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Re: Fear of Pharming (22/9/2004)

Here are the comments of EPA toxiologist Suzanne Wuerthele, writing in a personal capacity, on pharma corn. For the original Sientific American article, Fear of Pharming, see:
http://www.lobbywatch.org/archive2.asp?arcid=4360
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How quickly the discussion of GE pharmcrops has turned to tolerances - allowable amounts of drugs in our food. What we are talking about here is countenancing a new class of food contaminant.

While it is true that there are certainly levels of drugs which are not pharmacologically active and therefore "safe", that does not mean that setting tolerances for drugs in food will prevent toxicity to humans and wildlife or contamination of the environment. Consider pesticide tolerances in food:

1) The actual tolerances to set are argued vigorously by the pesticide manufacturers' scientists and lobbyists and they are not arguing for lower levels. Imagine a drug company with millions of dollars to send scientists and lobbyists to federal regulators' offices, and to take Congresssionals and political appointees out to dinner to argue for a higher level of a hormone in corn. Imagine environmental groups sending
grad student volunteers to lobby for lower tolerances.

2) Risk/benefit analyses determine how much pesticide is ultimately allowed in food. Those who bear the risks don't always get the benefits. Imagine routinely ingesting a drug in your breakfast cereal because the probability of harm for you is judged to be low, and it allows drug manufacturers to make millions by cornering the market for that drug in Europe. Imagine being exposed to experimental compounds which never become drugs and never help anyone, so that pharmaceutical companies can save money on development costs.

3) Pesticide uses are curtailed and sometimes pesticides are cancelled as new toxicity data emerges. Imagine learning that the levels of hormone legally allowed in your child's food for the last 10 years were three times higher than they should have been.

4) With few exceptions, no one can predict the additive effects of multiple pesticide exposures. Now imagine you have been diagnosed with an unusual disease. You've probably been ingesting legal and "safe" doses of dozens of different drugs at different times in different foods. How will you find out if they could have, in concert, contributed to your condition?

5) Pesticides are found in our soil, water, air and wildlife because they move from farm fields to the wider environment. Imagine discovering that you live next door to a pharmcrop field (the locations are kept secret) and you've been exposed to an unknown amount of an unnamed (it's confidential business information) drug just by breathing crop dusts created during harvest. Imagine being a farmer whose irrigation water comes through that field and who will have to pay to have his crop tested for a drug which he can't identify. Imagine fishing downstream from that irrigation flow. Imagine your drinking water provider taking water downstream from it. Imagine eating a duck or deer you shot that had been feeding in that field.

6) Pesticide applicators make honest mistakes, like applying the wrong amount of chemical to a crop. These can and have caused human illness. FDA can monitor only a tiny percentage of foods for above-tolerance amounts of pesticides. Now imagine the honest mistakes that can cause above-tolerance amounts of drugs to get into your food from pharmcrops: Seed mixups. Seed spills. Unanticipated pollen drift... Imagine that thanks to an honest mistake, and the inability of FDA to
test all foods, your family has been exposed to an over-tolerance amount of a potent drug.

7) It happens. A few pesticide applicators, and even manufacturers cheat. They don't follow the rules, with negative health and environmental consequences. Imagine a biotech company which plants its pharmcrop too close to a crop with which it can cross pollinate. Imagine a company which doesn't check for volunteer plants. (Oh, wait, that actually happened). Imagine a company which intentionally plants an extra "event" in a permitted field so it can get extra data and a drug even USDA doesn't know about gets into food...

8) After 9/11 we learned that some of the terrorists were learning to fly planes used for aerial pesticide applications. If there are tolerances for drugs in food, FDA will have to estimate exposure based on location and size of pharm crops. Now imagine someone stealing pharmcorn and intentionally planting it all over the seed production areas.

The Union of Concerned Scientists has it right: the tolerance for drugs in foods has to be Zero, and the only way to get there is to not manufacture drugs in food crops in an uncontrollable outdoor
environment.
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"Corn is the world's worst organism for this," says Norman Ellstrand, a plant geneticist at the University of California at Riverdale and director of the Biology Impacts Center.

"When I heard about this, my first thoughts were, 'What were they thinking?'"
http://www.lobbywatch.org/archive2.asp?arcid=4360

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