The Gerritsens’ Letter to the EPA
By Jim Gerritsen
Editor’s Note: While Monsanto continues to engineer more varieties of potatoes to be toxic to the Colorado potato beetle, organic growers continue to protest what they see as an irresponsible use of a useful insecticide. This article, reprinted from The WoodPrairie SeedPiece (Winter/Spring 1997) explains why transgenic potatoes are dangerous to organic farming and gardening – and to conventional growers as well – and how we can protest EPA registration of these crops. We thank Jim and Megan Gerritsen for letting us reprint their article and letter, and we encourage readers to write to EPA themselves. Jim says that this is an “ongoing battle,” but he believes that if the EPA believes it has a mandate to act courageously, it will.
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In April 1996, I traveled to Bethesda, Maryland, as an invited guest to the USDA National Forum on Insect Resistance to Bacillus Thuringiensis (Bt). In an unprecedented move the USDA sought the participation of stakeholders from the environmental and organic communities. My background is as an organic seed potato farmer and user of Bt. These observations relate primarily to the Colorado potato beetle (CPB) and Nature Mark/Monsanto, the developer of the transgenic Bt/potato, though transgenic corn and cotton were also covered. Transgenics is the transference of genetic material from one life form to another (i.e., gene splicing). Monsanto has gene-spliced the Bt bacteria to potatoes.
1. The National Forum reached consensus that the transgenic use of Bt will result in resistance in the targeted insect. Despite the posturing of the biotech industry, it is not a question of whether resistance will occur, it is a question of when.
2. The linch pin of resistance management strategy is that of refugia, or refuges geographically adjacent to transgenic fields where populations of targeted insects unexposed to Bt can theoretically multiply and interbreed with Bt-resistant survivors migrating out of the transgenic plots, thereby diluting the level of resistance in their offspring. At best, the refugia concept is seriously flawed and at worst is intellectually dishonest. For example, CPB have only moderate mobility and no one knows just how close refugia should be to transgenic plots (adjacent fields or alternating sections of rows within a field). Additionally CPBs commonly mate in the field before outmigration. So much for crossbreeding with CPBs from refugia. Finally and incredibly enough, Monsanto is instructing its transgenic growers to control (spray) CPBs in the refugia. So much for managing a population to dilute Bt resistant CPB.
3) Organic farmers and gardeners who conscientiously use Bt in a true IPM (Integrated Pest Management: The practice of monitoring pest levels and responding to economic threats with various preventive and control techniques) program have earned the moral right to use Bt. On Wood Prairie Farm we have controlled CPB for the past eight years through the integrated use of foliar sprayed Bt along with cultural practices, such as crop rotation, trench-traps and flame control. In 1996, for example, we relied on geographical rotation and flame control and avoided Bt in a strategy designed to extend its useful life. Under such responsible use, we would expect Bt to maintain effectiveness for the long term.
On the other hand Bt resistance brought about by Monsanto’s transgenic potatoes will ruin and render Bt useless for anyone else. Given the likelihood of resistance, one can only conclude that Monsanto has a short term cut-and-run approach: recapture R&D costs, take a quick profit and let Bt crash and burn.
4) Many speakers, including high level federal officials, referred to Bacillus thuringiensis as a “public good” or a national treasure, akin to fresh air and clean water, which belongs to all people, farmers, gardeners and consumers alike, not just to a chemical company that bought the use rights from another chemical company. A logical extension would be that if a corporation ruins a “public good” in the pursuit of a profit, it should be held accountable to the “owners“ of that public good.
5) EPA and FDA must be under incredible pressure from the gene-splicing industry to rush through approval of these transgenic products. This alone can explain the irrationality and seat-of-the-pants behavior coming from those agencies. Clearly EPA has insufficient data to have given its hasty registration approval of transgenic potatoes. In true cart-before-the-horse fashion, industry, researchers, and government viewed 1996, the first year of widespread commercialization of genetically engineered crops, with childlike giddiness as a colossal large-scale (10,000 acre) experiment.
Given the likelihood of the development of Bt-resistance by transgenics, EPA should review all transgenic registrations annually and have a back-out plan in place which includes immediate revocation of transgenic registration at the first hint of resistance.
6) The failure of FDA to require labeling of transgenic potatoes at the retail level was a stunning dereliction of duty. Gene-spliced potatoes are no longer potatoes; they are almost potatoes, genetically altered tubers that at the cellular level contain the Bt toxin. Given corporate behavior and logic, it is predictable, albeit incorrect, for Monsanto to argue that its pesticide-laced product does not merit differentiation from other potatoes. For the FDA to concur was paternalistic and monstrously ill-advised.
In a free society, we cast our vote daily by where we spend our dollars. Not requiring labeling restricts the flow of information and disables this responsibility. This is unacceptable. The FDA action needs to be reversed.
7) Those opposed to transgenics have glimmers of hope. Monsanto is experiencing numerous quality problems with its potatoes. Farmers are not yet convinced that they can’t live without Monsanto’s product. There is corporate and consumer unease with the concept of insecticide-in-every-bite products.
Monsanto is spending countless millions in development and promotion and clearing the regulatory logjams. While Monsanto pockets may run very deep, the patience of corporate chiefs and stockholders, hungry for recapture of those millions invested, may be wearing thin. Who among them won’t be jittery at the growing list of bio-tech blunders coming to light, including: 1) Monsanto’s transgenic Bt cotton, which in 1996 in fields from Texas to Georgia failed to control cotton bollworms, a targeted insect; 2) Monsanto’s recombinant bovine growth hormone (rBGH) for dairy cattle that is finding shrinking market acceptance; 3) Calgene’s tasteless “Flavr Savr” tomato; and 4) Pioneer’s ill-fated soybean spliced with a gene from the Brazil nut that carries with it the quality that causes a sometimes fatal allergic reaction. Loud and widespread consumer opposition exists in Europe to the import of unlabeled American genetically engineered products.
8) The destruction of Bt by transgenics is a clear, defining issue for the organic community and for society at large. Our seed potato company has joined Organic Gardening magazine’s call to neither grow nor sell transgenic potatoes and we encourage other companies to do likewise. Purchasing the products of certified organic producers who are appropriately prohibited from using genetically-engineered technology assures you freedom from gene-spliced food that is now in the American food pipeline.
Hundreds of letters sent by the organic and environmental community have already impacted the EPA. I encourage readers to send letters protesting EPA and FDA actions to:
• Dr. Lynn Goldman, Asst. Administrator EPA/OPPTS, 401 M St. SW, Washington, DC 24060 (Fax: 202-260-1847). Refer to Bt Crops Docket.
• Dr. David Kessler, Commissioner, Food and Drug Administration, HF-1, 5600 Fishers Lane, Rockville, MD 20857. Refer to Docket #92N-0139.
My letter, which follows, shows how the above issues may be addressed.
The Gerritsens’ Letter to the EPA
Comments for docket control #OPP-00470 to be submitted to Public Response and Program Resources Branch, Field Operations Division (7506C), Office of Pesticide Programs, Environmental Protection Agency, 401 M St., Washington, DC 20460.
My wife and I are certified organic farmers who raise certified seed potatoes in northern Maine. We have been using Bt for control of Colorado potato beetles for eight or nine years beginning with an EPA experimental use permit.
Here in Aroostook County, Maine, CPB are a recurring annual economic threat to potato crops. We have achieved excellent control by integrating various control strategies, such as propane singe and topkill flaming, trench traps, and geographical rotation, along with the use of Bt tenebrionsis. Bt is far and away the most important tool we have in dealing with CPB.
In most years we spray Bt once or twice. In 1996 (and in 1992) we judged that conditions were such as to allow us not to use Bt in a calculated effort to minimize the possibility of Bt resistance. Instead, for CPB control we relied upon flaming, geographical rotation and rapid foliar growth due to cool, wet growing conditions. In a normal year our potato ecosystem is exposed to Bt for about 96 hours. In some years it is completely Bt-free. Systematically, we minimize and avoid Bt presence in an effort to maximize its efficacy and longevity.
To my mind this is the only legitimate way to use and safeguard Bt. Used this way, we expect our sons to be able to grow their potato crops using Bt, and their children beyond them. This is treasuring a public good, maintaining its value to society at large, and our highest sense of creating stable and ecologically sustainable agriculture. These are goals that we believe the EPA should be embracing and protecting.
It is for this reason that we are extremely concerned over the introduction and EPA registration of transgenic Bt potatoes. The consensus of experts, convened in April 1996 at the USDA National Forum on Insect Resistance to Bacillus thuringiensis, is that Bt resistance is likely given the introduction of transgenic crops. This is unacceptable. Bt belongs to society and its use should only be allowed in a renewable setting. A consumptive use of Bt, as represented by overuse, misuse and transgenics, is a theft of a public good that hurts society now and forever.
Failures of transgenic cotton and corn in 1996 should serve as a warning to all of us. EPA should revoke transgenic registrations where failures occur. At the very least, EPA should make resistance management plans mandatory for any and all transgenic crops. We look to the EPA to be the preserver of the public good and the institution that protects our moral right, and that of our children, to use Bt in a renewable manner.
Jim & Megan Gerritsen
Bridgewater, ME 04735