quickly the global debate can hithome.

As Indiana farmers prepare for the 2001growing season, what can they expect? Willthere be any more unexpected �red flags�regarding the acceptance of currently availabletransgenic crop varieties? What can farmers doto best minimize the transgenic market risk totheir farming operations?

First of all, recognize that NONE of thecurrently available insect-resistant orherbicide-tolerant corn or soybean varieties areCRITICAL for the success of Indiana farmers.

• European corn borer, the corn pesttargeted by Bt corn hybrids, occursinfrequently enough and atsufficiently low levels that the useof Bt hybrids is not economical formost Indiana corn growingsituations (Hyde et al. 1998). Such

hybrids are best suited to extremelyearly or late corn plantings wherethe risk of injury to the corn borer isgreatest.

• The glyphosate tolerant soybeantechnology is a very handy weedcontrol tool and often lowers totalweed control costs, but cannot beconsidered critically important forthe success of soybean productionin Indiana. The same holds true forglyphosate tolerant and glufosinatetolerant corn hybrids.

Because these transgenic crop traits are NOTCRITICAL for the success of Indiana farmers,the choice of whether to grow them or notdepends primarily on the farmer�s assessmentof the uncertainty of market acceptance forsuch products and/or the available seedsupply of alternative non-transgenic varieties.

What if a farmer elects not to use transgeniccrop varieties, but is concerned about the riskof contamination of his/her grain bytransgenic grain? In other words, what are thepossible means by which one can end up withtransgenic grain interspersed with thatproduced from a non-transgenic variety?

Seed Supply. Seed producers face the samechallenges of producing pure non-transgeniccrop seed as do commercial grain producers.Consequently, most have been reluctant toassure 100 % �pure� seed relative to transgenecontamination.

In late December, the USDA stronglyrecommended that seed companies sample andtest all of their 2001 seed corn lots and all seedparent lines for the presence of the Cry9C Bttransgene because of the hue and cry raisedlast fall with the discovery of this geneticmaterial in corn flour and products made fromcorn flour. Any seed lot testing positive forCry9C will be channeled into feed or non-foodindustrial use. USDA also recommended thatseed companies provide the verificationinformation to customers when customers askfor it.


The seed industry has responded to thisdemand by supposedly testing all seed lots forthe presence of the Cry9C Bt transgene.Unfortunately, seed companies cannotguarantee zero presence of Cry9C in any seedlot. The currently available quantitative tests,when used with appropriate samplingintensities, are capable of detecting thepresence of the Cry9C protein at the minimumdetectable level of no less than about 0.2 %with a 99 % probability.

Every corn grower needs to take reasonableprecautions to avoid introducing the Cry9C Bttransgene into the 2001 corn crop. At aminimum, corn farmers should �verify beforethey buy� and insist on receiving the resultsfrom the USDA-recommended seed testingplan for the Cry9C Bt transgene. Ask for theresults in writing, keep this documentation foryour records, and help to assure the integrity ofthe 2001 harvest. Additionally, consider savinga sample of seed from each lot of supposednon-transgenic hybrid or variety for purityretesting in the event that you need to re-verifythe non-transgenic integrity of a particularseed lot.

At a maximum, ask for written assurances forANY transgene contamination in any non-transgenic corn or soybean variety. Somecompanies have taken the extra steps to test forany transgene contamination in their non-transgenic hybrid seed lots and are making thisinformation available to their customers.

Previous Crop & Variety. Because of the riskof transgenic volunteer corn, any field plantedto a transgenic variety in 2000 (especially theCry9C Bt transgene) should not be planted tocorn again in 2001. Similarly, be sure toprevent any such volunteer corn in this year�ssoybean fields from setting seed.

Planting Operation. Let�s say that a farmer hasobtained a �pure� supply of non-transgenicseed corn or soybean, but will also be plantingsome transgenic varieties in 2001. Obviously,then, there will be some potential for seedcontamination during the planting operation.The best advice here is to plant the non-

transgenic seed lots first, followed by thetransgenic varieties. In this way, any seedcarrying over from one seed lot to another inthe planter will be from non-transgenic totransgenic and not the other direction.

Pollen Drift Control. Corn is a cross-pollinating plant species, meaning that pollenfreely moves with the wind throughout a cornfield and, to a limited degree, outside of thefield during the active pollination period.While recent research on the extent of pollendrift strongly suggests that the majority of cornpollen from a field lands within a very shortdistance from the field, some small percent ofpollen will travel a quarter of a mile or furtherand still be viable. Consequently, pollen driftrepresents a means of transgene contaminationfor farmers growing non-transgenic hybridsadjacent to fields of transgenic hybrids.

Communication with neighbors is animportant aspect of pollen drift awareness.Farmers should find out what corn hybridswill be planted adjacent to their fields of non-transgenic corn, and document the hybrid seedlot information and planting dates. In Indiana,the risk of pollen drift is greatest from fields ofcorn planted to the southwest of the field inquestion because of the direction of theprevailing winds in mid-summer. Taking thetime to note the dates of pollen shed in yourfield and adjacent fields will help youdetermine the relative risk of pollen drift.

The risk of pollen drift from neighboringtransgenic corn fields may require theharvesting and segregation of a certain amountof corn around the perimeters of a non-transgenic field, certainly no less than 660 feetfrom the field edge. Corn harvested from thosebuffer strips should be fed on the farm, orchanneled to elevators willing to accepttransgenic corn.

Harvest Operation. Combines should be supercleaned prior to the start of grain harvest tominimize the risk of any leftover grain from2000 in the machine. If non-transgenic andtransgenic varieties are grown on the samefarm, then the sequence of harvesting those

APPENDIX 1


fields should follow the FIF-FOF (First-In-Field, First-Off-Field) principle. This meansthat non-transgenic varieties planted in thefield first should be harvested beforetransgenic ones to avoid transgenic graincommingling with non-transgenic grain fromthe nooks and crannies of the combine.

Handling, Storage & Transport. All graintransport vehicles (trucks, wagons, trailers,grain carts), all grain handling equipment(augers, legs, pits, wet holding bins, dryers)and all grain storage facilities should be supercleaned prior to the start of grain harvest. Byfollowing the FIF-FOF principle duringharvesting, the post-harvest operations willbenefit because non-transgenic varieties can bereceived, dried and transferred to storageahead of transgenic varieties. Obviously,transgenic and non-transgenic grain should bestored separately on-farm to avoid graincommingling, and to take advantage ofpotential premiums for identity-preservedgrains in the market place.

Assuming that transgenic grain was put intostorage last, then emptying storage facilities fortransport to market should begin with thetransgenic grain in order to avoid an extracleaning step, and thus, reduce the chance ofcontamination. However, given that thisstrategy will depend on a farmer�s marketingplan, all grain transport vehicles and grainhandling equipment should be super cleanedprior to every time that non-transgenic grainload-out follows transgenic load-out in order toavoid commingling of grain leftover from theprevious handling operation.

Guidelines for Corn, 2001:

• Expect little or no economic benefit fromplanting approved Bt corn varieties inIndiana.

• Make sure seed corn is certified �clean� forStarLink� according to the USDA testprotocol. Obtain a written verification fromthe seed company.

• Avoid planting glyphosate tolerant corn.Remember that glyphosate tolerant cornhybrids are approved only in the U.S. andJapan, but not elsewhere around the globe.No quick test kits currently exist for thistransgene and no tolerance levels havebeen established. Even though some grainbuyers are assuring farmers that they willpurchase grain from these hybrids, farmersbear the sole risk for rejection at the firstpoint of sale should buying policies changeat any time in the future.

• Recognize that grain elevators wouldprefer not to accept any transgenic cornthat does not have full approval for theglobal market place and, subsequently,may change their stance on acceptance ofsuch grain this fall.

Be aware that Monsanto has established achanneling program for glyphosate tolerantcorn. When buying glyphosate tolerantcorn seed, farmers commit in writing tomarket the grain from these hybrids onlythrough approved channels. We urge allfarmers to live up to this commitment!Approved channels are over 2000 U.S.elevators that are willing to buy non-EUapproved grains. The American Seed TradeAssociation maintains an online databaseof ��grain handling facilities that haveindicated a willingness to purchase,receive, and handle genetically enhancedcorn products that have full U.S.registration for food and feed use, but arenot yet approved for import into theEuropean Union.� The Web address for theASTA database is<http://asta.farmprogress.com/>.

• Recognize that grain processors have urgedproducers only to plant varieties that havefull approval for the global market placeand, subsequently, will unlikely accept anytransgenic corn this fall.

Be aware that Monsanto, as part of theirchanneling program, is also establishing adatabase of every farmer who purchasesglyphosate tolerant corn seed. Although

APPENDIX 1


they have committed not to reveal namesand addresses, they will work with anyinquiring processor and reveal to themhow many acres of glyphosate tolerant cornwere planted in the areas from where theyplan to purchase corn. For any area that aprocessor raises concern, Monsanto willcontact those farmers and remind them tomarket their corn only through approvedchannels after harvest. We urge processorsto inquire about glyphosate tolerant acresand urge all farmers to comply with thechanneling program!

Guidelines for Soybean, 2001:

• Non-transgenic soybean seed supplies arelimited.

• Some grain buyers have specialty contractsfor non-transgenic soybeans.

• Grain buyers and processors will be buyingglyphosate tolerant soybeans.

• Foreign buyers have been buying andappear to continue to be willing to buyglyphosate tolerant soybeans (and meal).

References:

American Seed Trade Association. December2000a. Grain Handlers Database. Onthe Web at: <http://asta.farmprogress.com/>.

American Seed Trade Association. December2000b. USDA Calls for Testing SeedCorn for Presence of StarLink� (Cry9CProtein). On the Web at:<http://www.amseed.com/newsupdate/asta_special_news_122900.html>.

Corn Refiners Assoc. 8 March 2001. Protectingthe 2001 Corn Crop from Cry9CProtein. A Joint statement issued by the CornRefiners Association, NorthAmerican MillersÕ Association, NorthAmerican Export Grain Association, andNational Grain and Feed Association. On theWeb at:<http://www.corn.org/web/rels0301cry9c.htm>.

Harl, Neil E., Roger G. Ginder , Charles R.Hurburgh and Steve Moline. 2001.The StarLink Situation. Iowa State Univ. Onthe Web at:<http://www.exnet.iastate.edu/Pages/grain/publications/buspub/0010star.PDF>.

Hyde, Jeffrey, Marshall A. Martin, Paul V.Preckel, and C. Richard Edwards.1998. The Economics of Bt Corn: AdoptionImplications. Purdue Univ.Cooperative Extension Service. Publication ID-219. On the Web at:<http://www.agcom.purdue.edu/AgCom/Pubs/ID/ID-219.pdf>.

Monsanto Company. 2000. Grain ChannelingInformation. On the Web at:<http://www.farmsource.com/Product_Info/GrainChannel.html>.

USDA - Grain Inspection, Packers andStockyards Administration. 2000a.Letter sent by USDA to seed companies,December 27, 2000. On the Web at:<http://www.usda.gov/gipsa/biotech/starlink/122700seedletter.htm>.

USDA - Grain Inspection, Packers andStockyards Administration. 2000b. GIPSAStarLinkª (Cry9C) Testing Program. On theWeb at:<http://www.usda.gov/gipsa/biotech/starlink/starlink.htm>.

USDA - Grain Inspection, Packers andStockyards Administration. 2000c.Sampling and Testing Recommendations forthe Detection of Cry9C Protein inHybrid Seed Corn. On the Web at:<http://www.usda.gov/gipsa/biotech/starlink/cry9cdetection.htm>.

For other information about corn, take a look atthe Corn Growers Guidebook

APPENDIX 1

© 2001, Purdue UniversityPublished at the Chat �n Chew Cafe,12 March 2001 (rev. 20 March)at: http://www.kingcorn.org/news/articles.01/GMO_Issues-0312.html


APPENDIX 2

Wheat Industry Is Cautious onBiotech Introduction

By Bill HordWorld-Herald via AgriBiz.ComMay 29, 2001

The word is out in the food industrydon�tmess up when it comes to wheat. Wheat is theworld�s favorite crop. It is bread, pasta, applepie crust, cookies and pastry. Be careful.

The U.S. wheat industry began waving thecaution flag more than a year ago as someconsumers around the world rebelled againstfood that contains genetically manipulatedsoybeans or corn.

Now even Monsanto Inc., a company that is aleader in inserting new genes in plants, hasgotten the word about wheat.

�We are breaking new ground, and we have toproceed carefully,� said Mark Buckingham, aMonsanto spokesman at the company�sheadquarters in St. Louis.

Monsanto introduced the first GMO(genetically modified organism) for amajor U.S. cropsoybeansin 1996. Now,nearly two-thirds of the U.S. soybean crop ismade up of GMOs, up from 54 percent lastyear.

But wheat is different. Forty-eight percent of allU.S. wheat is exported, compared to 20 percentfor corn and 8 percent for soybeans. Andnearly half of all wheat exports go to countries,such as Japan and European nations, that havea real sensitivity about GMOs. To lose foreigncustomers would be an economic disaster tothe U.S. wheat industry.

The concern is so great that the state legislatureof North Dakota considered a proposal inrecent months to put a moratorium on thegrowing of GMO wheat. In the end, thelegislation was amended to require a study ofthe issue instead.

Monsanto is expected to announce next weekthe formation of a wheat-industry committee toadvise it on how and when to put wheatgenetics on the market, including the currentfront-runnerRoundup Ready wheat.

As it does in corn and soybeans, the RoundupReady gene would allow farmers to use thecompany�s potent Roundup herbicide to killweeds without affecting the wheat plant.Monsanto expects to have the new plant readyfor farmers by 2005 and possibly as early as2003.

Many farmers would welcome a wheat plantthat would allow them to use weed killers orwould ward off wheat diseases.

�It would make my life a lot easier,� said DanHughes, a Grant, Neb., farmer. �But it doesn�tdo me any good if I can�t sell the wheat.�

Wheat is Nebraska�s third largest crop behindcorn and soybeans, with most of the state�swheat production coming from the drierregions of the south and southwest. In 1999,the state�s farmers exported $119 million worthof their $186 million wheat crop to foreignmarkets. Kansas was the nation�s leader with$805 million worth of wheat exports.

Very little wheat is grown in Iowa, wherehigher annual rainfalls favor corn andsoybeans, two crops that do not do as well aswheat in drier climates.

Even as the industry frets about stability inwheat markets, researchers all over the countryare testing plots.

The University of Nebraska-Lincoln is testingGMO wheat designed to resist diseases,increase seed size and improve protein orstarch quality.

�I truly believe transgenic wheat will be sold inthe future,� said Steve Baenziger, a wheatbreeder at UNL. Tom Clemente, manager ofplant genetics research at UNL�s BeadleCenter, said, �These products (being tested atUNL) wouldn�t be in growers� hands for yearsto come.�


Monsanto�s Buckingham said researchers arealso testing wheat plants that would improvethe quality of frozen dough or make it possiblefor people with a physical intolerance forwheat gluten to eat wheat products.

�There is a lot of potential down the road forvery direct consumer benefits,� Buckinghamsaid.

Wheat industry leaders say they have learnedtheir lesson from StarLink, the cuss word inplant genetics circles.

�I hate to even mention the word,� said DarrellHanavan, chairman of a joint wheat-industrycommittee on biotechnology and executivedirector of the Colorado Wheat AdministrativeCommittee.

StarLink was a corn plant genetically designedto release a protein that would kill corn borers.Although it was approved only as a livestockfeed pending further study of whether itwould aggravate allergies, the corn found itsway into taco shells.

The result was upheaval in the grain markets,including rejection of some U.S. cornshipments by Japan. There is now universalagreement in the food industry that no newseed should be sold until it has fullgovernment approval for human consumption.

Last month, Japan informed Hanavan and ateam of U.S. wheat industry leaders that itwould take its business elsewhere if U.S.farmers begin growing GMO wheat.

�Essentially, they said that at this point in timethere is no consumer acceptance of biotechproducts,� Hanavan said.

In an unprecedented concession, Monsanto hascommitted to withholding GMO wheat fromthe market until Japan gives its approval.Wheat industry leaders have determined thattwo other things are needed before GMOwheat seeds should be sold to farmers, both ofwhich are lessons learned from StarLink.

First, says Hanavan, the world needs to agreeon a tolerance standard. StarLink�s problemswere multiplied because the standard was zerotolerance, meaning that a trace of StarLink wasenough to have it turned away from food useeven though a trace was hardly consideredproblematic by scientists.

Second, wheat growers want a reliable systemfor keeping GMO wheat separated fromconventional wheat. No such system existedwhen the Environmental Protection Agencydecided StarLink could be grown for livestockfeed but not for human food.

Hanavan said wheat industry organizationswant to make progress toward a day whenbiotech wheat can have a place in the foodchain without jeopardizing wheat sales aroundthe world.

�Our whole policy position is based on thepremise that we support biotechnology,�Hanavan said. �It holds great promise for thefuture, but our concern is with marketacceptance.�

** NOTICE: In accordance with Title 17 U.S.C.Section 107, this materialis distributed for research and educationalpurposes only. **

APPENDIX 2


APPENDIX 3

On the Implications of the PercySchmeiser Decision

By E. Ann Clark, Ph.D.Plant Agriculture, University of GuelphGuelph, Ontario

The Crime of Percy Schmeiser

Let us first be clear on the crime for whichSaskatchewan farmer Percy Schmeiser wasfound guilty. He was found guilty of a) havingMonsanto genetics on his land, and b) notadvising Monsanto to come and fetch it. Hewas not found guilty of brownbaggingobtaining the seed fraudulently. Indeed, allsuch allegations were dropped at the actualhearing, due to lack of evidence.

Regardless, in his 29 March 2001 decision[http://www.fct-cf.gc.ca (click on bulletins)],Judge W. Andrew MacKay made it clear thathow it got there didn�t matter anyway. Theguilt was the same. Specifically, to quoteMacKay, �the source of the Roundup resistantcanola...is really not significant for theresolution of the issue of infringement....�

It also didn�t matter that Schmeiser did notbenefitat allfrom the RR seed. In order toderive any economic benefit from growingRoundup Ready (RR) seed, you�d either haveto sell it as seed, or spray Roundup. He didneither. He sold the crop as grain, not as seed,and he didn�t spray Roundup. He acknowl-edges spraying Roundup around his telephonepoles, a standard practice, which first alertedhim in 1997 to the contamination in his fieldbecause some of the plants didn�t die. Then, intypical farmer fashion, he got out his sprayerand made a couple of passes leading awayfrom the road to see how far the contaminationreached: the total sprayed area was 3 acres outof the hundreds of acres sown in 1997. None ofthese points are disputed. No oneincludingMonsantoargued that Schmeiser actuallybenefittedor even intended to benefitfromgrowing a crop contaminated with RR plants.But it didn�t matter. He was guilty

nonetheless, and fined $15/acre x 1030 acres.Monsanto also seeks the value of his crop:$105,000 (Canadian) plus $25,000 for punitiveand exemplary damages.

He also lost the improved genetics resultingfrom his lifelong practice of saving his ownseed to produce his own tailor-made variety ofcanola, as the crop was confiscated. The harmthat has been done to Percy and LouiseSchmeiser, now in their 70s, is grievous. But ofeven greater concern is how this incomprehen-sible decision will affect all western Canadianfarmers regardless of whether they even growcanola, let alone genetically modified (GM)canola.

The Problem(s) with Canola

Canola is a relatively primitive crop, and assuch, retains many of the characteristics of awild species. Unlike corn and wheat, whichhave been domesticated by over 10,000generations of breeding, canola pods matureunevenly, obliging farmers to cut and place thecrop in windrows to allow the green seed todry prior to combining. The dry pods alsoshatter upon maturity, dropping a fraction ofthe mature seed to the ground. The seed retainsdormancy, meaning that especially under thereduced or no-till conditions favored in theprairies, the seed can remain dormant for 6−10years, depending on the type of cultivarPolish or Argentineand the seed cangerminate anytime in the season,not just in thespring prior to seeding.

Further, because the seed is very small, round,and smooth, it travels readily in the wind. It isnot uncommon for windrowed canola to bepicked up and blown over adjoining fields.Seed is known to be dispersed by haul truckseither blown out the top if uncovered or fallingoff the exterior if not filled tidily. Schmeiser�scontaminated fields are to the east side of amajor haul road leading to Bruno,Saskatchewan, and the prevailing winddirection is west to east. The initial samplesused by Monsanto to charge Schmeiser wereactually taken from the roadsidenot the sownfields.


Although canola is primarily a self-pollinatingspecies, outcrossing is in the range of 20−30%,and canola pollen can move long distances,several km at least, primarily via insectpollinators. The required isolation distance forhybrid canola seed is 800 m. Who is it that hasto absorb the cost of installing an 800 m bufferbetween GM and non-GM crops onneighboring farms? Pollen has alwaysmovedit did not start with geneticmodification. But this is the first time we�vecalled it genetic pollution, because the genesthat move are proprietary.

To put these numbers into perspective, AlbertaAgriculture has calculated that even at 0.2%outcrossing (with a neighbor�s RR canola, forexample), a crop yielding 25 bu/acre with 3%shattering losses would deposit 10,000outcrossed seeds/acre, or 4 outcrossed seedsper square meter (http://www.agric.gov.ab.ca/crops/canola/outcrossing.html). And that isjust the genetic pollution from a single season.The lengthy dormancy interval of canolaallows the soil seed bank of contaminated seedto accumulate in the soil with each successiveyear�s addition.

Land can be contaminated with proprietaryseed in other ways. If you intentionallyplanted RR canola [or any other herbicidetolerant (HT) canola variety], shattered RRseed would contaminate your soil next yearanyway, and the next, and the next.Emergence of volunteer canola in subsequentcrops is nothing new in western Canadabutwhat is new is that the volunteer plants bearproprietary genes and are tolerant to one ormore common herbicides.

You can also bring RR canola into your landinadvertently, as an unavoidable contaminantin your sown crop. Cross contamination ofseed crops with GM seed is now so pervasivethat seed companies will no longer guaranteethem 100% GM-free, even in the seed they sellto farmers, for any field crop that has beensubject to genetic modification.

In the aggregate, these arguments explain thewidespread occurrence of RR canola growing

in places where it was never sown, and evenwhere no canola has been sown, in westernCanada.

The impossibility of reproductive isolationboth on-farm and post harvestis nowherebetter illustrated than the recent occurrence ofcontamination within Monsanto�s own RRQuest canola. Seed with an unapproved RRgene was found to contaminate bags carryingseed with the approved RR gene, obliging theurgent recall of thousands of bags of seed,some of which was already on-farm and beingsown. This is just the latest example of crosscontamination within the seed trade itself, ofwhich StarLink contamination in the corn to besown in 2001 is perhaps the best knownexample.

How then can farmers be held accountable forsomething that the seed trade itself cannot do?Well, they can�t, and even Monsanto knows it.So, Monsanto�s positionwhich the judgeinexplicably acceptedis that all the farmerhas to do is call them up and they�ll come outand deal with it. No matter how theproprietary genes got there, the judge held thatthe farmer is accountable for it, and they areobliged to inform Monsanto about itor riskthe fate of Schmeiser.

Between a Rock and a Hard Place

Now, this is an interesting conundrum. Putyourself in the position of a farmer. Toappreciate the gravity of the choice on-offer,you need to appreciate how Monsanto�s hiredinvestigators operate. They come to the door,advise you that you�re suspected of brown-bagging, and offer you a letter stipulating whatyou must pay to avoid being formallyprosecuted. Should you choose to pay the fee,you are also obliged to sign a letter whichstates that by signing, you agree to remainsilent and tell no one about what hashappened, or face further prosecution.Let�s say you know that you have one or moreof Roundup Ready, Liberty Link, Navigator/Compas or SMART canola (tolerant to theherbicides glyphosate, glufosinate ammonium,bromoxynil, or some ALS inhibitors,

APPENDIX 3


respectively) on your land. You know thisbecause, like Schmeiser, the plants didn�t diewhen you used the corresponding herbicide.So, what do you do?

Do you call up the company (Monsanto,Aventis, Aventis, and/or Pioneer,respectively), inform them that you haveinfringed upon their respective patent(s), andask them to come out for a visitthen hopethey arrive with a sprayer and not a subpoena?If the latter, no one will ever know, will they?Or do you wait for a neighbor to report you forsuspected brownbagging, using theanonymous hotline set up by Monsanto forthat purpose?

If the respective company(-ies) come out andactually do spray out the offending plants, doyou call them back again a few weeks later,when late germinating canola has emerged inyour wheat or pea crop? How is it that theyare going to eradicate these late germinating,potentially seed-bearing HT plants, in yourestablished crop? Will they compensate youfor damage done to your crop in the process, orfrom spray drift (a particular problem with theherbicide of choice, 2,4-D) to your adjoiningcrops, or your neighbor�s?

What if it was canola you were intending toplant in the contaminated field? You knowthat you will not be able to distinguishvolunteer HT canola from whatever canolayou�ve planted. You know that volunteer HTcanola will set seed and shatter, just like yoursown canola, re-contaminating the land withpatent-infringing seed. By definition, if yougrow canola on land known to have HT canolain the seed bank, your problems willnecessarily amplify over time. Where you hadone HT plant this year, you could have dozensnext year. So, do you abstain from growingcanola entirely? For how long, given that freshcontamination can occur annually?

Or do you take responsibility yourself foreliminating the proprietary plants? Do youadjust your crop rotation, your herbicideexpendituresand your bottom lineto copewith contamination that you did not want and

could not stop, and that will reoccur annuallyso long as neighbors choose to grow HTcanola?

Like the StarLink debacle which continues tohaunt US corn growers, marketers, consumers,government officials, and the seed trade itself,the guilty verdict in the case of PercySchmeiser illustrates some of the shortcomingsof applying GM technology to field cropagriculture. Far from making food cheaper,GM technology will necessarily make foodmore expensiveand particularly, but notsolelyfor those who have chosen not to growGM crops.

Why should non-GM growers be obliged toadjust their rotation and herbicide schedulesand field design in order to protect their owncrops from contamination from neighboringGM crops? Why should non-GM growers haveto absorb costs of coping with gene flow that isunwanted, involuntary, and unavoidableorface prosecution? Why should those who havemanaged their crop specifically for the high-premium GM-free market be forced to lose thepremium because of contamination fromneighboring land? Why should any farmer beforced to accept GM contamination in the seedthey sow on their own land?

Why should taxpayers be obliged to supportthe mushrooming government infrastructureneeded to monitor, regulate, and negotiate tokeep GM crops in the marketplace, and thevirtually endless costs of recallingcontaminated seed and food products from themarket? Why should consumers have to paymore for food that is worth no more (andarguably, less to them) because the costs ofdealing with unwanted GM both on the farmand in the marketplace must, necessarily, bepassed on to the consumer?

Why should all growers be penalized byplummeting crop prices incurred because aminority of growers chose to grow GM,causing traditional clients to refuse to buy GM-contaminated grain and instead to patronizeoff-shore sources? Since when do importingcountries have to buy GM grains, just because

APPENDIX 3


we want to grow them? What happens whenthe traits that move are not HT, but vaccines,pharmaceuticals, plastics, and industrialenzymes? When is the Canadian governmentgoing to stop promoting the commercializationof a technology which has so clearly beenreleased prematurely into the marketplace, andwhich so clearly externalizes its true costs ofproduction involuntarily and unavoidably toits own citizens?

E. Ann Clark, Plant Agriculture, Universityof Guelph, Guelph, ONCopyright 2001 E.A.Clark

This article first appeared in the Genetics Society ofCanada Bulletin, June 2001. It is reprinted herefrom Dr. Clark�s website at <http://www.plant.uoguelph.ca/faculty/eclark/> where other talksand articles are posted.

APPENDIX 3


APPENDIX 4

A History of Intellectual PropertyRights (IPRs)

Appendix 2 fromAgricultural Biotechnology:Critical Issues and RecommendedResponses from the Land-GrantUniversities

A report to the Experiment Station Committee onOrganization and Policy (ESCOP) and theExtension Committee on Organization and Policy(ECOP) January 21, 2000

Efforts to secure legal protection for inventionsrelated to living organisms while accountingfor their self-replicating and natural originstarted several decades ago. Improved plantcultivars, when propagated as clones, havebeen awarded protection since 1930 under thePlant Patent Act. Furthermore, Plant Breeders�Rights (PBRs) are patent-like rights forcultivated plants. PBRs were organized in 1961under the International Union for Protection ofNew Varieties (UPOV), an internationalconvention. The US adopted PBRs in 1970.

In 1980 the Supreme Court in the significantChakrabarty decision extended the scope ofutility patents to living organisms. Specificextension to plants was decided by the patentoffice in 1985 (Ex parte Hibberd) and toanimals in 1987 (Ex parte Allen). Utility patentclaims require demonstration of novelty,utility, and non-obviousness. By comparison,the tests for PBRs certificates are uniformity,stability, and distinctiveness.

PBRs and utility patents differ in somesignificant respects. PBRs make allowances forfarmers� rights (farmer saved seed) and includea research exemption for the use of protectedmaterial in the development of new varieties.PBRs also apply to whole plants orpropagating material. Typically they do notprotect individual and unique characteristics ofa protected variety. Accordingly, they provide

no effective protection for biotechnology. Anysingular bioengineered trait (e.g., a gene) canbe legally copied and transferred to anotherdistinct variety.

IPRs for living organisms are national rightsand vary substantially from one country toanother, both in coverage and enforcement.Patent rights for living organisms continue tobe hazy in the European Union, and manydeveloping countries explicitly exclude plantsand animals from patent or patent-likeprotection. The 1993 Uruguay Round of theGATT agreement changed this balance byrecognizing that exports of industrializedcountries tend to be technology-rich. As such,absence of IPRs protection in certain regionsacts as a trade barrier. The Trade RelatedAspects of IPRs (TRIPS) addition to the GATTagreement created a framework for increasedstandardization of IPRs for plants and animalsaround the world and the adoption of aminimum standard, in most cases PBRs.

The report this is reprinted from can be viewed ordownloaded as a pdf file on the Web at:http://www.escop.msstate.edu/committee/agbiotec.pdf


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