No need for Roundup Ready GE alfalfa

March 3, 2010

Re: Docket # APHIS-2007-0044

Regulatory Analysis and Development, PPD, APHIS, Station 3A-03.8
4700 River Road, Unit 118
Riverdale, MD 20737-1238

Comments on document ID APHIS-2007-0044-0253 “Glyphosate-Tolerant Alfalfa Events J101 and J163: Request for Nonregulated Status — Draft Environmental Impact Statement”

Thank you for the opportunity to comment on the November 2009 Draft Environmental Impact Statement “Glyphosate-Tolerant Alfalfa Events J101 and J163: Request for Nonregulated Status.” The extension to submit comments is very much appreciated.

PCC Natural Markets is a retail grocery chain, the largest consumer-owned grocer in the United States with 47,000 member/owner households. We have nine retail stores in five cities of Western Washington; each is a certified organic retail operation. Our annual sales are approximately $138 million.

We have reviewed the draft EIS on genetically engineered, Roundup Ready (RR) alfalfa and wish to address the areas that we are most expert on, and that most directly could affect the farmers, ranchers, wholesalers, distributors, and consumers in our supply chain – from seed to table.

We wish especially to point out some flawed assumptions, judgments and conclusions – starting with APHIS’ apparent confidence in the projected purity of non-GT alfalfa seed.

1. Gene flow

The EIS confidently states that “contractual ‘best practices’ have been found to produce non-GT alfalfa seed with >99.5 percent purity.” This figure apparently is based on a claim by a GT alfalfa producer, using a separation distance of 900 feet between glyphosate-tolerant (GT) and non-GT alfalfa seed fields; 1 mile separation if Alkali bees are employed; and 3 miles if honey bees are pollinating.

It is not acceptable for APHIS to rely solely on industry claims, given the obvious conflict of interest. Indeed, this industry based claim is readily refuted.

Numerous experts have documented that bees fly much further. A classic 3-year study [Eckert, 1933] found bees forage up to seven miles. Another [Chaney 1985] found that bees placed for alfalfa pollination collected 10 times more safflower pollen as alfalfa pollen, even though the nearest safflower field was 5 miles away.

In yet another study specifically designed to study pollen movement from alfalfa seed production fields, Hammon et al [2006] found the GT alfalfa gene at 83% of all collection sites, out to a distance of 1.7 miles. Yet the farthest distance bees can move pollen could not be determined, since the RR gene was found at the most distant site from the nearest pollen source/seed field. The RR seed was present at 19 of the 23 collection sites; the percentages ranged from 0.18 to 9.46%.

The 99.5 percent purity rate is no more realistic as a standard than 9.46%. To be based on sound science, “Best Practices” must require what science shows as typical bee foraging behavior: a minimum of 7 miles as a buffer zone around all GT alfalfa fields.

Even with a minimum of 7 mile buffers, significant gene flow is inevitable from birds, weather and other unpredictable factors.

There is not a single deregulated GE plant that has not significantly contaminated the rest of the seed supply. Most recently, this was demonstrated to be true even with an unapproved variety of experimental GE rice that contaminated fields in five states.

But contamination is widespread even with self-pollinating crops such as soy. The Union of Concerned Scientists reports that two respected laboratories have found GE traits in at least 50 percent and as much as 83 percent of the traditional soybean seeds bought by farmers. The UCS says it’s likely the contamination is a symptom of generally porous seed production and distribution systems.

2. Avoidance costs

The cost of any proposed separation buffers must be the responsibility of the company claiming proprietary ownership of GT alfalfa seed and any GT alfalfa farmer, since they are the aggressors seeking to disturb the environmental status quo and creating potentially disastrous impacts on others. It is a basic precept of corporate law that the “polluter pays.”

In “Avoidance Costs” [S-30], however, APHIS suggests that famers who choose to grow non-GT alfalfa may plant “buffer zones” as barriers around their fields, require “testing for GT alfalfa traits in alfalfa seeds used for production,” or by moving to another location (“relocating to non-deregulated areas”) to protect themselves.

This is a direct contradiction of APHIS’ own stated primary mission: “Protecting American agriculture is the basic charge of the U.S. Department of Agriculture’s Animal and Plant Health Inspection Service.”

Such recommendations also conflict directly with: “One of Aphis’ many functions is to regulate genetically engineered (GE) organisms … that might pose a plant pest risk.”

Indeed, when APHIS advises non-GT alfalfa farmers to take specific (and inherently costly) measures to protect their fields from the threat of GT alfalfa, APHIS clearly is acknowledging harm and acknowledging that such GT alfalfa is a pest.

The extreme recommendation that a farmer move his farm confirms that GT alfalfa and non-GT alfalfa cannot “coexist” in any equitable way.

Any protocol for coexistence must include provisions requiring the polluter to pay for resulting costs imposed on others.

3. Domestic Economic Environment at Risk

Discussion of “Domestic Economic Environment at Risk – Organic Alfalfa” [III, Affected Environment, 48] draws a misleading distinction between organic and conventional yields and pricing.

“Prices and quality requirements are significantly different between organic and non-organic alfalfa hay … The value-added price per ton for certified organic
alfalfa hay is, on average, 18 percent greater than conventional hay …”

The EIS also states, [S-25]

“we .. assume there is some demand for GE-free alfalfa. Although we have not found much evidence of this demand in analyzing the domestic market, we expect this will be the case of export markets.”

And, in S-32,

“we found no evidence of a domestic GE sensitive market for conventional alfalfa …”

It is not adequate for the EIS to claim there’s little or no evidence of a well-known fact in the U.S. food industry. That is, increasing U.S. manufacturer sensitivity to GE ingredients based on consumer sensitivity. An increasing number of non-organic products bear labels that say “Non-GMO soy,” “Non-GMO canola,” “Non-GMO cornstarch,” etc. A few years ago, such labels did not exist.

Such non-organic Non-GE declarations are numerous and growing in number, especially with The Non-GMO Project gaining traction. It has published the first national standard for 1) Non-GMO tolerance levels, 2) “Best Practices” for food producers to screen out sources of GMO contamination, and 3) testing of ingredients throughout the supply chain of enrolled products. The Project is based on growing consumer demand for non-GMO foods.

Partners in The Non-GMO Project include United Natural Foods, Inc, the nation’s primary “natural” (and organic) food wholesaler/distributor with sales of $3.3 Billion in 2008; the Independent Natural Foods Retail Association, with more than 70 member grocery retailers; the National Cooperative Grocers Association, with more than 140 retail grocery members in 32 states with sales totaling over $1 billion; Whole Foods, the dominant natural and organic food retail chain with sales of $8 Billion in 2008; and a growing list of non-organic (and organic) food manufacturers.

Many products involved in the Project, and many food manufacturers considering enrollment in the Project rely on conventional, non-GE crops and livestock feed, such as alfalfa. They earn value-added pricing at the retail level.

The EIS fails to acknowledge and calculate the economic value of “Identify Preserved” non-GE corn and soy ingredients. Their price premiums are well established. Price premiums apply to every crop where GE varieties are commercialized.

Given higher prices commanded by non-GE crops in the food supply chain, the EIS erroneously assumes that GT-alfalfa is “higher quality.” The EIS considers only the amount of non-alfalfa material in the hay in determining “quality” but that is just one measure and one not considered significant by the consumer market.

The EIS equates GT-alfalfa as “conventional” and that also is a flawed assumption. PCC Natural Markets currently is in discussions with the Country Natural Beef (CNB) ranching cooperative about securing non-GE feed for the beef “finishing” process. The finishing rations would include non-GE alfalfa and non-GE corn. CNB represents more than 100 ranching families across the U.S. West and Hawaii, with sales of more than $38 million in 2007.

We also are in discussions with Pure Country Farms in Ephrata, Wash. to promote its current non-GE feed status to shoppers. We are confident that when shoppers know the hogs are raised on non-GE fee, sales of these pork products will increase.

If GT alfalfa (or any other GE crop) truly was “higher quality” as the EIS argument assumes, then GE crops would command price premiums. That is a judgment not based in market realities as we experience it.

The market does not perceive any GE crop — not one — as “higher quality” earning a premium.

The EIS fails to assess the impact on “quality” adequately.

4. Economic impact

The EIS acknowledges that deregulation of GT-alfalfa will hurt conventional and organic alfalfa farmers. This means we, as a retailer, also could and likely would be hurt by deregulation.

Commercialization of GT alfalfa in the U.S. and the contamination of non-GT alfalfa would undermine the integrity of our supply chain and damage trust in our business model as a purveyor of “natural” food. It would hurt the 1,000 employee families who depend on the viability of our business.

We have built our business with dairy and meat products raised on both conventional and organic hay as feedstock. Our customer is the natural foods customer and they are very sensitive to GE issues in both conventional and organic foods. They call and email, asking for clarification on whether specific foods were raised on GE crops. For example:

“… Does the (Draper Valley/conventional) chicken feed contain pesticides and GE crops? If so, will PCC consider taking a stand against selling food which supports these industries? … I have sadly realized how food/health concerns are now beyond antibiotics, hormones and pesticides … GE corn and soy compound the food choices I make …”

“… GE contamination is a huge reason I buy organic despite its price, to show with my dollars that I don’t like GE food or pesticides.” – J. Lehto

PCC Natural Markets also sells four (4) dietary alfalfa supplements, often used as a natural diuretic and detoxifying agent. Customers demand supplements labeled non-GE, and prefer to purchase U.S. products over foreign imports.

Given concerns about the trial plantings of GT alfalfa, we purchase some alfalfa products from New Zealand, where GT alfalfa is prohibited. This means a loss of income for U. S. farmers, and also the products cost more for consumers.

Agriculture and the food industry are the largest employer and the greatest source of revenue in Washington state – more than Microsoft and Boeing combined.
Loss of the alfalfa export market would impact our state treasury, already crippled by a $3 billion budgetary shortfall this year. The value of our hay crop per ton is high, compared to the national average.

The EIS rightly acknowledges that GT alfalfa seed and hay is likely to be rejected — or will be rejected — by export markets, including Japan, Korea and Taiwan. Washington state’s alfalfa exports to these countries that are GE-sensitive would be jeopardized if GT alfalfa were to be deregulated. The act of deregulation alone would cast sufficient doubt on the purity of all U.S. alfalfa, costing all farmers and others in the value chain.

According to Shewmaker et al (2006) [III “Affected Environment” a. Alfalfa Seed and Forage Farming, 4. “Social Environment at Risk”], “The export market helps support and stabilize domestic forage prices in the Pacific Northwest …” and, according to a National Alfalfa and Forage Alliance document addressing coexistence in the alfalfa export markets (2007), the export hay market is of key importance to certain producers in Washington …” and coexistence strategies for minimizing comingling between GT and non-GT alfalfa may be effective.”

Use of the word “may” is not encouraging. It implicitly indicates doubt and potential for failure.

We notice a comment on this EIS, signed Concerned Northwest Seed Growers but without specific names, saying that new studies are needed before RR alfalfa is deregulated.

The Concerned Northwest Seed Growers ask good, solid questions in our view: that RR alfalfa seed contamination is showing up in non-GT alfalfa. They’re reporting contamination in mature hay fields, in non-seed producing regions as well as seed producing locations in multiple states. They say that reading the EIS gives the impression that this contamination cannot and does not occur now. That, they say, is not the case.

What this means is that Northwest Seed Growers are shipping “conventional” seed at this time as farmers plan to plant this spring. But while farmers believe they’ve ordered “conventional, non-GT seed,” they are getting contaminated seed and they are not being informed it is contaminated.

5. Consumer sensitivity to GE content in food

In III, Affected Environment, (2) Consumer sensitivity to GE content in food, APHIS’s assessment is completely inadequate. It also apparently is cherry-picking data.

The EIS, for instance, cites on page 58 a 2004 study [(Noussair et al, 2004]:

“There seems to be no estimate available of consumer demand for GE-free food products.”

But it fails to cite one of the USDA’s own reports, “The First Decade of Genetically Engineered Crops in the United States /EIB-11, Economic Research Service, 2006:

“In the United States … the data show that manufacturers have been active in creating a market for GE free foods. From 2000 to 2004, manufacturers introduced over 3,500 products that had explicit non-GE labeling … This is in addition to organic foods.” (Dimitri and Greene, 2002).

The EIS, in mentioning the Hallman et al (2003) study [PUBLIC PERCEPTIONS OF GENETICALLY MODIFIED FOODS: A National Study of American Knowledge and Opinion] also asserts on page 60:

“one half of U.S. residents surveyed approved of plant-based genetic engineering …”

But in fact, the Hallman-Aquino study cited by the EIS found that support for GE foods had slipped between 2001 and 2003. In 2001, 59% of Americans said they thought GE foods would make their lives better. In 2003, only 39% had a similar response. A full third (35%) in 2003 felt it would make their quality of life worse.

The EIS also fails to acknowledge that:

“Less than half (45%) believe it is safe to consume GM foods (another 18% say they don’t know), and in a separate question, only 44% disagreed that eating GM foods would be harmful to their health.

However, they also seem concerned about other potential unintended consequences related to the technology. Almost two-thirds (62%) feel “serious accidents involving GM foods are bound to happen” and 54% feel “GM food threatens the natural order of things.”

The EIS fails to acknowledge that more than two-thirds (65%) agreed with the statement, “I would be unhappy if I were served genetically modified food in a restaurant without knowing it.”

When Hallman and Aquino asked respondents directly whether or not they would like to see GM foods labeled, 94% said they did favor such labels, an increase from 2001.

Hallman and Aquino say,

“This apparent overwhelming support for additional information on food labels suggests that Americans wish to retain “consumer sovereignty;” the right to make food choices based on their own values (Thompson, 1997). When asked how a GM food label would affect their purchasing decisions, more than half (52%) said it would make them less willing to purchase the product … only 4% said they would be more willing to buy a product labeled as genetically modified.”

It is unacceptable that APHIS chooses to present excerpts of studies, such as Hallman and Aquino, that, by omission, are incomplete and suggest favorable consumer support for GE foods when, in fact, the Hallman/Aquino findings demonstrate the opposite.

The EIS cites Lusk and Rozan (2005) and as finding “U.S. consumers more receptive to GE foods than their European counterparts, although a preference for non-GE foods remains …”

However, the EIS fails to acknowledge that Lusk and Rozan found,

“… consumers wish to avoid GMO foods, not only for health reasons, but also for environmental and/or religious reasons, ethical or other non-safety issues …”

APHIS also failed even to mention, for instance, a more recent 2007 study published in AgBioForum, the Journal of Agrobiotechnology and Management and Technology [Esposito and Kolodinsky, University of Vermont]. It found:

“58.8% of Vermonters are, to some degree, opposed to the use of GMOs in commercially available food products. Females tend to be more wary of GMO use in food products, with 65% of the females (compared to 51.2% of the males) expressed some opposition to GMOs in food products …”

And, “respondents were in most agreement that the company selling GM seeds should be held liable for spreading GM pollen to organic non–GM crops (72.4%), as well as farmers using GM seeds (64.5%). There was also a strong consensus that organic farmers should not bear liability for GM seed spread (81%). Respondents viewed government as a culpable party, with type of government mattering: more than half the respondents (54.4%) agreed that the U.S. government (specifically the Department of Agriculture) should bear legal liability for the spreading of GM pollen to organic, non-GM crops.”

In another example, the EIS cites Fernandez-Cornejo and Caswell, 2006:

“Several studies have argued that even with the negative opinions Americans express about biotechnology in surveys, there has been little apparent effect on sales of food items that contain or are raised on GE ingredients or feeds.”

However, the same Fernandez-Cornejo and Caswell study also says,

“In most of these studies (table 5), consumers indicated that they were willing to pay more on average for GE-free foods or to avoid foods containing GE ingredients. However, in many of the studies, at least some consumers did not require a discount to buy foods containing GE ingredients, while some expressed that they would not be willing to buy foods containing GE ingredients at all.”

Indeed, APHIS’ citations on consumer sensitivity appear not to represent fully or accurately the studies’ findings.

Furthermore, the studies themselves do not read like independent studies. Some of the ones cited seem to have been designed to assess strategies to encourage greater consumer receptivity.

These are serious flaws in the EIS assessment of consumer sentiments. They raise questions about the accuracy of the way other studies are interpreted and represented in this EIS.

5. Human health and safety

Risk from Gene Product

The government policies on regulating GE foods are fundamentally flawed. The FDA guidelines, for instance, say GE foods must be thoroughly tested, but the biotech companies themselves determine whether their products are safe or whether they “warrant analytical or toxicological tests.” Even if companies acknowledge safety questions, “consultations” with the FDA are only voluntary.

When companies choose to talk with the FDA, they must present only summaries of their data. Because the government protects corporate safety studies as trade secrets, they aren’t available for public review.

Despite the fact that GE plants are different enough from the natural ones to be patented, the FDA doesn’t review all GE products hitting the market. Companies must obtain FDA-approval to market a GE food only if it contains a known allergen or toxic substance, if the nutritional content of the food has changed, or if it uses antibiotic –resistant genes.

Countless consumers have expressed disbelief over the years when PCC informs them that FDA has not tested any novel GE introductions to the food supply chain. They do not realize the FDA relies on industry-funded studies, which may be designed to produce a desired outcome.

For instance, in III Affected Environment, D. Human Health and Safety, 1. Risk from Gene Product, the EIS states:

“FDA concluded that the CP4 EPSPS protein produced by GT alfalfa … was biochemically and functionally equivalent … to the family of EPSPS proteins that naturally occur in crop and microbiologically-based processing agents that have a long history of safe consumption by humans and animals.”

Given that the FDA’s conclusion is based on Monsanto’s studies … and given what has emerged about the credibility and reliability of some Monsanto studies … it is shameful that FDA would stake its reputation on a corporation known to avoid releasing damaging evidence about its products.

For instance, in 2005, the “Independent” newspaper in Britain reported that secret research by the biotech giant Monsanto showed that rats fed GE corn had smaller kidneys and higher levels of white blood cells and lymphocytes compared to rats fed non-GE food. Monsanto had refused to release its full 1,139-page report. But a European court ordered Monsanto to release it for publication, under a law ensuring public access to documents on GE risks.

A European study [International Journal of Biological Sciences] also found health impacts on the liver, kidneys and other organs from three varieties of Monsanto’s GE corn. Researchers from Caen and Rouen Universities, and the EU Committee for Independent Research and Information on Genetic Engineering, based their analyses on data supplied by Monsanto to authorities for commercial approval — but they drew different conclusions after a two-year test period, compared to Monsanto’s much shorter test period. They found that for all three types of Monsanto’s corn, the kidneys and liver — organs that react to poisoning — revealed problems. All three GE corn varieties (Mon810, MON863 and NK603) are approved by the USDA.

These examples raise serious concerns about the current U.S. protocol in reviewing applications for GE permits.

It is not acceptable that USDA relies on voluntary consultations, does not require review of a company’s full data, and does not require any human feeding studies.

They might be just one contributing factor to the findings of a 2008 study commissioned by communications company Morgan & Myers. It found that consumers trust consumer advocacy groups and local grocers more than the government for information about food choices.

Risk from glyphosate

A 1998 study at the University of Wisconsin, cited by the EIS, says herbicides are applied to less than 17% of U.S. alfalfa hay acreage [Wilke, 1998].

That echoes the statement by alfalfa farmer Philip Geertson (as in Monsanto vs. Geertson Seed Farms) that 78-83% of alfalfa forage growers do not use herbicides.

They suggest that deregulation of GT alfalfa would increase herbicide use, adding more pesticides into the environment, as some studies show for other GT crops, that they actually encourage and increase glyphosate use. It suggests that farmers who haven’t used herbicides but might be persuaded to consider GT alfalfa, will add to the environmental burden from glyphosate.

The EIS acknowledges on page 63 that:

“Glyphosate acts on various enzyme systems and inhibits amino acid
metabolism of EPSPS in plants. This enzyme is absent in mammals.”

and that
“the concern, for risk assessment purposes, is glyphosate residue and
aminomethylphosphonate (AMPA), which shows up in mammals and is
excreted unchanged.”

and that

“Glyphosate is particularly effective because most plants metabolically degrade it very slowly or not at all, and it translocates well to metabolically active tissues such as meristems.” [Cerdeira and Duke, 2006]

Given that the EIS admits glyphosate degrades very slowly or not at all, and that it accumulates in a plant’s meristematic tissues — the rapidly growing tissues, such as root and shoot tips, and reproductive structures (why it’s showing up in grain) — it is tantamount to an admission that glyphosate is entering the food chain.

What the EIS fails to address adequately is the impact of glyphosate’s action on:

1) the physiological functions of plants
2) the soil environment
3) the impact on animals fed RR alfalfa, and
4) human consumption of those animal products, such as milk, butter, yogurt, sour cream, cheeses, ice cream, and meat.

A well-published Purdue University Professor Emeritus, Don Huber, in “Ag Chemical and Crop Nutrient Interactions – Current Update” (2009), documents some things known about glyphosate that influences plant nutrition and disease.

I understand some individuals at USDA choose to disregard Huber’s research, but at least some of his findings are validated by research by Bob Kremer at the University of Missouri, and Dr. Heather Mather’s research at Ohio State University support Huber’s research on glyphosate, as follows:

1. Glyphosate is a strong metal chelator (for Ca, Co, Cu, Fe, Mn, Mg, Ni, Zn) – in the soil and in plants.

2. Inhibits the uptake and translocation of Fe, Mn, and Zn at very low, non-herbicidal rates. It can immobilize Fe, Mn, Zn, or other nutrients applied as foliar amendments for 8-35 days after it has been applied. This reduces the availability of micronutrients required for photosynthesis, disease resistance, and other critical physiological functions.

3. It is rapidly absorbed by roots, stems and leaves, and moves systemically throughout the plant (normal and RR).

4. Accumulates in meristematic tissues (root, shoot and reproductive) of normal and RR
plants.

Dr. Heather Mather’s research [Ohio State University] has shown that glyphosate accumulates in perennial plants for many years (6-10 years at least).

5. Inhibits EPSPS and many other plant essential enzymes.

6. Increases susceptibility to drought and disease.

7. Some of the applied glyphosate is exuded from roots into soil.
[Kremer, Univ. of Missouri, European Journal of Agronomy paper]

8. Persists and accumulates in soil and plants for extended periods (years) – it is not ‘biodegradable.’

The Environmental Protection Agency, too, has called glyphosate “extremely persistent.”

9. Is available for root uptake by all plants, desorbed from soil particles by phosphorus.

(Degradation products of glyphosate are toxic to both Roundup Ready (RR) and non-RR plants.)

10. Toxic to soil organisms facilitating nutrient access, availability, or absorption of
nutrients. [Kremer, Univ. of Missouri]

11. Stimulates soil borne pathogenic and other soil microbes to reduce nutrient
availability.

13. Inhibits and reduces nitrogen fixation (by chelating Ni for ureide synthesis and is
toxic to Rhizoiaceae)

14. Reduces physiological availability and concentration of Ca, Cu, Fe, K, Mg, Mn, and
Zn in plant tissues and seed. This reduces seed nutrient content.

15. Residual soil activity can damage plants through root uptake.

16. Increases mycotoxins in stems, straw, grain, and fruit.

Huber notes that what is overlooked quite often is the increase in root and crown rot by FHB Fusaria with glyhphosate, and the production of mycotoxins in root and crown tissues with translocation to stems, chaff and grain.

Serious concerns have been raised about using straw and chaff as bedding for pigs or roughage for cattle because of mycotoxin levels that far exceeded clinically significant levels for infertility and toxicity. This also poses a health and safety concern for grain entering the food chain for humans.

17. Reduces photosynthesis (CO2 fixation).

18. Accumulates in food and feed products to enter the food chain, raising questions
about food safety.

Huber’s calculations indicated that about 3/4 of the applied glyphosate stays in the plant, and about 1/4 of it is exuded over time (directly).

Since glyphosate is NOT broken down in the plant, and only marginally or rarely in soil, there is an accumulation every time glyphosate is applied.

If glyphosate were to be applied during every alfalfa hay cutting, there would be a substantial amount in the tissue for consumption by cattle and entrance into the food chain through both meat and milk.

Given that it is an extremely potent biocide and micronutrient immobilizer that can affect many essential physiological functions, it is of deep concern to our member/owners that increased applications of glyphosate (with GT alfalfa deregulation) would accumulate in the soil, in plant tissues, and in the food supply chain – organic and conventional.

These initial studies indicate that deregulation of more GT plants could lead us into a major health calamity.

It is why any proper environmental review of GT alfalfa MUST include evaluation of the impact of glyphosate on

1. physiological functions of plants
2. soil environments
3. subsequent crops in the crop rotation
4. animals fed it
5. downstream consumption in the food chain by humans

Three recent studies, in fact, show that Roundup (glyphosate) is not the safe product we’ve been led to believe it is.

A group of scientists led by biochemist Prof. Gilles-Eric Seralini from the University of Caen in France found that human cells are very sensitive to Roundup at concentrations lower than those currently used in agricultural applications. As reported by the American Chemical Society last spring [2009], the scientists evaluated the herbicide’s effect on human embryonic, umbilical and placental cells and found that all cells exposed were killed within 24 hours. They concluded that residues in food and feed treated with Roundup can be highly toxic.

An epidemiological study of Ontario farming populations showed that exposure to glyphosate nearly doubled the risk of late miscarriages. Seralinii and his team decided to research the effects of the herbicide on human placenta cells. Their study confirmed the toxicity of glyphosate; after 18 hours of exposure at low concentrations, large proportions of human placenta cells began to die. Seralini suggests that this may explain the high levels of premature births and miscarriages observed among female farmers using glyphosate.

Seralini’s team further compared the toxic effects of the Roundup formula to the isolated active ingredient, glyphosate. They found that the toxic effect increases in the presence of Roundup “adjuvants.” These additives have a facilitating role, rendering Roundup twice as toxic as its isolated active ingredient, glyphosate.

Another study, released in April 2009 by the University of Pittsburgh, suggests that Roundup is a danger to other life-forms and non-target organisms. Biologist Rick Relyea found that Roundup is extremely lethal to amphibians. In what is considered one of the most extensive studies on the effects of pesticides on non-target organisms in a natural setting, Relyea found that Roundup caused a 70 percent decline in amphibian biodiversity and an 86 percent decline in the total mass of tadpoles.

In 2002, a scientific team led by Robert Belle of the National Center for Scientific Research biological station in Roscoff, France, showed that Roundup activates one of the key stages of cellular division that can potentially lead to cancer.

Monsanto attempted to refute some of these findings, but Relyea for one, stands by his findings.

Such findings are very much a concern not addressed by the EIS. These studies should be reviewed by the USDA and FDA and EPA, and independent studies should be conducted to see if the results can or cannot be confirmed.

Nonetheless, it is not acceptable that USDA/APHIS relies on voluntary consultations with the purveyors of the chemicals at issue.

It is not acceptable that APHIS and this EIS do not require access to all a company’s data if that company is appealing to release novel creations into the public environment.

It is not acceptable that the FDA and USDA do not require long-term feeding studies, including human feeding studies.

There has been only one scientific human feeding study done on any genetically engineered food and that involved soy. The results of even that single study raised concerns because the genetically engineered DNA was found to have transferred to bacteria in the stomach, something the biotech industry said would not and could not happen. (The study was done with people who had ileostomies, enabling easy tracking of foodstuffs.)

Any proper EIS would address all these concerns before releasing GT alfalfa, or any other GE crop, into the environment and the food chain, especially without any labeling.

We do believe that mandatory labeling of GE ingredients in the supply chain, a sentiment cited by USDA’s own studies, would be an acceptable measure that could mitigate some consumer concerns. Labels would allow consumers the ability to distinguish GE ingredients in foods and would preserve their right to an informed choice.

At this point, however, in the current regulatory system, deregulating GT alfalfa would be contrary to APHIS’ stated purpose, that it “improves agricultural productivity and competitiveness and contributes to the national economy and public health.”

Sincerely,

Trudy Bialic
Director, Public Affairs

Notes:

1. Eckert, J. E. 1933. The flight range of the honeybee. J. of Agricultural Research 47:257-285
2. Chaney, David circa 1985. Bloom dynamics in alfalfa: Implications for pollination and seed production. M. S. Thesis, International Agricultural Development, University of CA. Davis, CA.
3. Hammon, B. Rinderle, C. and Franklin, M. Pollen Movement from Alfalfa Seed Production Fields. 2006. Colorado State University Cooperative Extension, Tri River Area, P.O. Box 20,000-5028, Grand Junction, CO 81502-5028, (970) 244-1834; contact: bob.hammon@mesacounty.us