What’s up with the Media Response to Chipotle going GMO-Free?

A notice on the side panel of my box of Cheerios™ says “Not made with genetically modified ingredients.” But when General Mills, the company that manufactures this “Toasted Whole Grain Oat Cereal,” decided to make this one product in its product line without ingredients from genetically engineered (GE) organisms (AKA GMOs), I don’t recall it coming under the kind of flak that Chipotle is enduring now.

Chipotle, it seems to me, is being very transparent about what it is doing and why. For example, Chipotle spokesman Chris Arnold told Business Insider:

“Over the years, we have come to believe that the limited number of GMOs that were in our food were not making our food better or providing benefits to the farmers and other suppliers involved in producing our ingredients. We also found that switching to non-GMO alternatives in these cases was less expensive than initially predicted. We started this effort focused on the ingredients we use to make our food [my emphasis] simply because that is where our ability to affect change is most immediate.”

Sounds like a pretty all-American idea to me…affect change via your business practices and, ultimately, your pocketbook. I fully support the right of the owners of Chipotle to do so.

And because it would be downright unreasonable to expect Chipotle to take on Big Soda all by itself, it doesn’t bother me that Chipotle sodas still contain GMO ingredients either. To affect change you have to start somewhere, and Chipotle and General Mills have done just that.

What does bother me is that Dan Charles brought “meat” into this discussion about eliminating GMO ingredients.

As already mentioned, Chipotle’s current effort is focused on the ingredients used to make their food; and at this time there are no GMO “meat” ingredients in any commercialized food products, at Chipotle or anywhere else.

Chipotle couldn’t serve GMO pork or GMO chicken or GMO beef even if it wanted to.

I want to be very clear about this: THERE ARE CURRENTLY NO COMMERCIALLY AVAILABLE GE PIGS or GE CHICKENS or GE COWS anywhere on the planet that could serve as sources of GMO “meat” ingredients. (The GE animal closest to “market” in the AquaBounty salmon.)

So maybe Chipotle will someday expand its focus to include the GMO ingredients fed to the “ingredients” used to make their food. But that’s not the company’s current focus.

You have to start somewhere.

Chipotle has started with an effort to remove GMO ingredients from its food products.

General Mills did the same for Cheerios.

Maybe this is the start of something big.

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Time To Talk “Conflicts of Interest” In Relation to GMOs

Scientific conflicts of interest have been in the news a lot lately.

For example, a federal judge recently ruled that various members of the FDA’s Tobacco Products Scientific Advisory Committee had conflicts of interest and, consequently, the chairman and three other members of that committee resigned.

And then there was the case of the scientist at the Harvard-Smithsonian Center for Astrophysics who failed to disclose, in his scientific papers related to global warming, his conflict of interest over the more than $1.2 million he had received from the fossil-fuel industry; according to the New York Times, Wei-Hock Soon violated, in at least eight cases, the ethical guidelines of the journals that published his work.

In its ethical guidelines for authors submitting manuscripts, Science requires clear disclosures of “…any affiliations, funding sources, or financial holdings that might raise questions about possible sources of bias.” Annual Reviews requires the same but goes into some detail on “factors that might be viewed as biasing a literature review” including:

“Employment, professional affiliations, paid consultancies, membership in related advocacy organizations;

Funding, support, and/or grants received within the past three years;

Significant financial holdings or patents.”

So, according to Annual Reviews, not only scientists who are employed by biotech “life sciences” companies, but also academic scientists who utilize the techniques of genetic engineering to produce genetically engineered (GE) organisms (AKA genetically modified organisms, or GMOs) and who have received any grants or other funding for that research within the past three years, all have potential conflicts of interest on the subject of GE organisms.

In fact, according to Annual Reviews, I myself have potential conflicts of interest when it comes to GE crops because, for one thing, I’ve been granted a few U.S. patents that involve genetic engineering of various plant species.

But having potential conflicts of interest doesn’t necessarily have to be a bad thing. As per Annual Reviews: “A potential bias does not mean that the work presented has been compromised, nor does it disqualify authors from publication….” Rather, the point is to make an “effort to provide readers with information relevant to factors that might be viewed as biasing….”

In other words, conflicts of interest are all about what readers view as bias, i.e. bias is in the eyes of the beholder.

Well, this beholder has viewed many of the “stands” on genetic engineering taken by industrial and academic genetic engineers over the last 20 years as motivated by “conflicts of interest.”

Here are a few:

It’s just an extension of traditional breeding, only more precise.” Without further elaboration, especially of the imprecisions of genetic engineering such as insertional mutagenesis, vector “backbone” integration, rearrangements of inserted DNA as well as “landing site” DNA, etc., this statement not only smacks of conflict of interest but also lacks scientific basis since the biological processes underlying traditional breeding and genetic engineering are very different.

Regulation of GE organisms is onerous in the United States.” In addition to its economic implications, this statement ignores loopholes in the U.S.’s “coordinated” regulatory system so large that tens of GE products are now starting to fall through its cracks (as commendably pointed out recently by Camacho et al.).

Consumers are not well informed about genetic engineering and its potential to solve agricultural problems.”

I find this last example particularly vexing. In my opinion, it represents nothing more than “conflict-of-interest-driven” wishful thinking. These wishful thinkers have had more than 20 years to inform consumers about this technology and its potential and, therefore, if consumers are uninformed (and whether vocal opponents are truly uninformed is certainly debatable) then the promoters of genetic engineering are at least partly to blame. Even worse, genetic engineers have had 20 years to demonstrate the technology’s potential for solving difficult agricultural problems and what have they got to show for those two decades?

With exceptions of minor crops like virus-resistant GE papaya and GE squash, the answer to that question is GE crops that primarily contribute to industrialized, unsustainable agriculture and the very difficult agricultural problem of glyphosate-resistant weeds, a problem undoubtedly made significantly worse as a result of wide-spread cultivation of GE crops.

From my point of view, instead of “feeding the world,” GE foods are being fed primarily to Earth’s non-human animals…except in the U.S., of course, where lack of labeling ensures that people are eating them too.

So I, for one, am tired of hearing about the “potential” of genetic engineering.

Consumers like me want transparency and trustworthiness, not rhetoric and wishful thinking.

Therefore, I suggest that genetic engineers, both industrial and academic 1) admit their potential conflicts of interest and 2) be more mindful of telling the whole truth about it, warts and all. That, together with a re-vamping of the system for regulating GE products in the U.S. and–for the sake of transparency, capitalism and democracy–labeling them, would go a long way toward “depolarizing” the current debate engulfing GE crops, GE animals and GE foods in general.

Commercializing a GE product that consumers could embrace for its benefit(s) to individuals and/or to society as a whole, and promoting it with transparent labeling, wouldn’t hurt either.

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Exposure of Mammals, Birds, Reptiles and Land-Phase Amphibians to Dow Agrosciences’ Pesticide Cocktail?

I’ve already expressed my concern over the fact that U.S. government agencies recently unleashed a ticking bomb with regard to the genetically engineered (GE) “superweed” problem we’re already experiencing in the United States when the U.S. Department of Agriculture (USDA) deregulated GE corn and GE soybeans that can survive being sprayed with two pesticides that would kill their non-engineered relatives, and the Environmental Protection Agency (EPA) approved the herbicide cocktail, Enlist Duo™, comprised of the two pesticides that can be sprayed on those GE crops with impunity. Supporting this “pesticide treadmill” seems the antithesis of “sustainable” agriculture to me.

But after reading EPA’s “Response to Public Comments Received Regarding New Uses of Enlist Duo™ on Corn and Soybeans,” I have an additional concern: the toxicity of 2,4-D, one of the two pesticides comprising Enlist Duo™, to animals.

EPA acknowledges that,“should actual exposures [to 2,4-D] occur, direct effects (risk quotients…above the level of concern) may be possible only [my emphasis] for mammals, birds, reptiles, land-phase amphibians and terrestrial plants.” EPA also noted that “Acute exposure risk concerns were identified for both listed [i.e. endangered or threatened] and non-listed birds in the screening level assessment.”

But, while I find these “concerns” mentioned by EPA, well… concerning–especially since, as reported in the Huffington Post, the USDA predicted that 2,4-D use could now increase by an estimated 200-600 percent by the year 2020–the agency, apparently, does not.

And the difference in our perspectives over 2,4-D toxicity to organisms other than corn and soybean weeds appears to boil down to the issue of “exposure.”

As explained by the agency: “EPA requires a suite of toxicological data on mammals, birds, honeybees, freshwater fish and invertebrates, estuarine/marine fish and invertebrates, aquatic plants, and terrestrial plants. The purpose of the data is to determine the toxicity of the pesticide when direct exposures occur. This is known as “hazard” and is one of two components that make up “risk.” The second consideration is “exposure.” Exposure constitutes how much of the pesticide will come into contact with an organism. “Risk” is a combination of the hazard of the pesticide and the anticipated exposure of the pesticide….The risk assessment for 2,4-D choline salt incorporates both the hazard and exposure components into its conclusions; thus although it may be toxic to some groups of organisms [my emphasis] [but remember, only “mammals, birds, reptiles, land-phase amphibians and terrestrial plants”], the risk varies proportionately with exposure.”

And there’s the rub.

To me, spraying 200-600 percent more 2,4-D on corn and soybean crops, the largest crops grown in the U.S., is bound to “expose” mammals, birds, reptiles, land-phase amphibians and terrestrial plants to 2,4-D. And that exposure to 2,4-D, combined with the toxicity hazard it presents to “some groups of organisms” could constitute substantial “risk” to those organisms.

But EPA seems to believe that restrictions it has mandated for Enlist Duo™ will adequately limit exposure. As the agency put it: “By requiring pesticide application restrictions that limit off-site exposure [my emphasis] to levels below effects thresholds of the most sensitive taxonomic group, the action area (the geographic extent to where effects can reasonably be expected to occur), is limited to the directly treated footprint of the soy or corn field [my emphasis]. Consequently, no direct or indirect effects are expected for threatened and endangered species….” EPA summed up the situation this way: “When these types of information were considered, the endangered species assessment addendum concluded that there were no direct risk concerns for mammals, birds, reptiles, land-phase amphibians, and terrestrial plants.”

In drawing this conclusion, EPA considered “species specific biology, geographic location, and the ability of spray drift mitigation measures to reduce the geographic extent of exposures of concern to a limit of the boundaries of the treatment site [my emphasis].”

But the bottom line is that even if EPA’s restrictions for Enlist Duo™ are followed to the letter, all “treatment site[s],” i.e. potentially all fields of GE corn or GE soybeans in the six states for which EPA has allowed registration of Enlist Duo™–Illinois, Indiana, Iowa, Ohio, South Dakota and Wisconsin, present “exposures of concern” to sensitive mammals, birds, reptiles, land-phase amphibians and terrestrial plants which might wander into those fields.

So unless those “treatment sites” are all fenced and netted (and even if they were), I predict that sensitive mammals, birds, reptiles, land-phase amphibians and terrestrial plants will make their way into those fields of GE corn and GE soybeans and get themselves exposed to 2,4-D.

As I recall, mammals (mainly squirrels) often wandered in and out of “contained” field trials of Flavr Savr™ tomatoes two+ decades ago. GE corn and GE soybean fields could be just as inviting to mammals, birds and other animals today.

The EPA is currently considering whether to register Enlist Duo™ in ten additional states: Arkansas, Kansas, Louisiana, Minnesota, Mississippi, Missouri, Nebraska, North Dakota, Oklahoma and Tennessee. For the sake of the mammals, birds, reptiles and land-phase amphibians in those states that are sensitive to 2,4-D, I hope that registration is denied.

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EPA Expresses Concern Regarding Potential Development of 2,4-D-Resistant Weeds

I am not surprised that the U.S. Environmental Protection Agency (EPA) went ahead and registered Enlist Duo™, Dow Agrosciences’ pesticide cocktail made for spraying on corn and soybean crops genetically engineered (GE) to be tolerant of it.

Disappointed, yes. Surprised? No.

Now, it’s only a matter of time before American farmers will have an even bigger superweed problem than they already have, the current problem in large part the result of previous registration by EPA of glyphosate, the active ingredient in Roundup®, for use on the millions and millions of acres of farms where GE corn, GE soybeans and other GE crops are grown in the United States.

Even the EPA shares my concern.

As it states in its Response to Public Comments Received Regarding New Uses of Enlist DuoTM on corn and soybean:

“The Agency agrees that the registration of Enlist Duo™ for use on Enlist seed presents the potential for growers to over-rely on a single product that contains two herbicidal active ingredients. If it happens, the over-dependence can increase the selection pressure on weeds and lead to resistance.”

EPA goes on to state that “because herbicide use on herbicide-resistant crops presents this increased risk…of the likelihood of the development of resistant weeds and their associated impacts…the Agency is addressing resistance potential in this registration in an unprecedented manner.”

At one point that unprecedented manner included a requirement listed on Enlist Duo™ labels to “scout fields before and after herbicide application, which is consistent with integrated pest management (IPM) and is essential to early identification of lack of herbicide efficacy that could be an early sign of weed resistance. The critical importance of scouting is widely recognized by research and extension specialists in pest control and should be practiced when using Enlist Duo™ or other pesticides.”

However, although the “Agency firmly believes that it is a good best management practice to scout…[it] also recognizes that on-field weed resistance is best managed by the grower who understands his or her specific situation. Therefore, the requirement [emphasis added] to scout fields 7-21 days after application will not be imposed, but the labels will contain recommendations [emphasis added] for field scouting.”

In the end, the “terms of registration for Enlist Duo™ place the responsibility on the registrant [Dow Agrosciences] for reducing the potential for resistance or to significantly delay the onset of resistance.”  The “Agency is requiring that [Dow Agrosciences] have an Herbicide Resistance Management (HRM) Plan in place…[and] is also requiring the registrant to develop education and training programs that will provide growers with the best available information on herbicide resistance management…. The HRM Plan…will involve [Dow Agrosciences] working with growers to help identify early signs of weed resistance and to resolve the problem before it spreads. The HRM Plan also requires education and reporting to the Agency.”

Will putting the onus on the registrant for managing this critical issue do the trick?

History suggests not.

EPA also put the onus for managing the critical issue of keeping GE StarLink™ corn and the potential human allergen it produced out of the human food supply on the registrant of that product. That registrant’s management plan failed in a matter of months when that GE corn showed up in the human food chain in the United States. Not only that, but the wayward StarLink™ corn was detected in human food on grocery shelves only through the efforts of an NGO, not the efforts of the “responsible” registrant. StarLink™ corn remained detectable in US corn crops, at levels of concern to the US Centers for Disease Control and Prevention, for at least another seven years after EPA revoked its registration.

EPA has imposed a 6-year limit on registration of Enlist Duo™, partly to allow it to reassess the “superweed” issue. But, based on both history and biology, the increased selection pressure imposed by using Enlist Duo™ will most certainly result in significantly more 2,4-D-resistant weeds–and more glyphosate-resistant weeds than are already out there as well–and US farmers are bound to have an even bigger superweed problem by the EPA’s 2020 registration deadline.

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Hyper-propagandizing crop genetic engineering in The New Yorker?

I was very disappointed with Michael Specter’s recent piece in The New Yorker called “Seeds of Doubt: An activist’s controversial crusade against genetically modified crops.”

For one thing, Specter didn’t seem to understand the basics of crop genetic engineering (GE) itself, inaccurately describing the process multiple times in the article. For example, GE crops are not created by firing “a bacterium into seeds” (as was stated on p49 of the article). DNA isolated from various organisms (plants, animals, viruses, bacteria) is what is inserted into all GE crops, not an entire organism such as a bacterium. And that inserted (foreign) DNA is present in every cell in the resulting GE crop plant, not just its seeds or any other specific organ or tissue in that plant. We apparently have a long way to go in educating the public about this powerful technology when a staff writer covering “science” for The New Yorker doesn’t get it right.

The article also failed to mention any of the risks of genetic engineering, risks associated with (for example) what the US Food and Agriculture Agency (F.D.A.) has referred to as “unexpected” changes that can occur as a result of utilizing the techniques currently used to genetically engineer crop plants. [For more information on risks specific to genetic engineering (as opposed to traditional breeding) and examples of commercialized GE crops exhibiting “unexpected” changes or “unintended” risks see Crop Genetic Engineering is a Mutagenic Process,  Crop Genetic Engineering, Warts and All, and Science-based Regulation of GE Crops Requires More Long-Term Rat Feeding Studies of NK603 Corn.] Although I’m not formally trained as a journalist, it seems to me that mention of such technological risks, as well as documented failings like StarLink™ corn, should be made in an article casting doubt on an activist’s crusade against that technology.

Consequently, in my opinion, Specter’s piece contributes to the “hyper-propagandizing” of GE products that one of his interviewees, Dr. Deepak Pental, mentioned (p56) was a mistake made by the promoters of this new biotechnology.

I wrote a letter to The New Yorker expressing my disappointment, a drastically shortened version of which was published in the Sept. 15, 2014 issue of the magazine. My entire, original letter (containing quotes, and reference to The New Yorker pages that contain them) follows.

To: themail@newyorker.com

Unfortunately, Michael Specter only contributed to the “gulf between the truth about G.M.O.s and what people say about them” (p57) with his piece about genetically engineered (G.E.) crops and Vandana Shiva (“Seeds of Doubt” August 25th). “Genetic engineering takes the process [of breeding] one step further” (p48) is by no means enough information to enlighten anyone about how this technology works, how it differs from traditional breeding, whether it is safe, or anything else.

As a former genetic engineer who carried out safety studies submitted to the Food and Drug Administration (F.D.A.) to gain commercial approval of the world’s first G.E. whole food, the Flavr Savr™ tomato (in 1994 not 1996 as implied in the article), I know firsthand of the kinds of risks this technology presents…and so does the F.D.A. which has admitted that “unexpected” and “unintended” changes can occur in G.E. crops. [Commercialized examples of unexpected, unintended changes include one Bt corn variety (Bt176) that posed a 100 times greater risk of harming Monarch butterfly larvae than other Bt corn and another (StarLink™) that contained a Bt protein that behaved like a human allergen in multiple tests conducted in conjunction with the Environmental Protection Agency.] For the most part, long term studies to identify any such unexpected, unintended changes in G.E. crops have not been conducted but a few that have been suggest we should proceed more cautiously with this technology.

On the other hand, long term animal studies as well as human clinical trials have been carried out for G.E. insulin (mentioned in the article, p57) and all other commercially available G.E. drugs for humans in the United States. Those drugs are also labeled; patients know they are products of genetic engineering. Patients can therefore make informed decisions regarding any potential risks, risks they are likely more willing to take than a non-patient would be.

When it comes to groceries, people—healthy or not—can’t make the same informed decisions about G.E. foods, at least not in the United States; and most Americans, in poll after poll, indicate they want that opportunity. After all, it’s one thing to need a G.E. medicine, another to wear G.E. cotton, and still another to feed your G.E. yellow corn or G.E. soybean meal to your animals; it’s quite another when you are feeding yourself and your family and the foods in questions haven’t gone through rigorous, long term testing.

I agree with Mr. Specter that we will need many approaches to farming in order to “feed the world” (p57) but, to make informed decisions about the available approaches, we’ll also need more scientifically accurate and thorough descriptions of them than was provided for genetic engineering in his article. Otherwise, “Seeds of Doubt” could be classified as simply more “advertis[ing]” (p49) or “hyper-propagandizing [of] G.M. products” (p56) and that is not what I, for one, expect from The New Yorker.

Belinda Martineau, Ph.D.

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Why test GE Bananas on U.S. citizens?

According to a recent NPR article, “Somewhere in Iowa, volunteers are earning $900 apiece by providing blood samples after eating” bananas that have been genetically engineered (GE) to produce levels of pro-vitamin A some 5-6 times higher than levels in their non-engineered counterparts. Previous U.S. trials of the GE bananas, which used Mongolian gerbils instead of humans, were described as “successful” and this next test, the world’s first human test of a GE banana, is designed “to assess how successful it is in producing higher levels of vitamin A in the body.”

These GE bananas are a fresh fruit version of Golden Rice and have been created to “reduce infant mortality and blindness in children across Africa,” an admirable goal.

But why then are the human trials being conducted in the U.S.?

Will results obtained for U.S. residents with adequate vitamin A be applicable to residents of Uganda, Rwanda, Kenya, Tanzania and parts of the Democratic Republic of Congo where bananas are a staple crop and vitamin A (and other vitamin and mineral) deficiency is a major problem?

Shouldn’t these human trials be conducted in Uganda?

Better yet, wouldn’t a trial conducted with non-GE varieties of bananas like Asupina and Uht en yap, which naturally have ~20 and ~40 times as much pro-vitamin A respectively as found in the more common Cavendish variety, serve as a better proof-of-concept for solving vitamin A deficiency in East Africa? Trials in Uganda with naturally “golden” bananas could also give researchers an idea of how willing Ugandans are to eat orange-fleshed bananas. (Of course, if Ugandans were happy to eat banana varieties that are naturally higher in pro-vitamin A, it might not have been necessary to genetically engineer Cavendish or other banana varieties in the first place.)

Just what is the rationale for conducting trials of the GE bananas on U.S. soil?

Could the relatively lax regulatory environment for GE crops and foods in the United States have influenced this decision?

Legislation paving the way for commercialization of GE crops in Uganda is currently before that country’s parliament but, in the meantime, further development of GE “Golden” bananas must take place elsewhere.

And what better “elsewhere” than the (arguably?) most GMO-friendly nation on the planet?

Here in the U. S., these GE bananas require minimal regulation. They don’t produce a pesticide and so regulation by the U.S. Environmental Protection Agency (EPA) doesn’t come into play. Regulation of GE foods at the U.S. Food and Drug Administration (FDA) is on a voluntary basis so the developers of these GE bananas aren’t required to even consult with that agency either.

And while the U.S. Department of Agriculture (USDA) does consider this GE banana a “regulated” article (due to the fact that it was created using an organism on USDA’s “plant pest” list), it is being regulated by that agency using its less stringent “Notification” procedure as opposed to the usual “Permit” process.

With this “developer-friendly” system for regulating GE crops, it only makes sense that developers of GE foods from other nations will turn to the U.S. to test their prototypes, whether those foods are destined for U.S. dinner tables or not.

So, no matter what the results of the human tests of GE bananas in Iowa end up being, Americans should realize their broader ramifications. The relatively lax regulation of GE crops here in the United States encourages the rest of world to use us as guinea pigs (if not Mongolian gerbils).

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EPA Poised to Repeat Superweed Mistake

Twenty years ago scientists debated whether genetically engineering crops to be resistant to herbicides would lead to “superweeds” tolerant of those herbicides.

That debate is no longer hypothetical.

We now know, based on the rapid development of glyphosate-resistant superweeds, that genetically engineering crops to be resistant to additional herbicides will certainly lead to more superweeds. Creating next-generation herbicide-resistant crops amounts to repeating the same mistake as was made with Roundup Ready® crops…only this time around the herbicides that could be sprayed with abandon on the crops genetically engineered to be resistant to them will not be as relatively benign as Roundup® (active ingredient: glyphosate).  (And let’s all hope that glyphosate is that benign because another consequence of spraying glyphosate on vast acreages of resistant crops is that it’s showing up in human and animal urine samples.)

Nevertheless, the U.S. Environmental Protection Agency (EPA) is likely to allow that same mistake to be made again soon.

The agency is poised to register “Enlist Duo,” an herbicide cocktail containing not only glyphosate, the primary cause of our current superweed crisis, but also “2,4-D for use in controlling weeds in corn and soybeans genetically engineered (GE) to tolerate 2,4-D.”

But before EPA allows registration of Enlist Duo, it is seeking comments from the public about doing so. And the agency recently extended the deadline for submitting comments related to registering Enlist Duo until June 30, 2014.

If you’d like to join me in pointing out to the EPA that allowing the spraying of 2,4-D herbicide on U.S. crops will inevitably result in additional superweeds, weeds resistant 2,4-D, you can submit your comments on the agency’s web site. A copy of the comment I submitted to EPA follows.

[For more information on this issue please see “Going Backwards: Dow’s 2,4-D-Resistant Crops and a More Toxic Future,” a publication of the Center for Food Safety.]

May 29, 2014
Comment to the Environmental Protection Agency RE: EPA’s proposed regulatory decision to register Enlist Duo containing glyphosate and the choline salt of 2,4-D for use on corn and soybeans genetically engineered (GE) to tolerate 2,4-D (Docket ID Number: EPA-HQ-OPP-2014-0195)

To Whom It Concerns:
I am a plant molecular geneticist. I was part of the team at Calgene, Inc. that developed, obtained regulatory approval of, and marketed the first genetically engineered (GE) whole food to enter commerce. I believe that, like any powerful technology, crop genetic engineering and any pesticide use it engenders should be regulated on a case-by-case basis. I thank the EPA for this opportunity to comment on EPA-HQ-OPP-2014-0195 (Docket ID).
The cultivation of genetically engineered crops that are tolerant of the herbicide glyphosate, in combination with the use of glyphosate on multi-millions of acres of farmland in the U.S. over the last couple of decades, is a primary reason why, as EPA has stated, “Weeds are becoming increasingly resistant to glyphosate-based herbicides and are posing a problem for farmers.” Based on the requirements EPA proposes to impose on the manufacturer of Enlist Duo, EPA may already be aware that peer-reviewed scientific evidence has been accumulating since at least 2006 (http://www.bioone.org/doi/pdf/10.1614/WT-04-155R.1) indicating that weed management practices associated with crop plants genetically engineered to be resistant to/tolerant of glyphosate have led to substantial increases in plant pests that are resistant to this important herbicide. Weed scientists blame excessive reliance on glyphosate, and the strong selection pressure resulting from that reliance, for the increases in glyphosate-resistant species of Amaranthus, Commelina, Ipomoea and Cyperus (as examples) that have been documented in at least eleven U.S. states. Other peer-reviewed studies have documented biochemical and genetic processes underlying the acquisition of resistance to glyphosate (http://www.pnas.org/content/107/3/1029.full.pdf+html?sid=2ab7260b-932b-476e-b892-6d35ad6f7925). These results of the Roundup Ready crops/glyphosate “commercial experiment” indicate that plant pests can quickly evolve resistance to the herbicide a crop has been genetically engineered to tolerate.
There is no reason to doubt that the lesson learned from glyphosate-tolerant genetically engineered crops, i.e. that plant weeds can quickly evolve resistance to the herbicide a crop has been genetically engineered to tolerate, will also apply to any crop genetically engineered to tolerate being sprayed by any particular herbicide, including 2,4-D. Commercial availability of corn and soybean varieties that are tolerant of 2,4-D, in combination with EPA allowing registration of Enlist Duo, would therefore inevitably lead to excessive reliance on 2,4-D and, consequently, evolution of weeds resistant to that herbicide. If EPA allowed Enlist Duo registration, the question would not be “if resistance develops” among pest plants to 2,4-D but “when.” Therefore, EPA should not allow registration of Enlist Duo.
And while EPA states that “requirements on the manufacturer including robust monitoring and reporting to EPA, grower education and remediation” would “ensure that Enlist Duo successfully manages weed resistance problems,” similar requirements “imposed” by the agency in order to restrict genetically engineered StarLink™ corn to only animal food sources and thereby keep it out of the human food chain failed soon after that product was commercialized. Additionally, the fact that EPA’s current proposal “would allow EPA to take swift action to impose additional restrictions on the manufacturer and the use of the pesticide if resistance develops” is testimony to the agency’s lack of faith in its own ability to “ensure that Enlist Duo successfully manages weed resistance problems” as opposed to creating more of them. Therefore, based on the agency’s track record, the EPA should not allow registration of Enlist Duo.
Were “additional restrictions on the manufacturer and the use of the pesticide” swiftly imposed once it became clear that excessive reliance on glyphosate, and the strong selection pressure resulting from that reliance, was increasing glyphosate-resistant species of Amaranthus, Commelina, Ipomoea and Cyperus weeds in at least eleven U.S. states? (My understanding is that instead of adding restrictions on the use of glyphosate, EPA has increased the allowable levels of glyphosate on various crops.) Even if restrictions were imposed it appears that they were not very effective since the EPA and USDA are now considering Enlist Duo and corn and soybean plants genetically engineered to be tolerant of it as a “solution” to the problem of weeds “becoming increasingly resistant to glyphosate-based herbicides.” But rather than a “solution,” the evidence to date suggests that Enlist Duo in combination with corn and soybean plants genetically engineered to be tolerant of it will inevitably result in 2,4-D-resistant weeds and thereby pose more problems for farmers. Therefore, the EPA should not allow registration of Enlist Duo.
The excessive reliance on 2,4-D that would be encouraged by allowing registration of Enlist Duo for crops genetically engineered to be tolerant to it is also of environmental concern. Multiple peer-reviewed scientific studies have associated 2,4-D (and/or contamination in commercial formulas of same) with increased rates of soft tissue sarcomas (e.g. Hardell and Sandstrom: http://www.nature.com/bjc/journal/v39/n6/index.html) and non-Hodgkins’s lymphoma (e.g. Zahm et al.: http://journals.lww.com/epidem/toc/1990/09000). The commercial availability of corn and soybean varieties that are tolerant of 2,4-D and the inevitable excessive reliance on 2,4-D that will result will lead to significant increases of this carcinogenic compound (or formulas thereof) in the environment. Therefore, on the basis of risk of contamination of the environment, EPA should not allow registration of Enlist Duo.
In sum, 20 years ago environmental scientists and developers of genetically engineered plants could only hypothesize about the chances that cultivating herbicide-resistant crops would result in “superweeds.” But the debate is no longer hypothetical. We now know, based on the rapid development of glyphosate-resistant super weeds, that genetically engineering crops to be resistant to herbicides, and applying massive amounts of those herbicides on those GE crops, will result in superweeds. Creating 2,4-D-resistant crops amounts to repeating the same mistake as was made with Roundup Ready crops…only this time around the herbicide that could be sprayed with abandon on crops genetically engineered to be resistant to it is 2,4-D, a carcinogenic compound. We should have already learned the lesson: GE herbicide-resistant crops are not only not the way to sustainably manage weeds but a way to create more superweeds instead. Please, don’t allow the same mistake to be made again. Let’s get off this dangerous, unsustainable treadmill now. A more sustainable solution would be to encourage the use of an integrated weed management (IWM) program instead.
Thank you for your careful consideration of this matter.
Sincerely,
Belinda Martineau, Ph.D.

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