Proposed planting of GM safflower in Washington state

March 6, 2007

Regulatory Analysis and Development
PPD, APHIS
Station 3A-03.8
4700 River Road, Unit 118
Riverdale, MD 20737-1238

Regarding Docket No. APHIS-2006-0190

Dear APHIS,

We wish to comment on Docket No. APHIS-2006-0190 regarding the proposed planting of genetically modified (GM) safflower in Washington state.

We're a significant stakeholder on this matter. As a grocery retailer in Washington state, we're writing on behalf of the farmers who supply our stores and the shoppers who patronize our stores, in particular the nearly 40,000 members who own our business. We have 8 retail stores with sales approaching $110 million this past year. Since 1953, we have stood for a healthy and safe food supply.

We're writing to urge an immediate ban on the use of food crops to produce drugs and industrial compounds in food crops, commonly known as pharmaceutical or "pharma" crops.

As you know, numerous examples reveal continuing failures in the regulatory system governing GM crops, with enormous costs to the food industry and our overall economy. The extensive recalls of foods contaminated by an unapproved herbicidal corn in 2000-2001 cost $1 billion, yet residues still show up in the food supply.

In 2002, contamination of soybeans with pharmaceutical corn cost nearly $3 million to clean up and destroy. In 2005, a biotech company admitted that for three years it had sold farmers hundreds of tons of corn engineered with a gene conveying antibiotic resistance, even though it wasn't (and still isn't) approved for human consumption. This past year, the contamination of rice with experimental GE rice has impacted the commercial rice industry seriously, with market losses estimated to be $150 million.

Never intended for human consumption, the genes injected into the safflower for the Washington trial have not been tested for safety. USDA itself has admitted, "The safety of carp growth hormone to humans and animals other than fish has never been investigated." Breathing the pollen or consuming the seeds of a plant that expresses recombinant human insulin also is not tested for safety.

In the USDA's Environmental Assessment of the proposed trial by SemBioSys, it says, "Up to ten field sites (50-100 acres each site) will be located on private property in Douglas, Grant and Lincoln Counties, Wash." It's striking to realize that scattering the production around on multiple, smaller sites in three different counties is even worse than having a single 1,000-acre site.

The way it's proposed, there will be that many more potential adjacent fields to be contaminated. Unless SemBioSys has 10 different sets of dedicated harvesting/handling equipment, the equipment will be moving all over the place, further increasing the likelihood of contamination.

Because safflower is a favorite food of birds and in the path of bird migrations, it's inevitable that birds will feed on the pharma safflower. Bird droppings from Canada to Mexico will scatter pharma safflower across the continent, giving rise to volunteers in subsequent years, since safflower is not an annual but a perennial. Even without dissemination by birds, human error, other animals, storms, storage and shipping accidents are virtually certain to scatter the small safflower seeds across the region and beyond.

Since safflower is planted sometimes in rotation with wheat and perhaps other crops, contamination of our harvests could seriously impact the economic backbone of our state, and the nation's agricultural balance sheet. Contamination of even one regional harvest has caused buyers before to brand an entire U.S. crop as polluted. The real risks posed by this proposed planting are not worth any purely theoretical gain, especially when the intent is to reduce the cost of production for an industry as unsustainable as shrimp farms.

Considering that the U.S. Food and Drug Administration has declared a zero tolerance for drugs in food, and considering the impossibility of containment, it's clear that food crops should not be used to produce experimental drugs and industrial compounds.

If SemBiosys or other biotech companies want to produce plant-based drugs, they should follow the lead of Dow AgroScience, which won approval of a vaccine for chickens produced by tobacco cell cultures in a contained steel tank. Cell cultures are a proven way to generate pharmaceuticals under controlled laboratory conditions — without the risk of untested, experimental drugs in our food.

Respectfully,

Tracy Wolpert
Chief Executive Officer

with co-signatories:
Ashland Food Co-op, Ashland, Ore.
Basics Cooperative, Janesville, Wisc.
Bloomingfoods Market and Deli, Bloomington, Ind.
Blue Heron Farm, Rockport, Wash.
The Campaign to Label Genetically Engineered Foods
Central Co-op/ Madison Market, Seattle
Chantal Stevens, member PCC Board of Trustees
Change Your Food — Change Your Life, founder Dennis L. Weaver
The Cornucopia Institute, Cornucopia, Wisc.
EcoPraxis, Dr. Viki Sonntag
Equal Exchange
GM-Free Schools Campaign, Institute for Responsible Technology, Kevin J. Anderson, Director
Institute for Responsible Technology, Jeffrey M. Smith, Exec. Director
Jennifer Naas, graduate student, School of Public Affairs, Univ. of Washington
Jody Aliesan, founder, PCC Farmland Trust
Karen Lamphere, MS, CN (nutritionist)
La Montanita Co-op, Albuquerque, NM
Mangrove Action Project, Alfredo Quarto, Executive Director
Ocean Beach People's Organic Food Co-op, San Diego, Calif.
P-Patch Trust, Ray Schutte, President
People's Food Cooperative, Ann Arbor, Mich.
Rainbow Natural Grocery Cooperative, Jackson, MS
Sacramento Natural Foods Cooperative, General Manager Paul Cultrera
Skagit Valley Food Co-op, Mt. Vernon, Wash.
Ukiah Natural Foods Co-op, Ukiah, Calif.
United Natural Brands, Deb Leyva, Director of Sales
Upper Valley Food Co-op, White River Junction, Vt.
Washington Biotechnology Action Council, Vice President Prof. Philip L. Bereano
Washington Tilth Producers, representing 550 farmers
Wash. State Representative Maralyn Chase, Dist. 32

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