Action Alerts

Pharmaceutical Rice Threatens Missouri

Take action now — Send comments to the USDA by March 25th

In April 2004, Ventria Biosciences attempted to plant in California its drug-producing pharmaceutical rice, two varieties of rice engineered with human genes. An outcry from rice farmers and California citizens delayed regulatory approval, and prevented the planting last year. Ventria has since relocated to Missouri, another large rice-producing state, where rice farmers and environmental groups there are opposing it.

Ventria has requested permits for a total of 204.5 acres, and have publicly stated that they plan to eventually increase to as many as 28,000 acres. Ventria has contracted with a Missouri farmer who has never before grown rice. It is also important to note that no human health assessment of Ventria’s rice products has been conducted, and the Food & Drug Administration has not approved Ventria’s products as safe for human consumption.

Ventria requires a permit from the U.S. Department of Agriculture (USDA) before it can plant its pharm rice. The USDA has released a basic Environmental Assessment (EA) on each of the pharm rice varieties, and is accepting public comment on the EA until March 25th. After March 25th, the USDA could make a final decision on the permit, in time for Ventria to plant this year. To read the two EAs, download them from http://www.aphis.usda.gov/brs/aphisdocs/04_30201r_ea.pdf and http://www.aphis.usda.gov/brs/aphisdocs/04_30901r_ea.pdf.

You can help protect the food supply from contamination by drugs, and support Missouri rice farmers, by submitting a letter to the USDA demanding:

1. The USDA and the Missouri Department of Agriculture deny Ventria’s current permit application
2. Ventria be prohibited from conducting any field trials of its PMP rice variety until a full regulatory review is completed by the USDA, EPA and FDA

A sample letter is included below. The important case to make is that the EA does not adequately address the following important issues:

· Risk of Contamination — Pharm rice can be carried between fields by migrating birds, by water flooding, and by pollen drift. Human error is also a factor in the unintentional movement of seed. The EA dismisses these possibilities as insignificant.

· Economic Impacts — Missouri and the other rice-producing states in the Southeast pool their product into a few drying and milling facilities. Almost 50% of this rice is then exported to many countries, including the European Union (the second largest export market) and Saudi Arabia, both of which have strict regulations for genetic engineering imports. Riceland Foods, which handles almost all of the rice in the Southeast, has a large export facility located just 20 miles from Ventria’s proposed test site, and are at great economic risk in the event of contamination. The EA does not address these potential economic impacts whatsoever.

· Zero Tolerance for Drugs in Food — The FDA, the national food processing industry, and consumers around the world agree that any contamination of drugs in the food supply is unacceptable. The EA does not reconcile the potential for contamination with this zero tolerance policy.


SAMPLE COMMENTS — DUE MARCH 25th

Cite USDA/APHIS Dockets No. 05-006-1 and 05-007-1 (one for each of Ventria’s two pharm rice products)

To send your letter:

1. Electronically — Go to the link http://www.epa.gov/feddocket and click on “View Open APHIS Dockets.” File comments for both of the dockets, since they are different products but involve the same issues. There is a 2,000 character limit unless you attach a longer electronic file. The sample below is a short version that can be edited and pasted into the comment field.
2. By mail — Send an original and 3 copies to: Docket No. 05-006-1 and 05-007-1, Regulatory Analysis and Development, PPD, APHIS, Station 3C71, 4700 River Road Unit 118, Riverdale, MD 20737-1238.

SAMPLE COMMENTS — Please amend or select those most important to you.
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Ventria’s permit requests should be denied until a complete assessment of the ecological, economic and social impacts are conducted by the USDA, the EPA and the FDA. The EA does not adequately address the following important issues:

Risk of Contamination — Contamination can occur via pollen flow and the transportation of seed by birds, water or humans. The EA acknowledges these possibilities, but dismisses them as insignificant.
· Birds — The proposed Ventria test site is within 8 miles of the Mississippi River, a major migratory bird route. Studies have shown that birds frequently defecate viable seeds, and that unretrieved birds killed by hunters and predators can have undigested seed in their digestive tracts.
· Water — Localized flooding between rice fields and large scale regional floods present the possibility for uncontrolled seed movement.
· Pollination — Though rice is a self-pollinator, it does outcross at low levels, and pollen can be carried by wind or insects between fields. A weedy relative called red rice readily hybridizes with domestic rice, and could lead to a fitness advantage for the weed, making it even more difficult to control.
· Human Factor — While the EA concludes that stringent standard operating procedures will minimize human error, experience has already demonstrated that human error is inevitable. The fact that Ventria has contracted with a farmer who has never before grown rice increases the chances of errors.

Economic Impacts - The EA does not address potential economic impacts whatsoever. Missouri and the other Southeast rice-producing states pool their product into a few handling facilities. Almost 50% of this rice is exported, including to countries with strict regulations for genetic engineering imports. Riceland Foods, which handles almost all of the rice in the Southeast, has a large export facility located just 20 miles from Ventria’s proposed test site, and are at great economic risk in the event of contamination.

Zero Tolerance for Drugs in Food — The FDA, the national food processing industry, and consumers around the world agree that any contamination of drugs in the food supply is unacceptable. The EA does not reconcile the potential for contamination it describes with this zero tolerance policy.

Contact the Dean of CTAHR and encourage him to redirect the University of Hawaii’s resources away from genetic engineering and towards truly sustainable, non-GMO solutions to local agricultural problems. Dean Andrew Hashimoto can be reached by calling 808 956-8234, or by email at dean@ctahr.hawaii.edu.

Call Ray Uchida of the University of Hawaii’s Agricultural Diagnostic Service Center, at 808 956-6706. Encourage them to provide free, accessible PCR testing (“Polymerase Chain Reaction,” an accurate genetic analysis detection method) for local farmers and growers concerned about GMO contamination on their property.