Increasing Risks. Testing with GMOs in the USA

Increasing Risks. Testing with GMOs in the USA


Although the United States Department of Agriculture has authorized more than 47,000 GMO field tests, none of the institutions responsible for the approval process have been able to answer fundamental questions about the implications for human health, the environment, social and ethical aspects. .

Field testing of genetically modified crops in the United States

Although the United States Department of Agriculture (USDA) has authorized more than 47,000 field tests of genetically modified organisms, none of the institutions responsible for the approval process of GMOs such as the environmental protection agency EPA, the administration of drugs and Foods neither the FDA nor the USDA have been able to answer fundamental questions about the implications for human health, the environment, social and ethical issues related to this technology.

Field evaluations of genetically modified crops are done in order to evaluate the impacts of new crops on the environment and see how the plant responds to the genetic modification. However, the USDA has not been able to adequately regulate these field evaluations, and the standard is increasingly weak, despite the little empirical evidence with which it makes its decisions.

The regulation on GM crops at the USDA was designed to support the biotech industry. In 1984 the USDA proposal had as objectives
- facilitate the industry to operate efficiently and safely
- for this it is necessary to stimulate the growth of the biotechnology industry
- this requires eliminating barriers to trade

In order to achieve these objectives, it was decided that it was not necessary to draft any new law, or create a new agency to deal with the issue of GMOs. They considered that the existing laws and agencies were sufficient to accommodate these new products.

The USDA's philosophy on regulatory issues at the time is that GMOs are not expected to make fundamental changes compared to their conventional counterparts, and that their role is to promote markets. This makes the USDA a regulator and promoter of this powerful new technology.

In 1986 the USDA publishes its policy on the subject, and proposes not to regulate an organism or product merely due to the process with which it is obtained, with which several products were deregulated. There it was anticipated since some products were going to be exempted from any federal review. In 1987, only 5 permits had been given to carry out field evaluations and in 1988, 16. However, it is said that there is a significant number of experiments carried out that show that these represent a low risk, so not all field tests of GMOs will require prior federal approval.

In June 1987 the final version was published, establishing an inadequate monitoring system for GMOs, and through permits.

In 1993, with just 6 years working with the permit system, the APHIS plant and animal health inspection service announced that certain crops would be allowed to be grown without a permit, arguing that there was enough data to conclude that GMOs mean minimal and even non-existent risk for the environment. So institutions that wanted to do field tests simply had to notify APHIS. APHIS excluded 6 plant species: corn, cotton, potato, soybeans, tobacco, and tomato, as well as any additional plants determined to be safe to introduce. APHIS had just 30 days to respond to the notification.

In a 1995 study by academics at the University of Chicago, 7 crops approved by the USDA for commercialization were analyzed, and they concluded that decisions were made based on inadequate data.

In 1995 the USDA made a new proposal to simplify the procedures for the introduction of certain GMOs. The USDA said 87% of the field tests were already taking place in a simplified format, which required even less study. The goal was for 99% of field studies to be done with a simplified reporting system. To achieve this goal, APHIS had to deregulate another group of crops. Since APHIS could not describe these new crops, it created the term "Antecedent Organism." This is a body that has already received deregulated status, and will serve as a reference for comparisons. This means that if the transgenic plant wants to be released into the environment, as long as it is "closely related" to the "antecedent organisms", it could be a good candidate for release into the environment without any regulation. According to USDA files at that time, 16 crops were deregulated.

In May 1997, the requirements to release GMOs in the field for experimentation purposes were further weakened, for example, by reducing the monitoring of plants manipulated for virus resistance.

In 2003, the USDA proposed new rules for field testing to produce pharmaceutical and industrial crops. Although there are some improvements, these are not adequate enough given the impacts that these types of crops can generate.

In 2004, the USDA announced its intention to change its regulatory agency, and establish an environmental impact statement, but the results of the process to achieve this end are not yet known.


Between 1987 and 2004, APHIS received 11,090 applications to release genetically modified crops into the environment. Of these, 10,296 have been approved, allowing 18,608 releases to the field at 47,219 sites.

Between 1987 and 1993, when little was known about the dangers of genetic engineering, the USDA did not reject any of the requests for field testing of GM crops.

In 2004, the USDA denied only 3.6% of applications.

According to APHIS, perhaps the only reason an application is rejected is for minor violations of the formal requirements, for example, if the application is incomplete.

Each time it is asked for an evaluation, the USDA concludes that no significant impacts on human health and the environment have been found and that the plant does not pose a risk of becoming a pest.

As of January 2004, more than 1,000 sites have been established in 14 states and territories to evaluate transgenic crops.

States and Territories Where More than 1000 Transgenic Crop Evaluation Sites Have Been Made Between 1987 and 2004

STATENo. of sitesSTATENo. of sites
Puerto Rico3,483Idaho1,272

Since 1991, the USDA has received 240 requests for 418 releases to the field to evaluate pharmaceutical crops, industrial chemicals, and other crops called biopharmaceuticals. The number of requests to evaluate drug crops increased from 22 in 2003 to 55 in 2004.

In 1987 the USDA approved 5 evaluation sites, and in 2003 there were 901. In 2003 the USDA reported 2,946 field test sites.

Throughout 1992, the USDA only allowed releases of transgenic organisms if they followed a permitting procedure. Starting in 1993 there was a change in the system and some field studies were approved following only one notification system. In 1993 the USDA approved 323 field studies (36%) with the reporting system. In 2004 the USDA approved 95% of the field tests with the notification system.

The number of sites approved with the notification system dropped slightly after 1998 for a few reasons. First, several field evaluations of new crops were approved, but on the other hand, the USDA itself encouraged certain institutions to make their applications following the permit system because the agency was familiar with the evaluations and could dispatch a large number of applications. together without requiring as much paperwork. Then the institutions could combine several applications to do field evaluations, through a single permit.

The crops that have received the most authorizations for field evaluations are corn, soybeans, cotton, potatoes, tomatoes, wheat, bentgrass, alfalfa, beets, and rice.

Between 2003 and 2004, some new genetically engineered crops were accepted for the first time, including chestnuts, American elm, avocado, banana, eucalyptus, sorghum, sugar beet, calendula, safflower. These crops have been evaluated in the states of New York, California, Florida, Ohio, Hawaii, and other states. These new field evaluations reveal to us that new transgenic products could be commercialized in the next few years.

Between 1987 and 2004, APHIS approved 18,608 applications. Certain crops have outnumbered others, due to various factors, including their importance to the US economy, as well as scientists' familiarity with the crop. Between 1987 and 2004 the USDA authorized.

Field cultivationNumber of tests
Creeping bentgrass436

These field tests used 566,337 acres in 48 states and two US territories.

CultureLand extension
Used In Evaluations

Some crops have undergone few field evaluations since 1987. This is the case for eggplant, onion, coffee, and pineapple.

Who Makes The Evaluations?

Since 1987, Monsanto or its subsidiaries have submitted applications for field testing through notifications or permits every year, and it is the institution that has submitted the most applications (even not including its subsidiaries). Then follow companies (including some Monsanto subsidiaries).
The Universities of Iowa, Idaho and Rutgers have the highest number of requests for field tests using the permit system.

InstitutionRequests Field Tests 1987 - 2004
Du pont325
Seminis Vegetable Seeds195
Iowa State U129
Rutgers U102
U of Idaho102

Of the top 10 institutions that requested to do field tests either through the permit or notification system, seven have been merged into two: Monsanto and DuPont.

Confidential information

The percentage of field tests carried out with genes that have been considered confidential information, that is, cannot be subject to public scrutiny, increased from 0% in 1987 to 70% in 2004.

One example was DuPont's commercial release permit # 99-029-01, which is for 18 release sites on more than 5,000 acres and many of the released genes may not be accessible as information to the public.

Not only private companies are demanding that their genes be recognized as confidential information, but also some universities.

Violations of the Regulations for Field Evaluations

It is no secret that institutions doing field evaluations have violated USDA regulations. For example, in a report by President Clinton's Council on Environmental Quality and Office of Science and Technology Policy, it says that “from 1995 to 2000, APHIS has reported 63 violations. In response to a request made to the USDA by the authors of this report, based on the Freedom of Information (FOIA) resource on inspections to field studies, they were informed that there was no record on this subject prior to 2000, But the USDA was also unable to provide any post-2000 information.

The authors submitted another FOIA resource for information on the type of violations made to the field assessment regulations. Several years after filing the FOIA, the USDA has responded to two violations. The first is related to a cattle that ate some leaves that were being evaluated in an experimental field. In this case, the USDA called the attention of the company that was doing the evaluation to be careful that something like this does not happen again in the future. In the second case, the company started the field evaluation before having the corresponding approval. The agency responded through a letter.

The USDA has announced that it has established a website that contains information on violations, but it is incomplete. For example, there is nothing about the case where Ventria established its pharmaceutical rice crops near fields where rice was grown for human and animal consumption.

There is also no information on the co-responsibility that the EPA (Environmental Protection Agency) has with Pionner Hi-Bred International for having planted transgenic crops in unapproved places, and with Mycogen for not having used trees as a windbreaker.

The authors recommend that a moratorium be called on the commercial release of transgenic crops until an independent assessment is made that they do not cause a negative impact on human health and the environment.

They conclude that the US authorities have not made adequate evaluations of transgenic products, their impacts on health and the environment. Thus they have also overlooked the ethical and social dimension. Field tests to evaluate new transgenic crops have followed this same pattern and have only served to put the environment and the lives of farmers at risk. The field tests must be done in a comprehensive environmental framework, which allows evaluating all the impacts that these crops could have on the environment.

They also demand that biotech companies that manufacture GMOs must be held accountable for any damage they may cause.

They claim that the public should be aware of what field studies are being done.

Source: Raising Risk. Field Testing of Genetically Engineered Crops in the United States. TexPIRG Education Fund. April 2005.

The TexPIRG Education Fund presented in April this year a report entitled: Increasing the Risks. Field Testing of Genetically Engineered Crops in the United States (Raising Risk. Field Testing of Genetically Engineered Crops in the United States), where the approval system for releases in the new environment of transgenic crops is analyzed for evaluation purposes , its shortcomings and risks, as well as the deregulation process that has taken place on this issue in the United States. This text is a summary of it.

The full text can be found at:

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