Tuesday, August 01, 2006

Genetically Modified Food: A Case for Stricter Regulation

This is a paper I wrote last year.

Food security around the world, especially in developing countries is an extremely important issue. Genetic Engineering has been proposed as a technology that will increase food production and decrease starvation. Here, I will analyze the science of and policies formulated to regulate genetically engineered organisms. I will weigh the European view against the US view regarding production and consumption of genetically engineered (GE) crops and propose that developing countries should formulate policies with their own unique situations in mind. This is critical for the long-term food security of the world.

Genetic engineering of food crops results in two broadly classifiable types of genetically modified organisms (GMOs): Process-based GMOs are those that result from engineering the process that goes into the generation of the organism. For example, herbicide-tolerant soybean, in which the plant is engineered to be resistant to an herbicide, results in no externally identifiable change to the end product itself. Product-based GMOs are those where the end product is substantially different from traditional varieties of the product, either in terms of nutritional value or in terms of shelf life or aesthetic appeal [1]. For example, “Golden Rice” is rice engineered to produce high levels of beta-Carotene, which is the precursor to Vitamin-A.

The first GE crop to be cultivated commercially was planted in 1996 in the US. Since then, many countries have adopted GE crops. 25% of the world’s cultivated land is now under GE crop cultivation. That is about 200 million acres, of which 63% is in the US and 21% is in Argentina. Of the three most cultivated crops in the US, 85% of all soybean, 76% of cotton and 45% of the corn cultivation in the US is now genetically engineered [2]. This represents a major change in cultivation that affects large numbers of consumers as well as the environment. It also makes trade in GE food produce an important issue, especially for countries that produce large quantities of it.

Consumers are affected by changing patterns of cultivation as the produce they buy contains higher amounts GE food or seeds. If GE foods were labeled as such, it would represent new choices for the consumer. If, however, as in the US, there is no requirement to label GE foods, the consumer then has no choice but to consume the new kind of food or to rely on producers of non-GE foods labeling their products. There are many reasons why consumers may want GE food labeled. Being a relatively new technology, we are forced to rely on laboratory tests rather than data about direct effects on humans, as there has not been adequate time for such data to accumulate. All laboratory tests of nutrient content in process-based GE foods suggest that they are entirely benign with respect to human health, but without adequate data on direct effects on humans, there will always be a large percentage of the population that would simply rather have nothing to do with the new technology. As regards effects on the environment, cultivation of GE crops on farms, even process-based crops, could have adverse effects on the diversity of plants and animals in the vicinity. The possible effects have been documented and range from effects on non-target species to escape of the transgene from the GE plant to neighboring wild species. These risks are much greater when the country importing GE seeds has high levels of natural biodiversity, either in terms of wild species of the crop in question or animal and plant species in general. This makes countries importing GE seeds apprehensive of the effect accidental or intentional planting of these seeds in traditionally non-GE farms could have on their own production and exports. On the positive side, however, GE crops like Bt-cotton do have the potential to reduce pesticide use on farms, thus affecting the environment positively. The bottom line is that perceptions about GE crops around the world with respect to their effects on health, the environment and the economy are polarized, and this inevitably has an effect on the largest producer of GE foods, the US, in terms of export markets. Policies that deal with the production, labeling and trade of GE crops and food products differ between the European Union (EU) and the US, with the rest of the world left as yet largely, grappling with the issue.

The effect adopting GE crops could have on exports of countries is evident by looking at the exports of the US, the largest producer of GE foods in the past few years. As of 1999, 18% of all US corn production was marked for export, with Japan representing 37% of the world market for exported US corn. There have been restrictions imposed recently on GE corn in major Asian markets including Japan and Korea, requiring labeling of GE-containing shipments. This has resulted in apprehension among US exporters about the effect it will have on already falling US corn exports. Revenue from exports to Europe for exported US corn fell from $300 million in the mid-1990s to only $10 million in recent years because GE-varieties of US corn have not been approved by the EU. While Europe represents only 5% of the world market for US corn, this is still significant considering the sheer magnitude of the fall in revenue. As for Soybean, 29% of the production is exported, with the EU being the major importer of US soy. With only one variety of GE soy having been planted in the US, and its approval by the EU, soy exports from the US have not suffered as much as corn exports [3]. It is obviously in the best interest of US exporters to push for market access for their GE produce. However, some countries are formulating regulations that look at each product on a case-by-case basis, making a decision as to grant market access based on the specific risks associated with it. Furthermore, countries are taking into consideration EU import policies while making decisions on whether to adopt GE seeds on their own farms. Adopting the technology brings with it the risk of losing the European market for their food exports.

GE Policies and the issues that inform them

Policies to regulate import and production of GE crops are decided by countries concerned. However, trade between countries is regulated by the world trade organization (WTO). The Codex Alimentarius commission, created by the World Health Organization (WHO) is responsible for food safety standards that traders and countries adhere to. As far as Biosafety and environmental concerns go, the Convention on Biodiversity set up by the United Nations drafted the Cartagena Protocol on Biosafety, which came into effect after 50 countries ratified it. This happened in September 2003. Presently, 110 countries are signatories to the protocol, the US not being one of them. The Cartagena Protocol gives importing countries the power to ask for risk assessments and scientific tests if they have any doubt about the environmental risk associated with a “living modified organism” being imported [4]. The protocol thus adopts a “precautionary principle”, much like the European Union, whose regulatory policies are defined by it. The precautionary principle requires that it be proved that GE food or crops are risk free before they are deregulated. Of course, this requires defining the possible risks associated with GE foods or crops (see below for possible risks). In the absence of a scientifically defined risk associated with a particular food/crop, restricting import of the product may be viewed as going against the WTO’s trade rules.

US policy with respect to GE crops is quite different. The US is the largest producer of GE products. Market forces drive the country’s policy with respect to internal consumption of GE food products or crop cultivation. The US consumer has not demanded labeling of products that contain GE foods; the Biotech industrial lobby is of course large and powerful enough in the US to be able to ward off any such demands, should they surface. The US Department of Agriculture (USDA) oversees issues that deal with the environmental safety of GE crops, while the Food and Drug Administration (FDA) deals with issues about food safety. Crops and products are viewed as harmless unless there is a proven risk associated with them. There is, of course, a risk associated with an approach such as this. Once commercialization of a GE crop has been allowed and a crop planted on many thousands of acres of land, it may be too late to deal with a risk, should one emerge. Likewise, with respect to food safety, the “don’t ask, don’t see” approach will only identify the largest problems while any subtle risks associated with a GE food product will go unnoticed, especially if GE foods are not labeled as such [5].

This brings us to the issue of labeling GE food products. Europe has adopted the most stringent rules yet requiring that all products in which genetically modified substances make up 1% or greater of the total be appropriately labeled. This of course presents a problem for most large-scale exporters in the US as their packaging and handling practices make it economically unviable and practically impossible to keep non-GE produce completely free from GE produce. Many other countries are adopting rules requiring labeling of products that contain GE food. Consumers in Europe seem to be much more apprehensive of GE foods than consumers in the United States though some surveys do suggest that a growing percentage of US consumers may also want to have GE produce-containing foods labeled as such [6]. Survey after survey has shown that the European consumer believes that the risks associated with GE foods outweigh the benefits. The widespread European apprehension has been analyzed to be due to the high importance Europeans give to dining practices and their food in general [7]. Whatever the reasons, European people remain vehemently opposed to consuming GE food products. This leads to an interesting quandary for developing nations. They are faced with the option of either adopting GE seeds in the hope of increasing production and decreasing pesticide use, or rejecting GE crops for fear of losing the European market. The recent food aid crisis, which saw African nations faced with a famine turn away food aid from the US because it contained GE corn seeds, highlights this quandary.

Scientific studies of the risks of GE crops

In order to understand if the apprehension regarding GE crops is justified, we need to look at what the risks associated may be. The most popular GE crops have been Herbicide tolerant (HT) varieties of corn and soybean as well as Bt-Cotton. The HT varieties are, as the name suggests, tolerant to a particular herbicide that the farmer can then buy from the same Biotech Company he/she buys the seeds from. Application of this herbicide indiscriminately still allows targeting weeds for death while allowing the HT crop to survive. Possible risks associated with the HT technology are
* Resistance development in weeds
* Leeching of herbicide into ground water
* Any possible effects on plant and animal populations that make up the ecosystem of the HT crop plants.

Bt-crops have been engineered to produce a bacterial toxin that makes the plants resistant to lepidopteran pests. The risks associated with Bt-crops are
* Resistance development in target insects
* Undesirable effects on non-target insects and other organisms
* Introgression of the transgene into wild plant varieties growing near GE plants

The US Department of Agriculture (USDA) oversees most regulation of GE crops in the US. The USDA however, does not have a firm set of regulations and tests that must be performed on a crop that is proposed for commercial planting. The onus for setting up consultations with the USDA regarding any possible environmental risks associated with a GE crop rests with the company producing the seed. This makes the legal framework extremely weak. There is documented evidence suggesting there may be unforeseen effects of genetically engineered crops.
1. A recent study [8] in the journal, Nature, showed that a nematode-resistance gene from transgenic potato grown in the central Andes was transferred to wild potato plants growing near transgenic varieties. There is a possibility that stable introgression of transgenes could confer altered fitness on wild plants. Especially in areas of high biodiversity (the Central Andes is the center for biodiversity for potato), escape of transgenes presents a major risk of the technology.
2. A Nature study in 2000 [9] showed that Bt-corn pollen could kill Monarch larvae in laboratory tests. (Monarch butterflies are also lepidopterans, like the bollworm which is the target of Bt toxin) This was extremely worrisome as Bt-corn had already been commercialized and planted in huge areas of the US Midwest, through where Monarchs are known to migrate. However, miraculously, further studies showed that in the field, the variety of Bt-corn that proved most harmful to Monarchs had not sold well and hence had not been planted extensively.
3. Finally, a recent study [10] showed that there was considerable escape of the HT transgene from a creeping bentgrass variety that Monsanto is trying to commercialize. Creeping bentgrass is used in golf courses etc. as a perennial grass variety, and is known to be wind-pollinated, which makes it likely, right at the outset, for escape of the transgene to occur.

These are but three studies and by no means the only ones, that show that environmental risks associated with transgenic crops are very real and, as illustrated by the Monarch case, regulations to assess and deal with these risks are not in place even in the largest producer of GE crops, the US. There is also the possibility that more effects will be uncovered as time goes on; this is a young technology, which has had only 8 years since the first commercial cultivation of a GE crop. Furthermore, any effects on humans right now is probably going undocumented due to the lack of a labeling requirement in the US, the largest consumer of GE produce. The (as yet) unpredictable nature of the technology and the rush to commercialization by the Biotech companies should urge us to demand that the US government strengthen the regulatory framework within which the companies and traders operate.
Europe has adopted the precautionary approach, which mandates that until you prove that there are no detrimental effects of the proposed technology, it be treated as a risk. Thus, if there is any doubt regarding the risks associated with a technology, they follow the precautionary approach. Developing nations should waste no time in formulating policy to regulate entry of GE crops and foods. Many tropical countries have very high levels of Biodiversity. Any leakage of transgenes into wild relatives in biologically diverse environments, especially in the centers of biodiversity for the crop in question could wreak havoc. Why however, would developing nations be more concerned about effects on the environment than about ensuring food security for their people? We should hope that they adopt a long-term outlook; GE food crops may be able to feed the hungry now, but if transgenes introgress into wild varieties, long term biodiversity of the crop and hence, long term food security will be in peril. There are analyses that show that poor people are hungry in developing nations not for lack of available food, but for lack of buying power to acquire that food. Even if we accept the premise that increasing production is important in developing nations, sufficient safeguards to regulate use of GE crops and decrease risks associated with them are simply not in place in most cases. Safeguarding biodiversity, and thus, ensuring long-term world food security should be the foremost priority for all regulatory bodies and policy formulators, especially in the biodiverse tropical countries.

End Notes:
Fitness The fitness of an individual is measured by its contribution to the next generation.
Introgression Crossing of two plant populations to introduce new genes into a wild population
Lepidopterans The genus comprising butterflies and moths is called Lepidoptera.
[1] Phillips, P and Isaac, G. (1998). GMO labeling: Threat or opportunity? AgBioForum, 1(1), 25-30. Available on the World Wide Web: http://www.agbioforum.org
[2] Fact Sheet of The Pew Initiative on Food and Biotechnology. Available on the World Wide Web: http://pewagbiotech.org/resources/factsheets/display.php3?FactsheetID=2
[3] International Trade Concerns over Biotechnology Challenge U.S. Agriculture Exports, Report of the US General Accounting Office to the US Senate (2001). Available on the World Wide Web:
[4] Cartagena Protocol on Biosafety. Available on the World Wide Web:
[5] Mellon, M. and Rissler, J. (2004) Environmental Effects of Genetically Modified Food Crops. Available on the World Wide Web: http://www.ucsusa.org/food_and_environment/biotechnology/page.cfm?pageID=1219
[6] Genetically Engineered Organisms Policy Issues Education Project. Labeling of foods derived from GE crops. Available on the World Wide Web: http://www.geo-pie.cornell.edu/educators/downloads/fs7_tomato.pdf
[7] Richardson, JB. (2000). EU agricultural policies and implications for agrobiotechnology. AgBioForum, 3(2&3), 77-83. Available on the World Wide Web: http://www.agbioforum.org
[8] Celis, C., Scurrah, M. Cowgill, S., Chumbiauca, S., Green, J., Franco, J., Main, G., Kiezebrink, D., Visser, RGF. and Atkinson, HJ. (2004) Environmental biosafety and transgenic potato in a centre of diversity for this crop. Nature 432, 222 – 225
[9] Losey, JE., Rayor, LS. and Carter, ME. 1999. Transgenic pollen harms monarch larvae. Nature 399: 214.
[10] Watrud LS, Lee EH, Fairbrother A, Burdick C, Reichman JR, Bollman M, Storm M, King G, Van de Water PK. Evidence for landscape-level, pollen-mediated gene flow from genetically modified creeping bentgrass with CP4 EPSPS as a marker. Proc Natl Acad Sci U S A. (2004) 101(40):14533-8.