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The Environmental Protection Agency (EPA) has acted to reduce the likelihood that insects exposed to Bt crop plants will develop resistance. To this end, EPA has determined that effective insect resistance management (IRM) should utilize a high dose/structured refuge strategy and the agency requires that all applicants for registration of Bt technology provide IRM plans with their product.
EPA has imposed reasonable and scientifically supported IRM requirements as terms and conditions on registrants of Bt technology. The agency has required the generation of research data, development and implementation of structured refuges, annual resistance monitoring, remedial action plans, grower education and sales and research reporting for certain Bt crops.
Critical to the success of any IRM plan is grower acceptance and implementation of key crop production and pest management practices. The FIFRA Scientific Advisory Panel (SAP) on Bt Plant Pesticides and Resistance Management (U.S. EPA, 1998a) came to a similar conclusion. The sub-panel report states that "[resistance management] programs should provide growers with a sustainable approach and not discourage them from employing this very valuable and environmentally friendly technology."
The EPA IRM plan has been accepted by growers primarily because the agency plan reflects an insect resistance strategy recommended by the industry. The industry IRM plan is science-based and was developed to preserve pest susceptibility for more than 15 years. The industry is committed to implement Bt stewardship with clear and simple guidelines that are (1) adaptable to individual farming practices, (2) delivered by the participating companies and others through an intense grower education program, and (3) combined with IRM Stewardship Agreement, will result in maximal grower adoption.
Evidence of success for the IRM strategy and plans can be seen in the following:
Stewardship
- Compliance with Bt crop
resistance management strategies is high. greater than 80 percent
- Growers have accepted responsibility for logistically
feasible, economically sound and flexible resistance management plans
- Surveys are providing honest feedback through confidentiality and anonymous participation
- The biotech industry works with various crop
organizations such as the National Cotton Council and the National Corn
Growers Association to communicate IRM plans and information to growers
- Annually the biotech providers work with the scientific community and EPA to implement the most effective and sustainable IRM strategies
Monitoring
- The current corn and cotton monitoring programs were
developed in collaboration with experts and are managed and executed by
researchers at the University of Nebraska, University of Missouri and the
USDA-ARS
- Existing monitoring programs and methods were
thoroughly examined in 1999-2000 and new and improved plans for corn and
cotton were implemented for the 2000 season
- New monitoring plans are designed to detect small shifts in pest sensitivity and should allow for detection of pest adaptation before field failures occur and allow implementation of mitigation steps
Perhaps the surest sign of success comes from the fact that the EPA has found "& after five years of commercialization, no reported insect resistance has occurred to the Bt toxins expressed in Bt potato, Bt corn or Bt cotton products."
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