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Date:

November 1, 2000

Subject:

Benbrook Responds; Communicating Risk; Starlink Corn;

 

I appreciate Leonard Gianessi's critique of the assessment I made of EPA's
Bt crop benefits assessment. It raised many valid points and offers useful
additional information. I have posted Leonard's critique on Ag BioTech
InfoNet right after my original assessment, and done a response/revision
to the basic table re corn insecticide use targeting the ECB,
incorporating Leonard's suggestions/comments. For those interested in the
details, these items are accessible at --

http://www.biotech-info.net/bt-transgenics.html#ECB

For those not wanting to take the time, the basic point made in my
assessment remains valid -- it is impossible to conclude that Bt corn has
reduced ECB insecticide use 30% without assuming that about half the acres
treated with chlorpyrifos and methyl parathion are for ECB control, which
is clearly not the case. I conclude that based on available data re target
pests triggering corn insecticide use, it is not possible to calculate
precisely the change in ECB insecticide use, but it surely has not gone
down 30% as EPA claims.

These issues will remain, and indeed grow more complex if Bt corn
varieties engineered to manage the corn rootworm are approved and planted.
I note in my response the need for corn/cotton IPM experts to help develop
better insecticide-target pest data, and would welcome any help from
readers of this list, since we will be doing the same sort of calculations
next year, and want to use the best data and soundest method possible to
track Bt crop impacts in insecticide use.

Chuck Benbrook
Charles Benbrook Ag BioTech InfoNet <http://www.biotech-info.net> Benbrook
Consulting Services CU FQPA site <http://www.ecologic-ipm.com>
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Subj: Re: AGBIOVIEW: Urban Myths about Organic Agriculture
From: Wayne Parrott

There is another aspect that must be discussed whenever manures are used
as fertilizers. Credit our soils faculty with bringing this topic to my
attention, which has come to the forefront due to the massive amounts of
manure that Georgia's poultry industry generates.

Plants have about an 8:1 requirement for nitrogen relative to phosphorus.
The N:P ratio in manure is about 2:1 or even 1:1, depending on the source.
As described above, the loss of N from manure further decreases the amount
of N relative to P. The amounts of manure applied to crops are calculated
based on the amount of N that the crop will need. This means that far more
P gets applied than necessary. Once the soil sorption capacity for P is
filled, the excess P will run off. It is the P runoff that leads to
eutrophication in fresh water, which is why phosphates were banned from
detergents a long time ago (in salt water, it is excess N that causes the
problem; estuaries suffer from both N and P). Our soils faculty are
estimating that our organic farmers are reaching the P saturation point in
as little as 3 years, at which time they become P polluters.

>From: Tony Trewavas Urban Myths about
Organic Agriculture.

>heavy metal accumulations. The use of manure results in retention of N
and other minerals in soil with only slow mineralisation. Consequently
mineral release is not synchronised with crop growth as it should be (46).
Failure of sufficient mineralisation in spring, hinders early crop canopy
production, reducing yields . Mineralisation outwith the growing season
has led to higher overall N leaching rates than conventional farms, often
exceeding EC regulations (5,25,26, 29, 43). In Holland, Germany (1) and

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From: Barry Palevitz

The following website lists all of the StarLink implicated food products
FDA has now recalled. It's nearly 300 items. Scroll down to the list.
http://www.fda.gov/bbs/topics/ENFORCE/ENF00666.html

Barry A. Palevitz, Professor, University of Georgia
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Part of the ABSP LINKAGES NEWSLETTER from: Sue Gibbons
is reproduced here
http://www.iia.msu.edu/absp/news.html

FROM THE DIRECTOR--by Dr. Catherine Ives Greetings from ABSP.

Earlier this year, I attended the Risk Communication in Food Safety
workshop held at Michigan State University. The purpose of the workshop
was to provide a forum to better understand the differences that exist
among all stakeholders in the agriculture-food-consumption chain. While
not specifically geared towards agricultural biotechnology, the goal of
building trust and promoting improved public and scientific understanding
is one that I think is important to all of us currently involved in
agricultural biotechnology. I would like to share some of the information
from this workshop with you; much of it is based on the lecture of the
featured speaker, Dr. Peter M. Sandman, an internationally renowned
consultant on risk communication.

One of the main tenets of Dr. Sandman is that risk in comprised of two
main components hazard and outrage. Risk assessments and risk management
tools are generally geared towards addressing the hazards of risk (i.e.
what is the actual impact of Bt on non-target organisms), and generally
the hazards that concern experts are generally not the hazards that upset
people. For example, we know that obesity in developed countries is a
serious problem, yet the general population is apathetic to this health
epidemic. However, the general public does respond to outrage; that is,
anything that is perceived to be of high risk. So, when hazard is high and
outrage is low, the experts are concerned and the public is apathetic (as
in the obesity example). However, when hazard is low and outrage is high,
the public will be concerned and the experts will be apathetic (as in the
use of genetically modified organisms (GMOs) to produce improved crops for
food and feed).

So what sparks outrage in the general public? It seems clear that the
public will be outraged if it feels that it has been asked to assume risks
that appear to be:

-coerced as opposed to volunteering for the risk (i.e. have GMO foods
introduced into the foods system without their knowledge, as opposed to
choosing not to wear a seatbelt), -developed through an industrial process
as opposed to a 'natural' process or product, -from an exotic land,
science, or culture as opposed to something familiar, -potential problems
if something should go wrong, -controlled by others and
-from unfamiliar sources as opposed to risk from someone they know.

It should not really come as a surprise, then, that the public is
skeptical of GMOs. Currently available foods derived from GMOs appear to
have been introduced to the marketplace with little consumer choice and
developed by faceless corporations using incomprehensible technology which
is perceived to be dangerous should things go wrong (based upon the
general public' s exposure to genetic engineering through the popular
media; i.e. Jurassic Park).

How can those of us who recognize the potential benefits of agricultural
biotechnology reduce the outrage of the general public? Frankly, it has
very little to do with providing scientific and technical information, but
rather involves certain communication strategies that build trust. These
strategies include: -staking out the middle ground, not the extreme,
-acknowledging past mistakes,
-acknowledging current problems or lack of information, -discussing
achievements with humility,
-sharing control and being accountable and -paying attention to unvoiced
concerns and underlying motives.

How can we relate these principles to agricultural biotechnology? -Accept
that biotechnology is an extremely high-outrage risk for most people.
-Notice that biotechnology affronts both the left and right in most
societies. -Take biotechnology hazard seriously
-Recognize public acceptance as the primary issue to your reputation.
-Understand individual concerns as a stand-in for global concerns.
-Support individual choice.
-Support labeling where feasible.
-Acknowledge huge fears and real risks.
-Accept that regulators and critics will have a major role. -Lean on size
and tradition of major corporations. -Operate with transparency.
-Acknowledge uncertainty.

These are actually very difficult positions to take, given that most
people involved in agricultural biotechnology feel passionate about the
benefits of the technology and will not want to admit to potential
problems. However, discussing what has outraged people is much more
effective than pointing out their misapprehensions. The public responds
more to outrage than to an actual hazard and, while activists and the
media amplify outrage, they do not create it. As communicators of
agricultural biotechnology, our job should be to try and reduce the
outrage through open dialogue with the public.

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Subj: RE: Safety testing of GM foods?
From: "Geoffrey Wollaston" To:



Dear Mr.Williamson, No. It would be quite unreasonable to expect such
positive proof and I would not trust it. I cannot imagine designing tests
which would do so. How would you do it? The final proof of the pudding is
in the eating, as it has always been with food. New GM candidates for
release for growing for human consumption are subject to stringent and
much more exhaustive official testing for toxicity than any previously
introduced varieties. i.e. those resulting from selection and
incorporating massive haphazard gene transfers. In due course the answer
to your questions will become apparent, but I know of no instance so far
where there is any record of harm being sustained by humans or animals by
the consumption of GM foods, but if I am wrong, please write and tell me.
The conceivable effects upon the UK environment of growing GM plants are
being studied by the Field Trials, (if they are not destroyed or
threatened out of existence by those who fear the results). But what is
all this fear about? I do not understand it. Why has the public been
subjected to such a weight of detractive propaganda by the media and the
Greenpeace crowd and supported by the all powerful supermarkets and Boots
the Chemists? Is it to enhance the trade in “Organic” food, the producers
and sellers of which get more money. Perhaps they are all no different
from the much denigrated “Multinationals”, who opponents of GM say are
just doing it for money and profit. Anyway, there are no valid grounds for
believing that the consumption of GM food is any more dangerous than the
perceived threat to humans of speed when Stevenson’s Rocket took its first
journey. We cannot forget the later development of power, explosives,
chemicals, medicines, antibiotics etc. few of which are found in nature,
and all of which virtually every single person happily consumes or relies
on. The potential advantages which may arise from the development by GM of
better plant varieties are too well documented to repeat, but only those
with no concern for the present and future undernourished of the World can
ignore them.

To your second question, I would reply no, it is little surprise. There is
gross and wide lack of general knowledge about science and GM in
particular. I see no connection between the “assurances” about beef when
some of it was later found to have been BSE infected, and the present
concept of the “Safety” (Your word) of GM foods. The really dubious and
unproven concept so far is that it is “Unsafe”. Yours sincerely, Geoffrey
Wollaston.

-----Original Message-----
From: Marcus Williamson [mailto:marcus@myrealbox.com]

Mr Wollaston

Could you please refer me to published, independent research reports
showing safety tests which prove that GM foods (such as soy and maize)
currently in use in the UK are safe for animals, humans and the
environment?

If such independent research data is not available, is it any wonder that
people are comparing the so-called "safety" of GM foods with the
"assurances" that we received on the safety of BSE infected beef?

Look forward to hearing from you.

Thanks & regards
Marcus Williamson Editor, "Genetically Modified Food - UK and World News"
http://www.gmfoodnews.com/
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From: Julian Morris
Subject: Launch of New Book on Precautionary Principle

The book I've edited on the 'precautionary principle' is finally out! If
you are in london please come to the launch party at waterstones gower
street next wednesday (8th) at 6 pm, details below

Julian
------------
PRESS RELEASE for "Rethinking Risk and the Precautionary Principle," ed.
Julian Morris, published by Butterworth-Heinemann, 320 pp, £15.99, ISBN 0
7506 4683 7 (Paperback)

“Precautionary Principle” would make life more dangerous, says new book
edited by Julian Morris of the IEA. The ‘precautionary principle’ is being
used to justify arbitrary restrictions on the use of certain technologies
on the grounds that these technologies might be harmful – in spite of a
lack of scientific evidence that any harm is actually likely.

The European Commission has on several occasions used precautionary
reasoning to impose bans on technologies in spite of an absence of
evidence of harm:

· In 1985 the Commission banned the use of all animal growth promotion
hormones even though its own inquiry had concluded that use of the three
natural hormones posed no risk to human health. · Last year the Commission
instituted an emergency ban on the use of phthalate plasticisers in baby
toys in spite of protestations from the head of the scientific committee
charged with analysing their impact. The committee had concluded that
following 40 years of use there was no evidence of ill effects.

The precautionary principle has become a convenient catch phrase by which
environmentalists and consumer organisations justify calls for
restrictions on the use of technologies they dislike. In so doing they
threaten to stultify technological progress and consequently perpetuate
human suffering. A good example is biotechnology or ‘genetic modification’
(GM).

· Environmental and consumer organisations campaign vigorously against the
use of GM in agriculture (Greenpeace, for example, wants a ban on GM
food). · Yet, GM plants are likely to have many benefits, including
reducing the use of fertiliser and pesticide, increasing yields, enabling
better adaptation to more extreme conditions (such as saline soil, high
temperatures, low precipitation), and reducing allergenicity. · Of course
there may be costs (such as outcrossing of certain characteristics), but
these can be (and are) dealt with by obliging producers of GM plants to
test their products before they market them. In general it seems likely
that the benefits will outweigh the costs, but without testing we will
never know.
· An outright ban on GM foods would be counterproductive. · If people are
really concerned about human health and the environment then they should
be encouraging more rapid adoption of GM technology, especially in the
developing world where yield enhancements and greater adaptive potential
would be most beneficial.
· Yet, sadly, the Cartagena Protocol on Biosafety, signed this year and
justified on ‘precautionary’ grounds, achieves the opposite by imposing
unnecessary bureaucratic hurdles in the way of trade in GMOs.

As these examples demonstrate, the precautionary principle is already
having perverse effects. If applied widely, Morris argues that this
principle would have quite the opposite effect to that intended,
subjecting us to more risk and uncertainty. By preventing us from using
newer, safer technologies, the precautionary principle would both limit
our ability to cope with the risks we already face, and make life more
uncertain, undermining our capacity to cope with risks that might arise in
the future.

Ironically, if the precautionary principle were applied to itself, it
would militate against its own application.

Rethinking Risk and the Precautionary Principle (Butterworth-Heinemann,
£15.99) comprises twelve chapters by eminent academics and policy
analysts, including Wilfred Beckerman (author of ‘Small is Stupid’), John
Adams (author of ‘Risk’), and the late Aaron Wildavsky (author of
‘Searching for Safety’).

The book is described by Professor David Henderson (formerly head of the
economics and statistics division of the OECD) as ‘a timely and important
contribution to the debate on how to manage risk in the modern world’.

The editor may be contacted on 020 7799 8921 or by email at:
jmorris@iea.org.uk

You are invited to attend the launch of ‘Rethinking Risk and the
Precautionary Principle’ at Waterstones, Gower Street, on Wednesday 8th
November at 6.00 pm (the author will give a short presentation at 6.30).

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Unbalanced caution: Governments must avoid the utopian pursuit of a
risk-free world

Opinion/Editorial Page New York Times, page A31 November 2, 2000

Better safe than sorry. This proverb is the essence of the precautionary
principle, which has become a central element of several recent
inter-national agreements, and of policies announced by the Environmental
Protection Agency and the European Union.

While there is no official definition of the pre-cautionary principle, the
one expressed in the 1992 Rio Declaration is the most commonly cited:
Where there are threats of serious or irreversible damage, lack of full
scientific certainty shall not be used as a reason for postponing
cost–effective measures to prevent envi-ronmental degradation. On the face
of it, this is a reasonable principle. Business and government share a
common goal to exercise appropriate caution to ensure that new products
and business operations do not pose unwarranted risks to public health or
the environment. Where risks to public health or the environment exist,
cost–effective steps to manage and reduce these risks should be taken.

Unfortunately, using highly speculative assertions of risk, some activists
misuse the pre-cautionary principle to justify product bans and to stop
new developments, including those that hold enormous promise for improving
human life. Despite the absence of meaningful scientific evidence, claims
of serious potential harm are made, even in the face of experience with
the safe use of targeted products. Some types of plastics, genetically
modified grains, hormone–treated meat and even routine energy projects are
opposed because they are seen as too risky. Trade protectionists also use
the principle as an excuse to ban new products that compete with
traditionally protected goods.

Misuse of the precautionary principle should be cause for concern. In
practice, advo-cates are now demanding the impossible by in-sisting on
perfect certainty of no ill effects. A responsible approach to risk
recognizes that all human activities include both benefits and risks.
Electricity, air travel, and chemotherapy all entail risks, but on balance
society recognizes that their benefits justify facing their associated
risks

(even while working to reduce these risks further).

If the precautionary principle is used to block beneficial innovations,
public welfare is damaged. An unbalanced and excessive caution can
undermine economies, jobs, human aspirations, health and the environment.
Unjustified fears can lead to counterproductive behavior (as, for example,
when consumers avoid eating fruit because of the exaggerated fear of
residual agricultural pesticides). Trade restrictions arising from the
misuse of the principle strain international relations and hurt consumers
and producers.

Enormous benefits come from scientific research, innovative technology and
new developments. That is why governments must avoid the utopian pursuit
of a risk–free world and, instead, exercise common sense in applying the
precautionary principle. Above all, we should rely on science–based risk
assessment and management, recognize the potential benefits that new
developments entail, and use the scientific tools society has to seek both
greater safety and material progress.

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Africa News Service Publication Date: Nov. 1, 2000

Nairobi, Kenya (PANA) - The use of biotechnology to boost banana
production is gradually gaining ground in Kenya's agricultural based
economy.

According to experts, biotechnology, which was little known a few years
ago, is slowly revolutionising the future of banana farming in a small
community about 75 km north of Nairobi, in the country's Central Province.
Before 1997, that farming community's experimental farm used to produce a
variety of horticultural crops for export. Then the Kenya Agricultural
Research Institute or KARI introduced a banana project as a way of
increasing crop yields.

The success was instant and the farm now epitomises the usefulness of
research in guaranteeing food security in the area and indeed most parts
of Africa, where infant mortality rates stand at 93 per 1000.

According to KARI, the research, whose theme "Biotechnology to benefit
small scale banana producers" was mooted to encourage production of the
crop in Kenya.

The area was chosen, as it remains one of the largest producers of the
fruit, coming probably second to Kisii district in South Western Kenya.
Recognising that revolutionising banana farming could help save thousands
of lives of malnourished children in the country, KARI in 1997 introduced
several varieties of bananas through a process known as "tissue culture".

"Two years later, the results were encouraging," says KARI researcher
Faith Nguthi. "Our objective was to develop a close working relationship
with the farmers and other end users to ensure the evaluation,
distribution and utilisation of tissue culture bananas by small scale
farmers. It worked".

The bananas at the farm have proved what research can do to Kenyan farms,
where average banana yields have been in the region of 10 tonnes per
hectare. Today farmers are reaping the benefits, where average yields have
shot up to between 40-50 tonnes per hectare, considered a great leap.

Scientific research has also helped eliminate previous deterrents such as
pests, inadequate rainfall, lack of agricultural and farm inputs and
marketing problems - that contributed to low yields.
KARI says it is proud of the new technology, observing that banana farming
will now greatly augment the country's efforts in attaining food self-
sufficiency.

(Copyright 2000 Panafrican News Agency.)
+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+ Subj: Scope of biotech corn
product recall revealed
From: David Hildebrand


From: "Ric Bessin" < Subject: Scope of biotech corn
product recall revealed More than 300 items on FDA list November 1, 2000

WASHINGTON-- Nearly 300 varieties of tacos, tortillas, tostadas, and chips
made with the genetically engineered corn StarLink have been recalled from
restaurants and grocery stores, according to the Food and Drug
Administration.

"We had no idea of the scope of this," said Matt Rand, a spokesman for the
Genetically Engineered Food Alert, a coalition of green groups. "This
shows how widespread the StarLink problem is."

The recalled products included those served at restaurants such as
Applebee's, Wendy's, Del Taco, Casa Solana and La Cantina, according to a
list released Wednesday as part of the FDA's weekly enforcement report.

Starlink has not been approved for human consumption. Its use in human
food products was first detected six weeks ago in Taco Bell Home Brand
tacos sold by Kraft Foods under license.

All the products recalled were made by Mission Foods, a unit of Mexican
company Gruma. Mission initiated a voluntary recall on October 13, but did
not make public all the names of the products recalled.

The list of Mission's recalled products included many grocery store
private-label brands: Best Buy, Brookshires, Kroger Co., Food Lion, Fred
Meyer, Kash-n-Karry, Rich Food, Shurfine, IGA, Albertson's Inc., Safeway
Inc., Vons, Brookshire's, Bueno Comida, Food City, Sack'n Save, and
Wal-Mart Stores Inc.

EPA considers temporary approval

StarLink corn was approved in 1998 by the Environmental Protection Agency
for use only in animal feed because of concerns about the corn causing
allergic reactions in some people.

It was created by splicing in a bacterial gene into the corn that produces
a protein that is toxic to corn borer pests, but not to people or other
mammals.

Since StarLink was detected in human food six weeks ago, the gene-spliced
variety of yellow corn has unleashed turmoil in the U.S. food industry,
triggered widespread testing, and strained relations with big corn
importers such as Japan.

EPA officials this week launched a month-long review of StarLink
scientific data to decide whether to grant temporary approval to it until
all the contaminated corn is used up. "The agency will conduct a thorough
scientific analysis of this new information and will follow a rigorous
process of scientific and public review to evaluate the allergenic
potential of StarLink corn," said Steve Johnson, a deputy assistant
administrator of EPA.

The public comment period started Tuesday. The EPA plans to have a

meeting with scientists, which will be open to the public, during the week
of November 27-December 1.

Engineered to act as pesticide
The EPA regulates StarLink because it is genetically engineered to act as
a pesticide to protect young corn plants.

The food industry and StarLink-maker Aventis SA contend that new
scientific data shows there is no health risk from the corn. Aventis is
seeking the EPA's food-use approval for the corn to avoid further recalls
and shutdowns of food processors.

"The longer that there is no decision, the more confused consumers are
likely to become. We think consumers deserve to have action as soon as
possible," said Gene Grabowski, a spokesman for the Grocery
Manufacturers of America.

But Neil Harl, an Iowa State University agricultural economist who is
advising farmers on the StarLink issue, said EPA risks harming consumer
confidence in government food regulation if it acts too quickly.

"At issue here is the reputation of regulators," Harl said. "We should be
extremely careful that we do not give the impression that regulators will
bow to industry pressure or we'll end up with something close to what
Europe has where people don't trust the regulators."