Scientists Comment on Proposed EPA Plant Pesticide Rule

October 19, 1998

Scientists Comment on Proposed EPA Plant Pesticide Rule
Proposal to Designate Plants as Pesticides
What are the possible consequences of the U.S. Environmental Protection Agency (EPA) proposed plant pesticide rule? The Council for Agricultural Science and Technology (CAST), an international consortium of 36 scientific and professional societies, released an issue paper, The Proposed EPA Plant Pesticide Rule, in which a CAST panel of five members of the National Academy of Sciences discusses this proposal. In 1996 and 1997, two reports were published in which eleven professional scientific societies and an advisory panel of the Biotechnology Industry Organization (BIO representing over 550 companies and affiliated organizations) discussed the issues relative to the EPA proposal. The CAST panel formed in 1998 was charged with examining the scientific merits of the differing viewpoints based solely on scientific principles.
What is the Proposal?
Under statutes developed for chemicals applied externally to plants, the EPA proposes to regulate genetically engineered plants containing genes for pest resistance that have been introduced by techniques of recombinant deoxyribonucleic acid (rDNA). Plants with such genes would be designated pesticides.
Scientists View Proposal as Indefensible
The CAST panel members, as well as other scientists, say designation of plants as pesticides is indefensible on scientific grounds for the following reasons.
  • Pest resistant plants produced by genetic engineering may be indistinguishable from plants bred for pest resistance by conventional methods. These latter plants are exempt from the EPA proposed guidelines even though the end results of recombinant DNA strategies are the same as conventional breeding.
  • Scientific panels have stated that genetically modified crops should be judged on their safety, allergenicity, toxicity, and other properties, and not the means by which the trait has been introduced. Thus, the properties of the modified plant, in terms of risk, are important, not the technique used to modify the plant.
  • Numerous mechanisms, which confer resistance to pests, exist in plants. It is scientifically illogical to combine these various mechanisms in plants into one category and state that they must be regulated if they result from recombinant DNA technology.
  • No evidence exists that the plant's level of resistance to pests creates hazards in the environment.
Scientists Foresee Serious Economic Consequences
If the EPA rules go into effect, the CAST panel foresees the likelihood of serious economic consequences in the food industry.
  • Labeling plants as pesticides would undermine public confidence in the safety of the food supply. If plants are safe for human consumption, there is no reason to label them as pesticidal.
  • Adoption of the proposed EPA regulations would discourage development of pest resistant minor crops or crops resistant to minor pests, which would delay the time until chemical pesticide use can be decreased.
  • Enforcing the EPA regulations would increase the regulatory burden on all companies as well as on the EPA. Small companies, who are the ones most likely to develop pest resistance in those minor crop plants, could be forced out of business or find it necessary to change their business plans by the increased paperwork and scientific data gathering.