Whatever the final decision on how to rid U.S. rice of Bayer CropScience's GM LibertyLink601 trait, one thing is for sure: purging the system won't be easy.
The recent release of a “recommended plan of action” by the USA Rice Federation is another step towards the needed purge. But even the federation — which has all facets of the rice industry under its umbrella — admits its plan is a “living document” that could face tweaks, or major changes, as the industrywide debate continues.
(To see the plan, visit http://www.usarice.com/industry/communication/SeedRecs.pdf).
Shortly after release of the federation's plan, Bob Cummings, vice president of international policy, spoke with Delta Farm Press about the plan's structure, how it was formed, how it could affect farmers and continuing concerns from trading partners. Among his comments:
On how the USARF came up with the plan…
“In October, the USARF established a seed committee. It had become apparent the solution we had to the problem of LL601 being in the commercial supply was to attack it at the seed level. (The alternative) was to get into a situation where, for the foreseeable future, we'd be required to constantly test rice before it went to consumers.
“So the seed committee was tasked with seeing if we could rid the system of LL601 by going through the seed supply. That group met and organized a conference over two days in Dallas — Oct. 31 and Nov. 1.
“They came up with recommendations and regulatory requests of the rice states. All… was designed to rid the commercial seed stock going into the 2007 crop of LL601 and, more broadly, all LL rice traits.
“What we released… is a result of the seed committee's work, the Dallas conference and subsequent followup and discussion.”
Let me ask you about the difficulty of putting the plan together. Can you describe the scene behind closed doors?
“I'd say (the Dallas meeting) and subsequent discussions have been fairly open. We endeavored to have a broad cross-section participate in this effort.
“Producers were represented, rice marketers were represented. Rice exporters were there as were reps from the seed industry. We had reps from various state departments of agriculture and state plant boards that oversee rice seed certification. It was a broad group.
“And because it was a broad group, each (facet) had different interests. But all the interests were focused on — and everyone had agreed on — the need to get rid of the LL traits starting in the 2007 crop by focusing on seed.
“From there, we went on to the most appropriate way to (accomplish) that. What's the appropriate test to use? What's the appropriate testing sensitivity? In the end, we came up with the plan we (just released).
Are testing levels yet to be put in concrete?
“There's a sampling protocol we're recommending. It's one that goes along with using 35S Bar (PCR) test so each of the three LL traits developed by Bayer CropScience would be captured.
“USARF chairman Montna did say (the plan) is a living document, and as we go forward and get new information — either through testing results, from the APHIS investigation or new info that folks bring to the table — the document can be modified. My expectation is there will be information that causes folks on the implementation side to move a step further and develop.
“One thing to emphasize is there are really two parts to what's been put on paper. One is a request to states to take specific regulatory action to the extent they have that authority. We've learned that each state has different regulatory authority.
“To the extent that states don't have regulatory authority, we also have a series of recommendations we're making to the rice industry as to what should happen. And those are recommendations only. Folks will make their own decisions based on their economic interests. There will be discussion between buyers and sellers as this thing is implemented.
How might this break down for farmers if (the USARF) plan is implemented? You said there will be differences between states.
“There's two parts.
“If the farmer is presenting to the first handler rice that was grown from certified seed — seed commercially bought — we recommend the first handler provide documentation saying, ‘The rice I'm presenting you for sale was grown from commercially bought seed that tested negative for LL traits. Here's the document (stating that) and here's also a document that shows the total amount of seed I bought for my farm.’ That way we'll be better able to match up rice presented for sale with the seed bought.
“In the third document, we're asking for the grower to provide a certified acreage statement — the same they make to FSA as part of their program participation.
“For those three documents we have the expectation they'd be (worked up) in the process of a farmer purchasing seed commercially.
“If a farmer is growing a crop from farm-saved seed, we're recommending the farmer provide the first handler some proof the seed he used tested negative for LL traits.”
The USARF has no control over this, but I take it the farmer will have to pay for those tests.
“That's not mentioned in the plan. … I'd say a farmer with farm-saved seed, it needs to be tested. That's probably what happens.”
There's a lot of bin-run seed (in Arkansas). In the Arkansas Plant Board Seed Committee meeting a few weeks ago, there was some discussion about the problems with getting the LL traits cleaned up in this environment.
“Education is a critical component of the recommendations we put out. It will be key to everyone in the chain, not just growers. (That includes) exporters, mills, dryers, lenders — so they have a sense of the severity and importance of finding a solution.
“Part of that education is letting folks know how serious the situation is. If we don't clean it up, for years down the road we may be compelled in certain markets to be continually testing rice we offer for sale.
“That's a position the USARF doesn't want to be in. We want to take the steps necessary as much as possible early on rather than constantly have to test. That isn't in our interest long-term.
“One thing to remember is LL601 has been deregulated in only one country: the United States. For every other country we'd sell rice to, LL601 is regulated and it shouldn't be in the rice going into them.
“To our knowledge, Bayer has made the decision not to commercialize LL601. We don't expect there will be efforts made to deregulate it in foreign markets.
“That leaves us with constantly testing rice before shipping it out. Or, we can make the effort at the seed level to remove LL601 and other LL traits from the supply.”
There are questions about the 0.01 testing level versus the 0.05. Is there a testing level everyone can live with? Have any of our trading partners commented on this plan yet?
“I haven't seen any comments from trading partners — either governments or customers yet.
“As for the sensitivity of the sampling protocol, the decision was made within the USARF … to have relatively tight sensitivity levels for seed … to reflect the fact that we're serious about removing LL traits from the 2007 crop. There was an understanding that as you move from seed to rice that's made available to the customer, the tendency for presence of LL traits would go up, not down. … The idea is to be as tight as we can be at the seed level going in. …
“Right now, the feeling is we need to be sensitive on the seed, to start out in a good place and show the world we're making a credible, good-faith effort to remove these traits from the U.S. supply. (That would allow us) to meet regulatory requirements overseas and also meet consumer preferences. We haven't seen a lot of acceptance for GE rice, quite frankly, in many of our markets.”
The hope, obviously, is it will take a single year to get rid of (the LL traits) …
“We're certainly hoping for the best and trying to be aggressive with 2007 in order to reach our goal. That said, folks realize the chances are good we'll have more to do in the 2008 crop.
“The recommendations we put out are designed for the 2007 crop with the full expectation we'll be revisiting and assessing where we are. We'll develop plans for the future when we know more about what's going on.
“We didn't want to put something out today that would lock us into a rigid set of recommendations. … As we go forward, if we need to do more work, (we will). … Will we have more work to do for the 2008 or 2009 crops? I think it's probably fair to say, we will.
“We're responding to this GE situation in a way that's consistent with the USARF's stand on GE rice. We don't oppose genetic engineering. It has benefits to the industry and grower community.
“On the other hand, we want to make sure that when GE rice is commercialized, there are two things: widespread regulatory approval … in the major markets, including the United States' and widespread consumer acceptance.
“On the regulatory front, we only have approval in the United States for (LL601). On the consumer acceptance front — while the level of consumer acceptance is higher in the United States than in other markets — there's tremendous resistance in Europe. There's concern in some of the key Asian markets. …
“We need to remove these traits … from the U.S. supply so, going forward, we have a marketable supply of rice to consumers both in the United States and overseas.”