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Date:

November 10, 2000

Subject:

EPA Hearing on Starlink - Human Approval; Starlink Summit;

 

Dear Friends:

As you may know, the U. S. Environmental Protection Agency (EPA) is
accepting public comments to help them determine whether Aventis' Starlink
corn should be granted temporary approval for use in human food. Aventis
recently submitted a Supplemental Safety Assessment requesting a time
limited clearance that would cover any StarLink corn grown in 1999 and
2000.

THE DEADLINE FOR SUBMITTING COMMENTS IS NOVEMBER 27.

As a result, it is vitally important that you take a few minutes to let
your voice be heard on this important issue. Opponents of Aventis'
recommendation, lead by members of Greenpeace USA, have mobilized a
massive letter writing campaign that has flooded the EPA with opinions in
direct opposition to the Supplemental Safety Assessment.

ACTION NEEDED:

There will be a 1-day meeting sponsored by the EPA to review the request
for a time limited exemption from tolerance for StarLink on NOVEMBER 28
from 8:30 a.m. to 5:00 p.m in Arlington, VA. We urge you to attend this
meeting and voice your support for the limited exemption to allow StarLink
into human food.

For more information on the November 28 EPA meeting, click here:

http://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?dbname=2000_register&docid=fr07no00-74


Aventis' Updated Safety Assessment:
http://www.epa.gov/pesticides/biopesticides/otherdocs/starLink-10-25-00.pdf

Sample Letter:

Carol Browner, Administrator
Public Information and Records Integrity Branch (PIRIB) Information
Resources and Services Division (7502C) Environmental Protection Agency
1200 Pennsylvania Ave NW Washington, DC 20460

RE: DOCKET # PF-867B

Dear Ms. Browner,

I am writing in support of the Supplemental Safety Assessment submitted
by Aventis.

In this submission, Aventis has requested a time limited clearance for
the StarLink Corn in the food chain. This clearance would cover any
StarLink corn grown in 1999 and 2000. Also, since Aventis has pulled the
license for StarLink, there will be no production of this corn in 2001.

The data in the Supplemental Safety Assessment reinforces the conclusion
that the CRY9C protein in starlink corn is not an allergen and is not
likely to lead to an allergic reaction. The allergens that cause an
allergic reaction have certain characteristics in common. The CRY9C
protein does not have these characteristics. CRY9C protein represents an
extremely small amount, only 0.013 percent of the total protein in grain
from starlink corn. In contrast, the typical food allergens on average
represent between 1 and 40 percent of the total protein in the raw food or
grain Experts tell us that multiple exposure by repeated consumption of
the food, must occur before a person will exhibit an allergic reaction.
According to the best data, CRY9C is or may be present at levels thousands
of times smaller than that required to sensitize individuals and lead to
allergic reactions. . The submission also notes that even working on
the hypothetical assumption, that CRY9C protein is a potential allergen,
the quantity of CRY9C protein that might be found in food is so small that
the safety of the food supply is assured.

It is important to highlight the new information that has been provided
in the Supplemental Safety Assessment.The new digestibility study presents
more information on the breakdown of the CRY9C protein in the human
stomach. EPA's initial position was based on an earlier study that
suggested that CRY9C protein was slow to digest. The earlier study was
flawed due to the fact that it looked at data from a single acidity level
that was not representative of human stomach condition. The new
digestibility study was conducted over a wider-range of conditions, which
are more typical of our digestive process. This study clearly demonstrates
that CRY9C protein is digested over the range of conditions and time
frames normally found in the human stomach system.

In addition, new risk information has been provided in the Aventis
submission. This independent risk assessment compares the CRY9C protein to
the allergic proteins in peanuts, the most potent known food allergen.
Peanut allergy is both quite common and causes severe allergic reactions.
Peanut is used in the Aventis risk assessment as a hypothetical most
conservative basis for comparison. According to this data CRY9C-even if
assumed to be as allergic as the allergic proteins in peanuts-is not
present in foods at levels that would lead to an allergic reaction.

In light of the combined weight of the data provided in the Supplemental
Safety Assessment, I urge you to grant a time limited exemption from
tolerance for StarLink corn.

Sincerely,

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Subj: Starlink Summit Announcement
From:Alex Avery

STARLINK SUMMIT

HOLD THIS DATE DECEMBER 6, 2000

The Center for Global Food Issues and the Gruma Corporation are pleased to
invite you to attend the STARLINK SUMMIT on December 6, 2000 at the
GeorgetownUniversity Conference Center, Washington, DC. There will be a
welcome reception, dinner and remarks on the evening of Tuesday, December
the 5th.

The STARLINK SUMMIT will bring together all sides of the debate on the
genetically modified corn issue, as well as policy and scientific experts
and government officials. Groups invited to participate include: Azteca
Milling, Environmental Protection Agency, Food and Drug Administration,
Friends of the Earth, Grocery Manufacturers' Association, Tuskegee
University, Greenpeace, American Farm Bureau Federation, Guest Choice
Network, and Georgetown University's Food and Nutrition Center.

If you would like to attend, participate on a panel, or suggest experts in
the fields of biotechnology, food manufacturing, food safety,
international trade, or other related fields, please contact the
conference's director, Dave Juday at (202) 251-6320 or by e-mail at:
juday@earthlink.com or the conference's coordinator, Alice Killian at
(540) 337-6354 or by e-mail at: cgfi@rica.net Space at the Georgetown
Conference is very limited. Call now to assure a seat at the debate table.
I look forward to seeing you on December 6th. More information on the
program will follow.

Sincerely, Dennis Avery, Director, Center for Global Food Issues Post
Office Box 202 Churchville, VA 24421 (540) 337-6354 fax (540) 337-8593
e-mail: cgfi@rica.net www.cgfi.org
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From: Barry Palevitz Subject: Re:
AGBIOVIEW: Horizontal gene transfer and NZ Royal Commission

Great response on horizontal gene flow. You might consider adding the
following: As I recall, it's estimated that up to 80% of mutations in
Drosophila are caused by TEs. That's a terrific factor in evolution. Of
the 3 billion base pairs in the human genome, only 2% represent structural
genes. The rest is repetitive DNA, much of which consists of TEs and their
remnants. Humans have nearly 1 million Alu elements, just one family of
TE, some of which are responsible for diseases by inserting into genes.
Explosion of Alu elements, and the resulting genetic diversity they
produced, may have fueled evolution of the primates 30 million years ago.
A recent paper in the June 6 issue of Proc. Nat. Acad. of Sci. (Kalendar
et al., 97:6603) documents increased copy number of a class of TE called
BARE-1 in wild barely correlated with local microclimate. In other words,
retrotransposon activation could play a role in adaptation to water
stress. Recent activity of transposable elements in the grass family may
have fueled its diversification and primed the ability of humans to
selectively breed members of the family, resulting in today's grains
(wheat, barley, maize, rye, etc.)

Barry A. Palevitz, Professor Coordinator of Advising in Biology
Contributing Editor, The Scientist Department of Botany University of
Georgia Athens, GA 30602-7271
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From: Roger Morton
Subject: Horizontal gene transfer

I wanted to clear up some confusion that I have had recently and that some
others on the list may also have had with respect to a recent paper by
Michael Gasson on "Gene transfer from genetically modified food" (Gasson,
2000). In his commentary, Gasson introduces two references with the
sentence "Other studies of horizontal gene transfer of DNA from plants to
microorganisms have been reported by Broer et al (1994) and Hoffman et al
(1994)."

This sentence implied to me that both these papers found gene transfer.
However, as I have just found out, the Broer et al paper actually found no
evidence of gene transfer. Broer et al tried to find transfer from
transgenic plants to Agrobacterium. They thought this might work because
homologous DNA of the T-DNA borders in the transgenic plant may provide an
opportunity for homologous recombination with the T-DNA borders of wild
type Agrobacterium. In their experiments the transgenic plants had
Gentamycin R for bacteria (aacI gene), 35S-luciferase (luc) and NOS-nptII.
They added WT A281 Agrobacterium to transgenic plants, plant DNA or plant
homoginate. Transformation freq of the Agrobacterium with plasmid DNA was
2 x 10^-7 [GentR luc(+) bacteria were considered transformants]. However,
no transformants were obtained from the Agrobacterium when incubated with
plant DNA or plant tissue. Some Gent R bacteria were obtained but they
were not luc+ and did not have the aacI gene. Thus they were spontaneously
R to Gentamycin.

The paper concludes [in Denglish {Deutch-English} ] :-) :

"At least in the case of Agrobacterium-plant interactions the frequency of
DNA transfer to the bacterium is below 6 X 10^-12. Hence, supposed this
mechanism is actually working, it should not play an essential role in the
distribution of foreign genes into the environment, although this
bacteria-plant interaction seems to represent optimal conditions for an
event, that has not been observed up to now."

I translate the Denglish to: "Even if mechanism occurs in nature it would
not play a significant role in the distribution of foreign genes into the
environment. We have not observed a plant to bacteria transformation event
even though the conditions of this experiment would appear to be optimal
for such an event to occur."

So just be wary of people trying to use this paper as evidence for
horizontal gene transfer - the title of the paper is misleading.

With regards to the second paper referenced by Gasson (Hoffman et al
1994): In an in vitro experiment the authors selected Aspergillus niger on
hygromycin after incubating in presence of non-transgenic and transgenic
plants. Got between 4 and 36 times more hyg R Aspergillus from fungus
incubated with transgenic plants. Out of 200 hyg R fungi analyzed in 10 of
them the hph gene was detectable "at the DNA level" - presumable by PCR
but this is not clear. In one case the hyg R was maintained. In the other
cases it was lost by the time the DNA was assayed by southern. The single
case where the resistance was maintained came from incubation with plants
transformed by particle bombardment using a pUC based plasmid. The authors
conclude: "In our experiments we were able to provide evidence for gene
transfer from plants to A.niger via soil. However, the efficiency, the
occurrence in natural habitats, and the mechanism of such transfer remains
unclear."

Refs:
Gasson MJ (2000) Gene transfer from genetically modified food. Curr Opin
Biotechnol 11:505-508
Hoffmann T, Golz C, Schieder O (1994) Foreign DNA sequences are received
by a wild-type strain of Aspergillus niger after co-culture with
transgenic higher plants. Curr Genet 27:70-76
Broer I, Droge-Laser W, Pretorius-Guth L-M, Puhler A (1994) Horizontal
gene transfer from transgenic plants to associated soil bacteria.

--
Dr Roger Morton 02 6246 5069 (ph) (int: +61 2 62465069) CSIRO Plant
Industry 02 6246 5000 (fax) (int: +61 2 62465000) GPO Box 1600
roger.morton@pi.csiro.au CANBERRA ACT 2601
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From: Karen Edwards

The Alliance for Better Foods released the survey in conjunction with
World Food Day that showed a majority of American consumers support the
use of biotechnology to help reduce world hunger. Full summary of the
Alliance for Better Foods survey: http://www.betterfoods.org/fft_10_00.htm

In a Reuters/Zogby poll released on November 3 gauging American consumer
reaction to recent food recall linked to StarLink* corn, a little more
than half of the respondents expressed concern that the recent recall of
yellow corn products raises questions about the food supply. One third of
respondents said that farmers should not be able to plant biotech crops at
all - alarming statistics for the biotech industry.

However, a recent survey from the Grocery Manufacturers of America shows
that a majority of Americans are increasingly aware of agricultural
biotechnology and the product recall, but have not changed their food
consumption. In fact, about two-thirds of respondents expressed little or
no concern about the safety of their food. Instead, consumers reserve
their concern for whether or not food is fresh, or if it is handled in the
appropriate manner. Thomas Hoban, Ph.D., Professor of Sociology and Food
Science at North Carolina State University, who designed and analyzed the
survey, stated, "Biotechnology is simply not an issue for the vast
majority of U.S. consumers."

Full summary of the GMA survey:
http://www.gmabrands.com/news/docs/NewsRelease.cfm?DocID=645&
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From: Geoffrey Wollaston [mailto:geoffrey@greenwave.co.uk]
To: marcus@myrealbox.com
Subject: RE: Safety testing of GM foods?

Mr.Marcus Williamson. Not me, but if it worries you, I shoulnd't buy them?
So far as I am concerned they contain a certain variety of maize which has
not been shown to be unsafe to eat. If I were in the US, I would happily
eat the Tortillas described. Why not here? But if the supermarkets
concerned are falsely claiming that these products are GM free, then they
are of course in breach at least of The Trade Descriptions Acts, and
presumably the Labelling Regulations. They have only themselves to blame
for opting for this unreasoned caution by allying themselves with the anti
GM movement. Their reason..Money..just like everybody else who does
something positive, such as Monsanto, or anybody who works for a living.
After this, you will realise that I despise those who spend their time not
usefully, but by disparaging the efforts of those who are devoting their
working lives to trying to improve plants by genetic technology. It is
grossly unjust and irresponsible that the work of dedicated researchers
should be rubbished by specious negative propaganda spread amongst an
uncritical public largely untutored in science with the object of
destroying demand for the products . This is nothing less than unfair
competition. I am sorry, but we seem to be a long way apart! regards,
Geoffrey Wollaston.

-----Original Message-----
>From: marcus@myrealbox.com [mailto:marcus@myrealbox.com] >Mr Wollaston
>The latest news (see below) shows that the UK food supply has been
contaminated with unapproved GM >maize. Does this not worry you? >regards
Marcus Williamson
----------

From: "Geoffrey Wollaston"
Subject: RE: GM Maize

Mr Williamson. Thanks for your observations, but I do not understand your
elemental fear of GM. You paint a picture of a world about to be overrun
by selfish companies who think only of their profits and which you are
trying to save from their grips by turning everybody into hypochondriacs
by alarming them into the belief that GM foods are unsafe. My point of
view is that you are doing your best to cheat the world of the huge
benefits likely to arise from GM. But why are you doing it? Is it real
concern for people or to fan the demand and price for "organic" produce by
subduing that for ordinarily produced food? However, you do reveal how
devoid of real substance your arguments are, when you are forced to
bracket together inventions with such extremely diverse applications as
Agent Orange, Aspartame, and GM foods, to imply that they are all the
equally poisonous result of the activities of one company interested
solely in making money. It is such a warped and hurtful view of what I
know to be the motivation of those engaged in GM research ,that there is
little more I can say, other than to remind you that a company which is
engaged in any activity consists of people like you and me, who have every
right to use their intelligence and application for purposes they believe
and know to be good, and to earn themselves and the company money for
their work. What would life have been like had man been unable to work
cooperatively in teams and then companies, and what is so unacceptable
about working for money anyway. People who do not are very unusual. Yes we
are a long way apart, and whilst you may be winning many naive minds to
your view, I think it is grossly dishonest to behave as if the world is
and always will be amply nourished by turning back the clock to medieval
farming methods, and that GM has no place because it may carry unspecified
and undiscovered risks. However, I am confident that with increasing
education, its merits will in due course be widely accepted, even if its
progress may have been unfairly delayed in the meantime. regards, Geoffrey
Wollaston.

-----Original Message-----
From: marcus@myrealbox.com [mailto:marcus@myrealbox.com]To: Geoffrey
Wollaston Subject: Re: GM Maize

>Mr Wollaston
>Monsanto, something positive? This is the company which brought to the
>world Agent Orange, Aspartame, RoundUp and now genetically modified
>foods, whose only purpose is to make Monsanto more money... Where is
> the science in all of this? There have *never* been any independent
> safety tests of the GM soya and GM maize currently on the market.
> Why not? Myself and others are trying to save the world from being
> overrun by these companies who think only of themselves and of money.
> See below one example of my efforts in ridding the UK of these
> untested foods. regards Marcus Williamson http://www.gmfoodnews.com/
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Subj: Re: Manure
From: Wayne Parrott

>From: "Gordon Couger" Subject: Re: more on
>manure use.;Wayne Parrott's recent post on P indicates a continued
> interest in manure use. (And a continued >misperception about who is

>If you have a N P ratio problem just add manure to the level of P
>needed and make up the N with nitrogen.

My comments were in the context of organic farming, not of traditional
farming. Adding N fertilizer to make up the difference is what is
recommended in non-organic operations. The problem becomes finding
suitable sources of organic N, so the farm can stay organic.

>The solution to the N P ratio problem and to the odor problem of
> livestock >operations is to find some way to quickly tie up the
> nitrogen in the >manure treatment system so it doesn't escape to the
> air or leach into the >ground but can be applied in a way crops can
> use it or be used in some >other way.

The NP ratio is off by the time the manure comes out of the animal. N loss
from manure simply exacerbates the problem.

>That is a lot easier said than done. The only way I know to store
> nitrogen >is to get it in a plant and get it in a state microbes
> won't grow. You can >dry it, ensile it, pickle it, salt it, make it
> in to jam or sterilize it >and keep it that way. None of those easy
> to do to the manure from 10,000 >head of cattle every day.

You forgot another solution-- feed it back to the cows. Not a pleasant
thought, but one that is done anyway.

>Gordon Gordon Couger gcouger@couger.com

Wayne Parrott Dept. Crop & Soil Sciences University of Georgia Athens, GA
30602-7272

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From: Meredith Lloyd Evans - BioBridge
To:
Subject: GM animal feeds

I see from your web-site that you are promoting a negative and fear-laden
attitude to the use of GM materials in animal feeds. Your stance on this
is misleading, detrimental to the health and well-being of consumers,
negative for the wider environment and certainly economically detrimental
to countries that do not share your point-of-view. As far as 'red-listing'
the use of GM material in animal feeds is concerned, there is no
scientific reason or even moral rightness in doing this. Commonsense says
that the DNA of a food does not affect the DNA or the well-being of an
animal or person consuming it. Or we would have the logic that all
plant-eating animals should be regarded as vegetarian when they enter the
human food chain. Your ecoimperialist attitudes are therefore not only
scientifically incorrect and deceitful, but are not socioeconomically or
morally right. Sincerely Mr Meredith Lloyd-Evans,
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Italian schools must introduce organic food: minister

Agence France Presse ROME, Nov 8

Italian schools are to only serve organic food once a project dear to
Italian Agriculture Minister Alfonso Pecoraro Scanio and municipal
authorities has been adopted.

"Throughout Italy we need school restaurants serving organic food, " the
minister said Wednesday in a reaction to the latest consumer panic over
"madcow" disease but also concern about genetically-modified foodstuffs.
He said he was also working to impose a reduction of pesticides over a
three-year period, but added: "I don't know if we will succeed."

Italy is growing organic foodstuffs on one million hectares (2.5 million
acres), the largest area in any European country, according to Pecoraro
Scanio. He said the decision to favor organic food was designed to keep
tainted food off store shelves and genetically-modified foodstuffs from
school meals.

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BOGUS BATTLE AGAINST BIOTECHNOLOGY LESSON IN 21ST CENTURY CONFLICT (From
Agnet) November 10, 2000 www.meatingplace.com Dan Murphy

(Editor's note: This is one of a series of weekly commentaries written by
Dan Murphy, MMT Editor, appearing each Friday right here on The
Meatingplace.com. And following this column don't miss the special "bonus"
coverage of the election controversy ongoing in Florida this week.)

Let me say right upfront I'm a big believer in the potential of
biotechnology. Of course, I don't pretend that there aren't serious issues
that need to be resolved from a scientific as well as a political
standpoint before any significant progress can be made in terms of
developing greater productivity in our agricultural sector -- which is the
aspect of genetic engineering I care about.

But some simple math, and I don't mean the fuzzy kind, shows that we will
have a tremendous increase in the numbers of people to feed and clothe in
just the next couple decades -- a tripling in less than 50 years, if you
believe the most dire predictions. That is going to require far greater
efficiencies in both plant and animal production, as well as heightened
delivery of nutritional components in our food supply if we are to
adequately nourish the added billions of people who will soon occupy Plant
Earth. Okay, I'm starting to sound like one of those think tank
proclamations that precede the announcement of some initiative to
cultivate plankton underneath the polar ice cap, or an equally ridiculous
scheme. Biotechnology, and the opposition is it facing, is anything but
ridiculous. I am concerned, however, that its full implementation may be
derailed for reasons that have nothing to do with its efficacy.

Part of the problem has been that the food industry has hurt its own cause
in regard to consumers' acceptance of biotechnology. Monsanto's arrogance
in trying to shove genetically modified soybeans down the European Union's
throat several years ago has been well-documented. Since then, the media
has had a virtual field day covering a series of missteps, from labeling
of milk from cows given bovine growth hormone to a dead-end debate over
potential allergenicity from eating GMO foods to the most recent flap this
September over genetically engineered feed corn discovered in taco shells
sold at Safeway and Taco Bell.

Although, if you're eating regular meals at Taco Bell, is GMO corn really
your biggest concern? Along with industry screw-ups, the other overriding
factor driving the polarization of both consumer and political attitudes
toward biotechnology is media coverage. On the issue of Starlink, the GMO
corn that found its way into taco shells, Business Week quoted Charles
Margulis, the outspoken activist who specializes in genetic-engineering
issues at Greenpeace as saying, "Consumers are outraged." They are? I took
an informal poll of more than two dozen people on the subject, and not one
volunteered any outrage -- or any knowledge of the matter, either.

But biotechnology as an issue, not as a technology, offers the ongoing
controversy the media loves to cover. It's made to order for our modern
era. They have the pros and cons, the stark predictions of sci-fi disaster
that activists are so clever at creating, and the spectacle of scientists
and government squared off against "the people." I think we all saw how
much mileage Al Gore milked out of his "fighting for the people" rhetoric.
A sophisticated as our communications technology may be, there is nothing
better than an old-fashioned "them against us" battle to jack up ratings.
And keep in mind that the average consumer has a tough time distinguishing
between real food-related concerns, such as microbial contamination, and
the manufactured hysteria typical of the propaganda surrounding
biotechnology. For most people, it's simply common sense to express some
reservations about the use of techniques such as cloning and genetic
modification, about which they understand very little.

About the only thing the media don't have going for them in ratcheting up
coverage of biotechnology in the months and years ahead is a recognizable
spokesperson who can lend the force of personality to the debate --
somebody like the Rev. Jesse Jackson proclaiming that "minority peoples"
are being left out of the biotechnology debate.

Don't worry. Eventually, it'll happen. Right now, most industry executives
I've talked with take a pretty hard-line stance against the
anti-biotechnology activists. Who can blame them? The "biotech is bad"
position is based not on thoughtful, rational deliberation but on a
visceral loathing of all things corporate and technological. Basically,
the people who hate biotechnology are opposed to big companies and modern
science. Great. Where the heck do you go with that discussion? Where it
will eventually, lead, I hope, is along the same path that the food
industry's relationship with the environmental movement has gone in the
last 25 years. Think back to the '70s (that shouldn't be too hard. Half
the FM radio stations in this country are MIRED in that decade). Back
then, environmentalists were regarded pretty much in the same category as
plague and pestilence. In other words, bad news. But as time went on, the
more progressive leaders in both food production and agriculture realized
that much of the environmental agenda could be effectively neutralized by
political activism on the part of industry, the same way any business
needs to continually outflank its competition.

Most recently, we've seen the beginning of a rapprochement (that's French
for "maybe we shouldn't spend all of our time killing each other") between
industry and environmentalists. In fact, with the advent of such
initiatives as the pork industry's development of a proactive
environmental game plan, a few people in both camps have come to view each
other as allies in finding mutually beneficial ways to improve the
cropland, airsheds and water resources we in fact all must share. I
believe that the industry's relationship to the opponents of biotechnology
can follow a similar path. Only one that doesn't take a quarter century to
unfold.

What is most crucial, though, is that the senior executives of meat and
poultry companies, and their colleagues on food processing, start today to
take seriously both the potential threat to implementation of all that
biotechnology promises and the strength of the activists who've found a
reason to live in fighting what they see as a psychological replacement
for the terror we once felt about the atomic bomb. It's easy to make fun
of the hordes who swarm the streets of nearly every major political event,
global trade conference or scientific meeting that even remotely involves
biotechnology. But the bottom line is that biotechnology, as a tool to
improve our food supply (in terms of quality as well as quantity), is no
joke. Nor is the entrenched opposition to its implementation that is being
pursued like a military mission by thousands of career activists anything
to slough off, either. For both the food industry and the political
activists, it's not a stretch to say that biotechnology is a matter of
life and death.