North American Millers' Association
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 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 U.S. Government 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:
- Major market approval;
- Thresholds;
- Testing; and
- Identity preservation.
Major Market 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 large 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 can occur between biotech-based and conventional grains both in the field and in the system. Reasonable thresholds must be adopted to allow the movement of grains with adventitious admixture.
Testing
Test methods are highly sensitive and constantly evolving. 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 because it creates the potential to establish liability where none previously existed. Where testing is warranted, once the grain has been tested on receipt, it should be allowed to move normally through commerce.
Identity Preservation
Some U.S. millers currently use identity preservation (IP) systems to source non-biotech grains based on the premise the resources needed to support those systems are commensurate with the values received for them from the market. An IP system with incentives can create value for the producer through meeting specific market needs.
That description, however, is at odds with the segregation system that some are advocating for marketing biotech-based grains. They envision a system that channels grains with no added value creation. The addition of cost without value addition is unsustainable in a competitive global marketplace.
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.
October 2002
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