Raising Risk : Field Testing of Genetically Engineered Crops in the United States

Executive Summary

Although genetically engineered crops are still poorly understood, corporations and universities are growing them experimentally in the open environment with little oversight and public notification. Never before in the history of the planet have we been able to transfer genes across natural species barriers, creating unheard of combinations like tomatoes with fish genes, or even pigs with human genes. Contrary to assertions made by proponents of the technology, genetic engineering is not precise. Scientists cannot control where the gene is inserted into the host’s genetic code, nor guarantee stable expression of the gene in the new genetically engineered organism. As a result, genetic engineering raises a host of ecological and human health risks, and these concerns have not been adequately addressed.

The biotechnology industry began field testing genetically engineered plants and crops in the 1980s. Field tests are supposed to determine the impact of the new crops on the environment and how well the plants function. The U.S. Department of Agriculture (USDA), however, failed to adequately regulate these field tests from the start, and its oversight has weakened over time. An analysis by the General Accounting Office (now the Government Accountability Office) in 1988 roundly criticized shortcomings in USDA’s oversight, echoing calls by prominent microbiologists, ecologists, and others that certain regulatory decisions were “scientifically indefensible.” USDA has continued to weaken its oversight of the technology despite little empirical evidence on which to base such decisions.

USDA’s inadequate oversight of these field tests poses immediate risks. Nonnative organisms can invade and degrade ecosystems. Plants engineered to produce proteins with insecticidal properties may damage the soil or harm so-called non-target species. Plants engineered to be virus resistant can cause new viral strains to evolve through recombination or make existing viruses more severe. And if field experiments are not properly monitored, genetic pollution can result, putting farmers’ livelihoods, the environment, and human health at risk. In essence, our environment is serving as the laboratory for widespread experimentation of genetically engineered organisms with profound risks that can never be recalled once released.

Moreover, USDA has failed to require adequate data collection on field tests of genetically engineered crops, leaving the true impacts of these new creations still largely unknown. According to a review of the 85 most recent reports of field tests available in 1995, some of the most fundamental tests necessary to determine ecological effects, such as impacts on nontarget insects, were never even conducted. As the authors of the report concluded, this is a classic example of a “don’t look, don’t find” regulatory framework. Similarly, the National Academy of Sciences found serious shortcomings in USDA’s oversight, saying the agency at times “lacked scientific rigor, balance, transparency” and chastising the agency for “inadequate expertise.”

Key Report Findings
Raising Risk examines USDA data on field tests of genetically engineered crops in order to document the geographic breadth of these open air experiments and to demonstrate the implications of USDA’s inadequate oversight.

Key findings include:

- Between 1987 and 2004, USDA received 11,090 applications for field releases of genetically engineered crops. USDA has approved 10,296 of these applications, allowing 18,608 field releases comprised of 47,219 field test sites. Overall, USDA has served as a rubber stamp for applications to conduct field tests, rejecting only 3.6 percent of all applications submitted.

- As of December 2004, 14 states and territories have hosted more than 1,000 field test sites. They are Hawaii (5,413), Illinois (5,092), Iowa (4,659), Puerto Rico (3,483), California (1,964), Nebraska (1,960), Pennsylvania (1,707), Minnesota (1,701), Texas (1,494), Indiana (1,489), Idaho (1,272), Wisconsin (1,246), Georgia (1,051), and Mississippi (1,008).

- Since 1991, USDA has received 240 requests for 418 field releases of crops engineered to produce pharmaceuticals, industrial chemicals, or other so-called biopharmaceuticals; the number of requested field releases of “biopharm” crops increased from 22 in 2003 to 55 in 2004.

- The ten crops authorized for the most field releases are corn, soybean, cotton, potato, tomato, wheat, creeping bentgrass, alfalfa, beet, and rice.

- USDA authorized field tests on several crops for the first time in 2003 and 2004, including American chestnut, American elm, avocado, banana, eucalyptus, marigold, safflower, sorghum, and sugarbeet.

- Between 1987 through 2004, Monsanto (or a wholly-owned subsidiary) submitted the most applications for field tests (4,279). The ten universities submitting the most requests to conduct field tests are Iowa State (129), University of Idaho (102), Rutgers (102), University of Kentucky (80), University of Florida (78), Oregon State (69), Stanford (63), Michigan State (62), University of Arizona (55), and North Carolina State (52).

-The percentage of field tests conducted with genes considered Confidential Business Information and thus hidden from public scrutiny has increased dramatically, rising from 0 percent in 1987 to 70 percent in 2004.

Recommendations
Although USDA has authorized more than 47,000 field tests of genetically engineered organisms, USDA, the Environmental Protection Agency, and the Food and Drug Administration have not adequately answered fundamental questions about the human health, environmental, social, and ethical implications of this technology. Field tests of genetically engineered crops only should occur within a thorough and comprehensive ecological framework to assess their full impact. In order to make progress toward this goal, we recommend a moratorium on the commercialization of genetically engineered foods and crops unless:

- independent safety testing demonstrates they have no harmful effects on human health or the environment;

- the public’s right to know about field tests is improved and any products commercialized are labeled; and

- the biotechnology corporations that manufacture them are held accountable for any harm they may cause.