Tilth Producers submitted the following comment to USDA in response to their request for comments on the issue of “agricultural coexistence”. Submit your own comment online here (deadline: March 4, 2014).
Resources for submitting a comment:
National Organic Coalition alert
The National Sustainable Agriculture Coalition’s resource page
Tilth Producers’ video about submitting comments on regulations.gov (specifically about the Food Safety Modernization Act, but the online form works the same way)
Read comments in PDF form
The following comments are on behalf of Tilth Producers of Washington, a 600+ member organization of Washington state organic and sustainable farmers and allies. The issues of coexistence and contamination are of key importance to us as an organization of organic farmers. Especially where genetically engineered (GE) crops are concerned, Tilth Producers believes that the responsibility to prevent contamination falls on the patent holders of potentially contaminating crops and those who grow them, not their organic farmer neighbors.
In response to question 1, “As we seek improved communication and collaboration among agricultural stakeholders, we are interested in identifying information needs and exploring successful communication methods.”
The primary type of information needed in promoting agricultural coexistence is full transparency with regards to where GE crops are grown and who grows them. This can be achieved only by mandatory labeling of GE crops throughout the food supply chain, from seed and seed stock to ingredients in products on grocery shelves. An online, publicly-accessible registry of where GE crops are planted would also help to increase transparency.
In addition to complete information about which crops are GE and where GE crops are grown, information regarding best practices to prevent contamination should be shared. To ensure they are followed, the best practices should be mandated by law and enforced. USDA must use its authority to prevent GE contamination throughout the supply chain.
More research is currently needed into best practices for GE contamination prevention. Although there are suggested management practices associated with the use of many GE crops (such as recommended isolation distances) these are not always scientifically sound. For example, the recommended isolation distance for glyphosate-tolerant alfalfa is 900 feet to keep plants from cross-pollinating with non-GE fields. However, contamination from transgenes has been found in fields with a 1.5 mile isolation distance (NOC, 2010). More research is needed to identify truly effective means to prevent GE contamination. The following principles, outlined by the National Organic Coalition, should frame the process of developing means of preventing contamination:
PRINCIPLES TO DRIVE GMO CONTAMINATION PREVENTION STRATEGIES
Consumer choice – Consumers have the right to choose non-GMO food.
Consumer right to know – Consumers have the right to know where and how their food was grown.
Farmers Entrepreneurial Choice – Farmers must have the right and opportunity to grow food, feed, fiber, livestock, and fish that serve important and lucrative domestic and foreign markets.
Fairness – Personal and corporate responsibility must be upheld. If you own it and are profiting from it you are responsible for the costs associated with contamination prevention and any resultant damage from contamination.
Liability –Testing for contamination, establishing buffers, reimbursement for lost sales, loss of organic product premiums, clean-up and removal are the costs of doing business that must be borne by the GMO patent holder.
Precaution – The pre-market burden of proof of safety is on the patent holder. This includes comprehensive evaluation of health, socio-economic, and environmental impacts of GM crops and technologies.
Sustainability – Agricultural technologies and systems must be assessed for sustainability and those that facilitate further declines in family farming or erode the human and environmental foundations of American agriculture must not be allowed.
Health, Environmental and Economic Evaluation –Technologies that pose environmental, economic, and health risks should be evaluated before commercialization and tough choices must be made about whether their overall societal benefits outweigh their costs.
Parity – There must be a long-term commitment to supporting the vitality of diverse agricultural enterprises, including parity of public investment, infrastructure, marketing, technical assistance, research, and funding.
Transparency – Ongoing documentation, tracking and labeling systems must be established to monitor the movement of GMOs in the environment, seed banks, non-GMO seed stocks, and food.
Diversity – Society and agriculture will greatly benefit from the rapid reinvigoration of public cultivars and breeds to restore genetic diversity on farms, ensure greater farmer seeds/breeds choices, and to enhance national food security.
Once best practices are established, they must be enforced by a third party. Voluntary measures and education alone are not enough to ensure compliance. To help growers of GE crops understand their new mandatory responsibilities to prevent contamination, mandatory training should be provided, similar to current requirements for pesticide safety training.
In response to question 2, “As part of USDA’s outreach and education efforts, we are interested in identifying education needs and exploring the creation of ‘‘outreach toolkits’’ that will encourage communication, planning, and crop- specific practices to facilitate successful coexistence.”
More than education is necessary for the prevention of GE contamination and successful coexistence of GE and non-GE/organic growers. Best-practices for contamination prevention must be established and required of GE patent holders and growers. However, Tilth Producers understands that education is one component of preventing contamination. As an organization which conducts quite a bit of farmer-to-farmer education, here are some strategies we employ:
Conference: We hold an annual conference where farmers and agriculture professionals share strategies for successful farming in workshop format.
Journal: We produce a quarterly journal, written by staff, guest experts, and farmers which includes articles on a wide array of organic farming topics. The journal is published in print and mailed to our members, and is also available to them on our website.
Farm walks: We host a series of “farm walks” each year where farmers tour one another’s operations to observe innovative systems and learn new skills.
In response to question 3, “Farmers and others in the food and feed production chain have an important role in collaborating to make coexistence work, particularly with reference to stewardship, contracting, and attention to gene flow. As we seek to improve collaboration among those involved in diverse agricultural systems, we are interested in hearing what practices and activities that support collaboration are available or in use and how USDA can help make collaboration and coexistence work for everyone involved.”
Collaboration can only be achieved if the issue of GE technology is addressed with transparency. Currently it is hard for producers to know their legal rights surrounding GE contamination and if GE crops are being grown in their area. The establishment of an online registry would allow farmers to track where GE crops are being grown.
Collaboration and communication between farmers is not enough to foster successful coexistence. Contamination prevention is the responsibility of GE manufacturers and growers not organic farmers. Best practices for contamination prevention must be researched and required of those in the GE industry. Making GE growers accountable to USDA and not just their neighbors will improve collaboration and coexistence among agricultural sectors.
When contamination does occur, organic growers need a fair compensation mechanism. AC21’s crop insurance proposal unfairly places the burden on organic and non-GE growers to protect their fields from contamination. Contamination prevention and compensation should be the responsibility of manufacturers, producers and those who profit from GE technology not bystanders suffering from their impacts.
Thank you for reviewing these comments and for taking the rights and needs of organic growers into consideration as this process moves forward.
National Organic Coalition (NOC). Comments on Draft Environmental Impact Statement recommending the deregulation of genetically engineered alfalfa. Docket No. APHIS-2007-0044. (2010)