UCS Position Paper: Pharmaceutical and Industrial Crops
Most of the genetically engineered (GE) crops currently on the market are food or feed crops that have been modified for agronomic purposes—to better repel pests or to be compatible with chemical pesticides. A new generation of crops is now being modified for different purposes—to produce medicines or industrial compounds such as plastics. Many of these substances are being produced in corn and other food crops visually indistinguishable from their non-industrial counterparts. Contamination of food crops with drugs or industrial chemicals could occur through seed mixing and cross-pollination. The potential contamination of food crops with the hundreds, if not thousands, of drugs or industrial compounds promised by this industry poses new and serious risks to the safety of the food system. Pharmaceutical and industrial compounds also pose potentially serious risks if released into the environment.
This paper details the position of the Union of Concerned Scientists (UCS) regarding federal policy on crops genetically engineered to produce pharmaceutical and industrial compounds. After careful analysis, we have concluded that current U. S. Department of Agriculture (USDA) regulations governing such crops, although stronger than they have been in the past, are still insufficiently stringent to assure the complete protection of the food supply in the United States. Moreover, the routes of contamination in existing commodity crop production systems are so numerous that even very strong regulatory systems may not be sufficient to prevent the contamination of the food system with crops genetically engineered to produce pharmaceutical and industrial compounds. Although it may be theoretically possible to design an adequate regulatory system, we believe it would be too complex to be implemented effectively by the USDA, the federal agency with primary authority over GE pharmaceutical and industrial crops.
Because of the vital importance of commodity food crops to agriculture, the U.S. economy, and our food system, UCS believes that rather than attempting to impose ever more elaborate restrictions on the growing of food crops engineered for pharmaceutical and industrial purposes, it would be better to ban such applications altogether.
UCS is also concerned about risks to the environment from the outdoor production of both food and non-food pharmaceutical and industrial crops. We are not, however, calling for a ban on all outdoor production of such crops. At present, we believe that the regulatory system probably could be strengthened sufficiently to reduce environmental risks to acceptable levels. We believe that our approach, which combines a ban on outdoor production in food crops with a tightening of regulations on production in non-food crops, warrants support from the broadest possible spectrum of stakeholders.
The effect of the ban would be either to encourage genetic engineers interested in pharma and industrial applications to shift from food crops to non-food crops, or, even better, to further develop completely enclosed production systems based on GE plant or animal cells, bacteria, fungi, or algae. Enclosed systems, which pose little or no threat to the food supply and the environment, have already been used successfully to produce drugs approved by the Food and Drug Administration (FDA).
In this paper, we provide background on the current status, potential benefits and risks, and federal regulation of pharmaceutical and industrial crops (referred to as "pharma/industrial crops"); offer two recommendations for strengthening federal oversight, including a ban on the outdoor production of food crops for such purposes; explain our rationale for a ban; and briefly discuss how such a ban would be implemented. In addition, we attach a document ("Frequently Asked Questions") providing answers to a number of questions we expect to arise regarding the impacts of such a ban and our reasons for rejecting alternative regulatory approaches.
DOWNLOAD: UCS Position Paper on Pharmaceutical and Industrial Crops
