Addressing Seed Purity – Part 1 of 2

This post was written by Kristina Hubbard, director of advocacy and communications for Organic Seed Alliance. She recently published an article in Agriculture and Human Values entitled, "Confronting coexistence in the United States: organic agriculture, genetic engineering, and the case of Roundup Read alfalfa."

For another opinion on organic seed issues, visit UNFI VP of Policy and Industry Relations Melody Meyer's blog, Organic Matters.

Seed has been in the national headlines a lot these days. We’ve read about chefs teaming up with plant breeders to explore seed as a new frontier, and been reminded that good genetic diversity in our farm fields is important to improved taste and nutrition, as well as food security. Yet no issue gets more attention in the context of seed than that of genetically engineered (GE) crops and the controversy surrounding them.

Nearly half of U.S. states introduced bills this year requiring GMO labeling or prohibiting GE foods. There was also the discovery of unapproved GE wheat in Oregon this past spring. Also in Oregon, a longstanding struggle continued to keep canola (most of which is GE) out of the Willamette Valley to protect the burgeoning specialty crop seed industry.

Many of us in the organic community have spent years confronting the challenges posed by the interface of genetic engineering and organic agriculture. Farmers, organic seed companies, processors, and others have worked to keep unwanted GE traits out of their products to avoid impacts to the integrity of seed and food, and the livelihoods tied to them.

To date, these efforts have been one-sided. The current regulatory framework for GE crops does not require manufacturers or farmers using these crops to implement preventative measures to mitigate risk and harm, and instead relies on industry-led stewardship standards, a self-regulating approach that has no legal and regulatory teeth. The current regulatory framework for GE crops also lacks post-market monitoring and reviews – including testing, data collection on contamination, and general oversight – which has only made it more difficult to understand the challenges and consequences.

Field trial oversight in particular is woefully inadequate. The discovery of unapproved GE wheat in Oregon this past spring brought into stark relief the difficulty of containing GE crops and the inadequacy of current oversight of experimental trials. It also reinforced the sensitivity of our export markets, all of which reject GE wheat, in addition to the failure of USDA’s GE crop review process to consider potential market risks of new GE plants.

Following the discovery of GE wheat, OSA collected signatures from more than 150 businesses and organizations in a letter addressed to USDA calling for improvements in oversight of experimental GE crop field trials. In August 2013, OSA convened a delegation of wheat growers and other stakeholders to meet with Secretary Vilsack about the concerns outlined in this letter. While the investigation into the cause of the Oregon event is ongoing, the secretary promised a full report on the agency’s findings, including its sampling protocols and testing methodologies. We are still waiting for answers to other questions, including how the agency has handled more than 480 field trial violations over the years.

Major improvements are needed, as documented by the National Research Council and USDA’s own Inspector General (IG). For example, the IG’s audit report noted that the agency lacks “basic information about the field test sites it approves and is responsible for monitoring, including where and how the crops are being grown, and what becomes of them at the end of the field test.”

There is a lot we don’t know about experimental field trials underway on thousands of acres across the United States because most of this data is not made public. What we do know is that the burden to protect the integrity of organic unfairly falls on the shoulders of those who avoid GE products. Certified organic farmers in particular are required to follow a strict production plan that includes mitigating the risk of excluded methods and prohibited substances, including transgenic crops. And when contamination is found and the extent unknown, as was the case in Oregon this past spring, the costs associated with testing (or market loss) fall on the injured parties.

Even before the wheat event, the issues of “coexistence” and “who pays” in cases of contamination were the focus of industry discussions, organizing efforts, and lawsuits. In 2011, following the extremely controversial approval of GE alfalfa – the first perennial field crop to be released with a GE trait – Secretary Vilsack re-convened USDA’s Advisory Committee on Biotechnology for 21st Century Agriculture. He charged committee members with addressing coexistence, including what an appropriate compensation mechanism might look like for dealing with economic losses attributed to the unwanted presence of GE crops. The final recommendations were published last November, and a Federal Register notice asking for public comments in response to the recommendations is expected any day.

OSA provided public testimony at two of the committee’s meetings. Our comments can be found here and here. Although most committee members agreed that the status quo isn’t good enough for U.S. agriculture, our concern is that some of the recommendations, if adopted, would not only sustain the status quo but actually worsen current burdens and costs associated with coexistence for stakeholders who neither use nor benefit from GE seed.

One example is that the recommendations point to the crop insurance model as an appropriate compensation mechanism, where organic and other non-GMO producers would be told to pay more to protect themselves. We believe this approach is unjust, and that a more appropriate model would take into account proportional responsibility for ownership, such as a compensation fund paid into by technology owners. (To stay updated on when this public comment period opens and our own additional comments, follow us on Facebook, Twitter, or through our blog.)

As public input has long demonstrated, the organic community strongly agrees that genetic engineering has no place in our collective vision of what constitutes an organic production system. We are also united in our agreement that the burden of contamination prevention and must not rest with organic stakeholders alone.

Protecting the integrity of non-GE seed to meet market needs and maintain appropriate germplasm for innovation in the organic sector is paramount to the success of the organic industry. Not only does the NOP require non-GE seed, consumers of organic food also reasonably assume that certified organic farmers use non-GE seed.

In light of the urgency and widespread public interest in preserving organic seed as integral to retaining public confidence in USDA’s organic label, the NOSB created an ad hoc GMO subcommittee last year to look at ways the NOP can more directly address the challenges posed by the interface of GE and organic products.

Next week, I’ll write another post about these and other efforts within the organic community to confront contamination and protect the genetic integrity of seed.

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