To address these policy areas effectively, policy-makers must understand the current scientific findings in biotechnology; the public opinion and regulatory approaches of the United States, the European Union, and Asian countries; and international trade and regulation of GMOs.

Biotechnology in Food and Agriculture:
Costs, Benefits, and Uncertainties

Scientists modify plant and animal genes to improve resistance to pests and disease, increase fertility, reduce damage to the soil, increase nutritional value, or change other characteristics to make the organism more useful to humans. In fact, any type of cross-breeding, which agriculturalists have been doing for millennia, is genetic modification. Gregor Mendel pioneered scientifically based genetics research in the 19th century. Scientists are speeding the process by directly altering the genes of a plant or animal rather than waiting through generations of hybrids to achieve results.

Some critics dub these organisms that are patched together from various sources as "Frankenfoods." They believe that although genetic modification is intended to be beneficial, it could backfire and threaten human and ecological health. In the European Union, particularly in Britain, and in some Asian countries, the public seems to be especially suspicious of GMOs. Part of the problem stems from the poor information most consumers have about bioengineered foods and their understandable fear of involuntary exposure to an unknown risk.

No case has yet been reported of human health problems caused by bioengineered food. Moreover, genetically engineered foods have been subjected to more testing and scrutiny than conventionally grown foods, which carry their own risks. One major human health concern is that allergy-triggering or toxic genes could be inserted into a previously harmless food. Of course, biotechnology companies would share such concerns themselves, as they have every interest in ensuring that they develop safe foods. Opponents of GMOs also worry that bioengineered varieties could cross-breed with wild organisms, leading to pesticide- resistant "super weeds" or "super insects," pathogens resistant to antibiotics, or some other unforeseeable hybrid.³ However, these unexpected results are not unique to biotechnology-derived plants; they are just as likely to happen with conventionally bred crops.

Some harmful effects on plants and animals have been observed in laboratories. In a much-publicized study, scientists found that corn infused with a gene for Bacillus thuringiensis (Bt), a bacterium that kills corn borers and other pests, killed some monarch butterflies that fed on milkweed dusted with pollen from the corn.⁴ Although the researchers who conducted the study warned that their results were preliminary and should not be extrapolated to field conditions, the media and anti- GMO organizations presented the findings with stark simplicity: Bt kills butterflies.⁵ Few media outlets bothered to report on other studies that showed, for example, that the amount of pollen used in the laboratory tests was far more than would be found in the field, or that some Bt corn does not produce Bt in its pollen.⁶

Biotechnology can play a major role in ensuring food security. Many experts believe another biotechnology-driven agricultural advance, like the Green Revolution, will significantly contribute to feeding the world's poor, especially the 650 million who live in rural areas and must grow their own food in poor agricultural conditions. To overcome these handicaps, scientists in Africa, Asia, and Latin America, trained by the Rockefeller Foundation, the Consultative Group on International Agricultural Research, the Carter Center, and other international and nonprofit organizations, have bioengineered crops to resist weeds, drought, and disease while producing higher yields.⁷ With these advances, genetically modified crops can lower the cost of food production and make farming more sustainable.

Bioengineered plants have the potential to help remedy the malnutrition and nutrient deficiencies that pose serious problems in many developing nations. For example, 250 million children around the world are at risk for Vitamin A deficiency. This condition can weaken the immune system and cause vision problems, including, for as many as half a million children, irreversible blindness.⁸ Scientists have genetically altered rice to include enough beta-carotene to meet Vitamin A requirements from the rice alone, a potentially life-saving development for millions of children for whom rice is a staple food.⁹

Biotechnology has environmental benefits. Higher crop yields mean more food can be grown on less land, thus reducing the need to convert land to agriculture and preserving forests, uncultivated open space, and other wildlife habitats. Pioneer Hi-Bred is developing a strain of corn that delivers more of its phosphorus to the animal consuming it, resulting in as much as a 40% reduction of phosphorus in the animal's waste, which will lessen the water-quality threat to nearby waterways and aquifers.¹⁰ Similarly, Canadian scientists have genetically modified hogs to reduce the phosphorus in their waste.¹¹ The National Research Council acknowledges that crops with genetic pest protection like Bt could affect "nontarget organisms," but not as broadly as conventionally applied pesticides.¹² Monsanto estimates that U.S. farmers who planted Bt cotton crops applied 1 million fewer gallons of insecticide over three years than they would have with regular cotton.¹³ An Iowa State University survey of about 2,000 farmers who planted Bt corn estimated that about 6 million more acres of land had less or no insecticide applied in 1998 than in the year before.¹⁴

Some GMO advocates say that bioengineered foods may actually be safer than conventionally cross-bred organisms. When strains of plants are conventionally cross- bred, the breeder has no control over the thousands of genes that are exchanged and may end up with unanticipated characteristics in the hybrid. A scientist using biotechnology, however, can add or remove one specific gene to achieve the desired effect. And just because a product is naturally or organically produced does not automatically make it safe. Toxins occur naturally in many plant species.¹⁵ The National Research Council emphasizes that, with genetically modified plants as with conventionally bred ones, risk assessments should focus on the plant's properties, not on the process by which it was produced.¹⁶

The United States: Public Opinion and Regulation

Few Americans express concern about biotechnology. A September 1999 Gallup public opinion poll showed that 80% of respondents felt confident that the food they buy in the supermarket is safe. Only about one quarter thought that bioengineered food is a serious health hazard.¹⁷ A Wirthlin poll a month later found that 63% of consumers expected to see benefits from biotechnology over the next five years.¹⁸ Even while American consumers do not know much about biotechnology, a large majority of them trust the Federal Drug Administration (FDA) and other regulatory agencies to protect them.

In the United States, three federal agencies share regulatory authority over GMOs. The Department of Agriculture (USDA) certifies that an organism is safe to grow. The Environmental Protection Agency (EPA) confirms that any crop modified to include a pesticide is safe for the environment. The FDA assures the crop is safe to eat.

The FDA requires genetically modified foods to undergo a full food safety evaluation if they have "significantly altered nutrient levels, significantly different compositions from substances currently found in foods, allergenic proteins, new antibiotic resistance markers, or levels of toxicants significantly above those found naturally in edible varieties of the same species."¹⁹ However, the FDA does not require labeling of all genetically modified foods because it does not recognize them as different from conventionally produced foods. It mandates labeling only when the biotech food's composition or nutritional value significantly differs from its conventional counterpart. If the FDA determines a bioengineered food is unsafe, it is not allowed on the market, just as the FDA would ban an unsafe conventionally grown food if it threatened human health.²⁰ Testing thus far has largely been done voluntarily by biotech companies (which, of course, have a legal duty to market only safe products). The FDA, say some critics, is too willing to accept a company's claim that its product is "substantially equivalent" to its conventionally produced counterpart.²¹

Europe: Public Opinion and Regulation

Opposition to GMOs in our trading partners is another matter. Public opinion polls in 1999 showed that over two-thirds of Britons worried about eating bioengineered food and 96% wanted mandatory labeling of GMOs.²² Just 1% of Britons believed GMOs were good for society.²³ By mid-1999, 24 of Britain's top 30 food companies, including all of its major supermarket chains, had stopped using genetically modified materials or vowed to do so soon in response to their customers' concerns.²⁴ In France, more than half of the respondents to a 1999 poll had serious concerns about GMOs and believed more information was needed before genetically modified foods could safely be eaten.²⁵

In part, experience has fed the Europeans' fear of bioengineered foods and mistrust of the governmental bodies that are supposed to regulate them. In the past few years, several cases have come to light where the government not only did not protect the public health, but sometimes even knowingly continued to permit dangerous products on the market. The mad cow disease outbreak in Britain, the HIV-tainted blood scandal in France, the dioxin scare in Belgium, and other incidents diminished citizens' confidence in government regulators, science, and the safety of the foods they eat. In the United States, on the other hand, federal regulatory agencies like the FDA are trusted and have a history of rapid responses to food-safety problems.²⁶

This mistrust of authorities makes it difficult to counter the false information many Europeans have about bioengineered foods. The often hyperbolic media coverage in Europe shapes public opinion far more than science or government and does little to educate readers about the underlying science. Sociology and anthropology professor Thomas Hoban of North Carolina State University, who has studied public opinion of biotechnology for the past decade, believes that the more balanced news coverage in the United States has inclined Americans to be more accepting of biotechnology even when they are not well informed.²⁷ Likewise, reports by the Science and Technology Committee of the British Parliament ²⁸ and the London School of Economics ²⁹ blame the "volume and intensity" of media reporting in Britain for the public's fear of GMOs.

In terms of regulation, the European Union allows approved bioengineered crops to be imported, but individual countries can ban EU-approved GMO imports if they have new evidence of risk. The EU has not approved any new genetically modified crops since April 1998.³⁰ Toward the end of 1999, the British government decided to delay commercial genetically modified crops until 2003, when scientific trials of bioengineered crops will end. If "significant damage" occurs to the environment around the crop sites, biotech crops could be permanently barred from ever being grown in Britain.³¹

Asia and Oceania: Public Opinion and Regulation

Public opinion about GMOs in Asia and Oceania is similar to that in Europe. A 1997 Japanese government survey found that over 80% of respondents had reservations about GMOs and 92% wanted labeling.³² Likewise, the Korean Consumer Protection Board found almost 95% of those surveyed supported labeling.³³ In Australia, a 1999 poll by AC Nielsen showed 47% of consumers would not eat genetically modified food and only 28% believed GMOs were beneficial.³⁴ In 1998, bio-ethics professor Darryl Macer found that just one- quarter of New Zealanders believed the current biotech rules protected the public.³⁵

Australia, Japan, New Zealand, and South Korea have, or will soon, mandate, the labeling for foods made with genetically modified ingredients, though they all have yet to define specific guidelines. Yet, many Asian countries clearly see the potential benefits of biotechnology. The Japanese government supports biotechnology as its best chance at self-sufficiency in grain production. China is investing heavily in bioengineered crops to increase agricultural yields and has not indicated any desire to label or restrict genetically modified crops. Thailand also would like higher yields and has a fairly substantial amount of bioengineered crops, but the Thai government is worried by the anti-GMO furor in Europe. In 1999, Greek authorities seized a shipment of Thai tuna, demanding proof that the soybean oil in which the tuna was packed had not been genetically modified. Though it currently has no labeling laws, the Thai government may be forced to adopt some labeling scheme in order to continue exporting to Europe.³⁶

International Trade and Regulation of GMOs

According to the Biotechnology Industry Organization, bioengineered crops accounted for about one-third of corn acreage and half of soybean and cotton acreage planted in the United States in 1999.³⁷ In the two largest markets for American agricultural products, Japan and the European Union, the public is generally suspicious of GMOs. If these important markets ban genetically altered foods or institute labeling requirements that are difficult to meet or define, many American farmers could be in serious trouble.

Under the current World Trade Organization (WTO) system, a country that believes GMOs (or any other product) are harmful must prove its case. The Europeans want to shift the burden of proof to the exporter. They advocate the "precautionary principle," meaning that the proponent of GMOs must prove that the products are not harmful. If the science is inconclusive but a reasonable doubt remains that these products are safe, the Europeans want the power to ban them as a precaution.

The Biosafety Protocol--and particularly the Biosafety Clearing-House--provides a means for sharing scientific and regulatory information about the safety of biotechnology among countries. Better, more accessible information will allow governments, regardless of their domestic resources, to make informed decisions about the potential benefits and risks of importing GMO's.

Applying the Biosafety Protocol As per Article 19.4 of the United Nations-sponsored Convention on Biological Diversity, delegates from over 130 countries negotiated a Biosafety Protocol to regulate the environmental impacts of GMOs. The pact was adopted on January 29, 2000, but it will not take effect until ratified by at least 50 countries. Most of the conflicts in the negotiations were between the European Union, which wanted the Protocol to be an independent, legally binding instrument,³⁸ and the "Miami Group" of grain-exporting countries: the United States,³⁹ Argentina, Australia, Canada, Chile, and Uruguay, which did not want an independent agreement that would conflict with WTO rules. The Miami Group also wanted the Protocol to adhere to its charge under the Convention on Biological Diversity and address only the effects of trade in GMOs that would intentionally be released into the environment such as seeds not food safety or consumer-oriented labeling as well. The United States maintained that food safety issues, including labeling, ought to be settled in established multinational fora like the Codex Alimentarius.⁴⁰ The United States and its allies succeeded in concentrating on environmental issues, avoiding food-safety considerations, and ensuring that the final agreement provided certainty for exporters.

The pact does not alter any party's rights and obligations under the WTO. Nor does it give the WTO supremacy over the Protocol, or vice versa. Exporters must use an Advance Informed Agreement to inform importers in advance of shipments containing GMOs that are intended for release into the environment, and the importer may refuse the shipment even without "complete scientific certainty." Genetically modified commodities intended for food must carry a label saying they "may contain" genetically modified components, and the importing country has the right to bar them based on a scientific risk assessment.

The Protocol also recognizes that less-developed countries may not have the regulatory or scientific resources necessary to perform risk assessments. Leveling the playing field for these nations is a major reason for creating the Biosafety Clearing-House (Article 20). This Internet- accessible database will store research on various GMOs, the regulatory processes for approval in different countries, a register of which GMOs have been approved for import by which nations, and other information governments need to make science-based risk assessments. The United States strongly supports the Clearing-House and will provide most of the initial data.⁴¹ Facilitating information exchanges will only help biotechnology dispel myths and misconceptions by making research easy to access.

The Biosafety Protocol endorses a precautionary approach to some extent, but it is still vague on what level of scientific evidence will be required if a country wants to ban GMOs. The so-called "savings clause" in the Protocol's preamble asserts that it does not change the responsibilities and rights of countries under the WTO or any other international agreement. Article 10.6 states that "lack of scientific certainty... shall not prevent [a country] from taking a decision" on whether or not to ban the import of a particular GMO.⁴² Absolute scientific certainty is, of course, impossible, and this precautionary approach is enshrined in U.S. regulatory policy as well as in other international agreements.⁴³

The Protocol also gives countries the right to consider "socioeconomic factors" of importing bioengineered crops, including the impact on local farmers. Agriculture in the European Union countries is often inefficient and heavily subsidized. Bioengineered crops are a product of the technology-based New Economy and, with their lower pest-control costs and higher yields, could give farmers who plant them a competitive advantage. The European Union could conceivably argue that, because its farmers refuse to plant genetically modified crops, and because they are not competitive on an open market without GMOs, the Biosafety Protocol affords them special protection.

Avoiding a World Trade Organization Dispute Resolution. A ban on GMOs or overly restrictive or infeasible labeling could become a non-tariff barrier to trade, leading to a challenge at the WTO. Although its position on biotech crops is not yet clear, the WTO would almost certainly rule against any outright ban (unsubstantiated by scientific evidence) on GMOs.

A similar ruling on precautionary measures has already caused tension between the United States and the European Union. In 1998, the WTO ruled that the European Union's ban on American hormone-fed beef was not based on a scientific assessment of the health risks posed by growth hormones and was therefore illegal. The European Union appealed the decision but lost. When the EU refused to lift its ban on the hormone-treated beef by the May 1999 deadline but still could not provide any scientific evidence of its claim that the hormones threatened human health, the WTO allowed the United States to impose punitive tariffs on certain European goods to make up for the lost revenue from beef sales. Any WTO ruling on GMOs would probably have the same effect: the United States might win a dispute resolution, but American produce still would not be able to access European markets. U.S. agricultural exports to the European Union totaled $7.6 billion in 1998.⁴⁴ If the WTO allowed the United States to claim that even a quarter of that amount was lost due to a European ban on GMOs, the United States could impose massive sanctions on European Union imports.

Allowing the WTO dispute resolution process to determine GMO trade policy would only exacerbate existing tensions. In addition, leaving the GMO problem solely to this solution would do nothing improve testing procedures and ensure the safety of GMOs for those countries that do use them. And, unlike labeling, it would not give consumers the choice of buying genetically modified products, which might be cheaper or more nutritious than some conventional foods. The United States has other options to try to open markets to its genetically modified goods; a WTO dispute resolution should be a last resort.

Likely Areas of Policy Activity

While the U.S. works to increase acceptance of bioengineered food in overseas markets, it also faces challenges at home. Anti-biotech groups want to raise consumer awareness--and fear- -of bioengineered food in America just as they did in Europe. The federal government must take the initiative to ensure that the American public has access to unbiased, reliable, and comprehensible information on which to base their purchasing decisions. Policy debates will most likely center around clearly identifying the risks and benefits of biofoods, educating the public about them, and determining if and how to label foods with genetically modified ingredients.

Identifying and Assessing Risks and Benefits. A "zero-risk" policy is impossible. No food can be proven to be 100% safe for everybody. The challenge to policymakers is to assure adequate testing, be ready with back-up solutions if an unexpected threat appears, and create balanced policies that allow the maximum benefit at the minimum risk. Every bioengineered food on the market has undergone rigorous testing, and so far, any potential threats to human health have been caught early in the development stages, well before the product ever reached the market. Opponents to genetically modified foods admit that no health problems have yet been caused by a GMO, but they want more proof that such problems will never occur.

The Biosafety Clearing-House, created by the Biosafety Protocol, could be very helpful in collecting and disseminating scientifically sound risk assessments and contingency plans.⁴⁵ Although it is not a signatory to either the Protocol or its underlying Convention on Biological Diversity, the United States was a strong advocate of the Clearing-House and plans to help get it up and running as quickly as possible. Intended to be a respected, neutral forum for information exchange, it is the United States' best opportunity to prove to skeptical nations that the benefits of agricultural biotechnology outweigh the risks.

Educating the Public. Much of the opposition to GMOs, at least in Europe, relies on information from environmental nonprofits, advocacy groups for farmers who do not plant genetically modified crops, and newspapers looking to increase sales with exaggerated headlines. The United States can do little to counter misinformation in other countries, but fortunately, the American public has not yet reached the Europeans' level of suspicion about GMOs. This gives the U.S. government a chance to promote a balanced domestic debate on the benefits and risks of bioengineered foods and crops. The FDA should not compromise the trust the public has placed in it either by appearing to be a shill for the biotechnology industry or by allowing butterfly-costumed demonstrators to determine its policies. Rather, it should work with USDA, EPA, Congress, and the Administration to interpret without bias scientific results for the lay public, distribute this information as widely as possible, and let citizens make up their own minds. The FDA can also take the lead in passing this information on to the Biosafety Clearing-House.

Determining If and How to Label Foods Containing Genetically Altered Ingredients. Many consumers, activists, and governments advocate informational labeling to let consumers know what they are buying and allow them to make their own choices. However, the labels would have to convey relevant, comprehensible information, a difficult task given the very limited space available on many packages. Consumers would have to understand what "genetic modification" means. Regulators would have to decide if labeling should be mandatory or voluntary. Any labeling policy must determine the ingredients that a label would identify, the tolerance level for genetically modified components of these ingredients, and the wording and location of a label. It is important to ensure that a "GMO free" label would not imply the labeled food is healthier or safer.

Opponents to mandatory labeling point to studies that show that the very presence of a label on food implies danger to some consumers. Mandatory labels could cause some food- processing companies to drop genetically modified foods completely for fear of being stigmatized and losing customers. To make labels meaningful and useful, the government would have to launch a credible public education campaign. Any such project in Europe would be even more difficult to carry out than in the United States, given the public mistrust of government and scientists. Just as voluntary labels for organic or kosher foods cater to a specialized market, so too could "GMO free" labels. Although right now a voluntary labeling policy would appear to benefit mostly companies that eschew genetically altered products, when foods bioengineered to enhance health begin to appear on supermarket shelves, a voluntary label could prove a valuable marketing tool to producers who embrace biotechnology.

Countries currently trying to implement labeling laws are having trouble defining what amount of genetically modified ingredients would cause a food to be labeled and how authorities can reliably trace and test genetically modified components. It is difficult to track the genetically modified ingredients of a food product because different crops are mixed together at various stages in their journey from the farmer's field to the supermarket shelf. DNA testing can detect "one GMO part per trillion," according to Dennis Kitch of the U.S. Grains Council.⁴⁶ The smallest amount of genetically modified corn or soy bean mixed in with produce from a conventionally grown crop could result in the entire shipment being labeled as genetically modified, depending on the importing country's regulatory tolerance level. American agricultural processors like Cargill have pledged to keep bioengineered crops separated from conventional produce if necessary, but they note such "identity preservation" would be expensive and difficult. Though Cargill would not be able to guarantee a 100% GMO-free shipment, it would try to meet "reasonable tolerances" if the buyers were willing to pay a premium for identity-preserved goods.⁴⁷ Some estimates suggest identity preservation of crops could raise the shelf price of a food product by 25% to 30%.⁴⁸ Labeling a product with indirect GMO inputs--for example, a package of bacon from a hog fed with Bt corn--would be even harder to verify.

To facilitate trade, labeling laws would ideally conform to a common global standard. As yet, no country or organization has been able to create a feasible policy that addresses all of these concerns. Nor have any offered a remedy for the added expense to farmers, shippers, and food processors of keeping genetically modified crops separate from conventionally grown ones. In 1997, the European Commission mandated labeling for all new products containing GMOs. However, it has yet to determine what would constitute a "GM-free" product. The proposal currently under debate suggests a 1% tolerance level (meaning the product could have up to 1% of bioengineered content without being labeled).⁴⁹ However, the technical challenges mean that EU consumers would have to be willing to pay a premium for identity-preserved products. Timothy Galvin, the Administrator of the Foreign Agricultural Service in the U.S. Department of Agriculture, believes that the 1% tolerance level would be "a very, very difficult level to meet and presents the potential for substantial trade disruptions" with the United States, Canada, Argentina, and other countries that export genetically modified foods.⁵⁰ This potential for trade disruption will only grow as China, which is making substantial investments in genetically modified crops, moves toward joining the WTO.

Japan and South Korea have labeling laws on the books but not yet defined. Australia and New Zealand will require labeling by the end of 2000. Other countries, like Thailand, are feeling pressure to enact labeling laws so that they can continue exporting to Europe and nations with labeling requirements. In the United States, Rep. Dennis Kucinich (D-OH) has introduced H.R. 3377, a bill to require labeling of food containing genetically modified components or produced with genetically modified materials.

Conclusions

Any decision about the safety of genetically modified organisms will have ramifications beyond trans-Atlantic trade. Biotechnology could play a vital role in feeding the population of the developing world. If American farmers stop planting bioengineered crops because they cannot sell them overseas, biotech companies will no longer find it profitable to research and develop GMOs, and the developing countries will be the ones to suffer. Nonprofit and international development organizations like the Rockefeller Foundation and the Consultative Group on International Agricultural Research do biotechnology research in developing countries, but the loss of private-sector R&D would be damaging.

On the other side of the coin, if GMOs gain widespread approval and use, governments must have reliable safeguards and ongoing testing procedures. More research should be done on biotechnology's potential long-term effects on biodiversity and human health--on the benefits as well as the possible ill effects. Respected safety testing procedures, a strong scientific base of understanding, and a well-informed public are essential to reaping the benefits of biotechnology and avoiding potential harm.

Endnotes

1. Although all animals and plants have technically been genetically modified, whether through breeding or through recombinant DNA techniques, the term is generally used to mean "derived from biotechnology."

2. The National Academies, "U.S. Regulatory System Needs Adjustment As Volume and Mix of Transgenic Plants Increase in Marketplace," press release, 5 April 2000.

3. The biotechnology industry rebuts this argument by noting that, if a weed or insect pest developed a resistance to one pesticide, another could be used to kill it. The EPA has approved an industry plan to manage insect resistance to Bt.

4. Laura Dietrich, "Novartis Concedes Engineered Corn Merits More Study," Dow Jones International News, May 20, 1999.

5. See news stories titled "Gene-Spliced Corn Imperils Butterfly" (San Francisco Chronicle, May 20, 1999), "Altered Corn's Pollen Targeted Study Says It Can Kill Butterflies" (New Orleans Times-Picayune, May 20, 1999), "Genetically-Engineered Corn Seed Found To Poison Monarch Butterfly," (Dow Jones Business News, May 19, 1999), "Biotech vs.'Bambi' Of Insects? Gene-Altered Corn May Kill Monarchs," (Washington Post, May 20, 1999), "Environmentalists: Altered Corn May Have to Be Banned" (Chicago Sun-Times, May 21, 1999).

6. National Research Council, Genetically Modified Pest-Protected Plants: Science and Regulation (pre-publication copy), National Academy Press (April 2000), 76-78.

7. Gordon Conway and Gary Toenniessen, "Feeding the World in the Twenty-First Century," Nature, 402 supplement, December 2, 1999, C56-57. See also www.cgiar.org

8. Dean DellaPenna, "Nutritional Genomics: Manipulating Plant Micronutrients to Improve Human Health," Science, 285, July 16, 1999, 375-76.

9. Conway and Toenniessen, C56-57.

10. Raj Iragavarapu and Tom Doerge, "Manure Phosphorus: Problems, Regulations, and Crop Genetic Solutions," Crop Insights, Pioneer Hi-Bred International, 9 No. 6 (1999).

11. Colin Nickerson, "Making a Silk Purse from a Sow's Droppings," Boston Globe, June 24, 1999.

12. National Research Council, 80.

13. Alex Salkever, "Are These New Bio-Crops Safe?" Christian Science Monitor, August 5, 1999.

14. Associated Press, "Study: Farmers Reduce Insecticide Use with Bt Corn," Yankton (South Dakota) Daily Press and Dakotan, November 22, 1999.

15. Declan Butler and Tony Reichardt, "Long-Term Effect of GM Crops Serves Up Food for Thought," Nature , 398, April 22, 1999, 653.

16. National Research Council, 46.

17. Lydia Saad, "What Biotech Food Issue?" Gallup News Service, 5 October 1999.

18. International Food Information Council, U.S. Consumer Attitudes Toward Food Biotechnology," Wirthlin Group Quorum Surveys, October 1999.

19. Larry Thompson, "Are Bioengineered Foods Safe?" (Interview with FDA Commissioner Jane E. Henney, M.D.), FDA Consumer, January-February 2000, accessed at www.fda.gov on March 14, 2000.

20. Ibid.

21. Rick Weiss, "Biotech Food Raises a Crop of Questions," Washington Post, 15 August 1999. "Substantial equivalence," a standard embraced by the Organization for Economic Cooperation and Development and the British Advisory Committee on Novel Foods and Processes as well as by the U.S. FDA, means that a genetically modified food is comparable to the conventional variety in terms of toxins, allergy triggers, and nutrition (Butler and Reichardt, 652). Substantial equivalence is vague and poorly defined, however, and is not necessarily a reliable predictor of a food's effect on human health.

22. "GM Foods: The Independent of Sunday/NOP Poll Results," The Independent (London), 21 February 1999.

23. Marie Woolf, "Poll Reveals Public Doesn't Trust Labour on GM Food," The Independent (London), 23 May 1999.

24. "Euro Stores Cash in on 'Frankenstein Food' Fears," Reuters News Service, 21 April 1999 and "UK Food Producers Veer Away from GM Ingredients," Reuters News Service, 27 May 1999.

25. "French Not Impressed with GMOs Survey," Reuters News Service, 30 November 1999.

26. In a comparison of U.S. and European attitudes about government regulation of biotechnology, taken from studies done in 1996 and 1997, Europeans indicated that they trusted environmental (23%), consumer (16%), or farming (16%) groups far more than government agencies (4%) to tell them the truth about GMOs. In the United States., by contrast, 90% of respondents said they would trust the USDA's position on biotechnology and 84% would trust the FDA. George Gaskell, Martin W. Bauer, John Durant, and Nicholas C. Allum, "Worlds Apart? The Reception of Genetically Modified Foods in Europe and the U.S.," Science, 285 (16 July 1999): 386.

27. Thomas J. Hoban, "Public Perceptions and Understanding of Agricultural Biotechnology," Economic Perspectives, U.S. Department of State, 4 no. 4 (October 1999): 31.

28. Mike Peacock, "Media, Gov't Risk Robbing UK of GM Benefit, MPs Say," Reuters News Service, 19 May 1999.

29. Maggie Fox, "'Frankenfood' Headlines Scare Public, Study Shows," Reuters News Service, 16 July 1999.

30. "Factbox: Key Data on GM Food in the European Union," Reuters News Service, 19 November 1999.

31. Michael McCarthy, "GM Crops: Ministers Ban Commercial Use until 2003," The Independent (London), 6 November 1999.

32. John Freivalds and Daryl Natz, "Overcoming Phood Phobia: Changing Perceptions About Bio-engineered Products," Communication World, 1 June 1999.

33. "S. Korea Says to Label GM Food from July 2001," Reuters News Service, 9 December 1999.

34. Tim Colebatch, "GM Food Favored by Only a Few: Study," The Age (Australia), 3 September 1999.

35. Stacey Mair, "A Matter of Genes," The Press (New Zealand), 4 June 1998.

36. "Factbox: Asia's Place in the GM Debate," Reuters News Service, 19 November 1999.

37. L. Val Giddings, vice president for food and agriculture, Biotechnology Industry Organization, testimony before U.S. Senate Committee on Agriculture, Nutrition, and Forestry, 7 October 1999.

38. Ehsan Masood, "Collapse of Talks on Safety of GMO Trade," Nature 398 (4 March 1999): 6.

39. Because the United States has not ratified the Convention on Biological Diversity, it has no official role in the Biosafety Protocol negotiations. However, it is an important part of the debate.

40. Alan Larson, acting undersecretary of state for economic, business, and agricultural affairs, "Biotechnology: Finding a Practical Approach to a Promising Technology," Economic Perspectives, U.S. Department of State, 4, no. 4 (October 1999): 9.

41. Frank Loy, undersecretary of state for global affairs, speech to Washington International Trade Association, 12 April 2000.

42. Draft Cartagena Protocol on Biosafety, Article 10.6 (31 January 2000).

43. David B. Sandalow, The Biosafety Protocol: What It Does and Does Not Do," (Washington, D.C., U.S. Department of State International Information Programs, February 2000).

44. International Trade Administration, "U.S. Total Agricultural Exports to Individual Countries, 1991-98," Department of Commerce. Available at: www.ita.gov

45. Protocol on Biosafety, Article 20.

46. Sonni Efron, "Japanese Choke on American Biofood," Los Angeles Times, 14 March 1999.

47. Speech by Dan Dye, vice president, North American Grain Group, Cargill Inc., at the Agricultural Outlook Forum 2000, 24 February 2000.

48. Efron and The Economist, 19 June 1999.

49. European Commission, "The European Commission Approves the Labelling of Genetically Modified Organisms," press release, 18 June 1997, and "Factbox: Key Data on GM Food in the European Union," Reuters News Service, 19 November 1999.

50. Interview with Timothy J. Galvin by Economic Perspectives editors Jonathan Schaffer and Merle D. Kellerhals, Jr., "Biotechnology: Reshaping Global Agricultural Markets," Economic Perspectives, U.S. Department of State, 4, no. 4 (October 1999): 11.

Megan Susman is a policy analyst at the Progressive Policy Institute's (PPI) Center for Innovation & the Environment.