Statement on Biotechnology
The North American Millers' Association (NAMA) supports food biotechnology as a tool that can improve product quality, safety and sanitation; increase production efficiency; allow more judicious use of agricultural chemicals and help meet growing domestic and world food demand.
NAMA supports the coordinated regulatory framework established by the U.S. government to oversee introduction of new products from biotechnology and its implementation by the Department of Agriculture, the Environmental Protection Agency and the Food and Drug Administration. This process must continue to be scientifically-based and rely on prudent risk-analysis.
NAMA supports the current food labeling policy of the U.S. Food and Drug Administration that requires special labeling only when the use of biotechnology introduces an allergen or when it substantially changes the food's nutritional content.
NAMA, through other appropriate organizations, supports educational efforts needed to assist with consumer understanding and acceptance of the safety review processes, benefits and innovations occurring in agricultural biotechnology.
NAMA recognizes that agricultural biotechnology, like other technologies, should find its place in an efficient, free marketplace. In that marketplace, consumers and individual food chain members may choose to consider a variety of factors in their decisions to buy and market products, including whether they are produced from biotechnology or conventional raw materials.
Understanding that millers are a vital link in the food chain between growers and consumers, NAMA believes that as this technology moves forward, it is imperative that:
- The
Administration actively affirm the safety of
products made from approved biotech crops and
be pro-active in explaining the review
process and the scientific basis for the
commercialization of these products.
- Technology providers and regulators consider the following recommendations that fall under the headings of:
- World-wide approval;
- Thresholds;
- Testing; and
- Identity preservation.
World-wide approval
All grains, with rare niche exceptions, have the potential to be traded under agreed upon terms for domestic processing or for export; whether for food, feed or industrial use. Likewise, processed grain products are used as ingredients in food products consumed throughout the world.
NAMA believes it is necessary that international frameworks be established for predictable, uniform and transparent regulatory practice that permits unfettered trade in all grain and grain products. NAMA urges the appropriate government agencies to work as diligently as possible in all available international forums to advance the acceptance of products developed through biotechnology. No biotech grains should be released until regulatory approval has been obtained in all major markets for bulk grains and food products, assuming these major markets have functional approval processes in place.
For grains currently in the U.S. market without broad international approval, we strongly encourage technology providers to discontinue selling those seed varieties unless approvals are received and/or suitable tolerances can be established.
Thresholds
The U.S. grain marketing and processing system is extremely efficient and can move massive amounts of grain quickly and economically. That strength, however, is balanced by the inability to guarantee 100 percent purity. Just as the official standards for grain allow small amounts of other grains, adventitious mixing will occur between biotech-based and conventional grains either in the field or in the system. Reasonable thresholds must be adopted to allow the movement of grains with adventitious admixture.
Testing
Test methods are highly sensitive and improving constantly. The tests allow the miller to test incoming grain with a high degree of accuracy and precision. NAMA strongly supports testing (when necessary or appropriate) of the inbound grain. At the same time, NAMA opposes testing on intermediate or finished products which creates enormous liability questions. Where testing is warranted, once the grain has been tested on receipt, it should be allowed to move normally through commerce.
Identity Preservation
NAMA has some concerns with the concept that identity preservation (IP) is the solution to seamless marketing of biotech-based grains.
Many buyers, including some U.S. millers, currently use IP systems to source grains with special quality attributes. An example is Japan's purchases of special soybeans that processors there believe make higher quality tofu. What makes such a niche market work are the financial incentives offered by the buyers. IP systems inherently entail higher costs.
Some handlers and exporters may be willing to incur those costs with the hope that they will profit from the greater opportunity for reward. Those premiums drive the system and all parties benefit – growers capture added value, handlers receive premiums to offset their risk and the customer receives a product with special attributes. An IP system with incentives can create value for the farmer because the industry can be demand driven as opposed to supply driven.
That description, however, is at odds with the IP system that some are advocating for marketing biotech-based grains. They envision an IP system that channels grains with no added niche value. Regular quality grains will not drive an IP system.
The recent StarLink episode provides a useful example. In that case, growers had a legal obligation (but no financial incentive) to direct that corn to animal feed uses only. For grains with neither a legal obligation nor a financial incentive, an even more disastrous outcome is likely. Said another way, there is a big difference between different and special. StarLink corn was certainly different, it just wasn't special, at least not in any meaningful financial way.
Finally, even with appropriate financial incentives in place, an IP system cannot operate with a zero tolerance standard. A zero tolerance standard is not a realistic expectation in the world's supply chain environment.
NAMA offers these recommendations to illustrate the milling industry's capabilities, and limitations, in dealing with biotechnology-based grains.
The North American Millers' Association is the trade association representing the wheat, corn, oat and rye milling industry. NAMA's 45 member companies operate 173 mills in 38 states. Their aggregate production of more than 160 million pounds per day is approximately 90 percent of the total industry capacity.
April 2001
Read:
Food Labeling
Genetically Engineered Foods
2001:
A Consumer Guide to What's in Store
Food Chain Principles On
Plant Biotechnology
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