Rod Townsend, Director, Regulatory

Regulatory Process | Labeling | More Comments from Rod Townsend | What are we looking for in the testing process? | What are specific jurisdictions of various regulatory agencies? |

Transcript for Clip 1 -- Regulatory Process

...We have to work with three different parts of the government in order to get a product approved to go onto the marketplace. We have to work with the United States Department of Agriculture, the USDA, also with the Environmental Protection Agency, the EPA, and with the Food and Drug Administration, the FDA. It's a fairly extensive process of testing that lasts several years. It is testing not only out in the field to find out how the product grows, but to find out how it interacts with the environment, and to take a lot of samples out in the field and bring those back to the laboratory and analyze them. A lot of biochemistry is done on these crops and of course a lot of safety evaluations looking at food safety and feed safety.

Transcript for Clip 2 -- Labeling:

Well we would like to make sure the public has as much information on the food they're eating as possible. However I don't think it's always going to be possible to convey that information through labeling on a product. [Just] think about the way that we handle the corn crop in this country--where basically everything is harvested all at one time. It's stored in huge quantities in vast elevators and shipped around the country in large rail cars or in boats that hold hundreds of thousands of tons of grain. We really don't have a system that supports the sort of segregation that would allow you to have a stream of product that's GM and a stream that's non-GM, so that would make labeling very difficult.

More comments from Rod Townsend...

Q: What are you looking for in the testing process?

A: Let's consider for example a corn plant that might have been made resistant to an insect. We would be looking to make sure that the new gene we had put into that plant was stable, it was the same gene that we put in there, it hadn't been rearranged, that it was still working the way we intended it too. So we would take samples from lots of different plant tissues and plants grown in different environments, and measure the amount of protein being produced just to assure ourselves that the product really was behaving as we expected it to. We'd then look at the safety of the protein itself and that would involve maybe a lot of biochemistry to produce enough protein so we could actually feed that to animals, usually we choose mice for example and feed them a huge excess of what any human might be exposed to when they ate that product. We would also assess the potential of the protein to be a toxin, again that should show up very quickly in a test on mice if this protein has any toxic effects. We also evaluate it to find out whether or not it has any potential to be a food allergen. Of course we're very concerned with avoiding anything that might be allergenic so that people don't develop new allergies or we don't cause people who are already allergic to something to become ill. We also have to look very closely at the properties of the crop itself. So we look at the composition of the crop very carefully we measure a large number of parameters; the protein composition, the amino acid composition, the oil profile, the carbohydrate profile, any natural toxicants that may be in the products. After all many of our food crops contain a lot of natural toxins and it's important to make sure that we haven't changed the composition of those natural toxins during the genetic engineering process. And of course we also want to know that these products are safe for people to eat and animals to feed on but also that they're not going to have adverse interactions with the environment. So we would test the crop or the protein against some representative species particularly insects that are beneficial in fields, things like ladybugs that eat aphids. We would test the proteins against ladybugs and make sure they're not adversely affected. We might also feed the crop to birds for example to make sure they don't have any adverse effect on wildlife. So it's a series of these environmental tests. Looking also at for instance how quickly does it break down in the soil because we don't want to put some materials into the soil that are going to stay there for a long period of time. We're also concerned that it wouldn't affect things like earthworms which are important in maintaining soil quality. So again we look at a whole spectrum of these soil invertebrates, make sure they're not adversely affected. Once we've gone through all these different tests aimed at food safety, feed safety, and environmental safety, then we can go to the federal agencies, the FDA, the USDA, the EPA, and ask them for approvals to put out products on the market and that process can take several years.

Q: What are the specific jurisdictions of the various regulatory agencies?

A: It's a coordinated framework of regulations and the USDA looks particularly at the agricultural properties of the crop, for instance does this new plant that you've produced have any potential to become a weed that might be invasive of agricultural environments? Or could the gene outcross for instance through pollination/cross-pollination to a wild relative for instance and then become part of the natural flora which is something one would not want to see if that was going to have some sort of negative impact on the natural flora. So USDA's very much concerned about the nature of the plant and the interactions in the environment. The EPA is also concerned about the environmental impact of these products, but is much more concerned for instance about their impact on non-targets as they call them, in other words things that you don't want to kill. So if you're after killing corn-borers that there's a whole lot of other things that you don't want to kill, monarch butterflies for example. So the EPA focuses very much on the environmental impact on these non-targets. The FDA focuses mostly obviously on food and feed safety, they have responsibility for both things, not only for human food safety but they also have to evaluate these products to make sure they're safe for animal feed which is where most of them are going. So between the three agencies they have a fairly effective network that covers the environmental, the food and the feed safety.


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Posted March 6, 2001