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 GEO's 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 who 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 GEO's 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 biotechnology-driven revolution in farming systems. Many people will be surprised to learn how the 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 unhappy 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. 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 labelled 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.

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 favourite 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."

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 sceptical 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 that no one is paying attention to the pros and cons of the "biotech revolution" makes people nervous. Consumers have already heard enough contradictory information to approach too-good-to-be-true news about agricultural applications of biotech with a healthy dose of scepticism. For this reason, emerging applications, regardless of 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 GEO's. 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(1).

Key definitions

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 fibre 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 fibre 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.

Evaluation criteria
Applications of biotechnology need to 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 sceptics among us might call them "Barely educated guesses, bordering on foolish predictions." Some of the major evaluation criteria follow.

1. 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?
   

2. 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?

3. 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?

4. 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.

5. 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 might happen as a result? Will it be possible to detect such migration, and if it occurs, reverse it or deal with it in some other way? If nature takes its course, where might we end up?

6. 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?

7. 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?

8. Ability to Meet Global Food and Fibre 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?

9. 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?

10. 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?

11. 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?

12. 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?

Opposition to herbicide tolerant varieties is based on judgments 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 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 (2).

  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 defences 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 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.

• Ecological consequences are well understood, especially on whole organisms and ecosystem functions and interactions. GEO's 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.

  In order to reach this last judgment, 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.

  Consumers Union has recently filed 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(3). The application is proposed by a team of scientists led by Dr. Jim Cook of Washington State University, and covers a strain of Pseudamonas flourescens 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 led 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 chaff 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.

  Reference:
  Consumers Union (1996); Pest Management at the Crossroads, Consumers Union, USA

  Notes:
  

  1. 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.

  2. 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 http://www.pmac.net/geherb.htm, and the section on deformed frogs, http://www.pmac.net/frogs.htm.

  3. See the "Genetic Engineering" section of the PMAC web site for a copy.

     Acknowledgments
     This paper was first given at Sharing the Lessons of Organic Farming Conference, at the University of Guelph, Guelph, Ontario, Canada on 31st January 1998.

     ---

     
     Last Updated on 6/2/98
     By Karen Lutz
     Email: karen@hillnet.com