The USDA is accepting public comments following an invitation-only workshop on “coexistence.” We watched the event from afar and were disappointed by the imbalance in participation and presentations, where there was clear bias toward the interests of the biotech industry. Furthermore, the most important issues at hand were absent from the conversation, including how to prevent the problem of contamination to begin with.
Comments are due May 11, 2015
Submit comments electronically at this link. Submit comments by mail to: Docket No. APHIS-2013-0047, Regulatory Analysis and Development, PPD, APHIS, Station 3A-03.8, 4700 River Road Unit 118, Riverdale, MD 20737-1238.
The agency is seeking comments on the workshop it held and activities underway in response to recommendations provided by the agency’s Advisory Committee on Biotechnology and 21st Century Agriculture (AC21).
- Watch the March workshop, view presentations, and find other related documents here. The coexistence workshop held in March was a lost opportunity for productive discussion and strategy. OSA believes the event failed to present balanced and fair presentations and discussion on the problem at hand. Did you watch the webcasts? What did presenters get right? What did they get wrong? Include answers to these questions in your comments.
- Read the USDA activities underway in response to recommendations from AC21. OSA supports many of the recommendations being implemented, including: improving crop insurance options for organic farmers, funding research on gene flow and mitigation techniques, examining our public seed collections for GE contamination, supporting the Organic Seed Finder database, and evaluating the commercial availability of organic and non-GE seed varieties.
- Read the USDA’s proposed activities in response to recommendations from AC21. OSA is happy to see proposed initiatives that aim to gather data on the economic impacts of GMO contamination. Other initiatives focus on best practices for GE traits in seed stocks and communication and outreach strategies between growers. We believe best practices that aim to prevent contamination are important. We also believe that such a strategy cannot rely solely on voluntary compliance, which is why we enthusiastically support the USDA’s plans to update GMO regulations. While communication and outreach to farmers (and between farmers) is important, this strategy alone isn’t enough to prevent the problem of contamination and resolve disputes that arise. The last thing we need is to pit farmers against each other when communication and prevention strategies fail.
Other talking points:
USDA should level the playing field. The burden of preventing contamination is currently on organic and other non-GMO operations. Responsibility must be tied to ownership. Those who patent, promote, and profit from GE products should be responsible for preventing contamination and covering damage in cases where prevention fails.
USDA should establish a fair compensation proposal. The patent holder should be responsible for segregation and traceability, from seed to plate. They should be held responsible for the economic and market harm their products cause.
USDA should more fully analyze environmental and economic implications of GE contamination and the implications of managing GE crops. These are also of critical importance to the ideas underpinning “coexistence” – how one system of agriculture can directly and indirectly impact the viability of the other.