Yesterday, the USDA released an update on their analysis of the unexpected presence of an uncommercialized transgenic wheat in an Oregon field. There’s been a lot of unjustified attraction to the idea that since we haven’t figured out what happened yet, it must be sabotage. Unlike actual cases of anti-GM activism, there’s no direct evidence. When a lab is blown up by anti-biotech activists, it’s obviously a malicious act. Labs don’t just blow up for no reason. If a field trial goes up in smoke unexpectedly, it’s pretty obviously a malicious act. Fields that are behind locked fences with restricted access don’t light on fire spontaneously.

But this is pretty different. Unexpected seeds do actually appear in fields all the time. This is inevitable given imperfect seed cleaning, etc. Most of the time no one cares or even notices. In this case, if the farmer had tried to kill the wheat with a different herbicide, he probably wouldn’t have sent it off to be tested. Now obviously biotech seed trials are more heavily controlled than regular commercialized seeds. When the trials were ended, fields and equipment were cleaned thoroughly. Everything is inspected and documented. But humans do make mistakes and the seed line was available at dozens of places around the country for several years. It’s not impossible for some to have gotten somewhere it shouldn’t have and even possible no one noticed till now. There are literally hundreds of commercial wheat seed lines in the United States.

But they’ve tested some, of course. Monsanto, ironically doing a better job of public reassurance, has been testing commercial seed lines and publishing the results. Last week, they said they had tested enough varieties to cover 60% of the commercially planted acres of white wheat wheat in the Pacific Northwest and found no presence of the unexpected trait (white wheat is the variety the farmer in Oregon planted). The USDA’s press release doesn’t mention anything so specific which is unreassuring and vague. How many varieties have been tested? If there is some commercial seed line that has a small percentage of its output containing the transgene, it would only take a small bit of mixture. I wish the USDA would have been more specific about what they have tested.

Still, given how much has been tested, the “contamination”¹ is a mystery. Perhaps it is sabotage. But how would it happen? As Andrew Kniss noted on twitter yesterday², how would the saboteurs get the seeds? Monsanto starting shutting down the program in 2003. The last fields were cleaned up in 2005. Presumably Monsanto keeps the seed line alive somewhere, but likely that’s pretty heavily locked up. So did activists break into a Monsanto facility, find just the right seeds, then go pick a random field in Oregon to “contaminate”? Alternately, did some activists steal some seeds literally a decade ago, keep the line alive by planting and harvesting, then contaminate the field this year³?

I find the sabotage idea laughable at this point. I do not accept absence of explanation as proof of malicious intent. As far as I know there are literally hundreds of wheat lines that could have been the source. In my previous post, I clearly don’t consider this discovery unexpected or even particularly scary, but I do think it’s scary that some have so quickly jumped on malicious intent as an explanation. Many in the pro-GM side of the debate do not take the concerns of others very seriously. Escape of traits is a concern. Jumping to sabotage as the explanation rather than accepting that we don’t know everything is wrong. It reinforces the perception that some groups pushing biotechnology are arrogant and unconcerned with real risks and possibilities.

Some who oppose biotechnology spin fanciful stories about the risks of genetically engineered crops. Many of their stories depend on reasoning much like this. Without evidence, many anti-GM activists will accuse researchers or writers of being in the pay of Monsanto or wanting to “destroy the earth”. They don’t have positive evidence. They don’t need any in their mind because it’s the only explanation left in the complicated and confusing world they see.

Without evidence, a claim of sabotage here is the same. There is a world of possibilities for what happened. I’d rather a slow and careful investigation than conspiracies and accusations of malice. Instead of encouraging calm and reasoned discussions of values, risks and science, sabotage suggestions will just create a shouting match of competing conspiracies. That won’t do any good at all. To most people, Monsanto and large agribusiness surely look more malicious than activist groups who are trying to make the world better. Can we let the USDA and Monsanto continue their work? No one wins if evidence goes out the window.

This will hopefully be a short note, but something bugs me a bit about the current kerfluffle over one farmer finding a small number of wheat plants that have a Monsanto-origin trait for glyphosate tolerance. Even though we still don’t know how it got there (it’s been eight years since any field trials and it was never commercialized) or even how broadly spread the trait is in commercial seed, we’ve got entire countries stopping some wheat imports, others pushing conspiracies that it was intentional sabotage¹ and GE labeling groups using it to support their cause². But all this points to the fact that we aren’t having a reasonable discussion about the actual risks involved in plant modifications. The trait found was one that makes wheat tolerant to the herbicide glyphosate. It’s been successfully used in corn, soy and other crops. It’s safety record is quite good.

But Monsanto isn’t the only organization to develop glyphosate-tolerant wheat. Some researchers at Washington State University have developed non-transgenic glyphosate tolerant wheat, using mutation breeding (thanks to Steve Savage for mentioning it on twitter). They even patented it (most likely the university decides how to license it for development in commercially available seed). What is really different about this trait over the transgenic one? Fundamentally, the risks are similar. The major risk with herbicide tolerant crops (beyond overuse of an herbicide selecting for resistant weeds) is that the modified crop can interbreed with wild relatives, passing on the herbicide tolerance which might establish in the wild. This appears to be possible with wheat. Researchers are thus somewhat wary of widespread use of herbicide-tolerance traits in wheat (thanks to Bill Price pointing this out on Biofortified).

However, under the United States regulatory system (and most other nations’), only the transgenic wheat undergoes greater legal scrutiny. What would it mean for non-transgenic glyphosate-tolerance traits to be found unexpectedly in a farmer’s wheat crop? Practically it would mean the same to the farmer (difficulty controlling volunteers), but legally it would be very different. There would likely not be any talk of suing WSU for letting the trait escape or would Korea or Japan be suspending wheat imports. I’m not sure we would have even heard about it.

The worse part, to my mind, is that this inconsistent regulation means that non-transgenic versions of a trait may not be subject to the same scrutiny and care. With current transgenic traits, farmers often agree to use the seed responsibly. For example, with Bt corn, farmers are required to plant refuges³. There’s little in the regulatory system that would consistently require that for non-transgenic traits. The reason it works with transgenic ones is that the seed seller (e.g. Monsanto) has to get regulatory approval which mind end up requiring farmers agree to use it how the regulator wants. Fortunately, most seed sellers try to manage their products well even if non-transgenic (for example, Clearfield products are non-transgenic herbicide-tolerance traits that BASF at least recommends good practices.) I’m not sure what the answer is here, but it’s clear that we don’t consider non-transgenic traits as having similar risks at the regulatory level, even though they can.

Another part of this question is the expectation that there be 100% no “contamination” of seed lines with unexpected traits — if that trait is transgenic. But fundamentally this is impossible. We can make it unlikely it will happen (thru careful equipment cleaning, buffer zones in trial fields, etc.) but we can’t make it impossible. The focus on this being “GM wheat” distracts from reasonable investigation of how and why it happens and what is a reasonable way to control it. If it hadn’t been a transgenic version of the glyphosate tolerance trait (and even worse, Monsanto’s), would it have even been news? How many resources could the USDA have put behind the investigation to find out where the trait entered the seed supply? Would they have quietly tested likely varieties and, when they didn’t find them, throw it up as a fluke? Would there be greater pressure to have management practices (and regulations!) to prevent spread of possibly risky traits into wild relatives on the assumption that seed will occasionally be “contaminated”?

I’m not sure I have any answers. It just bothers me that (so far) a very low risk discovery is being spun into apocalyptic proportions. Grist worries about “GMO wheat infecting the food supply” which is clearly absurd. Would they worry so much if it was a trait derived from mutation breeding, but still with all the same practical risks to farmers and the environment? Our current regulatory system suggests few would. Maybe we can get past the idea that everything “genetically engineered” is dangerous while treating non-GE as safe. I still hope we can regulate the outcomes of using particular crops or crop systems, rather than the methods that developed them.