“Starlink” Demonstrates That Bt Plants Are Harmful to Organic Agriculture
Docket Control Number PF-867B
Submitted by Tom Hutcheson,
Associate Policy Director
November 27, 2000
The Organic Trade Association (OTA) urges EPA to deny any expansion of the use of Bt crops, including denying the petition for the continued production of StarLink. Not only are there health concerns, there are not sufficient controls over the product to significantly reduce the risk of genetic contamination of organic corn.
Bt is the most widely used biological pest control in organic agriculture,[i] and its discrete, temporary pattern of use by organic farmers has been adopted precisely to avoid pest resistance. StarLink was designed in recognition of the fact that Bt plants will lead to resistance to Bt among insects. The Aventis white paper “Unique Attributes of Cry9C (StarLink) Bt Help Assure Long-Term Viability of Bt in Crop Protection,” by Susan C. MacIntosh (Product Safety Manager, Global Biotechnology, Aventis CS USA, LP) states:
“Corn genetically engineered with Bt to control European corn borer (ECB, Ostrinia nubilalis) has been economically proven in farmers' fields across the U.S. But even as these benefits unfold in farmer fields, a shadow is being cast across Bt corn’s future.
“A possible threat to Bt arises from the potential development of insect resistance to Bt. Now, a new Bt protein called Cry9C, marketed as StarLink, can be used to address those concerns because of its unique composition and characteristics.”[ii]
It is this rush to prepare for insect resistance to other forms of Bt biopesticides that has resulted in an untested and potentially unsafe food becoming entwined with the human food chain. We can only hope that the contamination of the food supply by this gene is not permanent.
OTA requests EPA to reject the application to allow the presence of this gene in the food supply and further requests that EPA assess the damage to organic agriculture by Bt biopesticides.
[i] Organic Farming Research Institute. 1999. Final Results of the Third Biennial National Organic Farmers’ Survey. Page 80.