Evaluate Herbicide-Tolerant Alfalfa Fully Prior To Allowing Nonregulated Status for Alfalfa Genetically Engineered for Tolerance to Glyphosate:
Comments of the Organic Trade Association to USDA’s APHIS on
Docket No. 04-085-1
Tom Hutcheson, Associate Policy Director
Organic Trade Association
60 Wells St., P.O. Box 547
Greenfield, MA 01301
January 24, 2005
The Organic Trade Association (OTA) opposes nonregulated status for herbicide-tolerant alfalfa at this time. OTA is particularly concerned that a full environmental impact statement (EIS) be required prior to commercial approval.
OTA requests that APHIS consider the following points and recommendations.
1) This alfalfa would be the first genetically engineered perennial crop with the trait for glyphosate tolerance. The dynamics of a perennial are different from those of annual crops like corn and present different risks. These should be identified and resolved before proceeding.
2) Alfalfa is cross-pollinated by bees, creating the very real possibility of RR alfalfa cross pollinating with neighboring conventional and organic alfalfa crops. For organic producers this could cost them the added value of their crops as organic.
3) Until an environmental impact statement has been completed, OTA remains concerned about the ecological effects of a glyphosate-resistant perennial, including possible changes to weed populations, impacts on biodiversity, and the need for a resistance strategy for glyphosate-resistant weeds.
4) Each instance of a gene being introduced into a plant variety, let alone specie, is a separate event, and calls for an early food safety evaluation and the identification of possible safety concerns. The whole organism should be evaluated.
5) There are currently studies underway examining the risks of transgenes from feed being passed on to gut microflora in livestock, a grave concern in the case of alfalfa, which is largely used for livestock feed.
6) Recent studies have also questioned whether genetically engineered crops have the same chemical composition as their conventional counterparts. The biotech industry has always claimed that the GE varieties are “substantially equivalent” and that nothing but the gene they have introduced has changed. But scientists are beginning to see differences in GE and non-GE crops. A 1999 independent study analyzed the phytoestrogen concentrations in two varieties of genetically modified herbicide tolerant soybeans and their conventional counterparts grown under similar conditions. An overall reduction in phytoestrogen levels of 12-14 percent was observed in the genetically altered soybean strains (Alterations in Clinically Important Phytoestrogens in Genetically Modified, Herbicide-Tolerant Soybeans. Journal of Medicinal Food v.1, n. 4, 1 July 1999. Marc A. Lappi, Ph.D., Center for Ethics and Toxics, Gualala CA; E. Britt Bailey, M.A., Center for Ethics and Toxics, Gualala, CA; Chandra Childress, M.S., Children’s Hospital Medical Center, Cincinnati, OH; Kenneth D.R. Setchell, Ph.D., Children’s Hospital Medical Center, Cincinnati, OH).
7) While only 5% of US grown alfalfa is exported, 75% of those exports go to Japan. If this alfalfa is allowed on the market those exports could be lost. The largest buyer in Japan has already stated they would not buy any US wheat if GE wheat was commercialized due to concerns of contamination and lack of segregation in our current agricultural system. Alfalfa could likely face the same rejection.
In conclusion, OTA believes this new alfalfa may pose serious ecological, agronomic, and possibly even human health risks. Unless a full environmental impact statement is completed, APHIS will not have performed due diligence in its oversight of this new and problematic plant.
Thank you for your consideration.