Wheat Follies

“That way madness lies.” – King Lear

On July 29 the U.S Department of Agriculture (USDA) announced the discovery in Washington State of wheat plants of an unapproved variety containing an herbicide tolerance trait. News sources immediately picked up the story, and Monsanto confirmed it. This set off a predictable round of breathless anti-GMO panic, as evidenced by Japan and South Korea announcing that they will “step up quarantine measures for U.S. milling and feed wheat shipments” and block certain varieties.  All this despite the fact that the rogue plants (enough to make about an ounce of grain) were in a noncommercial field, and none have been reported found in any harvests.

We have seen this movie before, in 2013 and 2014. Spoiler alert: It turns out the monster isn’t scary.

In the present case, 22 wheat plants were discovered in an unnamed farmer’s fallow field, presumably when they survived a wheat treatment with glyphosate. Harvests from adjacent wheat fields are being tested for the presence of the unapproved trait, and held pending confirmation they contain no contraband.

The unapproved plants come from a variety, MON71700, that was field tested in Washington and Oregon between 1998-2001, but never commercialized. USDA’s Animal and Plant Health Inspection Service has issued a total of 33 permits for wheat field trials over the years. In addition to Monsanto, field trials have been conducted by Oklahoma State University, Montana State, Rutgers, the University of Idaho, USDA’s Agricultural Research Service, and biotech companies Bayer/AgrEvo, Betaseed, Pioneer HiBred, Applied Phytologics, Arcadia, and Biogemma.

How these rogue plants got there is not clear. It wouldn’t take much—a misplaced seed or two, here or there. Less benign explanations are also possible, but no proffered theory really makes much sense. It seems a genuine mystery. But what are the potential consequences?

In the present case, as with the previous renegade wheat sightings, the plants involved contain the CP4 gene (from a microbe so common and widespread we’ve all been eating it, without harm,  since forever) which makes them tolerant to the herbicide, glyphosate. The usual suspects have been quick to stomp on the panic button, and claim this is an illustration of the “dangers” of GM crops. But despite the fact-free campaign of demonization currently being waged, glyphosate is one of the safest agricultural chemicals in the history of agriculture; and the gene enabling plants to resist it has been repeatedly found completely safe by regulatory authorities around the world. So what is this all really about?

The USDA announcement contains a statement that, “In recent years, USDA has taken steps to strengthen its oversight of regulated GE field trials. APHIS now requires developers to apply for a permit for field trials involving GE wheat beginning with GE wheat planted on or after January 1, 2016. The decision to require the more stringent permit process rather than the notification process employed in the past, provides added protection that GE wheat will remain confined during field trials.” This brings to mind Santayana’s statement that “Fanaticism consists in redoubling your effort when you have forgotten your aim.”

The purpose of APHIS’s regulation of biotech crops is to protect American agriculture, specifically, “plant health.” The question is obvious: “From what?” The answer is equally clear—from plant pests and diseases. These regulations stem from a policy statement from 1986, at the dawn of agricultural biotechnology, when some folks had questions as to whether or not the products of these new technologies were entirely safe, even though all indications were positive. And if there were questions 30 years ago, they have since been answered, time after time and again. So why does APHIS continue to require premarket approval for traits like herbicide tolerance, but only when they are derived through biotechnology, and not when they are developed through conventional breeding? This is difficult to justify, even without noting the clear environmental and economic superiority of the biotech varieties. What are the relevant rules?

The international trading system is organized through the World Trade Organization (WTO). The animating spirit of the WTO is for major trading countries to agree on rules that will help facilitate international trade with the intention of improving economic growth to general benefit. The playing field for trade in agricultural products is kept more or less even by rules to which WTO members subscribe under the Sanitary and Phytosanitary agreement, known as the SPS. Under the SPS, the right of countries to regulate or restrict trade in order to safeguard the health and safety of their populations and agricultural systems is acknowledged, and their rights to implement measures to that end are detailed. Measures undertaken to mitigate or manage such risks, such exposures to potential hazards, are constrained by certain requirements:

• They must be based on scientific principles and risk assessments grounded in data rather than unsupported fears.
• The level of protection must be proportional to the level of risk, which is exposure to the hazards they seek to mitigate or manage.
• They must not discriminate in favor of domestic parties at the expense of foreign parties or importers.
• Disguised barriers to trade are prohibited.

A dispassionate reading of these rules would suggest that whatever justification there may have been three decades ago for premarket scrutiny of herbicide tolerant crops produced through certain biotechnology techniques (but not others), such an approach cannot today be justified on the basis of science, data, or experience. Far from increasing the stringency of its regulatory oversight in this arena, APHIS should be looking for ways to set such requirements aside as no longer justifiable on any data-driven grounds whatsoever, and refocus their energies on areas where uncertainties may remain.

The most efficient and effective way to eliminate the potential for disruption to wheat exports stemming from the discovery of unapproved varieties that cannot, by any stretch of the imagination, threaten the health, safety, or welfare of any plant or animal on the planet, is to remove the indefensible requirement for regulatory approval. APHIS, the solution is right there, waiting. It’s time to reach out and grab it.