Statement of
Will Duensing,
Bunge Lauhoff Grain Company, Danville, Illinois
On behalf of the North American Millers' Association
Before the Environmental Protection Agency
FIFRA Scientific Advisory Panel
Public Docket Number OPP-00724
July 17, 2001
The North American Millers' Association is the trade association representing the wheat, corn, oat and rye milling industry. NAMA's 44 member companies operate 166 mills in 38 states and Canada. Their aggregate production of more than 160 million pounds per day is approximately 90 percent of the total industry capacity. 24 NAMA member companies mill corn at 31 locations in 16 states. Corn dry millers use approximately 165 million bushels of yellow and white corn annually.
NAMA strongly supports the tolerance sought by the Aventis CropScience petition, and believes it can be granted while continuing our commitment to consumers that corn-based foods are nutritious and wholesome.
We believe there are four elements that will be helpful to the Scientific Advisory Panel (SAP) as it considers the additional scientific information concerning StarLink corn and the questions posed by the EPA. They are:
- The June 2001 report from the Centers for Disease Control and Prevention announcing the results of its investigation of adverse event reports (AERs) of human illnesses that were potentially associated with consumption of genetically modified corn products. The report stated its findings do not provide any evidence that the reactions that the affected people experienced were associated with hypersensitivity to the Cry9c protein.
- The Aventis Processing Study that shows dramatic reductions in Cry9C protein levels in finished foods.
- The `real world' data collected by NAMA members, using the most sensitive field test method available, show the absence of or extremely low levels of Cry9C protein found in corn being presented to human food processing channels. As soon as a test for Cry9C became available in October 2000, NAMA developed, and the membership adopted, a testing regimen. NAMA members have voluntarily submitted their Cry9C testing data for aggregation and presentation to this panel. As of July 1, NAMA members have tested 85,808 lots of corn. Of those, 1,042 (1.21 percent) tested positive and were directed to domestic animal feed and non-food industrial uses. While that is an aggregate number, even in areas with significant production of StarLink corn, the percentage of positive tests was in the range of 3-4 percent.
- On July 11, the United States Department of Agriculture announced (at www.usda.gov/oce/waob/wasde/latest) its projection for 2001 U.S. corn production at 9.495 billion bushels. This crop, once harvested, will further dilute what Cry9C protein remains by several orders of magnitude. We also know that no corn seed with Cry9C protein was planted in 2001 due to USDA's aggressive seed buy-back program. Finally, whatever StarLink corn that may exist in storage will be ineligible after September 1, 2001 for the significant financial incentives offered by Aventis providing a substantial motivation for that corn to be channeled to its appropriate feed or industrial end use.
NAMA proposes that the testing called for in the tolerance petition continue through the 2001 harvest. That will allow the milling industry to analyze the testing data and prove our premise that the new crop will further dilute the Cry9C in corn stocks to infinitesimally low levels. We propose the analyses to continue from now through November, and when that is shown to be true, as we believe it will, then additional, needless testing should stop on January 1, 2002.
Thank you for the opportunity to present this information to you. We hope it is helpful in your deliberations, and appreciate any consideration you may give it.
For additional information contact:
Jim Bair
North American Millers' Association
202.484.2200, ext. 107
jbair@namamillers.org
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