Rebecca Goldburg
Environmental Defense Fund
(prepared from the videotaped presentation*)
I have been invited to speak today about public support for biocontrol. I would like to preface this talk by stating that I am not a social scientist; my remarks are based entirely on personal experience and anecdotes obtained as a member of the environmental community.
I have divided the topic for this discussion into two subtopics:
I will end my remarks by discussing so-called "conditional registrations" of pesticides, which have the potential to increase public confidence in the use of certain pesticide products.
I have been invited to speak today about public support for biocontrol. I would like to preface this talk by stating that I am not a social scientist; my remarks are based entirely on personal experience and anecdotes obtained as a member of the environmental community.
In general, the environmental community is very, very positive towards biological control. An example of this is the 1993 report called, "IPM: The Path of a Paradigm," by the National Audubon Society, which traces the evolution of IPM from integrated control in the 1950s and 1960s to what it is today. The report discusses how IPM has evolved from a system that was heavily based on natural pest controls to a system that, at least in this country, now focuses on trying to use chemical pesticides in a more targeted way. The report makes a very strong case for returning to a much more biologically-based IPM including biological control. I think this report is very indicative of the environmental community's thinking on this topic.
Nevertheless, there are some cracks in the environmental community's broad support for biocontrol. There is a relatively new perception, I would say in the last 5 years or so, that biological control can be risky. If you went back a little further, most people in the environmental community would unquestionably say that biological control is great. One of the reasons for this changing perception is that the definition of biological control is expanding. A good example is the pamphlet that announced this conference where everything from classical biological control to transgenic plants is considered biological control.
Here are some of the things that have caused the environmental community to look a little more skeptically towards biological control and to perceive that it has some risks.
There are at least two other concerns about modern biotechnology and biocontrol that have influenced people's thinking. One is that modern biotechnology is being used to engineer biological control agents and biopesticides to be more like conventional chemical pesticides. This has been accomplished by expanding their host range, as has been done in the lab with baculoviruses, increasing persistence, which we've done with Bt in many different ways, and increasing toxicity or kill rate, which has also been accomplished with baculoviruses. In some senses there is a continuum from classical biocontrol to synthetic chemicals, with biotechnology products somewhere in the middle.
There is concern that biotechnology may overshadow traditional biological control, because biotechnology produces patentable products that may yield relatively high profits. There's nothing necessarily wrong with making a profit, especially in the private sector. However, the environmental community has worked closely with the sustainable agriculture community in recent years to push for more taxpayer-funded research for sustainable agriculture. I think there is a real feeling that biotechnology gets a lot of research dollars, sometimes at the expense of research on farm management, taxonomy, traditional crop breeding, and so on.
To conclude, the environmental community generally strongly supports biological control but is increasingly aware of various risks of biocontrol products and is skeptical that new biotechnology products will be as safe as traditional products.
Although there have been surveys of public opinion on pesticides and biotechnology, I am not aware of any surveys that have been taken to determine the public opinion on biocontrol, so, again, my discussion is relatively anecdotal.
It is important to keep in mind that public opinion can greatly affect the economic health of agricultural products. Two examples are 1) how consumer fears about BSE led to consumer rejection of British beef, and 2) the opposite phenomenon here in the US, the rapid growth of the market for organic foods - about 20% per year. In other words, the issue of food safety has quite a bit to do with how people regard agriculture.
Pertinent to biocontrol, the public is extremely concerned about the health and environmental effects of pesticides. For example, the Republican-dominated Nassau County (Long Island, New York) legislature this past March voted 18 to 0 to require contractors, landscapers, etc., to notify neighbors at least five days in advance before spraying pesticides or other airborne substances. I understand there were some pretty strenuous objections, but nevertheless, this politically conservative body recognized what their constituents believe to be dangers in pesticide spraying.
Public opinion appears to strongly favor biocontrol as a safe alternative to chemical pesticides. For example, the popular press - which both shapes and reflects public opinion - generally gives highly favorable reports on biocontrol. Reports on pest control agents such as a neem insecticide or some newly discovered fungus, are usually written in glowing terms. Corporate marketing tactics often reflect a belief that biocontrol has a favorable image. This can be seen in the home gardening market and its sales tactics for natural products, which stresses their safety.
What would be the effect of defining biotech products as biocontrol? This is an important issue - at least if you're concerned about public support for biological control in the future and whether that image will be positive.
Consumers are wary of biotechnology products. An example is an article in the New York Time from February of this year: "A New Goal Beyond Organic: 'Clean Food'," argues that, "A growing number of Americans are taking their health and well-being into their own hands, in part because they have lost faith in the institutions that are supposed to improve their lives." According to this article, fear of biotechnology may be part of this trend.
Perhaps it is even more instructive to look at what is happening in organic agriculture, which is designed to address environmental problems and sustainability, etc., and also has considerable market appeal. The National Organic Standards Board appears poised to define biotech products as "synthetic," which means that they cannot be used in organic agriculture unless special exceptions are made for particular products on a case-by-case basis. This tells me that, along with the concerns that the organic industry has about biotech products, the organic industry doesn't view biotech as a technology that will help them sell their products.
Given all this, are there lessons for maintaining the current high level of public goodwill towards biocontrol? My message would be that to maintain public goodwill, biocontrol should be kept "natural." Although that is a fuzzy term with no precise scientific meaning, from a marketing standpoint of keeping a clean image, I would look toward focusing what I term biological control on things like augmentation, classical biological control, and strategies that we traditionally understand to be biocontrol. There is still room in agriculture for transgenic products, like Bt formulations and so on, but to maintain strong public support for biocontrol, I would keep those things separate.
To change the topic slightly, I will talk about conditional registrations of pesticides under FIFRA because I believe they can be a tool to increase public confidence in many types of pesticide products.
Conditional registrations aren't new. When a pesticide is marketed in this country, it must be registered by the EPA - approved for use under FIFRA. Conditional registrations were originally created to eliminate a double standard when new data requirements were instituted for pesticides. EPA at one point increased data requirements for pesticide registration. One result was that a particular manufacturer might be marketing a pesticide, but you, as a second manufacturer, couldn't put that same product on the market under your brand name unless you complied with new, greater pesticide data requirements. So Congress established conditional registrations that allowed companies, under certain circumstances, to register pesticides for use under the condition that the company would be supplying data to EPA over a specified period of time following registration. Since then, EPA has frequently used conditional registrations to require companies to develop certain information that the agency feels in important, but doesn't require immediately.
Conditional registrations took a new twist 2 years ago when a controversy erupted over registration of the herbicide acetochlor. Registration of acetochlor was opposed by many environmentalists because evidence suggested this chemical is a carcinogen that may leach into groundwater. A chemical relative of acetochlor is alachlor, which has been a big problem in surface and ground water in the Midwest. On the other hand, manufacturers argued that the availability of acetochlor would greatly reduce the use of other more hazardous chemicals, such as alachlor. Even if acetochlor had a down side, its availability would be a net benefit to the environment. This was a fairly heated debate.
The EPA handled this situation in an innovative way by conditionally registering acetochlor. EPA established a number of conditions for continuing registration beyond a five year trial period. Acetochlor's manufacturers were required to document the promised decreases in herbicide use and were required to fund programs to monitor ground water and surface water for acetochlor contamination. If the conditions aren't met, the EPA will cancel the pesticide's registration.
Since acetochlor's conditional registration in March of 1994, there have been three additional conditional registrations issued as ways to resolve controversies. Bromoxynil was given a conditional registration in May of 1995 for use on genetically engineered bromoxynil-tolerant cotton. Bromoxynil is considered by EPA and the State of California to be a developmental or reproductive toxin. The manufacturer's arguments for bromoxynil were similar to those in the acetochlor case: use of bromoxynil-tolerant cotton would lessen the use of other herbicides that are even worse.
Genetically engineered Bt corn and cotton were conditionally registered in 1995. In this case, the argument against registration is that widespread use of these crops will lead insect pests to evolve resistance to valuable Bt biopesticides. The Bt products were registered under the condition that companies implement resistance management programs and engage in monitoring for pest resistance in these crops.
Conditional registrations are not appropriate for all products. They involve more work by EPA and somewhat more work by manufacturers in reporting to the agency. However, in some situations, they can be a "win-win" regulatory solution for controversial products. The advantages of conditional registrations are that they:
To sum up, I think there is strong support for biological control among the general public and in the environmental community. However, there appears to be small cracks appearing in that support. I think the biological control community should think carefully before embracing transgenic Bt crops and other transgenic organisms within the definition of biocontrol.
Conditional registrations provide one tool to increase public confidence in some pesticide or biotechnology products as well as increasing public confidence in registration decisions about some conventional pesticides.
Carlos Perez, Entomology, NYSAES: Please give examples of some Bt products that would not be in your biocontrol concept.
Answer: Certainly in my mind, transgenic crops would be in that category. My argument is that if you want to continue the strong public support for biological control, these Bt products should not be defined as biological control. I think there are scientific reasons for that, as well. To date, biotech has often been used to make biological products more like conventional chemical products, so that they are more salable to farmers. That said, biotech is not necessarily a bad tool to use to improve or change some biologically based pesticides, such as using genetic engineering to alter certain Bt spray formulations.
Anonymous: How would conditional registration boost honesty in reporting by manufacturers?
Answer: If a manufacturer wants to submit false data to the agency, this will not stop that. But at least, when it comes to making fuzzy claims about the changes on agriculture the product is going to cause - and there are a number of products for which such claims are now being made, particularly in the biotech arena - conditional registrations provide a means to put those claims to the test.
Anonymous: Do you feel the conditional registration process is better than the conventional registration process, and does it have any application to biocontrol agents?
Answer: In some instances, it's preferable than conventional registration, and it certainly makes sense for some sorts of controversial products. I'm not sure that traditional biological control agents fit that bill. If you want to embrace a very wide definition of biocontrol and include things like transgenic crops, it can make a lot of sense.
Milton Zaitlin, Plant Pathology, Cornell: The attitude against organic certification of transgenic plants amazes me. Wouldn't it be an advantage for growers to be able to grow a plant they wouldn't have to spray for insects or bacteria or fungi? Why is this prohibition so general?
Answer: It makes sense in the same way that prohibiting synthetics makes sense to the organic industry. You may not feel, as a scientist, that synthetic chemicals are necessarily dangerous - there are some natural chemicals as well as synthetics that are quite dangerous. However, the organic industry has been successful in part because it doesn't rely on government bodies to make decisions about what is safe under all sorts of political and commercial pressure. The organic industry asserts that it simply will not certify things that have the potential to have any kind of negative effect. Biotech is synthetic in some senses and the organic industry views transgenic Bt crops in the same context as it views synthetic chemicals.
Follow up: Here again, what are the benefits accrued opposed to the risks there might be? Why is it okay to get pyrethrum from flowers, but it's not okay for organic growers to take this exact same chemical, synthesize it, and use it for pest control?
Answer: It has to do in part with reassuring the public. At the present time, there is no way for people to discriminate in the supermarket between products that have been raised using the most destructive environmental processes, and those that have been raised in a context where virtually no pesticides have been used. The only alternative is organic, and I think the reason that organic has been successful is because it goes the extra mile and assures "purity." I realize that's a fuzzy term, but it means something to the public.
Ray Carruthers, USDA/ARS: It seems that it is implicit in the concept of conditional registration that the EPA accepts that we're going from A to B in pest management. The argument of the industry is that although we may not have the perfect product, it's a better product than what previously existed, and we're heading in the right direction, so let's use it to reduce the risks that exist now. This presupposes a plan on which this government/industrial partnership is based, because it then becomes a true partnership. For the time being the EPA is going to let industry proceed because it fits a plan. What I'm concerned about is that there may be the partnership without the plan, and this might be the negative consequence.
How does this relate, for instance, to fast-tracking biological pesticides? I see this EPA activity a little differently. With conditional registration, you're going from a yes/no, absolute position that something is safe or not to a conditional position: "Well, maybe it's safe. Let's try it out and see."
Fast-tracking biopesticides also gives advantages to certain products, but it gives advantages to products in recognition that the current registration procedures are not actually appropriate for that type of organism. It isn't creating a partnership arrangement between producers; it's simply acknowledging that the procedures in place are not really appropriate for that kind of product. I see that as a much less risky way of proceeding than with conditional registration, which creates a partnership and assumes a plan. Such a plan really needs to be in place so the company can be told, "We've done 5 years of that, and now what we want you to produce is this: we want you to produce cars in California that don't run on petrol." That sort of initiative says, "We're going there, and we're going to help companies get there, but they've got to follow our plan," and is a little bit different than the present status of conditional regulation, because there's no plan attached to it.
Is that a valid criticism?
Answer: I think that is a valid criticism, but I don't think that plans have to be very specific. Obviously, I can't speak for the EPA. Certainly, the EPA and the Administration have goals of moving to less use of pesticides, more IPM, etc. How, exactly, we'll get there is very nebulous to my mind.
As for implementing a plan where you tell companies, "You can use this for 5 years until you come up with something better," I just don't see this in the political cards. If you follow the car analogy, it's been a horrendous mess. Yet in many ways, changing to a different sort of engine in motor vehicles is a less complicated problem than dealing with all the kinds of agricultural crops we grow in the country.
So I think that we are likely to see regulators trying to promote changes in agriculture simply via providing some incentives within the regulatory system. "We'll make it easier for you if you're doing something that we regard as an environmental improvement."
Anonymous: There's always been a risk/benefit legislation, and if there is a risk, then the benefits have always been regulated. It sounds as if in a conditional registration, they can't document the benefit; they speculate on the benefit, and that's being used as the stick.
Answer: My understanding of how FIFRA is implemented is that EPA formally analyzes benefits when the agency evaluates whether to cancel a pesticide registration. In the registration procedures, for the most part, EPA focuses on risks and consideration of benefits is relatively informal. Companies have a lot of freedom to make speculative claims. At least with conditional registrations, they will be held to those claims.
Follow-up: With chemicals, if you have a risk, then it will be in an area of evaluation of benefit. But in biologicals, if there's a risk, you'll never move into the benefits area of registration.
Sinthya Penn, Beneficial Insectary: Did you say that the public's fear of biotech is greater than its fear of traditional chemical pest control?
Answer: I said, or at least I meant to say that the public's fear of biotech is much greater than its fear of traditional forms of biocontrol.
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