Unexpected Wheat Traits and the Contradictions of Regulation and Reaction
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.
Some headlines on this story suggest Monsanto is positively saying it’s sabotage. Sadly, their spokesperson used the phrase “accidental or purposeful mixing” to describe the likely source of the trait. A reporter took this to mean possible sabotage which the spokesperson did not rule out when questioned (how could they?) but also sadly did not say they have no evidence of it being sabotage. So, depending on our political ideologies, this is wild anti-GMO activists trying to make Monsanto look bad or Monsanto failing at their regulatory duties and blaming others. It’s depressing.
It is unclear to me how labeling matters for unexpected presence. It’s partially for this reason that EU labelling rules allow for 0.9% “adventitious” presence. That is, a small amount of genetically engineered corn in a non-GE batch that is unintended doesn’t trigger labeling. Sadly, the I-522 labeling campaign chose an image of a person in a protective coverall, complete with face mask, to head their petition.
Obviously, there is a lot of research and concern that current Bt refuge requirements are not sufficient to manage insect resistance, but at least the regulation exists.