Remarks before the Canola IPM Working Group
Canola's history began with a broad-based cooperative search for uniqueness and quality. The initial marketing of canola emphasized its health benefits, which remain the major reason most consumers seek out canola oil based products. For the industry to gain marketshare and compete with the increasing array of more healthful products, consumers will need to learn about canola's other advantages -- for example, industry-wide efforts to reduce pesticide use and risks, and promote soil-building sustainable farming systems.
Marketing and public education go hand in hand whenever new products are introduced, or when an effort is made to break an existing product into a new market. Seeking out media coverage is a necessary part of marketing campaigns, and sometimes the media will seek you out. Such is the case now in many countries where approval and labeling of genetically engineered canola varieties have emerged on the front lines of the struggle over genetically modified organisms (GMOs). Recent examples --
The December 5, 1997 "Frankfurter Rundschau," a major German newspaper, reported that genetically modified genes from canola had moved beyond field plot borders 500 feet or more. The German government is apparently moving quickly to shut down 10 trials underway around the country because of the perceived threat to conventional and organic farmers. How many people reading this story will understand why? The take home message, whether right or wrong, is not good for the canola industry.
Extensive media coverage on the findings of French scientists on herbicide tolerant canola varieties, and the government's decision in November to place a moratorium on approvals of any new GMO in food production.
Indeed, as you seek out new markets abroad, long shipping routes will probably be the easiest barrier to overcome. The ability to demonstrate high and consistent quality will be an asset, and is an historic strength of the Canadian agricultural industry. But new dimensions of quality are moving to the forefront in the minds of many consumers. Genetic engineering is at the center of the storm. Remember, as these controversies unfold, that your industry's marketing edge is grounded on quality attributes. Caution must be exercised to avoid undermining the positive public perceptions that have so benefited the canola industry over the last 20 years.
I am not a canola pest management expert, but my sense is that your challenges are manageable using several different approaches. Unlike some grower groups and industries, you typically have the luxury of choice.
Pesticide use and risks in canola production -- some observations.
IPM Labeling -- A Status Report
I have been asked to report on some of the IPM-labeling efforts underway in the U.S., Canada, and Europe: the WWF-WPVGA Wisconsin potato IPM project, the Core Values New England apple IPM program started by Mothers and Others, California Clean, "No Detectable Residue" programs, Salmon Safe, ECO-O.K., the Food Alliance, Wegman's/Cornell, organic foods and labeling, etc.
New efforts are emerging every week. The latest -- the National Audobon Society has teamed up with the Smithsonian Institute to certify "bird safe" organic coffee products. While the biotech industry is busy stacking genes, consumer and environmental groups are keeping stride by stacking endorsements and label claims. It is easy to understand why the canola industry wants to join in the fun!
Key elements to a successful IPM labeling program include --
Credible measurement methodology that quantifies the linkage between IPM and reductions in use of high-risk pesticides.
Willingness to collect and share data on pesticide use and IPM practices.
Establishment of tangible goals for progress that can be monitored over time.
A commitment to steady improvement as fast as the science and art of pest management will allow.
Consumer - and grower -- education about the program, its goals, and why it will make a tangible and positive difference.
Based on current events, it seems that the big issue for the canola industry in getting an IPM-labeling effort underway is likely to be biotech.
By many measures that reflect effort per acre planted, more resources have been invested developing transgenic canola varieties than any other crop. The canola industry may well share the honors -- and spotlight -- in introducing the North American consumer to the advantages, and potential disadvantages of biotechnology.
Almost all the consumer and environmental groups working on IPM labeling are skeptical, if not down right hostile toward biotechnology as currently applied in production agriculture. Why? Because most current applications of biotechnology are almost wholly focused on helping farmers climb further onto the pesticide treadmill. Take herbicide tolerant varieties, for example. Such technologies are inherently designed to increase reliance on pesticides. By their very nature, they lock in reliance on a SINGLE product -- a short-term advantage to the company perhaps, but a disadvantage to everyone else. Such varieties are going to be costly in more ways than one. They are sure to accelerate resistance and lead quickly to weed shifts. They will lead to cross-resistance in weeds to whole families of herbicides. And they may also cause consumers to worry about the "quality" of canola. At a minimum, use of such varieties will impose new labeling and marketing challenges and costs.
Many biotech advocates predict that consumer opposition will wane over time. But will the effort to win consumer acceptance for herbicide tolerant or Bt-transgenic canola reach fruition before resistance and weed and insect shifts render the technologies obsolete? And then, what will be next?
For the next few years, most major U.S. environmental and consumer groups are likely to support the biotech position advanced by organic farming groups and the National Organic Standards Board -- transgenic varieties and GMOs should not be permitted under any circumstances. This "just say no" policy is sure to trigger a lively debate soon to be featured center stage in the U.S., where it may remain for a long time, perhaps years.
Recall that the U.S. Congress passed the Organic Food Production Act (OFPA) as part of the 1990 farm bill. USDA has been working ever since to develop the regulations needed to start the program. The long-awaited proposed rule, some 600 pages I have been told, is scheduled for publication December 16th in the Federal Register -- a goal which is now firmly set and will likely be met. Major press coverage will follow in the following months. Some of it will feature intriguing findings reported in the December 1997 Consumer Reports, which includes a major article comparing pesticide residues and risks in conventional, IPM-grown, and organic foods (not including canola).
Whether and under what circumstances to allow use of GMOs will be one of the most hotly contested sections of the proposed rule. It will trigger a public debate which will no doubt spillover as consumers form attitudes about other agricultural applications of biotechnology.
Few consumer and environmental groups are willing to take on the difficult and risky task of articulating criteria to distinguish between positive applications of biotechnology and those likely to prove damaging to the environment, farmers and/or consumers. But fortunately some groups are beginning to work toward this end. Biotechnology is too important, too diverse and too inevitable to "just say no."
But at present diverse consumer and environmental communities in North America and Europe, and most of the developing world, are speaking up with remarkable precision and unanimity in opposition to approval and marketing of GMOs in food. What has brought them so together despite such different agendas?
First, the nature of early applications of biotech and the lightning speed at which they are moving into the agricultural mainstream.
Some pose new risks and/or entail major uncertainties in terms of ecological or human health consequences.
Certain applications seem unlikely to leave society better off because of their direct and hidden costs, and because they serve no purpose, perhaps other than perpetuating the "silver bullet" myth of pest management and helping private corporations show a return to past investments in plant biotechnology.
Attempts to commercialize misguided applications of biotech divert resources and focus both in the lab and on the farm from lasting, biologically based solutions to pest management problems. These concerns lead the Leopold Center for Sustainable Agriculture, at Iowa State University, to issue a policy statement on herbicide tolerant technologies and research:
"[Our] projects … have developed ways to reduce herbicide use through combinations of lower herbicide rates, banding, tillage, cover and smother crops, and rotations. These projects in no way represent a statement against herbicides; rather they are designed to offer options for appropriate and more economical herbicide use in Iowa row crop agriculture.
"Because of the substantial private sector investment in research on herbicide- tolerant crops, the Leopold Center has decided to direct its limited resources toward development of farming systems that are not reliant on crop varieties genetically transformed to tolerate herbicide applications." (See http://www.pmac.net/herbtol.htm for the full policy statement).
Last but not least -- farmers are likely to learn that some of today's GMO applications are a costly blessing that, like heavy reliance on pesticides, will yield erratic benefits that lessen over time as natural systems adapt to the latest genetic twist, as experience suggests nearly all will.
Environmental and sustainable agriculture advocates are not the only ones speaking out bluntly. Consider, for example, the "Perspective" piece authored by four senior USDA and land grant university scientists entitled "A Total System Approach to Sustainable Pest Management." It appears in the November 1997 Proceedings of the National Academy of Sciences and sets out clearly -- and compellingly -- the need for major changes in pest management systems. It also describes the roles of biological control, IPM, and biotechnology within such systems. The authors state --
"In this report, we argue that the central weakness in how we think about pest management as a component of agricultural systems has not been addressed. We must go beyond replacing toxic chemicals with more sophisticated, biologically based agents…
"The foundation of pest management in agricultural systems should be an understanding and shoring up of the full composite of inherent plant defenses, plant mixtures, soil, natural enemies, and other components of the system. These natural 'built in' regulators are linked in a web of feedback loops and are renewable and sustainable. The use of pesticides and other 'treat-the-symptoms' approaches are unsustainable and should be the last rather than first line of defense."
The Need to Grapple with Biotechnology
There are many reasons to develop and build confidence in a method to distinguish between well-researched, almost assuredly beneficial applications of biotechnology in contrast to those that promise to deliver few, if any net benefits and/or those that are risky because we are uncertain about how natural systems, including humans, will respond and/or adapt to them.
Government regulators, industry trade associations, professional societies, and consumer and environmental groups are all working toward this goal, but from different perspectives, for very different reasons and with different criteria and decision-rules. Consumer confidence in agricultural applications of biotech will be hard to win and vulnerable to the undertow until a broadly acceptable method emerges that draws upon the research, knowledge and insights that all communities have to contribute to this process. Such a system is badly needed because --
Many consumers want, and most need help in making buying decisions about genetically engineered foods.
Some promising applications of genetic engineering are not readily marketable in a product needed every production cycle. The private sector needs tangible reasons to keep investing in such technologies for the benefit of farmers, food processors and consumers. But which ones, and how?
Those managing large sums of private investment capital, whether working on Wall Street or in a large corporation, need guidance in projecting which applications of biotechnology are most likely both to yield profits and gain acceptance.
Public sector R+D managers need help in prioritizing the many areas of challenging and promising research, especially among applications not being pursued systematically by the private sector.
Regulators need assistance in evaluating when the potential benefits from biotech are likely to outweigh the risks inherent in any major new technology.
The food industry and grower groups need help in sorting out when biotechnology is likely to be embraced by consumers and the marketplace, and when it may create a backlash and cause more problems than it is worth.
To counter the argument that all environmental and consumer groups are against biotech on ideological grounds and are, as a result, anti-science and anti-progress.
By now I suspect you would like a few examples. Consumers Union (CU), the Environmental Defense Fund, the Union of Concerned Scientists (UCS) and many other organizations have taken strong public positions either opposing or raising serious questions about three major applications of biotechnology in agriculture -- BGH, herbicide tolerant varieties, and Bt-transgenics. Reasons for questioning these applications are set forth in many places -- highly technical public comments provided to Federal Agencies, books like CU's Pest Management at the Crossroads and UCS's Bitter Harvest, and short reports in magazines such as Consumer Reports. A growing number of scientists are now voicing similar concerns or discovering new ones.
Opposition to herbicide tolerant varieties is based on judgements that the planting of such varieties increases reliance on herbicides as the principal means of weed management. Such varieties will perpetuate, and in some places increase the agronomic, environmental and public health problems associated with dependence on herbicides. Plus --
The planting of such varieties will rapidly accelerate the emergence of weed resistance to some of today's safest herbicides, products that can play a positive role in weed management for many years if managed prudently and not relied on exclusively.
Increased use of certain herbicides linked to herbicide tolerant varieties may have severe and lasting adverse impacts on aquatic ecosystems and soil microbial communities. They may also be responsible for the alarming increase in frog deformities in parts of North America. (For more details and technical references, see the 1996 Consumers Union book Pest Management at the Crossroads, or review the herbicide resistance section of the PMAC website http://www.pmac.net/geherb.htm, and the section on deformed frogs, http://www.pmac.net/frogs.htm).
Opposition to Bt-transgenic varieties among consumers and environmentalists, and increasingly among academic experts, crop consultants and farmers, is based on four major factors --
Incompatibility with a fundamental tenet of IPM -- spray only where and when needed to keep populations below established thresholds, and then act in subsequent seasons to change the circumstances giving rise to the pest problem.
The critical importance of Bt foliar sprays to fruit and vegetable producers who will have to manage tough lepidopteran pests with much reduced reliance on organophosphate and carbamate insecticides within a few years as the Food Quality Protection Act is implemented in the U.S.
The likelihood of triggering resistance -- and soon. Indeed there is evidence it has begun to emerge already in some cotton insects.
The prospect of unanticipated ecological consequences in above ground food webs and pest pressure, and in soil microbial communities -- possibly adversely impacting nutrient cycling, root health, disease pressure, and long-term soil quality. (Herbicide tolerant varieties and associated pesticide use trigger similar concerns).
Consumer movement opposition to BGH is another story, best told by others some other time. But common themes surely would emerge -- lack of clear need, adverse impacts on the organism "benefited" by the technology, lingering public health concerns, the need for clear labeling.
Now, what about positive applications of biotechnology? First, there have already been many, especially in the laboratory and applied field research. More are sure to follow in research and plant breeding, and in enhancing natural plant defenses and in microbial biocontrol.
No consumer or environmental group I know of is confident in their ability, at this point, to distinguish "good" from "bad" biotech. Several are developing considerable scientific expertise and extensive databases and networks that will help them as they move in this direction. As evident in earlier remarks, some are willing now to make judgements at the extremes -- i.e., they are willing to identify applications that are "almost certainly very good and not risky" and those "most likely negative and clearly risky".
The rapid pace of commercial development is forcing their hand -- consumers (and the media) are raising more and more questions and expect consumer groups to provide answers. Ditto, questions from those concerned about environmental impacts and answers from environmental groups.
Consumers Union took a few steps toward this goal in the 1996 book Pest Management at the Crossroads. PMAC discusses biotechnology at some length. It states, for example, that --
"One of the fundamental criteria EPA should apply is whether a biopesticide or transgenic plant is inherently compatible with biointensive IPM, because it works through manipulation of largely biological processes and ecological interactions. Biopesticides or transgenic plants that simply make it possible to use pesticides or natural pesticidal compounds in new situations (herbicide tolerant plants for example), or deliver toxins in a novel way or in more potent forms (Bt-transgenic plants), do nothing to reduce reliance on pesticides. Their intent is to treat symptoms; biocontrol organisms and biopesticides compatible with biointensive IPM help relieve symptoms by altering the underlying circumstances that create or sustain an opening for pests." (PMAC, page 222-223).
Generalizing the criteria set forth in PMAC, an application of biotechnology might win consumer and environmental support if --
It produces a clear benefit to consumers and/or farmers that cannot be achieved in another way that poses fewer uncertainties -- an example, a variety with a nutritionally desirable profile of fatty acids, or higher levels of a limiting protein.
Potential health impacts are well understood and of no concern. In order to reach this judgement, any potential to cause food allergies, safety problems associated with marker genes, increases in the levels of natural toxins, changes in nutritional levels or the bioavailability of minerals and nutrients, must be fully explored in scientific studies published in the open literature and subjected to careful debate and reflection by experts from many disciplines and perspectives. Current legal requirements for testing and disclosure in the U.S. and Canada fall far short of this goal.
Ecological consequences are well understood, especially on whole organisms and ecosystem functions and interactions. GMOs should sustain or augment natural processes known to be an inherent part of healthy, dynamic living systems, including the human body. In managing pests, these interactions are the nuts and bolts of biointensive IPM!
Based on such criteria, engineering a canola plant to produce oil with a different fatty acid profile might emerge as a value-added, positive application of biotech. But engineering canola to be resistant to a herbicide almost certainly will not. Over time, experience will be gained in assessing both the benefits and risks of biotechnology. New knowledge and experience will make it possible to evaluate tradeoffs more comprehensively, and earlier in the process of development, review and commercial use.
Many applications of biotech have been promoted as "environmentally friendly" because they reduce the need to apply pesticides. Such positive applications will hopefully emerge but I do not see any in the first generation of technologies moving toward commercial applications. Still, I foresee a day when some consumer and environmental groups will lend their names to industries and companies that choose to only utilize applications of genetic engineering that truly and unambiguously advance biointensive IPM.
A few groups may support applications of biotech that markedly reduce dependence on high-risk pesticides, but also increase reliance on other pesticides or technologies posing different risks thought to be less serious or more manageable. Before groups will do so though, I suspect -- and hope -- they will insist on clear signs that such technologies will be utilized as stepping stones toward biointensive IPM rather than a sustained diversion from that goal.
I am no expert in canola biotech. My sense is that the canola industry will make some important choices in the years ahead. It is also safe to predict that many consumers and environmental activists in Europe, Japan and other health-conscious markets will hear -- and care -- about your decisions.
Thanks very much for the chance to share these remarks with you. I look forward to continuing the discussion.
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Last Updated on 5/21/99
By Karen Lutz