Profile

CSA believes that the use of agricultural biotechnology to produce new seed varieties, and to improve existing ones, is as safe as traditional breeding techniques. In fact, the use of recombinant DNA techniques in plant breeding may in some cases be safer than wide crosses or other traditional methods. Biotechnology offers a more precise and more efficient means of developing new plant varieties.

CSA also believes that crops and foods produced through biotechnology are safe and equivalent to similar foods produced through traditional breeding. The federal government and many in the medical and scientific communities agree with this view, and consumers have been safely eating foods and using medicines derived from biotechnology for many years.

It is the position of CSA that the Food and Drug Administration already sufficiently regulates the labeling of foods produced through agricultural biotechnology. Where such a food differs from its traditionally bred counterpart in allergenicity, toxicity, or nutritional composition, FDA requires additional testing and labeling to reflect those differences. That requirement adequately protects and informs consumers. Requiring special labeling simply due to method of production is misleading to the public, since these foods are substantially equivalent to and as safe as foods produced through traditional breeding.

Mandatory labels would be tantamount to a warning label and would discourage some consumers from buying these foods; CSA holds that it is improper to place warning labels on foods. CSA also opposes state or local labeling requirements that differ from those established by the federal government — uniform labeling throughout the country is essential to facilitate commerce in food products. Existing seed labeling requirements, along with additional information provided by seed companies, already give growers what they need to properly use biotechnology seed.

Mandatory labeling is not simply a matter of printing additional information on a label. It would require identity preservation from the point of purchasing seed and planting a crop through production, harvesting, transporting, processing, and distribution: segregation of commodities, dedicated equipment and facilities, special cleaning, and documentation and tracking systems — all adding cost. Some commodities, including soybean products, corn, cottonseed products, and wheat, may be used as either food or animal feed depending on market prices, and markets shift in seconds. A commodity may have to be diverted at the last minute from a food market to a feed market with no way to recover the added costs of identity preservation.

A recommendation by a seed distributor that a customer purchase a variety of seed — whether produced through traditional breeding or biotechnology — should not automatically be deemed a pesticide recommendation, even where that variety has characteristics of pest resistance or herbicide tolerance. Such a recommendation may be made for a range of agronomic or marketing reasons, and those who merchandise seed have agronomic expertise other agricultural consultants often do not.

Pest control advisors may recommend the use of a seed variety for pest management purposes. However, since a PCA recommendation is not even required to use a pesticide, CSA opposes requiring one in order to sell, buy or use a seed variety — even where such varieties are virus, nematode, or pest resistant, or herbicide tolerant.

CSA believes the advent of seed enhanced by biotechnology should not materially change traditional seed warranties. Those selling seed should warrant and indemnify only up to the value of the seed sold if a problem arises, regardless of how the seed was produced. This position should govern arbitrations and mediations conducted under the mandatory seed arbitration and mediation law in the Food and Agricultural Code.

Tolerances relating to the constituents in a lot of seed or commodity being marketed, if deemed necessary, should be science-based for all seed and commodities regardless of production method. A tolerance suitable for one commodity may not suit another, depending on whether the crop is self- or cross-pollinated, how long the commodity has been in production in an area, and other factors. Allowable tolerances should be based on the quality requirements of the product commodity, not on the methods used to develop the variety.

Mandatory consultation

CSA believes mandatory consultation with the FDA interferes with bringing new products to market that will benefit the environment and the public, and therefore opposes mandatory consultation between FDA and biotechnology companies in gaining approval of new varieties. Agricultural biotechnology foods are among the most tested and scrutinized foods on the market; voluntary consultation has proven adequate and has provided a high degree of protection to consumers.

State regulation

CSA opposes a separate state approval process for varieties developed using biotechnology. The California Department of Food and Agriculture has reviewed these varieties since 1988, and a patchwork of state laws would impede the development and introduction of new varieties.

CSA also opposes planting moratoria on biotechnology commodities, across the board or by individual commodity, which would place California producers at a competitive disadvantage with producers in other states and countries. California should be a leader in this arena, and all California consumers should have the opportunity to benefit from the nutritional and environmental advancements it brings.

Testing

The association supports scientifically validated, accurate, cost-effective, and expeditious laboratory testing for biotechnology traits. Stakeholders should have broad access to testing methods and protocols, and USDA and FDA should provide research funding for test development.

There should be consensus among all stakeholders as to which laboratories, sampling, and testing protocols provide the analyses on which disputes will be settled. CSA opposes biotechnology-free regulations and restrictions imposed by foreign and domestic entities until standardized, accepted laboratory tests are available and there is agreement on who will perform them. CSA also opposes mandatory testing requirements for all commodities; markets and consumers should determine when testing is warranted.

Education

CSA supports educational programming in agricultural biotechnology and urges the University of California and the Seed Biotechnology Center to continue developing courses and distributing extension materials on the discipline, covering the major aspects of production and distribution of biotechnology commodities in California.

Bio-terrorism

CSA supports increasing penalties for those committing acts of violence in order to thwart the introduction of biotechnology in agriculture and the food industry.

Isolation

In the seed industry it is the responsibility of the seed company to produce in areas that provide adequate isolation, so as to prevent contamination of the seed they are producing. Isolations for ensuring the integrity of crops in production should not automatically be the responsibility of growers employing biotechnology. Issues of isolation, cross-contamination, and related liability should be resolved through the judicial process. In no case should seed breeders or producers be responsible for contamination occurring within production agriculture; such incidents should be resolved by the parties involved in producing the crops.

Identity preservation

Effective identity preservation programs should be developed as needed to facilitate the marketing of both biotechnology and traditionally bred commodities and seed. CSA supports voluntary identity preservation programs offered by entities who wish to provide such services.

Resistance management

Pest resistance management should be carefully monitored by those involved in agricultural biotechnology. Where resistance management is an issue, refugia and other production methods are effective. Determining the necessary procedures for each crop should primarily be the responsibility of the entity developing the variety, in consultation with EPA and USDA, and it is proper for federal agencies to require modifications when warranted by the scientific data.