Thank-you for inviting me to testify on the subject of genetically modified organisms. I'm a commercial beekeeper, and the secretary/treasurer of the Empire State Honey Producers Association. I also sit on the executive committee of U.S. Beekeepers, a national trade association.

Honeybees are an important component of our agricultural economy. Many crops are dependent on honeybee pollination for cost effective production. A recently published Cornell study set the honeybee's value to U.S. agriculture at 14.6 billion dollars. An additional value accrues to home gardeners and wildlife who forage on wild seeds and fruit set as a result of bee pollination. Over ? of the 3 million colonies kept in the U.S. are now trucked around the country for the purpose of pollinating our crops. Thousands of colonies are moved into N.Y. every year and provide a valuable service to N.Y. farmers and consumers.

Sadly, bees and beekeepers have had a rough time recently. We must contend with 3 exotic pests introduced over the past 15 years. The wholesale price of honey in inflation-adjusted dollars is lower than at any time since World War II. There also has been a resurgence of American Foulbrood, which had been successfully controlled by antibiotics in the past.

Are GMO's a real or potential threat to honeybees? I've tried to answer this question by searching for publicly available research on the subject and by drawing on my own knowledge of honeybee biology.

Honeybees collect and consume nectar and pollen. Nectar is a complex sugar solution which provides carbohydrates. There is very little protein from forage plants in nectar. Since GM plants generally express their special characteristics in the form of biologically active proteins, there is probably not much danger to bees from nectar.

Pollen is their protein source, and when collected from GM crops, contains the modified gene structure of the GMO. It may also contain novel proteins produced by the modified plant. Pollen is the male fertilizing component of flowering plants and so is a concentrated source of genetic material. Damaging effects to bees from GMO's are most likely to result from pollen. A colony of honeybees will collect and consume approximately 75 lbs of pollen in a year. Corn, canola, soybeans, and cotton yield pollen that is collected by bees within foraging range of these crops. All of these crops have GM varieties which are extensively cultivated in the U.S. Field tests in England have shown that bee colonies 4.5 km from GM canola fields collect GM pollen. Bees forage in all directions, and pollen grains are transferred between bees within the colony through bodily contact. It is theoretically possible that small quantities of GM pollen can be transported up to 9 km from GM crops.

The recommended isolation distance between GM crops and non-GM crops in England is 200 meters for corn, and 50 meters for canola. It seems to me that these distances are arbitrary and based more on convenience than on actual isolation of GM crops.

Professor Mark Winston, a Canadian bee research specialist, has attempted to review scientific studies pertaining to bees and GMO's. As you might expect, most GM research has been conducted by the biotechnology companies who create GMO's. What I did not expect is that this research is considered proprietary information, and not subject to public scrutiny. Prof. Winston contacted the Canadian Food Inspection Agency and encountered a brick wall. Their response was that, yes, honeybee larvae or adults had been examined in tests with GM pollen. They would not reveal what GM crops were tested, who did the testing, what the experimental protocol was, or the results of the tests. Information which is absolutely essential for the independent validation of Biotech company claims regarding the safety of GMO's is unavailable to the GMO consuming public. It is my understanding that FDA policy is similar to the Canadian Food Inspection Agency. This veil of secrecy does not serve the public interest and should be lifted as a precondition for EPA approval of GMO's. Proprietary research on presently approved GMO's should also be publicly accessible.

There are a few publicly reported studies regarding the effect of GM pollen on honeybees. Minh-Ha Pham Deleque has done some work on this area for the French government research institute, INRA. She has studied the effects of GM pollen from varieties of canola and soybeans on honeybees in a laboratory setting. Her findings indicate that none of the tested pollens kill adult bees outright, but that they may shorten their lifespan and cause some behavioral changes, particularly in a loss of their ability to learn and to smell. This may cause foraging bees to "forget" where flowers or even their own hive is located. Obviously, some issues have been raised by this work which need to be further explored.

The most important research finding in this area has recently come from Jena University in Germany. Researchers there have shown that a gene used in GM canola transferred to bacteria in the guts of bees. I believe this is the first publicly documented case of horizontal gene transfer from GM crops to bacteria within any animal. This discovery may have major implications for the future of GM crops. One main objection to GM crops has focused on the fact that during genetic manipulations required to create GMO's, antibiotic resistant "marker" genes are combined with the so-called genes of interest. These combined genes are inserted into the target plant together. Within the plant, the antibiotic resistant gene has no expression and is harmless. However, if this gene were able to transfer out of the GM plant and re-enter a bacterium, this bacterium would become antibiotic resistant. This might render commonly used antibiotics useless against diseases attacking humans and livestock, including honeybees.

At the beginning of my testimony, I mentioned the fact that bees in the U.S. are increasingly afflicted with a strain of antibiotic resistant American Foulbrood (AFB). Before the advent of antibiotics, this bacterial infection was the most serious bee disease in the world. Tetracycline had been used effectively against AFB for 40 years until 1996. In that year, tetracycline resistance was confirmed in both Argentina and the upper Midwestern states of Wisconsin and Minnesota. Since then, it has spread to at least 17 states, including New York. During the 1990's, millions of acres of Round-up Ready crops were planted in the U.S. and Argentina. According to my information, the antibiotic resistant gene used in the creation of Round-up Ready crops was resistant to tetracycline. After 40 years of effective usage against an infective bacterium found in the guts of honeybees, suddenly 2 geographically isolated countries develop tetracycline resistance simultaneously. A common thread between the U.S. and Argentina is the widespread and recent cultivation of GM crops containing tetracycline resistant genes.

I spoke about this with Dr. Haricho Shimanuki who until recently was the research leader of the USDA/ARS bee research lab in Beltsville, M.D. Dr. Shimanuki is not aware of any attempt to analyze the resistant foulbrood for genetic pollution from GM crops. I think that with the proper equipment these bacteria could be inspected for the presence of the Round-up Ready gene. That gene should have tagged along with the tetracycline resistant gene if in fact this unlikely coincidence was due to horizontal gene transfer between GM crops and foulbrood bacteria.

Since the public health implications of this are of major proportions, I would urge you to immediately direct funds to a suitable independent research facility such as Cornell for the purpose of determining whether or not this unwelcome gene transfer has occurred. If so, the state of N.Y. should recommend to the FDA that the approval for GM crops containing antibiotic resistant gene markers be reviewed and possibly revoked immediately.

Biotech corporations have maintained that we should trust their research findings which secretly prove to Federal regulators that GM crops are safe. I would suggest that it would be wise to maintain a healthy skepticism on this matter. Often there is a fundamental conflict between the corporate interest in short term profit, and the public interest in the health and safety of the people. In fact, we have recently seen examples of this conflict exposed in the courts concerning other corporations.

I think there are enough valid uncertainties about GMO's to justify NYS to require labeling of GM foods. The world is now participating in a vast GMO experiment. New Yorkers should have the choice of opting out of this experiment if they so desire. GM food labeling would partially provide this option.

Thank you.

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