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Drug corn and the meaning of a ZERO percent tolerance level

Editor's note-- After this commentary you'll find a letter that the author wrote to Colorado lawmakers on the issue of biopharming. The legislature's Joint Agricultural Committee will meet today to discuss biotech and trade issues; biopharming likely will also be on the agenda.-- RS

by David Dechant
for CropChoice

(Wednesday, March 5, 2003 -- CropChoice guest commentary) -- Last week, the Colorado Department of Agriculture held a couple of "Plant-Based Pharmaceutical Information Meetings." According to Jim Miller of the CDA, also the moderator, the meetings were meant to inform and for listeners to ask questions.

At the rural Akron, Colorado meeting, there were five panelists, each of whom spoke for about twenty minutes: Dr. Margaret Jones from the USDA, Virile Walker from the FDA, Dr. Tom Holtzer from Colorado State University, Charles Benbrook from Benbrook Consulting Services and Dr. Susan Harlander, President of BIOrational Consultants, Inc.

Many pharmaceutical crop promoters think that Colorado, where fields are fewer and further in between than they are in the Midwest, is a good place to grow such crops. Moreover, they think corn is the best crop to use, being that its chemistry is well known, as well as its history of being made transgenic. The equipment to plant and harvest it already exists, and it has a high grain yield and the grain keeps well.

Dr. Jones spoke about USDA regulations on drug corn, saying that a 50-foot fallow border and a one-mile separation from other corn would be required. He gave an overview of the inspection process throughout the planting, growing, harvesting, and post harvest periods.

Pollen drift was discussed quite a bit. Both Dr. Holtzer and Dr. Harlander played down the possibility that the one-mile separation would not be adequate to prevent pollen drift. They pointed to studies done by CSU and Monsanto saying that the movement of viable pollen is limited to much shorter distances. However, neither mentioned that corn pollen lives for one to two hours after it is shed. It is very hard to believe that the absence of pollen at distances less than a mile means that viable pollen will not travel much farther under the right conditions.

Temporal separation was also discussed, whereby drug corn would be planted at a different time so as not to be shedding pollen when other corn does so. However, this concept is of limited use in Colorado because of the short growing season. Another method talked about was to use ordinary corn as a pollinator and make the drug corn male sterile.

In addition to the use of dedicated planting and harvesting equipment, such methods and regulations to avoid contamination might seem fine and dandy. However, the Grocery Manufacturers of America association does not seem convinced that they are. It would prefer that food and feed crops not be modified to produce drugs in the first place.

Recently, in response to the FDAís "Proposed FDA Regulations for Plant-Made Pharmaceuticals," GMA said, "It is up to the U.S. Government Ö to ensure that we do not sacrifice food safety to technological progress. The proposed guidance fails to strike this balance and, in the process, fails to inspire confidence among U.S. food companies about the integrity of U.S. commodity supplies and the ability of current regulations to isolate and contain these products."

http://www.gmabrands.com/publicpolicy/docs/Comment.cfm?DocID=1068&

Nor is the National Grain and Feed Association convinced. In its response to the FDA, it made statements such as:

"We want to preface these comments with our strong reservations regarding the likelihood of achieving zero contamination of existing grain and food supplies in the U.S. through a combination of corporate responsibility and regulatory control Ö developing a fail-proof system `that includes a strong dependence on human performance is an unrealistic expectation Ö Even among some informed regulators, the expectation is a probability greater than zero that contamination of the U.S. grain-based food system will occur at some point."

http://www.ngfa.org/FSC_response_pharma_guidance2-6-03.pdf

The NGFA is right on target. Zero percent contamination is not a realistic goal. It does not mean one kernel per hundred thousand, nor does it mean one kernel per million, nor one per billion. Zero means nix, zilch, nothing. And until our export customers and food processors are willing to accept some level of contamination, albeit a very tiny one, the risk of growing drug corn is just too great. If a Japanese importer or a food processor in the US finds so much as single kernel of drug corn in their supplies, the resultant market disruption will cost US farmers heavily.

Still, many think drug crops can be grown without causing marketing disruptions, such as http://www.molecularfarming.com, which bills itself as the "Homesite Of A Future $50 Billion Global Industry." But what do insurance companies think? Molecularfarming.com features Farm Bureau on one of its web pages. Would Farm Bureauís insurance arm be happy to offer liability insurance to farmers and Biotech companies against possible non-approved GMO contamination and other problems that could come along?

Even if zero percent tolerance can be achieved, there are other concerns with pharmaceutical crops, such as their effects on wildlife and the environment. In fact, one listener asked what if wildlife feed on such crops? Dr. Harlander answered that they would have to put up a fence. But, one wonders, what kind of fence? Even if it is made high enough and tight enough to keep out deer and rabbits, how does one keep birds and honeybees out?

The sole skeptic on the panel, Dr. Chuck Benbrook, by far got the biggest applause from the crowd. While recognizing that there is potential in using plants to grow drugs, he also said a lot of surprises would be coming because of the novelty of doing so. He also pointed out that drug plants likely would produce in nearly all plant tissues whatever drug they are modified to produce, not just in the grain alone. He thought most drug crops would be grown in high security greenhouses, as there are too many things farmers donít have control over.

Do we farmers need alternative crops? In light of the perpetual surpluses of everything else that we grow, of course we do. But, we donít need to shoot ourselves in the foot. Imagine what would happen if a Japanese importer found a few kernels of corn modified for birth control. Non-EU approved GMO corn varieties have already cost us 100 million bushels in whole corn exports to the EU every year since 1998. In addition, the StarLink and ProdiGene fiascos have cost us heavily in other markets. We donít need any more repeats.

About the author: David Dechant grows corn, wheat and alfalfa in Colorado.

Below is the letter that Dechant sent to Colorado legislators about the issue.

Dear Legislators:

I have many concerns about the prospect of growing drug crops in Colorado.

First, the Grocery Manufacturers of America association and the National Feed and Grain Association have very strong reservations about modifying crops meant for food and feed to make drugs and chemicals. They also don't think the zero percent tolerance levels for any contamination from drug and chemical crops can be met.

Second, the US GMO regulatory system, which describes itself as being transparent, is about as transparent as a brick wall. Because it won't tell us the precise location of field trials and production fields of drug and chemical crops, nor will it tell us the precise nature of those crops (what they are modified to produce), we farmers do not have the right to know such crops are in our neighborhoods and what they might be producing.

This is appalling! Is our regulatory system supposed to operate in secrecy?

The biotech companies and the regulators say there are concerned about vandals and protecting "confidential business information." Well, how about protecting farmers growing ordinary crops? While I know of no farmers who would vandalize someone else's crops, I do many who would at least like to know that the growers of such crops have adequate liability insurance to cover any damages from contamination.

Until food processors and our export customers are willing to accept some level of drug or chemical crop contamination, albeit a tiny one, such crops should not be grown at all, as a 0% contamination level is an unrealistic goal. And, if they are, we farmers should at least have the right to know their precise location and nature so we can action, in a legal and peaceful manner, of course, to protect ourselves.

Sincerely,
David Dechant