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FIFRA Scientific Advisory Panel Bt Plant-Pesticides Risk
and Benefit Assessments Insect Resistance Management
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STATEMENT OF MICHAEL J. PHILLIPS, PH.D. EXECUTIVE DIRECTOR FOR FOOD AND AGRICULTURE
October 18, 2000
Good afternoon. I am Dr. Michael J. Phillips, Executive Director for Food and Agriculture at the Biotechnology Industry Organization. I am privileged to be here today on behalf of the Biotechnology Industry Organization. Our membership includes over 900 member companies and research institutions in North America and around the world. These members are actively involved in research and development of new medicines, foods, and industrial products to benefit the lives of people and the environment.
In the first of three days of meetings by this distinguished panel, today's focus is on insect resistance management (IRM). Bt IRM is very important because of the threat insect resistance poses to the future of Bt plant protectants and to Bt technology as a whole. Farmers, scientists, public interest groups and the agricultural biotechnology industry have expressed concern that the widespread planting of crops improved through biotechnology could hasten the development of resistance to plant protectant Bt endotoxins. Effective insect resistance management can reduce the risk of resistance development.
EPA should be applauded for instituting IRM requirements on registered plant protectants. Sound IRM requirements will prolong the life of Bt plant protectants and universal adherence to the plans is to the advantage of farmers, technology providers, researchers and the public.
Beginning with the first Bt plant protectant, EPA has taken steps to manage insect resistance to Bt with IRM plans an important component of the regulatory decision. Beginning with the 2000-growing season, EPA instituted mandatory refuge requirements on Bt field corn and popcorn products. A coalition of BIO member companies who are Bt registrants working with the National Corn Growers Association approached EPA with a uniform IRM plan for their products. With some modifications to this plan, EPA put in place a consistent set of refuge strategies for all Bt corn products. These requirements greatly strengthened the IRM plan to mitigate insect resistance to Bt proteins produced in field corn. For this growing season, EPA required a 20 percent non-BT corn refuge to be planted within one-half mile. EPA also required a 50 percent non-Bt corn refuge for Bt Cry 1Ab corn products in certain southern states and counties where most cotton is grown. This was done to mitigate the development of resistance to Bt proteins for those insect populations that feed on both corn and cotton.
Refuge Strategies
The current IRM plan was developed to help sustain the performance of Bt corn in all areas of the corn belt, including the high-plains region and other areas where insecticides have historically been used. Farmers must have the flexibility to control other important pests (e.g., mites and CRW beetles) infesting Bt corn and non-Bt corn refuges, as well as high infestations of corn borers that could cause severe economic losses to unprotected non-Bt corn refuges. Farmers cannot predict at the time of planting whether insecticide sprays later in the season will be needed; consequently farmers cannot be expected to sacrifice the economic benefits of planting of Bt corn.
Current Bt corn IRM requirements are based upon Integrated Pest Management (IPM) principles designed to reduce the need to apply insecticides for supplemental pest control. Experts expect that reduction in pest population resulting from increased adoption of Bt corn will lead to reduced pest outbreaks in refuges and less need to spray conventional insecticides. Any further limits on the use of Bt corn (such as increasing the refuge size) in regions where insecticide usage has historically been high would reinforce continued use of insecticides and compromise potentially important environmental benefits resulting from reduced reliance on conventional insecticides.
Monitoring Programs
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, Stoneville, Mississippi. 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.
For cotton, a three-tiered approach includes a modified F2 screen for CBW as well as continuing testing of targeted pest populations and instances of unexpected damage. For corn, monitoring has been intensified and focused to regions of greater Bt corn adoption and insecticide use. The new monitoring plans are designed to detect small shifts in pest sensitivity, and under most circumstances should allow for detection of pest adaptation before field failures occur and allow implementation of mitigation steps to slow the spread of resistance. We believe these improvements are adequate and suggest that the plan be implemented and evaluated before any further modifications are initiated.
Grower Compliance
To be effective, the IRM plan must achieve a high level of grower compliance. Refuge requirements must be logistically feasible, economically sound and flexible, including a variety of options to address unique characteristics of individual farming practices and challenges.
A major theme of the 1998 EPA sub-panel on Bt plant pesticides and resistance management was grower acceptance of IRM programs. Quotes from the Consensus Statement include "... regulatory strategies used in development of such programs should provide growers with a sustainable approach and not discourage them from employing this very valuable and environmentally friendly technology"; "... resistance management programs should be based on structured refuges designed to provide sufficient numbers of susceptible adult insects with a minimum of economic and logistical impact on producers"; "... grower participation is the key factor in successful implementation of resistance management, and grower acceptance is likely to hinge on economic and logistical feasibility".
Education is the most effective means to support a high level of grower compliance. The biotech industry works together with various crop organizations such as the National Cotton Council and the National Corn Growers Association to communicate IRM plans and information to growers. A program that educates growers to the necessity of IRM and provides guidance on deployment of IRM programs needs to be an integral part of any resistant management strategy. BIO members make every attempt to provide growers with consistent messages and with the most current resistance management guidelines.
Collaboration among stakeholders has helped to achieve a high level of compliance. Efforts to increase understanding and awareness of IRM requirements have been successful; compliance with Bt crop resistance management strategies is generally high . over 80 percent. Growers have accepted the responsibility for resistance management so long as approaches are logistically feasible, economically sound and flexible for a variety of common farming practices. Consistent and simple IRM strategies are critical to reduce confusion and ensure compliance with IRM requirements'surveys provide honest feedback through confidentiality and anonymous participation and allow evaluation of compliance and understanding of IRM requirements in a timely and cost-effective manner. Most important, surveys provide critical information about ways to communicate and improve IRM compliance programs.
To achieve a higher level of grower compliance, programs may need to be developed to ensure grower conformity. We would support studying alternative mechanisms regarding IRM compliance to ensure that resistance is kept at a bare minimum.
All available data indicate that after five years of commercialization, no reported insect resistance has occurred to the Bt toxins expressed either in Bt potato, Bt corn or Bt cotton products. Bt insect resistance management is the key to assuring that target pests do not build up an immunity or resistance to the individual plant protectants. BIO shares EPA's and others. concern that the potential for insect resistance be addressed through appropriate management practices. But above all, an IRM plan must be grounded in sound science and constantly up-dated as the science changes to prolong the utility of the Bt crop protectants and guard against unintended consequences.
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