"Organic Farming: Facing Choices at the Crossroads"
"Sharing the Lessons of Organic Farming" Conference
January 31, 1998
I have been asked to describe some of the choices ahead as the Canadian organic farming and food community - producers, consumers, processors and retailers -- move forward in a time of exciting yet challenging change.
Exciting in that opportunity abounds. More and more people have come to appreciate the added dimensions of value and quality available in the organic marketplace. For good reason consumer demand for organic food is growing rapidly, not just in North America but worldwide. Both the art and science of organic agriculture is gaining respect and delivering the goods, at the dinner table and on the farm and in rural communities.
Challenging in that today's forces of change are undisciplined, unpredictable and increasingly unprincipled. Plus, the forces driving change are gaining most of their energy from outside the organic community, and indeed here in Canada, from across your borders. In a way the organic community in both Canada and the U.S. is a victim of its own success. Organic farming and food have been "discovered" by those seeking solutions to many of the structural, environmental and behavioral problems of society.
On the one hand, old-time organic advocates enjoy the attention and welcome the new interest in the organic trade, and what organic farming can offer society. But for organics to solve diet-health problems, or clean up polluted runoff, or enhance soil quality on a national level, it has to be adopted much, much more widely. A two percent solution is not acceptable given the needs of a nation, and its customers abroad.
For organic farming to rise to these challenges, many new players must enter the fold, and with them will come their values, goals, loyalties, business resources and skills, and linkages to community and society as a whole. The gene pool will expand. But will enhanced diversity in the organic community lead to stability and growth, or set the stage for confusion and conflict?
My job is to highlight how some of the choices at the crossroads might affect the outcome, and hence change what it mean in the years ahead to be part of the Canadian organic community. Even with a perfect crystal ball, choices lie ahead that will tough and require a certain degree of faith and conviction. No one has a secret map showing the way to the Promised Land, nor any idea what the local "Fresh Fields" might offer in the way of nourishment.
I. A Cottage Industry or Global Competitor?
One of the fundamental sources of tension in the organic community arises from a fear shared by many long-time growers, processors, retailers and activists. Will growth and success turn the organic food industry into a reflection of the convention food system?
Will a love for fresh food, community and the soil erode as the community learns ways to keep double-shift processing plants going, or satisfy contract commitments to supermarkets 3,000 miles away?
I hope not and am sure most people here this morning also hope not. But is there a way to tilt the odds? I think there is.
Will the market's ability to provide premium prices to larger volume producers draw into organic production those motivated only enough to find an acceptable-to-some-certifier way of substituting natural inputs for synthetics?
To some extent the draw of the market already has brought into organic production some farmers and business people who are marginally committed, if not oblivious to the broader social agenda of the organic community. But the fabric of the community remains strong - just look at the harmony, and vehemence emanating from every pore of the U.S. organic community in response to the publication of the proposed rule by the U.S. Department of Agriculture (USDA). Nothing like a threat from the outside to draw a community together.
Will organic standards sink to an ever-lower common denominator in the interests of consistency, reciprocity, growth and seamless international trade?
Maybe. Some recent developments are not encouraging, but there are counter-veiling forces which might grow stronger, creating a place for continuing improvement and excellence in organics, despite some slippage around some edges.
Can Growth and Conviction Co-exist?
Can CSAs and small-scale organic farming thrive alongside the local "Super Organic" store, supplied by the Cascadians and Muir Glenns of the future?
I am convinced both can and will evolve, and indeed hopefully both will thrive. There are, after all, a lot of mouths to feed, and a few hundred million acres to convert to organics in North America before the job is done.
There is no immutable law that growth in large-scale organic farms and processing companies has to come at the expense of small scale, local organic producers, processors and retailers, or vice versa. It is true that both traditional, small-scale organic operations and large-scale newcomers benefit from consumer trust in the integrity of organic production and certification processes. Both are hurt when unscrupulous actors tarnish the image of organic.
Large companies typically have more to lose measured in dollars and equity. For this reason, most invest heavily in quality control. The good companies are able to deliver a level of consistent quality that most small time operations are hard-pressed to match, especially throughout the year and across a diverse product line.
Family businesses and small-scale operations have more to lose in real-life terms. Their risk-capital is often heavily weighted toward personal assets most people cherish more than money - freedom to work on one's own, keeping a piece of land in a family, finding a way to support a preferred rural lifestyle, making a living from the land. They are closer to the food they are growing and handling, and during season peaks, can deliver a level of quality and freshness that no big company can match consistently. Those with their own direct marketing channels built on personal contacts and trust are less vulnerable to what happens in the broader arena of public opinion, and in the retail markets around the corner.
The future of larger organic processing companies rests on their ability to meet consumer and institutional needs that are not now being supplied by local growers or small-scale businesses. Their competition is not smaller organic businesses, it is the conventional food industry. Their battle involves breaking into a still often hostile marketplace, where many are afraid to give organic products a real test. But as more consumers discover the qualities of organic foods, more people will seek out local farm markets and think about participating in CSAs. To larger companies, that is fine. There will remain plenty of markets and lots of demand for other products that they can find ways to fulfill on terms favorable to both buyer and seller.
The secret to nurturing growth and health in all sectors of the organic community is for the community as a whole to invest more energy in growing the market than fighting over it.
There is ample room in a growing market for cottage industry and globally competitive big business. A growing market will expand the public benefits that organic production can plausibly deliver. This will bring new voices, new genes, to the party. Choices will become more complex and difficult to make, but their consequences more powerful and far-reaching.
Room to Grow?
The Hartman Group, based near Seattle, Washington, has carried out some very intriguing consumer and marketplace research. The group's leader, Harvey Hartman, is convinced that there is huge untapped demand for green-labeled food, including of course organic food. His research suggests that once this latent demand is unleashed, consumers will rapidly grow the markets for all shades of green-labeled food products, from humanely raised livestock, to Salmon Safe, IPM-Grown, Bird-Friendly, and finally, the Gold
Standard -- certified organic fresh and processed food products.
The Hartman Group's 1997 report for the Food Alliance, The Hartman Report: Food and Environment: A Consumer's Perspective, Phase II, Winter 1997, shows that 52 percent of American consumers are open to, if not seeking green alternatives in the supermarket. But they are not finding many products that meet their core purchase criteria. Hartman's research shows the demand is there but the marketing acumen and message is not. Many companies and players are moving toward ways to fill the void.
Long-time organic activists worry where this is headed. Most are a little skeptical. Many are out-right cynical, and fear that the conventional food industry will in short order homogenize green-labeling and organics, rendering both next to meaningless, accept to those competing for advertising accounts, shelf space, and marketshare.
II. The Nuts and Bolts of Consumer Confidence
In its 1997 consumer survey, "The Packer" found that 26 percent of consumers had bought fresh organic produce in the last six months. Of these, 75 percent said they were "Extremely" or "Very" satisfied, and another 23 percent were somewhat satisfied with their purchase. Tomatoes and apples are by far the most frequently purchased organic produce items.
Organic sales are growing fast - 20 percent to 25 percent annually in the U.S. Why? Surveys show that concern over pesticide residues in food is the dominant reason. Most consumers equate "organic" with pesticide free, even though this is not always the case. The long-standing quest to reduce pesticide use and risks is what has brought many environmental and consumer organizations into the campaign to expand the scope of the organic industry. They see in organic farming a way to promote positive solutions to negative agriculture production problems.
Those who care about resource stewardship and environmental quality see much of value in organic farming systems, because such systems are grounded by necessity on gentle management of natural resources, systems and cycles. It helps, of course, that organic farming principles reject unambiguously the notion that farmers can dominate nature with synthetic chemical inputs.
So what do consumers think about organic food and pesticides?
The best and most recent data comes from the 1997 Hartman report that was commissioned by the Food Alliance, a group promoting sustainable agriculture in the Pacific Northwest. The Hartman report contains several dozen survey questions in a section on "Attitudes Towards Agriculture and the Environment." Respondents were asked whether they agreed or disagreed with a number of statements --
"To me, organically grown means no pesticides were used to produce the food."
78 percent of 715 respondents "Agree."
"Naturally occurring pesticides are a better choice than synthetic pesticides."
68 percent agree.
"I would like to know whether the milk I buy has been produced by cows
who are receiving injections of BGH, used to increase milk production."
79 percent agree.
"I prefer that food products making claims about improved environmental
performance be certified."
74 percent agree.
"I read point-of-purchase information about food products and would
appreciate more details on how food is grown."
66 percent agree.
"I support plant biotechnology as a tool in agriculture if it reduces
the amount of synthetic pesticides used."
60 percent agree.
"I would like to support the use of IPM by farmers through the
purchase of food that has this identity on the label."
49 percent agree.
"I worry more about spoiled food and bacterial contamination than I
do about pesticide residues."
47 percent agree.
"IPM means that less pesticides are used on the food I buy."
40 percent agree.
"I am more concerned about chemical residues on my food than chemical
pollution of water."
18 percent agree.
Consumers are correct in expecting that organic food is free of synthetic pesticide residues if organic production standards and principles have been adhered to. There are certain exceptions that various organic laws and certifiers deal with in different ways - persistent residues in the soil, contamination from drift or atmospheric deposition, government-mandated spray programs designed to eradicate some new pest. I will resist the temptation to deal with the difficult questions that arise in dealing with these cases because the problems are not widespread and are being dealt with relatively well.
Concern over pesticides is what brought many consumers to the organic
marketplace. Further steps may be needed
to assure the integrity of that marketplace. Choices will need to be made
in figuring out how, and who will bear the cost of whatever steps are taken. This is one of the sets of issues that people in the U.S. are struggling with as they craft responses to the recently published organic rule.
Green-washing is another concern - the promotion of frivolous and untrue claims about the environmental attributes of foods. One of the more outrageous recent examples is the partially successful test marketing effort by Monsanto. The campaign was designed to convince retailers and food writers in the Seattle, Washington area that consumers are so enamored with Bt-transgenic "NatureMark" potatoes that they are willing to pay higher prices. The headline in a July 14, 1997 story in "The Packer" about the NatureMark test market campaign is evidence of the triumph of P.R. and hype over "good science" --
"NatureMark: Pesticide-free potatoes please consumers"
There is considerable debate over what consumes want and expect in organic food. Do they think organic means "pesticide free"?
Unfortunately there is scant solid consumer research on these questions, other than the work of the Hartman Group. But there is lots of conventional wisdom. For generations Americans have turned to The Joy of Cooking as the authoritative source of conventional wisdom about food and how to prepare it. Just a few months ago, the first new edition in 25 years was published. Chapter 4, "Diet, Lifestyle, and Health" contains a section entitled "PESTICIDES" which reads in part --
- "Pesticides, insecticides, herbicides, and fungicides are used widely in U.S. agriculture to protect food crops from worms, insects, weeds, or fungi that may affect their quality and profitability. Most of the produce we buy in the supermarket -- virtually everything that isn't labeled "organic" -- has been grown with one or more of these agents.
"Careful buying and cleaning of produce is clearly important. Whenever practical, buy organic produce -- which by definition has been grown without pesticides and their relatives. It is not always cosmetically perfect, but it is free of potentially harmful substances and may even be more flavorful than mass-produced fruit and vegetables."
(from p.4, Irma S. Rombauer, Marion Rombauer Becker and Ethan Becker, The Joy of Cooking
, Scribner, 1997)
The U.S. Organic Program "Proposed Rule"
Building consumer confidence in organic foods rests in part upon how organic standards are set, by whom they are set, and the integrity of the certification process enforcing compliance with those standards. Right now, these issues are moving into the mainstream of news coverage in the U.S. Public reaction to the rule - almost all negative - has attracted the attention of the press, who are beginning to write about the program, organic farming, and what all the fuss is about. The coverage is bound to introduce many consumers to organics for the first time.
As most of you know, the proposed rule was published Federal Register on Dec. 16, 1997. Public comments are due March 16, 1998. The rule itself is about 400 pages double spaced; or 118 pages of 3-column wide Federal-Register-Speak. It is an eye-ball crunching read. Few people survive the ordeal still on the bright side of the day.
I am sure many aspects of the rule will come up for discussion during this meeting, and I'll share my thoughts as time allows. Rather than get into the details of the rule, I want to instead share some "big picture" thoughts about it.
Many of you recall the excellent presentation made by last year's conference keynote speaker, Mr. Fred Kirschenmann. Fred and I have shared thoughts for years on the issues of the day. We decided in November to write a short piece about the "first principles" of the organic trade, as a guide to others in assessing the rule. I thought this audience would enjoy a chance to review our thoughts, which appear in the box "PROPOSED PRINCIPLES FOR EVALUATING THE ORGANIC 'RULE'."
PROPOSED PRINCIPLES FOR
EVALUATING THE ORGANIC "RULE"
Charles M. Benbrook and Frederick Kirschenmann
As we anticipate the publication of the organic rule, which will define the Organic Foods Production Act of 1990, it occurred to us that a set of principles for judging the appropriateness of various provisions might be useful. Such principles may also be helpful in shaping recommendations for change in the language proposed by USDA.
The complexity of the rule, the scope of its impacts, the short comment period, and the range of views held in different communities are bound to result in a wide range of suggested reforms. Widely different perceived or hoped for impacts of the OFPA will be described. The circle of individuals hoping to influence the outcome of the process is growing rapidly, as is the diversity of issues likely to arise in the comment period.
How will USDA respond to the expected, large volume of recommended reforms? How will the public debate over controversial provisions, and needed solutions, influence the views of consumers, most of who are just learning about the program?
USDA's ability and willingness to accept recommended changes in the rule will be a function of three things---unanimity, consistency with the statute, and the justifications offered for changes in light of the general goals of OFPA and "good government."
Accordingly, we felt that a shared understanding of a set of "first principles" to apply in reviewing the rule may be useful to a wide range of communities who will structure their comments and recommendations largely independent of one another and without the benefit of time and dialogue to recognize mutualities. To that end we offer the following principles to anyone that finds them useful.
Perhaps they will also prove helpful to USDA as the department works to integrate the expected recommendations into a cohesive set of changes that collectively will---we all hope---make the rule simpler, clearer, and more effective in achieving the stated purposes of OFPA.
- Ecological Principle. Organic production should fit into and benefit from nature's systems. Dual goals should guide farm management decision-making: producing high quality, safe food in a manner that tends to preserve the integrity and stability of the biotic community, and builds, or at least sustains, the inherent productive capacity of the soil and biological resources used in the production process.
Organic processing should, as much as possible, retain the integrity of the product so produced. Any deviation from this ideal, in production or processing, should only be allowed when there is clearly demonstrated need, and must not undermine the long-term goals of building soil productivity and producing nutritious, safe food that consumers can buy and enjoy with confidence.
- Precautionary Principle. Any materials used in the production or processing of organic food must be proven safe. No materials will be allowed simply because they have not been proven unsafe or because benefits may appear to outweigh risks and uncertainties. The burden of proof shall always be on the party wishing to use the material and contending it is safe.
- Systems Principle. The acceptability of practices, processes and inputs in organic production should be judged, first, on their impacts on whole organisms and the biological and ecological process that govern interactions within living systems. Those that are found to contribute to the health of organisms and systems should then be evaluated in terms of their intrinsic properties independent of their use and impacts on living systems.
- Don't-Fix-What-Isn't-Broke Principle. First do no harm. Focus on quality outcomes rather than process or compliance with norms. Allow for the continuity and preservation of processes and decision-making models that have established a record of integrity in meeting the basic goals of OFPA, that demonstrate both transparency and responsiveness to all concerns and communities, and which enjoy the respect of those involved in and affected by them.
- Perpetual Improvement Principle. The rule should encourage the continued improvement of the organic craft of both producers and processors of organic food. The rule should avoid freezing practices in place based on current knowledge and research.
- Flexibility-Within-Integrity Principle. The rule should embrace diversity and simplicity to the full extent possible without eroding consumer confidence or violating organic principles.
- Equitable Fee Structure Principle. In all instances those who benefit should pay. In general, the industry should continue to cover the costs of certification. Provisions in the rule should strive to keep costs to a minimum while providing adequate resources to insure credible certification. Necessary costs imposed on growers, processors, the trade or taxpayers should, as a basic goal, be shared equitably and in relation to the benefits received from the costs imposed. USDA, working with public funds, should bear the administrative costs of the accreditation process, and on an ongoing basis, should collect and share data, and carry out and commission independent analyses helpful in documenting the magnitude of direct and indirect costs and benefits associated with OFPA implementation.
The Big Three
Much of the public discussion on the proposed USDA organic rule to date has focused on the "Big Three":
- Sewage sludge
- Genetically engineered organisms (GEOs)
The rule explains that USDA is perplexed over the appropriate role for these technologies and inputs in organic production, and is seeking public input on whether they should be allowed. The vast majority of the thousands of comments already received by USDA focus on the "Big Three" and the message is the same: no, no, no.
I cannot imagine sewage sludge making the cut since there is so much data showing that even relatively clean sludge periodically has worrisome levels of contaminants in it that organic farmers would clearly not be allowed to use if they were knowingly purchasing such inputs.
Irradiation is a tougher call because of the great concern over E. coli 0157:H7 and food safety. Some people fear that organic poultry and meat producers could be placed at a competitive disadvantage if irradiation is prohibited in the organic industry, but wins consumer acceptance and becomes common practice in the conventional food supply.
Recent experience with microbiological hazards is sobering. No one knows what new strain of an age-old or new pathogen will emerge, like the new strain of E. coli, and the chicken flu in Asia that has so panicked many people. But microbiologists are warning everyone who will listen that more "super-bugs" are coming, and that conventional drug treatments will be increasingly ineffective because of overuse and resistance.
It also remains unclear how effective irradiation will prove to be. My guess is that the final USDA organic rule will not allow irradiation for the foreseeable future, but the rule will leave the door open for the National Organic Standards Board (NOSB) and/or USDA to revisit the issue in a few years. Such a resolution makes a lot of sense given what is at stake.
Genetically engineered organisms are likely to be handled in a similar way in the final rule. My guess is that there will be a moratorium of three to five years before the NOSB will accept applications for GEOs to be added to the approved materials list. During this time, the USDA and NOSB will carry out further analyses to determine what sorts of applications of biotechnology, and which GEOs, might be consistent with the principles of organic farming and processing. In the meantime, U.S. organic foods can and will be marketed as GEO-free, and organic food shipped into the U.S. will also have to be GEO-free.
In a perfect world, the final rule would set the stage for an open and participatory science-based process for the NOSB to determine when and under what circumstances applications of biotechnology might be judged consistent with organic farming and food processing principles, and hence permitted for use. Hopefully, the narrative section of the rule will state more clearly the basic characteristics of an application of biotechnology that would likely lead to a negative judgement by NOSB, in contrast to those attributes of an application that might lead to a positive response. The basis for reaching such judgements is the focus of the rest of my talk.
III. Biotechnology and Organic Production and Processing
There are many reasons to develop a method to distinguish between well-researched, almost assuredly beneficial applications of biotechnology and those that promise to deliver few, if any net benefits while posing new, possibly uncertain risks. Dealing with GEOs in the context of organic farming standards is just one of them.
The current debate in the U.S. is the first time in recent memory a significant minority of farmers and citizens have joined together to petition the government to "Just Say No" to a major new set of technologies. This places the government in a box, since it is responsible for implementing the laws of Congress as written, including the "Organic Farming Production Act" passed in 1990, yet it also has thrown caution to the wind in becoming a tireless promoter of the industry. Consider these August 1997 comments by an EPA official that wishes to remain anonymous -
"We haven't really worked out methodologies to assess these (GEO) risks yet….
"EPA has accepted the idea that GE organisms shouldn't be regulated any differently than non-GE organisms. Then, using logic which escapes me, the Agency has concluded that it shouldn't make any special efforts to evaluate organisms made by GE, either."
One thing is certain. Because of the debate over GEOs and the organic rule, a larger percentage of the U.S. public is going to hear about the big plans the pesticide industry has for the next biotech-driven revolution in farming systems. Many people will be surprised to learn how pesticide companies are using biotechnology to gain control of the seed industry and lock in proprietary profits for both old and new technologies.
Based on recent public dialogue in the States, many people are not happy about what they are learning about biotechnology and the food supply of the future. Some will speak up. As they do, U.S. government leaders and agencies will start to move back to a more appropriate role - requiring thorough and well designed safety studies, and overseeing open, objective, science-based evaluations of the net benefits and risks of new technologies and applications before they are approved and promoted by government. Some evidence of such movement is already apparent in the Environmental Protection Agency (EPA).
In just over a week there will be a two-day meeting of an EPA scientific advisory panel to review the adequacy of Bt-transgenic plant resistant management plans. If the panel concludes, and EPA concurs, that the plans can longer be judged as effective or based on "sound science," the agency will have to start a process leading to cancellation of the conditional registrations granted to these "plant pesticides."
It is hard to imagine that EPA will take this step prior to next planting season, not because the scientific documentation is lacking, but because federal agencies rarely reverse themselves in the same decade, especially when so much money is at stake. Plus, EPA knows a reversal of its decisions in the last 24 months to approve several Bt-transgenic varieties would unleash a political firestorm. Still, if adverse field experience and scientific evidence continues to mount in crop season 1998 as it did in 1997, the agency may have no choice but to act next fall. Major U.S. food and agribusiness corporations may be among those urging action if the Europeans stick to their current requirement calling for the labeling of foods containing GEOs.
What might get the attention of major players in the food industry? A shift in market share of two or three percent. Steady growth in the exports of U.S. grown and processed food to Europe and Japan that is labeled organic and GEO-free.
Why We Need Better Tools to Assess Biotechnology
Government regulators, the organic community, industry trade associations, professional societies, investors, and consumer and environmental groups are all working toward a way to leverage positive change in agriculture and the food system. But like beauty, positive change is in the eye of the beholder, and the vision of many is clouded by self-interest.
People without a stake in the GEO debate, or time to study all the angles and arguments are looking for some help from sources they trust to be thorough and objective. There is not much out there. The big money flowing from the biotech industry into academia, professional associations and government has kept a lot of people out of the debate, not because they have little to add, but because the personal costs of joining the debate have become too high. I know there are a few people in the audience today who know what I am talking about from personal experience.
Industry likes to portray consumers as uninformed and fickle. How many times have we heard a corporate spokesperson or hired apologist say something like - "If consumers paid a little more attention to 'good science ' (i.e. corporate science), they would see the great benefits our technologies offer." Or consider a favorite recent quote from Dennis Avery, a tireless promoter of "high tech" farming methods. According to Avery, scientists should -
"… take the best genes and assemble the perfect plant like a Tinker Toy." (Statement made
November 18, 1997 at the U.K. "Brighton Crop Protection Conference on Weeds."
Quote from Pesticides and Toxic Chemical News, November 9, 1997, p. 11)
The perfect plant would be, of course, Roundup Ready and Bt-transgenic, just for starters. According to Dr. Avery, these technologies are -
"…wonderful examples of high-yield technologies which use some of the safest and most sustainable technologies ever tested by science."
This disregard for facts and arrogance is one of the major reasons the public remains skeptical about biotechnology. The industry's P.R. is part wishful thinking, part boosterism.
Most people do not trust mankind, let alone industry scientists, to know how to "design the perfect plant." Perfect for what? Judged by whom? When people ask such questions of corporate leaders, the answers are all over the map but never to the point. Some are evasive -- "we need to feed the world." Others are circular - "we cannot feed the world without new technology because new technology is the only way to feed the world." Many are factually shaky, if not dishonest - "We need to feed the world while reducing the volume of toxic pesticides farmers need to keep up with pests"; or "High yield agriculture is the only thing standing in the way of the total loss of the world's wild and forested areas…"
Boosterism, coupled with a sense no one is paying attention to the pros and cons of the "biotech revolution," makes people nervous. Consumers have already heard enough contrary information to approach too-good-to-be-true news about agricultural applications of biotech with a healthy dose of skepticism. For this reason, emerging applications, regardless how benign, will be vulnerable to the undertow and will remain so until a widely trusted technology impact assessment methodology is in place, and used, to guide decision-making. What might such an assessment system look like? What questions might it seek to answer?
Principles for Rating Agricultural and Food Industry
Applications of Genetic Engineering
A new paradigm is needed to evaluate both near- and long-term impacts of GEOs. The scope of inquiry must be grounded in the real world and span changes over time triggered by ecological interactions and adaptation. Scientists must focus both on first-order adaptations and second-order evolutionary change.
All inquiry must evolve from the principles and concepts of biological and ecological systematics rather than mechanistic, input-output, dose-response toxicological models. Such conventional approaches to risk assessment assume away most of the forces of nature, and all complex interactions - synergism between nutrition, stress and disease pressure; exposure to multiple chemicals and interactive health risks; endocrine disruptors altering expression of hormones two or three generations hence. For a fuller discussion of the need for and nature of such a new paradigm, see the compelling paper by Katherine Barrett and Carolyn Raffensperger delivered January 23, 1998 at the Wingspread Conference on Implementing the Precautionary Principle. It will be accessible via the PMAC web page in the near future.
Biotechnology -- A range of scientific tools and techniques used to study, manipulate, or otherwise influence the genetic characteristics of organisms or their interactions.
There have been and will continue to be many valuable applications of biotechnology in the discovery of new farming technologies, understanding the biological basis of sustainable farming systems, the characterization of genetic diversity and its maintenance, and increasing the efficiency of food and fiber production and processing. Applications in genome mapping and plant breeding are, alone, worthy of the label "revolutionary."
Like "The Force" in Star Wars, biotechnology can serve mankind's highest ideals while meeting practical needs, or it can be captured by "The Dark Side," serving only those whose mission is to suppress and then conquer.
Agricultural biotechnology -- Applications of biotechnology designed to alter the performance of farming systems or food processing activities.
Genetic engineering in food and fiber production and processing -- A process involving the insertion of genetic material foreign to a plant variety, animal or microorganism into a plant, animal or organism for the purpose of altering its genetic make-up, performance and/or its attributes when and as used in agricultural production or food processing.
Genetic engineering, as defined above, does not encompass a range of applications of biotechnology in research, plant breeding, the design and monitoring of farming systems, the enhancement of soil quality, biological control and food processing. The critical distinction between an application of biotechnology and one of genetic engineering is the presence or absence of a sustained change in the genetic make-up, and hence characteristics, of an organism or plant variety that is subsequently used in food production or processing.
In terms of the core principles of organic farming, the key criterion that must be applied in judging a genetic change achieved through application of genetic engineering techniques is how novel the altered organism is relative to its wild relatives.
Applications of biotechnology need be evaluated according to several criteria. Some will be relatively easy to evaluate; others will be very difficult. In such cases, results will be, at best, speculative. The skeptics among us might call them "Barely educated guesses, bordering on foolish predictions." Some of the major ones follow.
Purpose of the Application Does the application intend to reinforce an existing positive feedback loop or mechanism, or does it strive to create a new one? Does the application strive to alter, or might it alter the nutritional profile and value of food? Does the application strive to alter processing/cooking qualities or storability of food?
Whatever the stated goal, why is it considered a problem in need of solving, and what other options are there to deal with the problem, or avoid it entirely?
Reversibility of Genetic Modification Is the genetic modification supposed to, or likely to become a stable feature of the genome of the target organism, or an organism impacted by the application? Is this important to the application's success? How reversible is the genetic change likely to be, if the need ever arose to do so?
Impacts on Genetic Diversity and Biodiversity What impacts will the application have on soil microbial communities, biocontrol organisms and processes, and the diversity of agroecosystems, surrounding natural areas, and/or mammalian digestive systems?
Novelty of Genetic Modification and Experience with Possible Outcomes The greater the phylogenic distance between the engineered organism and the source of the transferred genetic trait, the bigger the prospect for unexpected outcomes and unstable expression. Uncertainties are greater and so too must be the burden of proof on proponents.
Likelihood of Recombination with Related Plants or Organisms Is it likely the introduced genetic trait, or a marker gene, will migrate to other organisms? If it does, what happen as a result? Will it be possible to detect such migration, and if it occurs, reverse it or deal with in some other way? If nature take its course, where might we end up?
Allergenicity Does the application involve, limit or otherwise alter exposure to known or possible allergens? How solid is the evidence to judge "no impact" on allergenicity?
Ecological Consequences in Whole Organisms and Within Ecosystems How fully are the organism-level and ecosystem impacts and fitness of the modified organism understood? To the extent they are understood, are there sound reasons to judge them fleeting or benign?
Ability to Meet Global Food and Fiber Needs How will the application affect the quantity, quality, price and availability of food, both in the macro-global food supply sense, and in terms of populations in need?
What will the impacts be on expected yields per planted/harvested acre under varying soils, climates, and systems of production? Is the technology intended to overcome a management-induced problem of Northern high-input systems, or a biological or natural resource constraint facing traditional low-input systems?
Nutritional Impacts and Consequences Is the application designed to address a specific dietary shortcoming in a given population? Is the target a problem rooted in dietary excess or nutritional inadequacy?
Consumer Choice Will it be feasible to label foods impacted by the application? If there are certain segments of the population likely to be sensitive to the application, are there practical ways for them to avoid exposing themselves to potential harm?
Impacts on Farmers What will be the impact on farm level cash costs of production, and gross and net returns? Will a farmer's range of technological choice be impaired? Will rotational options be foregone? Will marketing options be altered?
Will the application enhance the yield and income risk borne by farmers, in contrast to seed and pesticide companies? Will GEO crops require more careful management and prove less resilient when conditions are less than optimal in a given season?
Compatibility with Biointensive IPM To what extent will the application reinforce natural feedback loops and interactions within farming systems that reduce pest pressure, enhance biocontrol mechanisms, or raise thresholds by strengthening the plant's ability to deal with pest pressure? How might the application trigger new pest pressure?
"Bad" Applications of Biotechnology
Largely as a result of applying such criteria to assessment of new applications of biotechnology, many organizations and leading scientists have taken strong public positions opposing major contemporary applications of biotechnology in agriculture. Several reasons are typically cited -- the applications have yet to be proven safe, effective, or necessary. The most widely criticized applications have been 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, and books like CU's Pest Management at the Crossroads and the Union of Concerned Scientist's Bitter Harvest. 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 --
Consumer movement opposition to BGH is another story, best told by others another time. But common themes surely would emerge -- lack of clear need, adverse impacts on the organism "benefited" by the technology, lingering public health concerns, scientific uncertainty, and the need for clear labeling.
- The planting of such varieties will 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, lasting adverse impacts on aquatic ecosystems and soil microbial communities. They may also be responsible for the 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 web site
and the section on deformed frogs.
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 importance of Bt foliar sprays to fruit and vegetable producers, who in the U.S. will have to manage lepidopteran pests with much reduced reliance on organophosphate and carbamate insecticides within a few years as the Food Quality Protection Act is implemented.
- 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).
Potentially "Good" Applications
Over the last 15 years there have been several beneficial applications of biotechnology, 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.
The rapid pace of scientific progress and commercial development is placing a premium on the ability to distinguish between "good" and "bad" applications. 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 community support
In order to reach this last 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. Scientific evidence must be subjected to careful reflection and debate among 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.
- 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.
- Ecological consequences are well understood, especially on whole organisms and ecosystem functions and interactions. GEOs 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!
- Potential health impacts are well understood and of no concern.
Consumers Union has recently filled comments to the EPA in support of a small field scale experiment that represents what will hopefully prove to be a positive application of biotechnology (see the "Genetic Engineering" section of the PMAC web site for a copy). The application is proposed by a team of scientists led by Dr. Jim Cook of Washington State University, and covers a strain of Pseudomonas fluoresces engineered to combine two desirable traits isolated from two existing, natural strains.
The WSU team has spent years isolating and studying the genetic characteristics of natural strains of fluorescent Pseudomonas found in the soils of Pacific Northwest wheat growing regions. A few strains were found to emit natural antibiotics at levels sufficient to control, or at least suppress the three common pathogens causing wheat root disease. Upon moving these strains to the field as wheat seed inoculum, the researchers discovered that they did not colonize root systems effectively, and hence were not competitive with other indigenous strains. This lead to the effort to combine the genetic attributes of two closely related strains of Pseudomonas, one chosen because it colonizes roots well, the second because of its ability to emit relatively high levels of antibiotics. The major breakthrough came in 1997 when the attributes of two strains were merged using genetic engineering. Each strain has been thoroughly studied and characterized for years.
Using genetic engineering to understand and tweak this process is consistent with the principles of biointensive IPM. The engineered strain combines the natural attributes of two very closely related natural strains of microorganisms, with the hope of reinforcing a natural mechanism of microbial biocontrol that has been functioning as a routine part of farming systems since the area was first planted to small grains. Indeed, the research team expects that these and closely related strains have probably shared the same genetic material in the past in many combinations, and will continue to do so. The goal of the application is to tilt the competitive balance toward a particular strain for just a few weeks when wheat roots are most vulnerable to pathogen attack.
In the decades ahead, there will no doubt be many other beneficial applications of biotechnology to the science and art of conventional and organic farming and food processing. The precautionary principle should be adhered to as the community moves toward new crossroads. No time should be wasted in putting in place a process that will separate the wheat from the chafe efficiently and openly.
Organic farming has forced science to ask new questions about the biological foundation of safe and sustainable food production. It would be unfair and a big mistake to categorically deny organic farmers the benefits of the new production systems and technologies that emerge as a result.
Thanks very much for the chance to share these remarks with you. I look forward to continuing the discussion.
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