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August 16, 2002


Starving People because of 'Cocksure Ignorance'; Superweeds or hy


Today in AgBioView: August 17, 2002:

* Zambia to Refuse GM Food Aid, Says Diplomat
* Response to 'Comment on Apel vs. Snow'
* Nitrogen-fixing Gene
* Responses From Apel and Avery to Greenpeace Letter
* The Problem of "Cocksure Ignorance"
* Public Perceptions and Willingness-To-Pay A Premium For Non-GM Foods
* Conceptual Framework For Implementing Biosafety
* Risk and Man
* The Precautionary Principle: Protectionism and Environmental Extremism
by Other Means
* GM Trials Ruined By Rogue Gene Strain

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Zambia to Refuse GM Food Aid, Says Diplomat
- Aug. 16/02 (Via Agnet)

LONDON - Silumelume Mubukwanu, Zambia's High Commissioner to London, was
cited as saying Friday that Zambia will refuse to accept food aid that has
been genetically modified even though it faces an acute hunger crisis. The
story says that the U.N. World Food Programme urged Zambia this week to
decide whether to accept genetically modified maize, saying a shipment
destined for the country could otherwise be diverted.

Asked if there was any way his government would accept the GM maize,
Mubukwanu was quoted as saying, "The answer is an emphatic no on the
grounds that too much is unknown about GM foods yet. The fact that the
people are starving doesn't mean that we should allow them to eat what
they don't know. Mubukwanu said Zambia was appealing to nations like
Britain, Germany, Japan and the United States for money to buy "the
ordinary food that the people in Zambia normally eat." Zambia, Mozambique
and Zimbabwe have all expressed reservations over offers of GM grain,
despite a food shortage that threatens up to 13 million people in southern


From: "Andrew Apel" Subject: Comment on Apel vs. Snow

Mark Tepfer appropriately points out that the study conducted by Snow et.
al. on the effects of the Bt gene in sunflower hybrids had a control
sufficient to validate the experiment. And we both agree on the importance
of not only having a control, but having the right control.

Having the "right" control depends entirely on whether the "right"
question is being asked. Certainly, Snow had the right control if the
right question is, simply stated, "What are the effects of the Bt gene in
cultivar/wild sunflower hybrids?"

Is that the right question? If you look at how the press has taken Snow's
results as proof that the horror of "Superweeds" is about to descend upon
us, it looks like the wrong question was asked. The question should be:
"Do cultivar/wild hybrids enjoy any selective advantages over weeds?" and
the subsidiary question should be, "Which cultivars confer the greatest
selective advantages?" (Snow et. al. might be considered to have answered
these questions, but in such a narrow context that their results might be
considered to be more in the nature of anecdotal evidence. And those who
look hard enough for anecdotal evidence will generally find it.)

Cultivars have been developed by borrowing genes from non-native sources
using techniques such as conventional breeding or mutagenesis. These genes
will as readily pass to wild relatives as engineered genes, and all of
them will be foreign to the weed population, with any number of
possible effects. For this reason, "superweeds" may have lurked among us
Virtually since the dawn of agriculture.

By setting up the experiment the way they did, the Snow team made it
appear that genetic engineering is somehow a special case when it comes to
outcrossing from cultivars, which is not necessarily true. It happens to
be the question that remains to be answered.

The implicit bias against genetic engineering is also apparent in the case
Tepfer refers to in which Bt cotton was not authorized in areas of Florida
where wild cotton grows, in order to avoid the question of potential
impact from gene flow. If a "potential impact from gene flow" is a
justifiable concern, then all commercial cultivation of cotton should be
banned in those areas, because all cultivars could introduce foreign genes
into the wild population.

I have no doubt that Snow et. al. are competent, thorough scientists, and
no doubt that the results of their sunflower study are valid. But by
singling out an engineered trait as a special case in the design of the
experiment, the results made it look as though genetic engineering is a
special case--which it may or may not be.

Though conventional/mutated crops may be contributing to the fitness of
weeds in innumerable ways, there's no research program I know of that's
focusing on the impact on weeds of these crops. The focus is all on
engineered crops and so long as this imbalance remains, the discovery of
new anomalies among them is guaranteed. If there's no comparable focus on
the impacts of conventional crops, the anomalies will all be discovered on
the engineered side.

So to conclude: research on engineered crops is subtly biased against the
technology and is even conducted by well-meaning scientists.

P.S. I wouldn't mind hearing what Dr. Snow makes of all this.


From: "Kershen, Drew L"
Subject: Nitrogen-fixing gene

Listserv readers may recall that in early June I put out a request for
information on transgenic plants (if any) that improved the uptake of
phosphorus and nitrogen fertilizers. I received a number of very helpful
responses. Thanks to all who responded with information.

Yesterday, I read the following news item. I think it is very important
for food security, environmental protection, reduced costs for farmers,
poverty alleviation. I quote the article in full:


Nitrogen Fixation Gene Found

Martin Parniske, a geneticist at the Sainsbury Laboratory in Norwich, UK
and Gabriella Endre of the Institute of Genetics at the Hungarian Academy
of Sciences have independently discovered a gene that allows legume plants
such as peas and soybeans to breed helpful "nitrogen-fixing" bacteria.
These organisms transforms atmospheric nitrogen into nitrogen fertilizer
for the plants. Reporting their work in the journal Nature, Endre's and
Parniske's teams said they found the legumes' relatively new
nitrogen-fixing partnership, only about 160 million years old, is tied to
an enzyme somehow genetically derived from a far older phosphate symbiotic

Although nitrogen-fixing symbiosis is restricted to the few plants that
make up the legume group, the ancient phosphate symbiosis is found in
nearly every species in the plant kingdom. According to Parniske, this
suggests that relatively be genetic changes might be necessary to enable
symbiosis with nitrogen-fixing bacteria on important crop plants. Source:
AgBiotech Reporter August 2002 p. 6 http://www.bioreporter.com


Response From Andrew Apel to Greenpeace Letter

>>Greenpeace Policies Clarified
>> - Francis Joseph C. dela Cruz Campaign Team Leader. Greenpeace
>Southeast Asia
>> Letter to the Philippine Star.com
>>The recent visit to the Philippines of a US-based genetic engineering
>> Dr. Channapatna S. Prakash, has prompted us to write to you to correct
>some inaccurate
>> And misleading statements about Greenpeace made by Dr. Prakash and
>published in the
>> Philippine Star (June 23, page B-2). It is a fundamental principle of
>Greenpeace - written into its statues
>> that it retains financial independence. Therefore, we so not solicit or
>> unding from corporations, governments and political parties.
Apel: Greenpeace International has for years accepted substantial funds
from the dutch national postcode lottery. it also accepts money from
foundations which have political agendas. see

or instance http://www.brainerd.org/grant/viewitem.cfm?ID=65 AND
http://www.firedoll.org/firedoll_2001_grantawards.html AND

>>>We neither seek nor accept donations that could compromise our
independence, aims, objectives
>>and integrity. Ninety-five percent of our global income comes from
individual donations, including
>>bequests and major donors. Greenpeace has over 2.6 Million supporters who
live in over
>>100 countries throughout the North and South and share our concern about
the future of the planet.

Apel: : its integrity is completely compromised by its hunger for cash.

>>Furthermore, Greenpeace believes in transparency. Our audited financial
report is a public document and is available in printed form or on the web
site (www.greenpeace.org) The $170 Million budget that Dr. Prakash claims
we spend to oppose genetic engineering is substantially above the total
Greenpeace budget for its entire operations in 40 countries across all its
campaigns, as can be seen from our financial report. Money used to
campaign globally against the release of genetically engineered organism
into the environment is a fraction of the amount spent in the promotion of
genetically engineered (GE) crops by the industry.
>>As a not-for-profit organization, Greenpeace does not own companies,
neither does it endorse, sponsor or certify companies.

Apel: look at greenpeace annual report and you will see that they
receive licensing income from business activities. the greenpeace true
food campaign which lists food companies which have gm-free food is an
obvious endorsement of various business interests.

>>Greenpeace has however, for the increasing number of food manufacturers
who want to exclude GE ingredients from their production process,
identified those companies that have stated or certified their aim to
provide non-GE supplies. This continues to be necessary for as long as GE
crops are produced and the industry refuses to separate its crops from
conventional crops, routinely risking the pollution of the food chain with
genetic contamination. Greenpeace believes that it is the genetic
experimentation with our food and the environment that is tyrannical,
rather than any campaign advocating the consumers right to know about GE

Apel: Greenpeace has failed to identify any food risks associated with
genetic engineering. consumers have a 'right to know' about risks, they
have no right to know about risks that don't exist.

>>Dr. Prakash leads his audiences to believe that the release of GE crops
is the wave of the future. However, the reality is that consumers are
demanding the regulation of these products. At the beginning of July,
China joined the 15 countries of the European Union, Australia, Japan,
Norway, Saudi Arabia, Switzerland, and many other countries in requiring
compulsory labeling of GE food. The addition of China means that now over
two billion people worldwide 30% of the population have access to
products that are covered by GE labeling, confirming the trend that
compulsory labeling of GE food is becoming the standard international

Apel: These are not consumers making demands--these are governments intent
on erecting trade barriers and using consumers as the excuse.

>> Preserving the integrity of this planet is paramount to our
Apel: This is a sham. preserving the integrity of this planet is not
Greenpeace intention. if it were, Greenpeace would applaud the gm crops
that have already made a vast contribution by reducing the use of
pesticides and fostered a shift to a more eco-friendly herbicide.

>>We will continue to work with corporations who are willing to clean up
their productions processes in recognition of their social responsibility.
We will also continue to help governments craft environmentally sound
policies. Greenpeace has always highlighted the environmental practices
that have changed.
Apel: Greenpeace notion of working with corporations is better known as

>>Promoters and supporters of GE should respond to the substantial issues
that are being raised against the technology and its products.

Apel" They do respond to the substantial issues. greenpeace prefers to
ignore their efforts.

>> GE products have not been proven safe.
Apel: These products have been proven safe. greenpeace prefers to ignore

>> Releasing them into the environment continues to put people and the
>planet at risk of contamination that is as irreversible as genetic
>pollution can not been recalled.
Apel: Greenpeace has failed to identify these risks, though it has
imagined many. like the gonorrhea tampons.

>> The GE industry promotes its products based on unsubstantiated or false
Apel: Greenpeace is alleging criminal activity. if the industry promoted
its products based on unsubstantiated or false claims the products would
be pulled from the market and the companies prosecuted and fined.

>> that promote benefits that may never materialize, and ignores the
>possibility of adverse affects.
Apel: Greenpeace has long said that GM crops will never feed the
developing nations and that the hunger is a problem with food
distribution. now we have an opportunity to feed starving Africans with GM
crops that have much lower chemical residues and dangerous mycotoxins but
Greenpeace doesn't want us to distribute the food. the real problem here
is greenpeace, who doesn't care if people die. greenpeace doesn't like
golden rice, either. if Greenpeace doesn't care if people starve or go
blind, how can they claim to care about consumers?

GM crops have proven beneficial for the environment but Greenpeace opposes
them. how then can they claim to care about the environment?

Greenpeace doesn't care about consumers or the environment. it only cares
about money and their financial success proves it.


Response From Alex Avery to Greenpeace letter

>>>Greenpeace policies clarified By Francis Joseph C. dela Cruz
>>>.... produced and the industry refuses to separate its crops from
>>>crops, routinely risking the pollution of the food chain with genetic

Avery: Genetic contamination" is term created by the activists. Geneflow
is reality. Been happening for hundreds of millions of years. You can't
contaminate corn with corn, even if the corn has novel genes. Greenpeace
is hoodwinking the public because of the technical capability created by
scientists to find and track movement of genes. It's not new or dangerous
or worrisome in any way. Genes move between cultivars and plants - it's
nature for God's sake!

>> Greenpeace believes that it is the genetic experimentation with our
>food and the
>> environment that is tyrannical, rather than any campaign advocating the
>consumers .....
Avery: They can eat organic foods if they want, or other GMO-free foods,
but demanding that the world treat one corn different from another corn
because of the techniques used to breed/create the new, improved varieties
is absurd -- as has been pointed out by H. Miller/Conko again and again.
Corn is corn, wheat is wheat, soybeans are soybeans. Even with our awesome
technical capabilities, we can't distinguish the products (oils, starches,
sugars) from GM from non-GM because the products are exactly the same.

>>>Dr. Prakash leads his audiences to believe that the release of GE crops
is the wave of the future.
>> However, the reality is that consumers are demanding the regulation
of these products.

Avery: And getting regulation! Greenpeace doesn't want to accept the
regulations or trust the regulators. Greenpeace hasn't shown any
willingness to accept regulation--only bans.

>>> At the beginning of July, China joined the 15 countries of the European
Union, Australia, Japan,
>>>Norway, Saudi Arabia, Switzerland, and many other countries in requiring
>>>compulsory labeling of GE food. The addition of China means that now

Avery: But China isn't demanding labelling of it's own GM products, just
imports. It's protectionism, pure and simple.

>>>Preserving the integrity of this planet is paramount to our

Avery: What about farmers who are now "cleaning up their productions
processes" with the HELP of Biotech crops? Why is Greenpeace opposed to
products with some many clearly demonstrated environmental benefits?

>>>Promoters and supporters of GE should respond to the substantial issues
that are being raised ....

Avery: Name us one single "substantial issue" raised against the
technology? Improved nutrition? Lower pesticide use? Enormous fossil fuel
savings, lower soil erosion and thus sustainability? More friendly to
non-target insects and organisms? Reduced allergenicity?

>>>GE products have not been proven safe.
Avery: Yes, the ones on the market HAVE been shown to be safe -- proven
safe is an impossibility. They are AT LEAST as safe as the foods
currently on the market and much more safety tested.

>> Releasing them into the environment continues to put people and the
>planet at risk of
>> contamination that is as irreversible as genetic pollution can not been
Avery: Gene contamination is called "LIFE".

>> The GE industry promotes its products based on unsubstantiated or false
Avery: When has Greenpeace been right once on ag biotech?


From: "Andrew Apel"

The Problem of "Cocksure Ignorance"

The Moon and Balasubramanian paper is quite interesting but it overlooks
something extremely important which is beginning to emerge from other
somewhat similar surveys. In the survey below, the authors note a
difference between US and UK consumers both in their attitudes towards
biotech and the proportions of those who give dont know answers. With
respect to these factors, the authors conclude that there is relatively
less knowledge or awareness about agrobiotechnology issues on the part of
US consumers because more US consumers give dont know answers. The
authors also found UK attitudes toward biotech to be significantly more
negative. This is nothing new, actually: Activists proudly point to
surveys which conclude that the more consumers know about biotech, the
less they like it. There is good reason to reject such a conclusion.

The central and often-overlooked problem is that consumers who say they
are well-informed about biotech generally arent. Surveys which use an
objective test to determine if consumers actually ARE informed about
biotech show: a) that those who think theyre well-informed are often
misinformed and b) that believing misinformation strongly correlates with
negative attitudes toward biotech. In the vernacular, this syndrome is
known as cocksure ignorance.


Public Perceptions and Willingness-To-Pay A Premium For Non-GM Foods In
The US And UK

- Wanki Moon and Siva K. Balasubramanian, Southern Illinois University,

This study has consisted of two parts: analyses of the NPD survey data and
development of the probit model in an effort to advance our understanding
of consumer perceptions about various aspects of agrobiotechnology and
their linkages to willingness-to-pay a premium for non-GM foods in the US
and UK. Our analyses of the NPD survey data confirms substantive
divergences between the US and UK in two key respects: (1) perceptions
about the negative aspects of agrobiotechnology and (2) the extent that
consumers trust the government in securing the safety of foods, in
general, and GM foods, in particular. United Kingdom consumers exhibit
higher distrust of regulatory agencies and associate agrobiotechnology
with negative attributes more intensely than US consumers. These insights
are likely to underlie the discrepancy in the levels of public acceptance
of GM foods across the US and UK.

An additional significant finding from our survey was that a greater
portion of US consumers were withholding judgment about agrobiotechnology.
This result was evident in consumer responses to questions asking (1)
overall attitude toward agrobiotechnology, (2) perceptions about
individual attributes of agrobiotechnology, and (3) willingness-to-pay a
premium for non-GM foods. These differences may constitute an important
share of the discrepancies in public sentiments about agrobiotechnology
between the US and UK and reflect: (1) relatively less knowledge or
awareness about agrobiotechnology issues on the part of US consumers, (2)
greater ambivalence of US consumers about the attributes of
agrobiotechnology and/or (3) a stronger belief that the potential effects
of agrobiotechnology on human health or environment are intrinsically

The core of the controversy over biotech foods is the extent to which
consumers perceive benefits from agrobiotechnology relative to its risks.
The role of risk and benefit perceptions in shaping willingness-to-pay a
premium for non-GM breakfast cereals was evaluated. Overall, our analyses
indicate that risk perception exerted a stronger influence on the
willingness-to-pay for non-GM foods than did benefit perceptions in both
countries. This finding suggests that addressing negative perceptions of
agrobiotechnology (e.g., conducting scientific risk assessment, educating,
and communicating with the public about the results of such assessment
efforts) is potentially the most direct and convincing way of dealing with
consumer concerns about GM foods. In reality, such strategies may prove
ineffective in altering consumer perceptions because of the difficulties
associated with communicating highly technical scientific results to the

Although it is important for the scientific community to continue its
research to establish the safety of GM foods and to gain their long-term
acceptance, the negative and statistically significant impact of benefit
perceptions on willingness-to-pay in the UK casts hopes for altering
negative reception of GM foods in Europe: promoting/educating consumers of
the benefits of agrobiotechnology could offset negative sentiments about
GM foods, to a certain extent. The result is particularly significant in
the sense that the benefit used in this study is in the form of reduced
world food shortages and most likely represents a remote (public) benefit
to consumers in Europe and North America. Golden rice (with improved
Vitamin A, primarily beneficial to consumers in the developing world) is a
good example of offering direct benefits, while it remains to be seen what
impact it will have on the GM debate. If GM food products can present
direct and private benefits to consumers particularly in developed
countries, they may trigger a change in the consumer reception of GM
foods. In this regard, the role of the research community and
agrobiotechnology industry in bringing to the market GM products offering
direct benefits relevant to European consumers who most strongly demand
non-GM foods is of critical importance.


A Conceptual Framework For Implementing Biosafety: Linking Policy,
Capacity, And Regulation

- Morven McLean, Robert Frederick, Patricia Traynor, Joel Cohen, and John
Complete article: http://www.isb.vt.edu/news/2002/news02.aug.html#aug0202

The domestic and international consequences of the cultivation,
consumption, and trade of genetically modified plants and foods have
changed considerably over the past decade. The associated regulatory
environment has evolved as well, and new tools are needed to analyze,
support, and provide recommendations about biosafety system development.

In response to this identified need, ISNAR initiated the development of a
Conceptual Framework to guide regulatory implementation and capacity
building in developing countries. 1 The Framework was produced in
collaboration with developing country partners, donor agencies, and
capacity building providers during an expert consultation in July 2001.


From: "Gordon Couger"
Subject: Risk and Man

In my considerable observation, man is a risk seeking animal but to take
there must be reward that he see worth the risk and the risk have been
distorted until many is unwilling to take some of the lowest risks such a
vaccinations and still choose to drink and drive.

I have thrown dice for my lunch money in grade school, and made larger
bets as I grew older until I bet hundreds of thousands of dollars a year
on the weather bringing me enough timely rain and temperature to make a
crop. The greens my consider GM crops a risk to far because they don't see
the millions of tons of top soil that stay on the land and out of the
water way and the replacement of herbicides that are resistant up to two
years with one that is less toxic than table salt, inactive when it hits
the ground and degrades completely in a few weeks. These same dunderheads
think that hydrogen can cut down on pollution when it takes more power to
make the hydrogen than you can get back from it you electrolyze it or less
energy than there is in natural gas if you reform it from natural gas. And
that doesn't consider it take close to an hour to fill a tank with enough
hydrogen to drive 100 miles. I guess they then need plenty of time so shop
in the little stores popping up in the craft malls.

If apply the precautionary principle to itself it obviously not save to
use and untested method like the precautionary principle to form policy.

- Gordon Couger, http://ww.couger.com/gcouger


The Precautionary Principle: Protectionism and Environmental Extremism by
Other Means

- Gregory Conko, Director of Food Safety Policy, Competitive Enterprise
Institute http://www.cei.org/gencon/027,03079.cfm

Presented to the International Society of Regulatory Toxicology and
Pharmacology workshop on: The Precautionary Principle, June 20, 2002,
Arlington, Virginia

Every day, consumers, producers, and regulators confront questions about
risk. Even the most commonplace activities, like eating, traveling, and
working, are replete with risks. So, in both our personal and professional
capacity, we must decide how to proceed with incomplete knowledge about
the potential dangers that confront us and what level of caution is
appropriate in making those choices.

The question were trying to resolve today is: Does the precautionary
principle provide a useful tool in resolving those dilemmas? Or, more
specifically: How should regulators, acting as society' surrogate,
approach risk in the absence of certainty about the magnitude or
likelihood of potential harm?

Although caution is usually warranted, it is not in and of itself a
prescriptive concept. We do not forgo eating even though we always run the
risk of food poisoning. Nor do we avoid work because we run the risk of
occupational injuries. (Of course, being a policy wonk can sometimes seem
like avoiding work. But that's another matter.)

The point is that lots of activities pose some risk of harm, but the
choice to forgo them poses its own, greater danger. We can not escape
risk. The best we can do is try to choose in a way that is most likely to
make our lives, and our communities, safer.

I suggest that the precautionary principle is the wrong approach - that
it, in fact, exacerbates one of the major existing problems in risk
regulation. Ill also argue that it is being pursued, not to make the
world safer, but rather to advance specific political and philosophical

Let me begin by noting that there is a lot of disagreement about what
exactly the precautionary principle means and what exactly it requires
risk managers to do. Generally, though, proponents believe that
governments should prohibit or restrict technologies or behaviors when
they are suspected of posing some harm to human health or the environment,
even if the probability and magnitude of such harm has not been
demonstrated scientifically.

Members of this audience should be well aware that all sorts of new
technologies and behaviors that are laden with risk, often can be used in
a way that confers net benefits: that is, although their use poses some
new or unique potential for harm, their use also reduces or replaces
enough pre-existing risk that the users or society as a whole - are
made healthier, safer, or in some other way better off.

Risk analysis professionals constantly must ask themselves if restricting
a new technology will lower overall risk or trap society in a world that
could be made safer by adopting that technology. And, of course, this is
not an easy question to resolve, since both potential harms and benefits
are typically not well characterized at the outset.

Advocates of the precautionary principle on the other hand, just assume
that this dilemma does not exist. In their view, only potential harms are
uncertain, so we are rarely put at a disadvantage by passing up the
benefits of new technologies. Missing from precautionary calculus is an
acknowledgment that, even when technologies introduce new risks, most
confer net benefits. What I think most of us really want from public
policy, however, is not for it to focus only on the risks generated by new
technologies, but rather that it genuinely try to deliver a safer world.

Now, practitioners of the precautionary principle often argue that
regulators will carefully weigh "potential benefits and costs." They try
to make it sound as though the precautionary principle is a rational
pursuit of overall safety that has a cautionary bit of foresight built
into it that the alternative is just charging ahead with reckless
abandon. In this scenario, the precautionary principle is really just
another version of the risk versus risk analysis made famous by our
keynote speaker, John Graham.

One could make the argument that the plain language of the precautionary
principle is open to such an interpretation and a few scholars have. But
that is not how the principle is actually applied in the countries that
have formally adopted it. Nor is it how it is interpreted by its primary

In fact, if the goal of the precautionary principle really was to ensure
that regulatory decisions look at both the potential harms and the
potential benefits of a product before its put on the market, then we
wouldn't need anything more than conventional risk assessment. This whole
debate would be moot. After all, the point of risk assessment is to
anticipate plausible harms and either prevent or manage them. Andrew Apel
has done a fine job of showing why the precautionary principle is not just
a form of risk assessment, so I won't dwell on that point any further.

I do think it's important, though, to raise the matter of varying
interpretations, because the lack of specificity within the precautionary
principle gives regulators the freedom to act without an established set
of expectations.

This inherent ambiguity practically invites abuse. It can be, and has
been, used to justify trade protectionism and environmental technophobia.
Those specific goals would be rejected by most consumers if lobbied for
directly. But under the guise of defending people and the environment,
politically-motivated actors have been able to achieve their dubious
objectives by other means. Let me take each of them in turn and provide
some examples.

First, protectionism. I think its obvious that any arbitrary
decision-making process could lend itself to disguising trade
protectionism. This is not unique to the precautionary principle. But
practitioners, such as those in the European Commission, have tried to
inoculate themselves from such charges by arguing that, under their
auspices, the precautionary principle will only be used in a manner that

"proportional to the chosen level of protection;" "nondiscriminatory" and
"least trade restrictive;" and further, that decisionmakers would
carefully weigh "potential benefits and costs," and that decisions would
be "subject to review in the light of new scientific findings."

In a magazine article published in the Spring of 2000, Health Commissioner
David Byrne asked rhetorically, "How could a Commissioner - reject or
ignore wellfounded, independent scientific advice in relation to food

Let me tell you how.

Take a look at the beef hormone case. The European Commission has argued
that the precautionary principle permits the restriction on imports of
U.S. and Canadian beef from cattle treated with certain growth hormones.
But a scientific committee assembled by the World Trade Organization found
that justification invalid for a number of reasons, including:

(1) The scientific studies cited by the Commission in its own defense do
not indicate a safety problem when the hormones in question are used in
accordance with good animal husbandry practices. (2) EU health officials
have expressed no concern about endogenous hormones that occur at higher
levels in the un-castrated steers more common in Europe. And (3) The
European Union did not, at the time, ban growth hormones in the pork
industry, where many European livestock operations are internationally

Nevertheless, members of the European Commission still manage to claim
with a straight face that its restriction on hormone treated beef is not
intended to be a trade barrier.

Next, consider the EU's mandatory labeling of genetically modified foods.
The current labeling mandate covers any food or animal feed made from
GMOs, where residues of the novel gene or protein can be detected in the
final product. In practice, this means that cooking oils from genetically
modified corn, soy, or canola are therefore exempt because the heat and
friction from the crushing process tends to break apart DNA chains and
break down proteins, making it impossible to tell the difference between
GM and conventional.

This perfectly reasonable exemption upset the anti-biotech protest
industry, so a new labeling mandate has been proposed and likely will go
into effect within a year. It covers all food or animal feed produced from
a genetically modified organism well, almost all of them.

What both the existing rule and the proposed new rule do not cover is
foods or feeds that are produced "with" a genetically modified organism.
The distinction between "produced from" and "produced with" may not seem
obvious to the uninitiated, so let me explain. Specifically exempted are
products produced with the aid of genetically modified enzymes including
cheeses produced with the GM clotting agent chymosin, or beers and wines
produced with GM yeasts even though enzyme residues often can be
detected in the final product.

Naturally, one is led to wonder how important a principle precaution
really is if consumers only need to be alerted to the genetic status of
foods that come primarily from other countries. After all, if the
precautionary principle just happens to exempt foods from industries where
European producers have a competitive advantage, it doesn't seem like much
of a principle.

What is really intriguing, about the GM labeling debate, is that groups
like Greenpeace, Friends of the Earth, and others have not found anything
wrong with this double standard. But, when we look a little more closely,
we find that most environmental groups have their own quirky double
standards when it comes to precautionary regulation.

Consider pesticides. Last Friday ( June 14th ) was the 30th Anniversary of
the EPA's ban on DDT, so this example is rather timely. DDT was the
original bte noire of the environmental movement, featured prominently in
Rachel Carson's Silent Spring.

Right from the start, let me acknowledge that DDT poses risks to birds and
some fishes. But when DDT was introduced as a commercial pesticide in the
1950s, it was a considerably safer technology than the arsenic-based
pesticides that it all but replaced. After more than 60 years of testing,
DDT has never been shown to pose any real threat to human health. And in
the 28 countries around the world where DDT is still used in malaria
control, it is an essential compound, saving literally tens of thousands
of lives every year.

The same can not be said about either the copper-arsenate pesticide that
preceded DDT or the pyrethrins and synthetic pyrethroids that have
replaced it. Judged by environmentalist standards, both are hazardous to
the environment and to humans. But the environmental movement has based
its push for a global DDT ban on the precautionary principle and
strangely has argued that the existence of pyrethroid alternatives make
such a ban practical.

But, if the precautionary principle was standard operating procedure in
the 1930s when the insecticidal potency of DDT was first really
understood, or in the 1940s when DDT was an indispensable tool for the
allies during World War II, or in the 1950s when farmers began using it
commercially, we'd probably still be stuck with the old
copper-and-arsenic-based Bordeaux Mixture for pest control.

I suppose that would suit environmentalists just fine, though. Both
copper-arsenate and pyrethrin pesticides are still used to this day in the
organic agriculture that precautionary principle advocates hold as the
pinnacle of consumer and environmental safety. They remain the darlings of
the environmental movement because they are "natural" mined from the
earth in the first case, and refined from flowers in the second.

So, one has to ask, is the precautionary principle really about improving
consumer and environmental protection? Or is it about opposing technology
and preserving a lifestyle based upon some ideal of communing with nature?

I'll give just one more example: the environmental movements campaign to
rid society of chlorinated compounds, which has extended even to opposing
the chlorination of drinking water. By the late 1980s, environmental
activists were lobbying water authorities around the world, trying to
convince them that carcinogenic byproducts of chlorination made drinking
water a potential cancer risk.

The Peruvian government saw this as a great way to save money, and it
stopped chlorinating much of that country's drinking water. Greenpeace got
what it wanted, but more than 1. 3 million people contracted cholera and
at least 11,000 died in one of Latin America's biggest cholera epidemics
all to save a handful of purely speculative cancer cases.

This highlights, better than most other examples, how ridiculous in
fact, how dangerous it is to get caught up in the kind of tunnel vision
that Supreme Court Justice Stephen Bryer once called "the last 10 percent
problem" that is, pursuing ever smaller risks to the point that we
distract consumers and policy-makers from larger and proven threats,
divert limited public health resources from genuine and far greater risks,
and ignore the fact that new regulations and restrictions could actually
make us less safe.

Now, lest I seem to be singling out Europeans, let me note that lots of
people have observed that many U.S. laws are also precautionary in nature,
and subject to the same criticisms. This is largely true, with a caveat.

Rules in the United States requiring pre-market approval of things like
new pharmaceuticals, pesticides, food additives, bioengineered crop
plants, industrial chemicals, and many others, do put the burden of
demonstrating safety on the producers of new technologies.

Furthermore, they almost invariably weigh the potential risks of new
products much more heavily than they do the risks of forgoing those new
products. There tends to be an institutional bias in regulatory agencies
that predisposes decision-makers to avoid approving products that could
later be more harmful than beneficial, and to play down the human cost of
keeping products off the market. This problem too needs to be addressed if
we truly want to maximize safety.

But, the precautionary principle takes this inadvertent bias and formally
institutionalizes it. Perhaps more importantly, unlike U.S. rules that are
precautionary in nature, there exists no formal mechanism within the
precautionary principle for preventing or rectifying arbitrary decisions.

In the United States, the extremes of our precautionary outlook are
tempered by two things: (1) Many of the underlying statutes actually
require benefits to be taken into consideration when setting policy, and
(2) There is a well-defined body of administrative law that provides for
judicial review of regulatory decisions that are alleged to be arbitrary
and capricious.

Although they aren't perfect, the effect of these safeguards is to reign
in much of the political abuse that is characteristic of the precautionary
principle. If we genuinely care about making our world safer, we must
require regulators to consider both the risks of rushing headlong into the
future and the risks of staying too long in the past. Until advocates of
the precautionary principle can:

Agree upon a single definition that prevents arbitrary application,
provides for legal redress of mistaken decisions, and is equally cautious
about the potential risk of over-regulation, we have to reject it.


GM Trials Ruined By Rogue Gene Strain

- Paul Brown, environment correspondent, The Guardian, ugust 16, 2002
(Forwarded by Dennis R Keeney" )

Seed sown in GM trials over the past three years has been contaminated
with controversial antibiotic genes which went undetected by government

Embarrassed officials admitted yesterday that there had been a "serious
breach" of regulations and that the seed company, Aventis, was under
investigation and could be prosecuted if found to have broken licence
conditions. Although company executives could face up to five years in
jail and unlimited fines, the government none the less has a PR disaster
on its hands.

The joint statement by the Scottish Executive and the Department for
Environment, Food and Rural Affairs admitted there had been a complete
failure of its regulatory system which failed to detect the contaminated
seed despite many "paper" inspections, meaning it had simply accepted
Aventis's word.

The government said yesterday it was investigating its own failures and
may overhaul the entire regulatory system. It said the entire crop, which
is about to be harvested, would be destroyed, and that there was no danger
to public health even though the 2.6% of rogue genes found were

Critics have repeatedly called for antibiotic genes to be phased out amid
evidence that GM plants and weeds of the same species readily swap genes.
This is a particular problem with oilseed rape, which has relatives
growing wild in hedgerows. Antibiotic genes are controversial because of
the danger of gene transfer to bacteria in animals and humans, who could
then develop immunity to common life-saving antibiotics. The government
said Aventis, not its own inspectors, had found the contamination and had
notified authorities. It is unclear whether the contamination occurred
from accidental mixing of two types of seeds or cross-fertilisation of two
different GM crops.

A Scottish Executive spokesman said: "Aventis has been given very strong
advice to make sure this doesn't happen again. And we have called on the
GM inspectorate to investigate and see if legal action should be taken
against the firm. "This is a very serious breach of regulations which
shows there could be problems with how Aventis puts together rape seed for
GM trials." No one at Aventis was available for comment yesterday. The
contaminated fields are in Aberdeenshire, Gloucestershire, Oxfordshire,
Yorkshire, Lincolnshire, Wiltshire, Warwickshire, and Worcestershire.

The seeds were also sown at three trial sites in England in 1999, and at
six in 2000. The find comes days after the government launched a "public
debate" on the future of GM crops in Britain as the three-year crop trials
draw to a close. The tests aimed to assess the impact of GM crops on the

The fact that contaminated seeds have grown undetected throughout the
trial will be hard for Margaret Beckett, the environment secretary, to
explain away as she tours the country this autumn. It also begs the
question whether the last batch of oilseed rape due to be planted this
autumn to end the trials is also suspect. Aventis has been asked to
reassure the government before planting. Friends of the Earth called
yesterday for an immediate halt to the outdoor testing of GM crops. It
said that before planting, the government must carry out a full
investigation and ensure there is no repetition, guarantee that winter
oilseed rape seed is not contaminated, and publish results.

Friends of the Earth's Adrian Bebb said: "This is yet another biotech
blunder from the GM industry. How can we trust them to produce our food if
they cannot even run a GM test site? It is clear Aventis are incompetent
and should not be allowed to experiment with our countryside or our food
anymore. It beggars belief that the government's own inspectorate visited
Aventis in April but did not uncover this contamination." Contrary to
government comments, antibiotic-resistant genes can provide immunity to
the important antibiotic gentamicin, which is used to treat
life-threatening illnesses such as meningitis, he added.