Katherine Ozer is executive director of the National Family Farm Coalition. This statment was delivered to the EPA FIFRA Scientific Advisory Panel (SAP) on November 28, 2000. PUBLIC COMMENT: Docket Number OPP-00688. Request Published in October 31 Federal Register (Volume 65, Number 211)

Assessment of Scientific Information Concerning
StarLink Corn Cry9C Bt Corn Plant-Pesticide

On behalf of family farmers who are members of the National Family Farm Coalition (NFFC), I appreciate this opportunity to present our concerns to be considered as part of the public comment process on the response to the submission by Aventis requesting consideration for the retroactive approval of StarLink corn for human consumption. NFFC is an active participant in the Farmer to Farmer Campaign on Genetic Engineering. How the government responds to the current StarLink fiasco is an important indicator of how the public perceives the role of government in food policy.

As an organization representing farmers who grow crops in an effort to make a decent living, the thought of an after the fact, retroactive approval process is simply outrageous. We support a strong regulatory process - one that truly examines the longterm effects of all genetically engineered crops. The scrutiny for all types of genetically engineered crops needs to be examined to ensure that all issues are being addressed before approval - instead of after the fact. In this case, we applaud EPA for recognizing that there were potential negative impacts for human consumption of the Cry9C Bt corn but would strongly question why there was a dual approval process - one for humans and one for feed. This dual approval process either totally ignored the issues or made the inaccurate assumption that it is possible to separate crops - on the field, in the air, and through the marketing channels.

To date, this has been a very expensive experiment. For family farmers, it is not only the expense for those farmers whose fields have been contaminated but the further reduction in the demand for U.S. exports. With a record corn and soybean crop, and the lowest prices in decades - this situation is deplorable.

The Aventis corporation tried to limit their risk by sending out planting agreements as farmers were harvesting that outlined the buffer requirements as well as marketing information. This was a clear example of trying to account for a very sloppy sales and marketing process. Fortunately the Attorneys General in at least fourteen states have expressed their growing concerns with a letter to Aventis urging clarification on some major issues. While we support the actions to date of the AG’s and have encouraged them to go further on issues of liability, we feel that regulatory issues of this magnitude must be addressed on a national level with real action by USDA and EPA, not simply letting each state address the issue separately. Tomorrow, we will send a letter to USDA Secretary Glickman outlining some of our concerns and present testimony at the meeting of USDA’s Advisory Committee on Agriculture Biotechnology.

This is not just an isolated situation affecting StarLink and corn producers, it is an example of the increasing corporate control of our food supply. We strongly urge the EPA to increase their scrutiny and scientific review on the approval of all genetically engineered seeds and crops. This is an essential step to restore the confidence in the food supply by consumers - whether in the U.S. or around the world. A retroactive approval of StarLink would be devastating to farmers and consumers - reducing even further any semblance of confidence in our regulatory system.

Again, I thank you for the opportunity to present our concerns. We strongly urge this panel to recommend that StarLink not be on the market for either food or human consumption. We further urge that a regulatory process among the applicable government agencies be established that conducts an independent and comprehensive assessment that addresses the economic, environmental, and health impacts of a proposed genetically engineered seed or crop. The EPA/FIFRA process provides the important framework for the development of longer-term studies and public input that should be a pivotal part of all future reviews and approvals.