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COM 0728.009 2000-2002
S®p-09-2002 11 .21 am From-HARC 808°488-5020 T-508 P.002 F-383 . Y T FpRMtER~YHAdt~AllaN$7ICrr1R PtaNTEFtS~A$SUCIATlON 99-193 ATEA ~$E1Gx7's 171tT'VL, SUITE 300.At~, sF1Ar~vAn 96701-3911 '~'LEPI•IONL; (8U8) 487-5561 Fnx: (808) 486-5020 hrrp://www. hawallaq.or~/hurt 'r>FS~cn~r®lv~ T~ c®MIrT~I~ oar I-~UIVIAN IS~~J.RC~S ~i IBC®IV'~MYC I~~~~Y.CDPIiiIIFIOT'~ AWAiI< C®CJ'NT~ CCgI<7191'CI~ ~~t:erV~r~ 1:telaled t®~ $.es®!at>d®et Su~p~refi a ttrr,~.__1? _1`!_ a s> sy.._-_.__.~..-..~.Msaratoa°iu~t.ore l~lan~ng ~emmet1ca11y Enaeer°eci t5ots__._._--------~~7-t~?-"=•-----m.--...,.~ Co$1ee ~ 1~1®ritla and ~®~8.hh 1~®n~e County Council s~~>relnbe~ ~o, ~oo~ Chair Pisicehio and members of the committee: My name is Stephanie Whalen. I am President and Director of the Hawaii Aglzculture Research Center (HARC). Y atn testifying today on behalf of the center, our research and support staff, and our rrernbers and clients. I~AI2C is in strong opposition to Coun[y of 1Flawaii proposed laesolution No. 236-02, a resolution Supporting a Moratorium on eha release and ]Planting of Genetically Modified (GM) Cogfee in the Districts of P'.Torrh and South Kona in Carder to Assure and Protect the I3iotie integrity and Market Value of Pure Kona Coffee. I want to make it very clear that in no way does l°IARC oppose the concept of developing market niches for flawaii's crops. In fact, true quality differentiation is very important:for 1Flawaii's agricultural export producers to compete in a tough :global. marketplace. 1-~owever, F€A1~C is concerned about the use of partial information and/or misinformation to advance an agenda of a few at the expense of other segment<S of the agricultural indtlstry in I~awaii. All sectors of the industry have to worPc together in a cooperative spirit advancing all sectors for the good of the whole. Over 100 years ago dua-ing I°Iawaii's last major agricultural transition i€ was stated, "First of call they (the fixrrras arrd businesses} rraust he united.. fibs jecalocasies of nattoracadity, of location, of cdifferent degrees of scsccess in business, should he sctrtk in the general desire for the welfare of the whole". All farms need to coexist; there is morn for all processes; no one sector needs to advanae itself at thL expense of the success of an other. Only through cooperation can 1"8awaii's agriculeure met the huge challenge ahead of it. It needs to carry a shsu-e of the ecanonlic diversity for the state through ecanotnically viable and environmentally sustainable land based businesses. N~o single crop can do that for the state any mare; it wilt be z3 collection of many . advancing collectively, supportive of all agriculeure businesses in I~awaii. Fnergy should not be Lost in local squabbles; it is not neighbod agailtst neighbor: there has bezn too pnuch of that; it is i-Iawaii's products in competition with the rest of the producers of the world. Focus needs to be on real issues. In addition, IHfARC cannot support she establishment of regulatory systems based on approvals by limited Special interest Organizations. replication of that concept would result in chaos. A public review process is available to all pareses bath at the national and seats level for regulation development. It is difficult to understand the County of I-Ia~vaii's intent in this resolution where it clearly admits that the county has no regulatory authority nor scientific can~pctence in tha area, but is supporting a request shat seeks that authority for privau: sector organizations -"a regulatory regime has beea~ developed, (;o~ana, Nms file 3~0. ~ , ~f. ~~~t~ Ufa Dam . S®p-09-1002 11 :21 am Fra~RHARC 808-486-5020 T-508 P.003 F-3B3 r~t~?wAal E#laBUC:ua:l uK~ acra~acc:ra (:lrfV`I'!:^IZ -2- adopted, and approved by those organizations....". It is further disconcerting that they has apparently been no inquiry to the local director of the federal agency that does have regulatory oversight in this area before resorting to the action proposed in this resolution. The really sad state of this is there is no real issue here. 'There are no GM coffee plauats in field testing grad there never were. There are three University of 1"iawaii field test ~I~IS notifications on a website at Virginia Tech posted since 1996. ~Iowever, no plant was produced ira the laboratary that showed enough promise to advance to field trials nor were there funds available for field trials. See the attached document for a baief sun~xaary of that activity and its current status. Interestingly enough during that earlier period there were many articles generated nati~„a>ly and internationally over the potential for Ca1~1 decaffeinated coffee plants in ~iawaii. At this time there was no concern expressed in the industry, every by Kona. The initiating work in this area was supported by the 'i~awaii coffee industry. Unfortunately, it was this website lis[ing that is alleged to be the basis for the concern that generated the momentum for this resolution. A simple phone call to the applicant would have been all that waS needed to detvrrraine whether there were any CYIOVI coffee plants in the field. !~s for client concerns over the potential presence of CM coffee. any grower could clearly state that there are rto CrM coffee plants in the fields in I-iawaii And calara any buyer concerns :based on the itafarmation provided by the applicant- Thal is still a viable salutian and the most rea.SOrlable. Out of curiosity, l went to the iaternet grad was only able to find articles generated by the ]Kona Coffee Council itself or rncdia coverage initiated by it with respect to GM coffee and hlawafi. 1 can only assume theft the Council members have been provided some writtrn dacumentation that this is a marketing crisis needing ianmediate response. 1`ndeed, actions taken by the KCC and stated in the proposed county ordinance may work to the detrimene of the Kona Coffee Industry by giving buyers a perception that GMQ coffee is already in the field. l:f something is seen and heard often enough, it becolYaes fact far many people. In reviewing the websites and articles brought up using 'genetically modified' and coffee in a (ioogle search, X found several anti-GM® articles. The vast majoraty, h®wever, deal with Searbuck's and the harassment inflected on it by special interest groups. These groups want Starbuek's to sell only free trade coffee and non-GMO products. 12ight now the issue is mainly over milk since G1V1 coffee is not corramercially available. To Starbuck's credit it is resisting efforts to be bullied, while agreeing to be sensitive to labor and activist's issues. It prefers [o offer its customers many choices, including all types of coffees and processes. This is not good enough for some groups who selectively boycoet its stores and protnise to continue until the business does what they want. At the beginning of this testimony I alluded to partial oa• rrusinfornaati.on. In the 7`~ whereas statement; it says that "organic coffee must contain no trace of GM interference". This is a common public misconception, unfortunately, even an;aong organic producers. The law establishing the organic regulations and the regulations themselves clearly address that the organic standards are processed-based. The growers' process is certified, not the pr®duct. It is the geawer tree eer~fyi~g ngeaat's resp®~ea~hility to agasure t ~Il r~~ommalsl~ steps 3® S®p-Og-2002 1i:22a,n Frr~s~-HARC 808-486-5020 T-508 P.004/025 F-383 rtAwAU. At%tuc.;l1L~!'Ultla KESE~tCii (.'~N7~R -3- av®acl c®attacir with the products of excluded methods. Since using a GM plant is an excluded method as requested by ehe organic producers in the public coznn2ent process for the National regulaton, it is the organic producer's responsibility to avoid contact through his/her operational procedures. As Long as the grower does this his process is certified and his products can be labeled organic. Nowhere does the law or the regulation state that an organic crop 'trsust contain no trace of G.M interference'. In fact, some countries have established G1WI levels below which a product is considered "GMQ free" for labeling and marketing puaposes. This is cleaz recogatition that zero tolerance will not be the marketplace standard. The U.S, rr~ay chose to do the same. 'c'hose Issues will be decided with the opportunity for public comment at the national level to avoid trade restraints. These issues were made very clear in the regulations and in response to questions that were asked specifically about G1LI0 presence in organic products and aze available on the USDA website under the National ®rganie Seandards. For your perusal, I have attached the parts of the regulation, its preamble and frequently asked questions that refer to the "genetically modified" as an eY^l,tded method. USDA regulations set no quality standards for organic products because there is no demonstrated quality differ<;nce between organically produced products and non organically pr®datced products. What has been demonstrated in general far produce irrespectsve of the farm operational procedures is that the fresher the product the higher its quality since son~ae vitatmins and some nutrients are prone to decline with time. In promulgating the organic standards USDA wac concertaed that certifying the organic process may confuse the public who historically equate US]~A ccrtifacaeion with quality. There are some agrieultut'al products in the marketplace that are regulated to meet quality standards and are certified by the USDA in that respect. The ones we are most familiar with are meat, eggs, dairy products, etc. The 8~ whereas statement is misleading because the Specialty Coffee Association of America did noe rnalse such a statement. The statement was made by a committee within the SCAR and has yet to be brought before ehe SCAA Executive Committee. GM Techniques offer many opportunities for development of specialty coffee including altexed caffeine content, unique flavor and disease and pest resistance. The latter leads to reduced pesticide ue. The 9`~ whereas statement regarding delayed acceptance by Japan and/or the European Union is oddly worded since there is no reque.t for acceptance for a GNl coffee and none on the horizon. There are 43 varieties of 6 different crops that have been approved by Japan. .Japan is cat the approval process for the laainbow papaya; it was delayed because cea~ain tests were no[ available. The u:sts requested were not unreasonable. rf and when a GM coffee is cammerciali2ed somewhere enough experience will be had with the global regulatory systems that applicants will have prepared for the requests made by the regulators. This whereas statement is irrelevant to the resolution. The fact that several states are reviewing labeling GM foods is irrelevant; legislatures review many issues that never go beyond that. finis issue has so far failed at the national level tatxd is S®p-D9-2002 11:22art: Frain-MARC 8D8-486-5020 T-508 P.005/D25 F-383 MAWl#![ AGt~ICCJLT[Jlt~ RT?S~ARCH CENTER -4- heing moved to the local level by special interest groups. Labeling is advocated as a consumer Cho%Ce iSSlt~, However, the consumers have a choice already; they can buy organically growl! products. Speculating that the price of Crll~1 coffee in !Kona could be negatively impacted dtae to decreased demand is based on unrealistic assumptions. It assumes that there %s GM coffee; there isn't and there is no imminent risk of it. It assumes delayed acceptance without an application even being considered Since there arc no GM plants to seek acceptance for. This whereas statement is irrelevant to the resolution. In conclusion, H~RC urges the Council merrabers not to support moving this resolution out of committee because of the shear lack of necessity, the lack of authority any of the parties have in this area, the confusion that eacists over existittg variety purities, the nusrepresentations rtaada in soave of the VVlaereas statements and the damage it may cause the industry through repeated media exposure to anon-imminent issue. There are no cottlmereial Gldrl plants; there are no test plants in the field or greenhouse and the local researchers engaged in this teclaraology have agreed to )<e°~ the I3awaii coffee industty apprized of !heir work and consult with them before any field introductions are made, if ever. 'Thank you far [his oppoMUnity to testify on Resolution No. ?36-0?. S®p-09-2002 11:23am Fram-MARC 808-486-5020 T-508 P, 006/025 F-383 t1AWAU ELCiIZICULTLJdd~ RESEARCH CEN'CEk ~'TTACI~1l~~rv7~ 1 Staterr~ent regarding coffee research involving use of Knodean genetic research tools. Sep-Og-2002 11:23am PrQ~-HARC B06-466-5020 T-506 P.OOT/025 F-363 `717 v~ ~,Y F'Od2hIBRLY F1AWAd1AN SUGAR P.tAN'll•!tS' AS,SOCIAflON 99-193 A1JEA F$1riGgTTS Dtatv~, S~(7tT~ 300, ASIA, I-TAWATi 96701-3911 T`)rLt?Pi°IONE: (808) 457-5561 1FAX: (808) 486-300 http: //wwrv. hawa i iub•, o rg/havr I~TJE4Mr~TiO~ GA.J~Ild1~ GE1m1~m~C~4.LLY 10~C~~I~'~~~ CC~F~~~ ~LT~ by Stephanie A. dVhalen There appears to be some misinformation circulating in the community regarding the existence and/or presence of commercial or experimental genetically modified (GM) coffee plants in the state of ~lawaii. There is no eminent threat of any CrM coffee plant being released for cort~ercial use or for testing, in spite vi ins fact that there is a permit issued for a field test. PLtmits are r~uested by coinpanics in advance of having plants ready for field testing to prevent delays if and when they have plants ready for a veld tese. Although ehere is a valid permit for field testing of an experimental GM coffee plant, there has been no plant developed in the laboratory or gacenhouse that has been shown to warrant use of that permit. At the request of she industry through funding by the state, HA.RC and the University of Hawaii initiated a cooperative project to explore the possibility of creating a caffeine-free coffee plant. There was concern over ehc residues of pnethylene chloride, left in decaffeinated coffee frown its use in the extraction process, which removed c~afffeine frown coffee buns. IdARC developed the laboratory procedure which would allow the ittset~tion of a gene into selected coffee tissue. I°1P~.2C destroyed all the experimental material when there was no gene of value available for insertion. This i.S standard procedure in this area of research established well over a decade ago. In 1997, Integrated Coffee Technologies, Inc. (ICTI) negotiated a research agreerraent with I€AfZ,C to reevaluate this concept and to produce GM coffee with ehc University of I•Iawaii-owned decaffeination gene (antisense of X1VI'T gene). 'The project was terminated on November 1998. Prior to terrseination, HA.RC produced live GM coffee plants that were eon~rmcd by a single laboratory procedure to contain the antisensc XM1` gent. However; ..^.one of the five plants showed a lowered level of caffeine in their leaves in 2000. 'T'here ale no plants froth ttais pro~pect regnaining. In addition, the Iniversity of Hawaii has publicly stated that all the experimental G1vI coffee plants developed through their involvement with this gene have been destroyed. Currently, l°IAIZC, in cooperation with the University of Hawaii, is conducting research on production of G1VI coffee for nematode resistance. The projece, initiated in 1999, is supported by a federal grant. plfATiC has some GM somatic embryos of coffee under controlled laboratory conditions. No plants have been regenerated from these Cr1V1 somatic etxabryos. It is expected that it will felts a ruinirnum of six months before Cslvi sanall plants develop. It will take at least one year lbef®r~ she fast group of GM coffee reaches the greenhouse stave. It will take another 1.5 to 2 years before field testing could occur. Sip-09-2002 11:23am Fri-HARC 808°486-5020 Y-508 P.008/025 F-383 ~ W ~4L! f3C,1Cil:UL I UK~, IC~JLiAKI:If l.:~N"IER -2- This process would cake at least until the end of 2005 or the beginzaing of ?006. That assumes that this procedure is successful in producing plants that survive the testing and selection that occurs throughout this process. It further assumes that funding will be available throughout the process and that the process of eonzmerefalization will be undertaken by tho private sector. It is important to understand that field testing is very castly and is not undertaken lightly and without significant resources. p'or example, in the sugar industry 1~RC has not proceeded with field tests for any ~M sugarcane since there is no potential product yet that warrants the cost. b][owever, f~~C is coneinuing to iaaprove the laboratory procedures so that when and if a gene of value is available that the industry feels warrdtats the cost of pursuing, H1~KC will be ready and have the expertise to assist the industry in that effort. ~n industryy has to be ready to not only Find the resources to do the field testing, but it roust be willing and able to negotiate the licensing of the genetic materials. So Far, this has only occurred in the papaya industry in 1°€awaii and that was because the industry was in a dire situation. There was no viable alternative. The papaya ring spot virus continues to create problems all over the world for papaya growers. Fortunately, l~awaii's papaya industry was t_'~e first to be able to benefit from the tools developed in malectalar biology. The University o>r l~awaii, Corner University, the USDA-ARS, Hawaii State and County supported the Hawaii papaya industry financially and with research expertise to save this industry through the developanerat and commercialization of a genetically modified papaya plant. The process took over 10 years and it took a lot of support by ail these players to get ehis product prioritized in the regulatory and commercialization processes. Where this urgency does not exist, #iaeure products will not receive this support and prioriti2arion grad, consequently, the entire process is expected to take longer. Based oat the actual process of producing, testing and coraamercializing GM plants and the status of Grllad coffee research in the state there is no eminent risk that potential Glv1 coffee products will create any probleaza for the Kona Coffee growers. However, continued attetation provided to this subject such as official governtr~erat ;action opens up the possibiliey for tnisinforrraation to spread and create the perception ehat there is a problem where in fact there is not. ai~sro2 Sep-09-2002 11;23am From-HARC 808-486-5020 T-508 P.009/025 F-383 !'YA W A11 1.11iK1t;U L 1 U1C~ K1=Jt:AFZC:H (:~'V']~R ~`~~`AC'~H[IVl~1~T~ Paragraphs of National Organic regulations, QUA, prearrbble chat per~ains to 'genetic modification'. Sep-09-2002 11;24art! Fram-41ARC 808-486-5020 T-508 P.0100025 F-383 Pr®gram, Natd®~~ ®e°gc lQrogra ®ver~erv Snitp~rt A - l~faniti®ras l~scr~pti®ia of late®a~s This subpart defsttes various terms used in this part. These definitiorss are inutaded to enhance conforsraance with flee regulatory requirements through a clear undeestanding of the meaning of lcey terrris. Wo have amended terms and defaxtitions carried over morn the proposed rule where , necessar'y' to make their wording consistent with the language used ita this final gale. We have revised the defrniiriotas of flee foil®~ving words for greater clarity: per3on, practice staaadard, were ingredie$at, processing, tolerance. We have rerraoved the de~aitions for the following terrras because the terms are not used in this final male or have been deterarsined to be unnecessary: accredited. latsoratory, esrimated r?atioa~al mean, systetx? of orgataic plroduction and handling. We received corrarrsents on soaaae of these definitions that have been deleted. We leave not addressed those comrr~erats here because the relevattt defeaitions have beea deleted ll~5ni~®ns -Changes based on C®rnmcm4s This subpar dii~ers from the proposed male in several respects as follo®vs: (1) Iviany corgamenters requested changes to the definition of "excluded anethods." ornaments included requests to use flee more conraanon terra, "getaetically gnodified organisms{GI+~®)", to include the products of excluded methods/(}lViO's ire the definition; to more closely follow the N4S~ definition by adding gene deletion, doubling, introdtaction of a foreign gene, and chasagtng ge%ae poSiti0a3; to include that excluded methods are prohibited by the 5 S®p-09-2002 11:24am Fram°HARC 608-486-5020 T-508 P.O11/025 F-383 Act and by the regulations in this pare; to change the wording of the referennee to "reeornbinant DNA"; and to add that the dei5aitaon of excluded rraethods otaly covers "intentional use." 'OVe have accepted some of the coartrncnts and have anodifred. the definition accordingly. ~e~ifically, w'e have included reference to the "methods"--gene deletion, gene doubling, chaaagiaag positions of $eaaes, and introducing foreign gene that were included in the original N®S$ d~eflnition. `This will rraake the defnnity..on even more closely parallel the N®S~3 reconarnca~dation. V6Ve also refer to recotnbinazat DNA technology, which is technically Snore accuante Haan the proposed rules reference to recotaebinant DNA as a "anethod." We have not accepted the comrnettts that requested adding the products of excluded methods to the definition. The emphasis atad basis of these standards is on process, not product. yVe have specifically structtared the provisions relaeirlg to excluded methods to refer to the ease of methods. Including the products of excluded methods in the definition would not be consistent with this approach to organic standards as a process based systean. For the same reasota, we have retained the terror, "excluded methods," to reinforce thae process-bassed approach. 'We have also rejected coixaineaets requesting that we include the prohibition on excluded methods ire the definition and, lilce~~isc, chose requesting that we refer to "intentional arse" of excluded methods. The final rule tiiaintains and clarifies the prohibition oti the use of excluded rraethods inn organic production systeiris. The prohibition is taaost properly addressed iti the appropriate provisions of the regulations, particularly in Sectioai 2p5.105, and not in the definition. Similarly, althaugh we recognize that a diseinction betvveela intentional and unintentional use of excluded traethocis may be meaniiagfizl, particularly as it pertains to issues of Britt, this is era issue that u best handled in the sections of €lie regealatioto governing ease of 6 Sep-09-2002 11:24am From-HARC 808-486-5020 T-508 P.012/025 F-383 excluded methods, not in the definition. 'The definition for "excluded rrAethods" novv reads: A variety of methods used to genetically modify organisms or influence their growth and development by aateans that are not posse~le under natural conditions or processes and are not considered compatible with organic production. Such methods include cell fusion, microencapsulation and macroencapsulation, and recombinant DNA technology {including gene deletion, gene doubling, introducit2g a foreign gene, and changing the position of genes when achieved by recombinant DNA technology). Such methods do not include the use of traditional breeding, conjugation, fermentation, hybridization, in vitro fertilization, or tissue culture." - (2) Maaay commenters objected to the definition of "compost" in the proposed rule because it required that compost muse be produced in a facility that was in complaatace with the Natural Resource Conser~ration Service's (NRCS) practice standard for a composting facility. ~1Ve agree with these commenters and removed the requirement to comply with the NRCS practice standard, However, the final rule incorporates nevv requirements for the production of compost that are included in the definition. T1ie final rule requires that compost must be produced through a process that combines plant and animal materials with an initial C:N ratio of between 25:1 and a0:1. furthermore, producers using an in-vessel or static aerated pile system must maintain the composting materials at a temperature of between i31GT` and 170L)f for 3 days. Producers using a windrow system muse maintain the composting materials at a temperature between 131~7g and 170f1f for 15 days, during which time, the rrsaterials must be turned a Yrainimurn of five times. @Ve developed the requirements in the final rule for producing an allowed. composted material by integrating stazadards used by the Environmental Protection Agency (EPA) and USDA's Nattual Resources Conse~ation Service (NRCS). Tb.e requirements for the carbon- ? Sep-09-2002 11:24am Fram-HARC 808-486-5020 T-508 P.C13/025 F-383 U ` ~ , _ ~ . specific documentation they require to review and evaluate an operation's organic syseerri plan. Section 205.200(a)(6) allows a certigying agent to request additional information needed to determine that an organic system plan meets the requirements of this subpart. The site-specific nature of organic producrion and handlinb necessitates that cemfying agents have the authority to determine whedaer specific information is needed ro carry out their function. Cr®p pr®daacti®ta Any field or farm parcel used to produce an organic crop must have been managed in accordance with the requirements in sections 205.203 through 205.206 and have had no prohih*¢c~d substances applied to it for at ]east 3 years prior to harvest of the crop. Such fields and t faun parcels must also have distinct, defined boundaries and buffer zones to prevent contact with the 1~ d or cro~~ prohilbia~d substances applied to adjoining land A producer of an organic crop must manage soil fertility, including tillage and cultivation practices, in a manner that maintains or improves the physical, chemical, and biological condition of the soil and minimizes soil erosion. 'I'he producer rnust~ manage crop nu~ients and soil fertility through rotations, cover crops, and the application of plant and animal materials. The producer mast m~ anage plant and animal materials to anaintain or irrtprove soil orgataic rriatter content in a manner that does not contribute to conaatnination of crops, soil, or water by plant nutrients, pathcgenic organisms, heavy rrtera.ls, or residues of prohibited substances. plant and animal mater+a.ls include raw animal manure, composted plant and anima! materials, and uncotnposted plant rraaterials. Raw animal manure must either be composted, applied to land used for a crop not intended for Human consumption, or incorporated into the soil at least 90 days before harvesting an edible product ehat does not come into contact with the soil ac soil particles and at 45 Sep-09-2002 11:25am From-HARC 808-486-5020 7-508 P.014/025 F-383 co*~-r. crcial availability statdard arriong multiple certifying agents? Could potentially adverse ef>t'ects of a comiraerciai availability standard, such as taatcerraincy over the cost and availability of essential ingredients, impact ar impede the developartent of rxaarkets for organically processed products? i~Vhat economic and admirusrrative burdens are imposed by the comrrtereial availability standards found izt exisaing organic certification programs? How would producers benefit fiotn market incentives to increase use of organic ingredients that result from a commercial availability standard? '6~V'ould lack of a cotntneccial availability standard provide a disincentive for handlers of products labeled "organic" to seek out addational organic minor iatgtedients? l~Vhat impacts could this have oat producers of minor ingredients? AMS welcomes any new or unpublished research results or information that exists concerning a cotntnercial availability standard AIMS specifically invites comment from establisharaents which currcratly operate using camre~rcial availability or a cortaparablo provision in the conduct of their business. AMS will receive comment on dais issue unt~190 days a#>:er publication of tltc final rule. (4) ~trvadon of Biod' a si Many commenters recotntalc~ded amending the definition of organic production to include eha requirement that an organic production systenn tttust promote or enhance biological diversity (biodiversity). Cotatrtienters seated that the definitions for organic production developed by t}ze NOSE aatd the Codex Commission include this requiretrtent, vVe agree with these commenters and have amended the definition of organic production to require that a producer roust conserve biodiversity on his or her operation, °I'he use 61 Sep-09-2002 it:?F?~ From-HARC 608-486-5020 T°508 P.015/025 F-383 of "conserve" establishes that the producer must initiate practices to support biodiversity and avoid, to the extent practicable, any activities that would dianinish it. Compliance with the requirement to conserve biodiversiry requires that a producer incorporate practices in his or hex organic system plan chat are beneficial to biodiversity oat his or her operation. General - Gfin~ges I~eganested 13ut N®t IVlade This sabpart retains from the proposed rule regulations on which we received comments as follows: flr~anic Plan.. Excessively Restrictive. one organic inspector dues concerned that the requirements of the organic system plan were coo prescriptive and would create an excessive paper work burden for producers and handlers. The comrtaenter stated that the excessive specificity of certain requirements {composition and source of every substance used), combined with the ambiguity of others (soil and tissue testing required but with no mention of the frequency), would confuse the working relationship between a producer or haa~dier and his or her certifying agent. The commenter was concerned that strict adherence to the specifications in the organic system plan would compromise the ability of producers and handlers to rtm their \ ~ businesses. while agreeing that flexibility ita the development of the organic system plan was valuable, the coa~nrnenter seated that producers attd hatadlers, not the certifying agent, must retain the pri9nary managerial role for their operation. 4eher commetcters maintained that the organic system plan requirements were coo ambiguous and would inhibit eerrifyiabg agents' e4lrores to review necessary inforaa~ation. For example, a trade association connrnented that the absence of specific recordkeeping requirements for livestock feed materials, medications, and health care activities woeald impair coanplaance a~nonitoring. 62 S®p-09-2002 11:25am FrAm-tIARC 808-486-5020 T-508 P.016/025 F-383 1 ,i ' . this subpart. production practices iarzplernented in accordance with this subpart must rraaitatain or improve the natural resources of the operation, itacIuding soil and water quality. § 205.0! ®rganic pr®ductioae and h~dling system pEan. (a) `The producer or handler of a production or handling operation, eaccept as exempt or excluded under § 205.101, intending to sell, label, or represent agricultural products as ``I00 percent organic;' "organic," or ``made with organic (specified ingredients or food group(s))" must develop an organic production or handling system plan that is agreed to by the producer or handler and an accredited certifying agene. An organic systexra plan must rrieet the retirements set forth in this section for organic productions or handling. An organic production or handling systerrt plan must include: (1) A description of practises and procedures to be perfotxned and nsaintained, including the frequency with which they will be performed; (2) A list of each substance to be used as a production or handling input, indicating its corxaposition, source, locations} where it will be used, and docurrientation of commercial a~v^_'a'~ility, as applicable; (3) A description of tlac monitoring pracdces and procedures to be perfottned and rnaintaizaed, including the frequency with which they will be performed, to verify that th®plan is effectively implemented; (4) A description of the recordkeepirsl; system implett~ented to eonsaply with the requirements established iri ~ 205.103; (S) A description of the management practices and physical barriers established to prevent commingling of organic and nonorganic products on a split operation and to prevetat contace of 371 Sip°09-2002 11:25am FromTHARC BOB-4B6-5020 T-508 P.O1T/025 F°3B3 otgareic production and hatadling operations and products with grohibited substances; and (6) Additional itafotmatioaa deeaxaed necessary by the certifying agent to evaluate compIiaatce with the regu3arioras. (b) A producer may substitute a plan prepared to treat the regtaireattents of another Federal, State, or local govetnnaetac regulatory program for the organic system plan: ovided hat, the submitted plan meets all the requirements of this subpart. § 205.202 Laid ,req>tBrettaeraes. Away >l"aeId or farm parcel from which harvested crops era intended to bo sold, labeled, or represented a~ "Or~a111C," mUSt: (a} Have been managed in accordance with the provisions of § § 205.203 through 24s ?Ob; {b) Have had no prohibited suksseances, as listed in § 205.105, applied eo it for a period of 3 Years irntttediately preceding harvest of the crop; and (c) Have distinct, defined boundaries and buffer cones stack as ttanoff diversiotas to prevesat the egnintended application of a prohibited substance to the crop or cotttaet with a prohibited substance applied to adjoining land that is not under organic rt1anagemezzt. § 205,203 Sergi fea~ila4y and cr®p naatritttt naana~ea~nt lsractice sfiaudarci. (a) `T'he producer must select and ipnplctneaat tillage and ctilrivatiota practices that ntaiittaiin or improve flee physical, chemical, and biological condition of soil and ftttinixatia;e soil erosion. (b) Tht producer must manage crop nutrients and soil fet-tiliry through rotations, cover crops, and rite application of plain and animal materials. {e) The producer trust manage plant and animal materials to maintain or improve soil 372 Sep-09°2002 11:26am From-HARC 808-486-5020 T-508 P.O16f025 F-383 Applicabi~ty - Clarifications Clarification is given on the following issues raised by cotaanaenters as follows: (1)"Genetic" drift. Many cotrimeaatexs raised issues regardiaag drib of the prodeacts of e~tcluded methods onto organic farms, 't`hese cornaiaenters were concerned first polleta drifting frorra near°by ~ would cantatttinate crops on organic operations and that, as a result, organic farmers could lose the premium for their organic products through too fault of thew own,lVlany commenters argued that vye should use this reels to somehow shift the burden to the technology providers who market the produc>Ac of excluded raaethods or the nonorganic fartniYag operations that use thew products. Soixie, for example, suggested that this regulation should require that the nonarganic operations using genetically engineered varieties plant buffer strips or take other steps to avoid drift onto organic farms. (Jtliers suggested that the regulation could provide for citi2eias' right to sue in cases of drift. while we understand the concerns ehac commenters have raised, the kind of r dies they suggested are outside the sco a of the Act and this regulation. ~'he Act oaaly rovides or e r strata o ~ orgarcuc ra io . We ca'attot ease this regulation to iaaapose restrictions, sue ' ' r p o o er measures, an operations that are not covered by the Act. Similarly, while citizens nosy have the ability to bring suit undex other trews, the Act itself does not provide for the right to bring suit as a Federal cause of action, and we could not grant it through this regulation. gift has been a difficult issue for organic prodezcers tom the beginning. ®rgaxaic operations have always had to worry about the potential for drifg from neighboring c~.rations, partticularly draft of synthetic chemical. pesticides. As the nuanber of organic fauns increases, so does the potential for coxallict between organic and nonorganic operations. Xt al~9ayS ~~n the >r~p®~SSibi~ty Q1e O~al'H#~ ®pe~$ti®$]~ t® P®tentaa9 ca~ntfect oa~ac products with othet° suDstaaac~ n®t nppro®ea~ fsar u~ i~ organic p>t oducti®'la systeans, wheea° >~`otn the nonea>ariac psaa~kis~n ai ~ split ope>r$'l~ain ar fi°oan tt~ighbaring fa'r. the ®rganac syst~n plaza Fntast ~s~t!!i>tae steps that an aa'aic aptaon vvi11 take to' nv®id this lt$~d of ~ainten~oa~~ co~>t. Caen we ~e ~~ezq~g d~~ ices, it is p y i~pat~tanlt to 8.1~t• that ®rgaaaic sds ~e pry a C~~ii~eng ~~en~ amt to ties nbality af' aazaic ®peratiaxts to foitow $ set ®f pra~dticti®n sty -sand a-ac t ar+a~t the r~gaal»a~n~ ®f flee Act anel ~ ~ aalatio>~as reg teen prohibits the use of exo u e anetho s an organic operations. The presence of a detectable residue of a product of excluded rciethods alone does not necessarily co~titute a violation of this regulation, AS long as an organic operation has not used excluded >inethodS and takes reasonable steps to avoid contact with tlxe produces of excluded methods as detailed iii their approved organic systeYn plan, the. unintentional presence of the products of excluded methods should not affect the status of an organic product or operation. Sep-09-2002 11:26am From-HARC 808-486-5020 T°508 P.C19/025 F-383 Issues ®fen d~ ~ got c®n~ned to the w®r9~ of ® sic cc~t~°e> F®r e~.ple, plant laree~e~°s ~ aced couap~nnts m~~nsu~e ~e~etic ~ entt~~ ®f plant veldes by ping any eiross-p~~nataou >~at xrea~h;t result m pollen r~~fC. Y7ndex reseaBr c®ndaltgoa~, sell-stele ffie9t~ test ®f ne>d~ily e~~irseerect plaaats in~rpearate va~ous ~dees cif lafalogl~ c®~atai ~ to li>~it a pob~y of ~en~ ~~w ~ ®er sexually ea~patable plus, federal reg~tory agencies r~aight impose speck planting requireBnents to ~irmit pollen drift in certain situations. partners planting a~ortbiotechnology~derivzd varieties may face similar kinds of questions if cross- polluaation by biotechnology-derived varieties alters the marketability of their crop, Ttcese discussions within the broader agricultural cotixn?anity may lead to new approaches to addressing these issues. They are, however, outside the scope of this regulation by defYnition. s S®p-09°2002 11:26am Fran®HARC 808-486-5020 T°508 P.020/025 F-383 ' ~ - 1'~!~'C J Ul Z / requires alia8aasct botarad~ries eansl 'hdegascsae'~asff¢pZones, feast aaalnYanasnas are not speci,~a~, nor is 8dte tea~ras saelegas eatd. SectioA 202.202(c) requires distinct, defined boundaries and buffer zones to prevent the unineended application of a prohibited satbstance to land under otsanie anaAagement. Ia exax»aning ehis issue, CJSDA concluded that imposing a specific size for buffer zones could itaapose unnecessary burdens on sottae organic producers without offexing greater protection of organic fields and ~ropS frown unintended contact with prohibited substances, l~or example, buff cones tAisltt noe be needed for an organic farm if it were coaApletely surround~l by wilderness or areas not in agricultural production. Accordingly, the nations! standards do not specify specific dimensions for buffer zommcs, but leaves the determination of their size to the organic producer and she ccrdfylna assn[ on a oase°-by-case basis. It has always beeA rite responsibility of organic operations to manage poeeAtial contact of organic products with other substances not approved. for etas in organic production systems. 'lie organic systerrt plan must outline steps that an organic operation will talcs ro avoid ddit from neighboring operations, pareieula,~ly dvifft of synthetic chemical pesticides. 'VGlhen considering drift issues, bath certifying agents and producers muse remember that organic standards are process based. CereifyiAg agents attest to the ability of orgat?ic operations to follow a see of producriomm standards and practices chat meet tits requirements of Ylic ®rganic Foods Produotion Act and the naeioaal standards. `l:'#re natioAal standards prohibit the use of geAetically modifaed organisms (defined in she standards as excluded methods) in organic operations. The prCSLAC~ va a detc~tablct residue of a product of excluded methods alone does noe necessarily constitute a violation of the re~alations. As loatg as an organic operation has noe used excluded methods and takes reasonable steps eo avoid contact with the products of excluded methods as detailed in [hear approv®d organic syst8m plan, the unintentional presence of the products of excluded methods should noe affect the seatus of an organic product or operation, Therefore, whale the naeaonai osgatafc standards provide significant discretion in eseablishiAg buffer zoAe dimensions, buffer zones should tape be sized at distances which aettmpt to achieve a sera eolerance for prohibited substances. The intent of rtes regulations ate to foster a collaborative effort between she eertifyittg agents and their grower clients to determine an appropriate buffer zone with each party being fully cosnizant of the process-based nature of the organic label claitr?. Does Rhe 1+Iational ®rsaatic I'sograrra pdaan 8o provide any msaanyng or workshops std dose producer/~sow~>a level? USDA does not envision conducting any training or workshops at the producer or haAdler level. USDA has entered into a cooperative asreetnene with the National Center for Appropriate 'ffechnology to provide cotnplianee tools for organic a&ricultural producers and certifying agents. ~:.floty close 8fie 1Vrataoeaal ®rgaeaac ~oograear (N®P) envision drat pr®dracers/g~vwer~s sera bee®nat~axna7~sar 4vatdt 8lts dastricssc$es of Sdais new regaaltali®n? A: Under the NAP, USDA provides oversight to accredited certifying agents. Cereifying agents provide oversfglat to prodtaezrs and handlers. Section 245.501(x)(8) se~uires that certifying agents provide sufficient information co persons seeking certification to znable tllecn to comply with ®FPA and national erganic standards. USDA has entered into a cooperative agreement wirh the National Canter for P,,ppropriatt Technology co provide cotnpliaatce tools for organic agrictalcural producers and certifying agents, 1Q: 1?o atoaaeagrscaal~aral ssrbsS~pgces ioaclasslesi opt 8fie laTsttaoaaal LaSP o, f Allvwsd ara~ ~rolsfbated Sasbs~racas iastve &o be prosiaaces$ waslaorsa r9~ a~,se o,{voJ~drde syta~aetec solventsP NYy c®rak,~asag sagene says yes lrecssrase of rise prohabi8aion oaa !h~ arse ol'volca~fe syn$aetis sodvenfs, foaamrg in secaaoaa a0~,~7d1(CJ(Z). Labraryhttp://v~rvvw.~s.usda.govlnap/nop2000/non2/FAQ.ht~m Q/~/rn S®p-09-2002 11:26am From~°HARC 808-486-5020 T-508 P.021/025 F-383 - ~as4vva i~ A: No. Section 205.270(c)(2) prohibits the use pf a volatile synthetic solvent unlt,5s included on the NatiottaI List as an allowed substance. ;E3(owever, synthetic solvents do not have to be on the National List to be allowed in the produoeion of an allowed nonagricultural substance found on the National )dint. The use of volatile synthetic solvents in the production of allowed nonagricultural subs[ances included on thz National ]List is considered approved through the materials review process, unless otherwise stated through an annotative to the approved substance, pExample: § 205.605(a)(9j, Flavors nansynthetic sources only and must not be produced using synthetic solvents attd carrier systearts or any artificial preservative.) o3rnt m' Q: Iba jtelals wave to lessee aany laze regaiire~srenis an order to ~eroduce ea~®~SS eesd can ®e'gacnic? A: No. `There are no firld-size requirements relative to whether or not an operation can be certified organic. osro~ra2 Q: Is dPat feed td~at is fed to organic livestock and,poaslery „vegetaa acaR " Bred? A: Not necessarily. Although as stated in the National Organic Standards subpart C, section 205.237(b)(5), "The producer of an orgataic operation must nay feed mammalian or poultry slaughter by-products to zrtammals or poultry." There is no restriction against organic livestock fend containing appropriate fish products. ©srt:~,roz Q: I ~aow or~arear agra~aadtasre pr®iefbits the use of Gll~Os, brat ~ flee grsadetaaaes allooa~ detectable leve~i dace to d~a, ft? A: The Preamble to the National Organic Program regula[ions, Applicability, Clarifications (1) Genetic Drift, states: "This regulation prohibits the use of excluded methods [which include G1dIQs] itt organic operations, fin®presence of a detectable residue of a product of excluded methods alone does not necessarily eanstitute a violation of this regulaeion. AS long as an organic operation has not used excluded ttte[hods and talres reasonable stops to avoid contace with the products of excluded methods as detailed in their approved organic systems. plan, ahe unintentional presence of the products of excluded methods should net affect the status of an organic product or operation." Nowcver, if a certifying anent has reason to suspect that an organic product has evens into contact with prohibited substanezs or bc;en produced using excluded methods, the eertifyitag agent can call for testing, which under certain conditions could result in that product no longer being considered "organic." Pot a complete discussion of this issue, you mast read the National (3rganie Standards, subpare Administrative, sections 205.670 - 2®5.671. osr~>> ~o? Con recdardnaed ivaater be used for irragatfon on organic fanres? A: Generally, fire National Organic Standards place no further restrictions on reclaimed water used for irrigation beyond those imposed by State Departments of Natural Resources, However, to fully answer this question, we would need to l,-t?o~cv how and from what source the water is being reclaimed. rra>t/rY,t 'di'e ire a sraeat proeessing plratat iaaterested era processStag add natured p~oa°k tired beef. '~liratlcirsd ®fgBaaeraad anforaraatdon can you gdve us? A: There are now specific CJSDA standards that must tie rnac by all producers and proecssoas who wish to label weir agricultural products as organic. (Please notz that "natural" is not synonymous with "organic.") These producers and handlers must be certified by USDA-accredited certifying agenes by October 21, 2002. The organic standards for producing and processing livestock can bz Libra~yh~tp:/0'~ww.a~as.usda.gov/r~o~/no~2000/nov2/FA~.h9:m Q,~on~ Sep-09-2002 11:27am From-HARC 808-486-5020 T-508 P.022/025 F-383 organic operations to verify that the operation is complying with the provisions itt the Act and the regulations in this part. Certifying agents are responsible for monitoring organic operations foa the presence of prohibited substances; we view residue testing as a cost of doing business. Therefore, we believe that terrifying agents should factor monitoring costs associated with irnplepstenriaag the provisions in the Act and Rule into their certification fees. (2} Ctetaortin~ to Federal„_~ulator~y Auencies. Commenters disagree with section 205.b71(b} of the proposed rule which states that if test results indicate a specific agrieultural product catttains pesticide residues ar environme-ntal contaminants that exceed the FDA action level or 1;PA tolerance, the data must be reported promptly to appropriate public health agencies, Coa~nrnenters believe that since results of all analyses and tests must be provided to the Adxninistrator, USDA should be responsible for cotntmunicating such test results to other Federal agencies such as 1FDA or EPA if regulatory tolerances or action levels are exceededo They also suggested that section 205.b71(b) be removed from the National regulations. Commenters expressed the view that such a rec}uiretnent is not related to organic certification. Vde do not agree with the commenters. It is not our intent to create additional responsibility for the cereifying agent. Section 205.b71(b), redesignated as section 205.b70(e), is a statutory requirement. Section 2107(a)(b) of the Qrganic Food Production Act of 1990 requires certifying agents, to the extent of their awareness, to report violaeions of applicable laws relating to food safety eo appropriate health agencies such as EPA and FAA. 'T'herefore, due to section 2107 of the Act, section 20S.b70(e) has been included in ehe national regulations. (3) "Threshold" for Genetic Contamination. Many commenters suggested chat we establish a "threshold" for the unintended or adventitious presence of products of excluded 324 . Sep°09-2002 11:27am Fram-HARC 808°486°5020 T-506 P.023/025 F-383 methods in organic products. Sorrie commenters argued that a threshold is necessary because, without the rnartdatory labeling ofbiotechnology-derived products, organic operations and certifying agents could not be assured that products of excluded methods were not being used. Others argued that, without an established threshold, the regulations would constitute a "zero tolerance" for products of excluded methods, which would be impossible to achieve. ~e do not believe there is sufficienc consensus upon which to establish such a standard at this time. Much of the basic, baseline information about the prevalence of genetically engineered products in the conventional agricultural marketplace that would be necessary to set such a threshold®e.g., the effects of pollen drift where it may be a factor, the extent of mixing at various points throughout the tnarketirtg chain, the adventitious presence of genetically engineered seed in nonengineered seed lotsr-is still ]acgely unknown. Our understanding of how the use of biotechnology in conventional agricultural production might affect organic crop production is even less well developed. also, as was pointed out in Borne comments, the testing rt~ethodology for the presence of products of excluded rraethods has not yet beers fully validated. °Testing rtiethods for some \J. biotechnology traits in some commodieies are becoming commercially available. Wirl~out recognized methods of testing for and quantifying of all traits in a wide range of food products, however, it would be very difficult to establish a reliable numerical tolerance. There are publicly and privately funded research projects underway that may provide useful baseline information. Efforts of Federal agencies to clarify the marketing and labeling of ~ biotechnology- and nonbiotechnology-derived crops may also help address these concerns. pL)A, for example, is developing guidance for food producers who voluntarily chose to label 325 Sep-Og-2002 11:28am From-HARC B08-486-5020 T-506 P.024/025 F°383 Emmiovice. Gray person providing paid or volunteer sc9rrvices for a certifying agent. laccluded, methods. A variety of methods lased to genetically rrlodafy organises or influence their growth acrd development by means that are not possible under uataaral conditions or processes and are not considered compatible with organic production. Such methods include cell fusion, rraicraencapsialaeion and tnacroencapsulation, and recombiraaatt DNA technology (including gene deletion, gene doubling, introducing a foreign gene, anal changing nc~ positions of genes when achieved by recombinant ANA technology). Such methods do taot include the erse of traditional breedisag, cotajeagation, few tion, hybridiz~tioa, an vitro fertilization, or tissue ~ - - c~ltagre. ~ F,dible ~aaterials which are consumed by livestock for their nutritional value. Feed may be conceratxates (grains) or rotaghages (hay, silage, fodder). The teraxa, "feed," eracoaxapasses all agricultural coBranlodities, including pastuxe ingested by livestock for nutritional ptarposes. Fee ~ five- A substance added to feed in micro c~aritaes to fcelfiIl a specgfic nutritional need; i.e., essential nutaients in the form of amino acids, vitamins, and atainerals. Feed ar,leBnent. A corrabination of feed nutrietats added to livestock feed m ianprove the nutrient balaaacc or performance of the total ration and intended to be: (1} Diluted wish other feeds when Fed to Iivestoel~ (2} Offered free choice with. other P of rise ratios if separately available; or (3) Fesreher diluted and mGixad to produce a eompl feed. e "liter. A single or blended substance containing anc or more recognized plant nu~::nt(s) which is used primarily for its plant nutriexat content and which is designed for use or claimed to have value in prorxaoting plant gxowtb. 3S6 Sea-09-2002 11:28am From-iIARC 808-486°5020 T°508 P.025/025 F-383 !°~8 ~ oI S Dne of the sought afd:er traits in genetic engineering is the capability to Convert atnrospherEc nitrogen into nutrients that Plants need. Two studies have identified the protein that enables s®rsae plant roots to eucCsange nutrients with micre~b~, ~'he first study was done by Gyorgy KISS and Ca(teagues at the tiungarFan ACadetriy of Sciences In Szeged. T`he seCOBtd study was conducted by iMartfn Aarnisise and Coldeagu~ of the Sohn Inner Centre in (~orves;:r+, 16K. both graups fosRnd the carne grotein though they used daffestienc narrate. ®nly a fes4t plants, ineludfng peas arld beans, Rave the trait to form a syrvsbiotfc relationship Frith bacteria that convert the attrreospherfc Hitt®gen to arnnaonia. In return, the plants give eaa'bohydrates to the bacteria, which dwell in nodules in their roots. Kiss said tSaat the obvious next step is to use the findings to give non-syrrab(otic plants the nltroQen-fixing trait. However, he cautions that altering staple crops (ike wheat, rice anct rtaalze a+mill take a long t~rne. 1'he original article was written by Saaah Cooney and appeared in the 27 lone 2002 issue of ~ store Science Update. Yt can also be downloaded at http://v~rww.nature.corn/nsu/0206x4/®2D624-~,htrril. ~IFtGd6l~TCS 1'dr®°Y' 9~Sls~ES~a'~i~ILY ~®Et~ ldL8~82ST°Sd)t~S A revieww of~ZQQ Corrapar'afi6ve studies of organic and conventional foods disprove dalrvas that ~r~ani~lly praducad food has 5uperi®r nuttltional benefits. Th: ~r;;ecr~fty ~9` ®tl~ga in f4evu Zealand conducted the Judy whEch is the first eritis~f review of research corsaparfng organic and corsventior~tal f®ods. i'he research lasers 3ed by ®iane bourn and Sohn Prescott, published their findings in m recent edition of Grilles) Reviews in food Science and t~utr€tlon. "~FOe footed no strong evidence that organic and a®nverstional foods dIl'fer in eoncent~artions of variosrs nutrients, stJltly the p®SSii7(~ e9eceptlOJi a9f netrate Con$~nY, which may b@ lower its 5o7t°Be organic cr®ps" mourn says. iV® evidence was found that cer#lfled organic foods might be rraore su5ceptibie t® rrsicrobfological +con~rrainatlon. Studies investigating taste found no canvincfng eviderce of any differences b~reen convent) Hal and organic, isroduCe. hiowever stud"acs have not clearly considered factors such as variety, tirrae oP harvest, distribution, and st®r7ge condations," Bourn added. Additional details are available at: http://w+irw.bio-scope.org/disp_doc.cfna? id ~ I4A$92096pf3g~42988i~C~0AF2911139A13i~6 i I;Sd~!®'S lA~eiafe~! ~e~cloat BCS; s~,vaiia~ie ®n-Dine the International Service for the AcquiSitien ®f Agri-biotech Applications through its Global Knowledge _ Center ors Crop 6foarechnology has updated earlier editions of Its PoeKet K (Knowledge) series.Pocket KS are paClcaged information on ~p biotechnology Products and relatee8 issues that are wrltteto foI an easy to understarsd style. ~°op1C5 available are: questions and answers about geiaetfcally modified crop; plant pr®ducts ®f bfoteehn®logy; food safety: GM crops and the environment; Arad docairnen~d ben its ®f CM crops. ®owryl~ad the two rr4atarials and other Pocket lCs for free at http:/lwmvw.isaaa,org/kc/services/media/PocketK downioad.hfm .~11Vil9~9lPJia~9~irlll'T: CsTtt® IB~`irRNr~7`I®PdAlR 8iad®RICSIF9®~ 'fhe Con'."~'^onweaith Scientific and Industrial Research OrQanizatlora (CSIAI®) evil! hold an intern) clonal workshop entitled "Towards $uilding a CYlobal Rice Gene Machine" tee be held fVovernber I.2-12,~2DD2 at the CSIIiCi Dlant Industry. Cant~erra, Austraifa. the workshop focuses on rice functional genoen cs, focusing ®n lnsertiona! rvsutagenesis as a resource for assagnrraent of Qene function. CS%R® is planning to 8/23/02