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Date:

September 18, 2000

Subject:

StarLink Maize

 

Colleagues,

This situation with StarLink maize presents the US with a
number of challenges, all of which are best met quickly and
coherently. Here are a few of them:

1. The US has not set a "threshold tolerance" or "tolerance
limit" for GM ingredients in food, as other countries have
done or propose to do. Should the US have a similar
tolerance for unapproved GM ingredients in food? After all,
we have tolerance limits for rat hair, insect parts, etc.

2. If we are not going to have a tolerance limit for
unapproved GM ingredients in food, what is the wisdom of
approving for cultivation a version of maize which cannot be
used in food? Just as in the European seed fiascoes, where
thousands of acres of various crops were destroyed because
they were grown from seed "contaminated" by unapproved GM
seed, this current fiasco was foreseeable because of
cross-pollenation, lack of rigor in identity preservation,
not sweeping the bins, etc.

3. This maize has not been approved for food use because the
Bt version used does not break down as quickly in the human
gut as other versions. This has prompted some to speculate
that the maize could trigger an allergic reaction in humans,
even though maize allergenicity in humans is so rare that
most experts consider it mythical and testing of this
version of Bt for allergenicity has been inconclusive. This
makes the alleged allergenicity what advocates of the
Precautionary Principle would call an "unknown risk." Will
the US now show itself to be a staunch advocate of the
Precautionary Principle and take action on an unknown risk?

4. If we are to become advocates of the Precautionary
Principle, such as the Europeans are, and since there now
appears to be a proven risk that non-food maize will become
mixed with food maize (more testing has yet to be done),
does that mean that we should have a Euro-style seed fiasco
and order all StarLink crops torn up, and all seed
confiscated and destroyed?

5. Because of all these things, should the food industry
turn away from the seed industry and nix all biotech crops
to prevent this sort of thing from happening to food
products? Product recalls are not cheap, and are often quite
embarassing for the company involved. In North America, the
fast-food industry killed modified potatoes, they can do the
same for maize.

6. Because of all these things, should we conclude that the
wisest heads are in the activist community? This is a
brilliant strategy: get the food industry to eschew biotech,
while forcing policy in a more precautionary direction. It
worked quite well in Europe.