CSPI s Comments to EPA FIFRA SAP on Bt Corn and Rootworm Resistance

Transcription

1 CSPI s Comments to EPA FIFRA SAP on Bt Corn and Rootworm Resistance Gregory Jaffe Director, Biotechnology Project Center for Science in the Public Interest December 4, 2013

2 Summary of my comments Background on CSPI and its Biotechnology Project Three facts relevant to SAP s Charges Compliance with Bt corn refuge requirements Glyphosate Resistant Weeds Characteristics of insect resistance to Bt corn Comments on SAP Charge Conclusions

3 Center for Science in the Public Interest (CSPI) Food and nutrition consumer organization. Nutrition Action Healthletter 900,000 subscribers in US and Canada. No government or industry funding. Advocacy and education based on the best available scientific evidence

4 CSPI Biotechnology Project s Positions Current crops in the US are safe to eat Some benefits from some crops Products need to be assessed on a case by case basis Functional biosafety regulatory systems that ensure safety and allow safe products to be marketed are essential Protect benefits of GE products for future generations

5 Compliance with Bt IRM refuge requirements

6 IRM for Bt for corn borer 80% Bt corn 20% non-bt corn ½ mile

7 Corn Borer-Protected Bt Corn Source: Complacency on the Farm, CSPI 2009 and Industry CAP Reports to EPA

8 Corn Borer-Protected Bt Corn Source: Complacency on the Farm, CSPI 2009 and Industry CAP Reports to EPA

9 IRM for Bt for corn rootworm

10 Corn Rootworm-Protected Bt Corn Farmer Compliance with Size Requirement 100% Compliance Rate 90% 80% 70% 60% 50% 40% 30% 89% 80% 74% 79% 73% 20% 10% 0% Year Source: Complacency on the Farm, CSPI 2009 and Industry CAP Reports to EPA

11 Corn Rootworm-Protected Bt Corn Farmer Compliance with Distance Requirement 100% 90% Compliance Rate 80% 70% 60% 50% 40% 82% 79% 63% 71% 67% 30% 20% 10% 0% Year Source: Complacency on the Farm, CSPI 2009 and Industry CAP Reports to EPA

12 AcreMax 80% Bt corn 20% non-bt corn ½ mile 10% non-bt corn rootworm

13 Pioneer AcreMax Grower Awareness Survey results Grower Awareness: 98% in % in 2012 Growers that believe IRM is somewhat or very important: 97% in % in 2012

14 Pioneer AcreMax Bt Corn Borer Size Requirement: Compliance 65% in 2011 (3% no refuge)[ %] 70% in 2012 (7% no refuge) Distance Requirement: 78% in 2011 (87% of fields but 11% no refuge at all) [ %] 86% in 2012 (87 of fields but 12% no refuge at all)

15 IRM for SmartStax 95% Bt Corn 5 5% non-bt corn

16 Industry CAP Reports for 2011 and 2012 Covers all Bt corn products except AcreMax Bt for corn borer and for corn rootworm Single traits Stacked traits Pyramided traits Different refuge sizes 5%, 20% etc.. RIB products

17 Industry CAP 2011 and 2012 Grower Awareness Grower awareness of refuge requirements: 98% in % in 2012 Grower s belief that IRM is somewhat or very important: 95% in % in 2012

18 Industry CAP Report 2011 Compliance with Corn Borer requirements: 66% for size requirement (cotton region 42%) No refuge 16% (32% for cotton region) By comparison in 2009, 76% met size requirement and only 7% planted no refuge -- compliance got significantly worse 76% for distance requirement (49% cotton region) 2009 compliance was 87% 81% of fields met distance requirement

19 Industry CAP Report 2011 Compliance with Corn Rootworm Requirements: 72% met size requirement (40% cotton region) 16% planted no refuge (32% cotton region) By comparison, in 2009, 9% planted no refuge 61% met distance requirement (38% cotton region) 70% of fields met distance requirement

20 Industry Cap Report 2012 Overall grower adherence with refuge size requirement: 65% met refuge size requirement 9% planted no refuge Those numbers INCLUDE 5% of farmers who only planted integrated product (automatically in compliance) and 45% who planted at least one integrated product That means active compliance was 60% and there was some percentage of farmers (possibly substantial) whose only refuge was integrated yet they planted products needing an active refuge

21 Industry CAP Report 2012 Corn Borer Compliance with size requirement 67% met requirement (42% cotton) 9% planted no refuge (34% cotton) Compliance with distance requirement all fields 73% (42% cotton region) Compliance with distance requirement by field 84% (66% cotton region)

22 Industry CAP Report 2012 Corn Rootworm Compliance with size requirement 77% met requirement (55% cotton) 7% planted no refuge (34% cotton) Compliance with distance requirement all fields 62% (44% cotton region) Compliance with distance requirement by field 78% (58% cotton region)

23 Conclusions from Recent CAP Reports Overall compliance with IRM in 2012 was the worst in 10 years Grower awareness is high as is their view that IRM is important Yet, actions don t reflect this knowledge Number of farmers planting no refuge is not small and is clearly unacceptable Compliance rates in cotton growing region is pitiful. Cannot assume refuge compliance when thinking about charge questions, especially questions addressing remedial action and mitigation plans

24 Compliance with Bt Corn Refuge

25 Glyphosate Resistant Weeds A Comparison

26 Glyphosate and Glyphosate Tolerant Crops Glyphosate Herbicide -- regulated at EPA Kills a broad spectrum of weeds Easy to use Breaks down quickly so reduces environmental impact CHEAP brand name and generic No till agriculture Charles Benbrook: It is one of the safest herbicides ever marketed. Monsanto s Roundup ready seeds (regulated at USDA) soybeans, corn, cotton, sugar beets, alfalfa, canola -- more than 150 million acres

27 Herbicide-resistant Major Crops in the United States* Corn 73% Cotton 80% Soy 93% Sugarbeet 95% 0% 20% 40% 60% 80% 100% *Sugarbeet data is from All other data is from Sources: Agricultural Statistics Board, USDA, June 2012; Sugar and Sweeteners Outlook, ERS July 2010

28 Glyphosate Resistant Weeds 14 weed species in multiple states Millions of acres of farmland impacted

29 Conclusions about glyphosate resistance Overuse and misuse No rotation of herbicides with different modes of action No rotation of crops No integrated weed management Problem is behavior, not the science No government imposed resistance management measures -- these are needed to force change in behavior and provide a level playing field

30 Bt Corn Resistance Characteristics

31 Confirmed Resistance Puerto Rico resistance to Cry1F South Africa resistance to Cry1Ab Midwest US resistance to Cry3Bb1

32 Observations about insect resistance to Bt corn Common characteristics High adoption Less than high dose for target pest Little or no refuge Continuous corn production Conclusion overplanting of Bt corn and no rotation is a contributing factor to development of resistant insects

33 Comments on SAP Charge

34 Overarching Principle to Apply to Charge Questions EPA must be PROACTIVE Early detection of insects developing resistance characteristics Early initiation of concrete actions to arrest the problem and prevent its spread Prevent what happened with glyphosate resistant weeds stop and reverse development of resistant organisms before problem is too large

35 Charge Questions Question #1 Support localized focused sampling that is risk based in areas where resistance is likely to develop first Question #2 Samples of insects should be collected in the area where the damage occurred (in the field) Any damage that is significantly more than what would occur in the average field should be trigger for insect sampling

36 Charge Questions (cont.) Question #3 The on-plant assays should be required to test suspected corn rootworm populations Question #4 Define resistance in a proactive manner so that there is still time for remediation to work effectively, not just stopping the spread of resistant populations but also eliminating the resistant insects

37 Charge Questions (cont.) Question #5 Define remedial action areas to be over-inclusive to ensure capture and containment of the resistant insects Question #6 Require species and toxin specific remedial action plans at time of registration (and retroactively for already registered toxins) Require separate plan for local hot spots versus widespread resistance Require remedial action plans to prioritize rotation of crops and alternate modes of action over soil incesticides (and pyramided products with same toxin)

38 Early Warning System Define local insect population(s) with increased tolerance so it is the early alert system of a biological problem with toxin Require the Bt toxin registration to include a remediation plan to address those localized populations with increased tolerance Require remediation plan to be proactive in addressing the problem e.g. not soil insecticides but rotation to soybeans Sets up a two step system 1) early warning of local problem populations, and 2) established resistance

39 Conclusions Compliance with refuge requirements continues to be poor, even with smaller refuge requirements and RIB products Involvement of EPA is essential to ensuring product effectiveness Actions around determining resistant insects populations and preventing their spread need to be PROACTIVE

40 Gregory Jaffe, Director CSPI Biotechnology Project Website: address: