Roundup Ready Update
On Thursday, November 4, the Animal Plant Health Inspection Service (APHIS / USDA) proposed three options for addressing the regulated status of RRSB.
The three options, along with a 336-page environmental assessment, are under review by the industry.
One option is to do nothing and keep the crop regulated. Clearly, that option is disastrous for beet growers (and processor-owners) as well as our customers. Our industry strongly opposes it.
The second option, which is the option preferred by APHIS, is to allow RRSB to be planted under permits provided to the processor.
Growers would need to agree to comply with the conditions of the permit.
It is important to remember that these are recommendations(italics) by APHIS, and we will be making and submitting comments as to our views of their proposals.
So please understand that these are in draft form,(italics) and may change before final decisions are made by APHIS.
There are also a number of restrictions on the seed crop in the Willamette Valley of Oregon that are also included in this article.
These will be addressed by the seed producers, but it is important for you to be aware of the restrictions.
Industry leaders have been working hard to review these options and will submit comments by the December 6 deadline.
Once the comments are received, they will be reviewed by APHIS, which will determine whether and how to proceed.
The Agency is fully aware of our views that there is an urgent need to have seed available to producers for next year's plantings and that our industry faces significant harm if RRSB are not able to be planted.
Mandatory Permit Conditions Imposed on Root Production
Under this proposed Alternative, the following mandatory permit conditions would be imposed on event H7-1 sugarbeets intended for root production via permit conditions where the cooperatives (permit holders) will acknowledge and adhere to these mandatory conditions:
1) Planting of H7-1 sugarbeets is not allowed in the state of California, and counties
[west of the Cascade mountains] in Washington State.
2) Applicants shall ensure that root crop fields are surveyed to identify and eliminate any bolters before they produce pollen or set seed. Fields shall be surveyed every 3-4 weeks beginning April 1. Applicants shall ensure that field personnel maintain records of removal of bolters.
3) Applicants shall randomly choose a statistically representative sample of fields and conduct inspection for bolters. If bolters are identified, field personnel shall be notified immediately and those bolters must be removed. Applicant shall notify APHIS/BRS within 48 hours after finding bolters, with the location and action taken by the field personnel. The applicant shall maintain all records of inspection and bolter removal and records must be made available to APHIS/BRS and/or to authorized third-party inspectors/auditors upon request. APHIS will provide an inspection form to be used to capture this data.
4) Planting/cultivating/harvesting equipment that might be used in chard/red beet production shall not be used or shared for regulated GE material in the same growing year.
5) Trucks used for the movement of root crop from field to storage/processing shall be loaded in a manner to minimize loss of beets during transport or equipped with a retaining device.
6) During transport, chain of custody and records shall be maintained. Records shall be made available to AHPHIS/BRS and/or to authorized third-party inspectors/auditors upon request.
7) Root crop fields shall be monitored for three years following harvest and volunteer plants are to be destroyed. If the same land is used for crop cultivation during the volunteer monitoring period, that crop shall be visually distinct from sugarbeets or the fields left fallow. [This would require a 4-year rotation, which we will address in our comments.]
8) The applicant shall ensure that all site cooperators/growers have received the permit conditions and are trained in all the processes and procedures.
9) The applicant shall maintain records of all the activities authorized under the permit to demonstrate adherence to 7 CFR 340, the permit and the permit conditions. These records shall be made available to APHIS/BRS and/or to authorized third-party inspectors/auditors upon request.
10) APHIS inspections and/or third-party inspections/audits will be required to ensure that sugarbeet producers comply with the requirements under 7 CFR 340, the permit and the permit conditions. Records of audits shall be made available to APHIS/BRS for review upon request.
The Third option is to have Monsanto/KWS be the responsible party for overseeing implementation and monitoring of conditions for cultivation of H7-1 sugarbeets as outlined above.
The conditions, similar to those above would be imposed by Monsanto/KWS through technology stewardship agreements.
Mandatory Permit Conditions Imposed on Seed Production
Under this proposed Alternative, the following mandatory permit conditions would be imposed on plantings of event H7-1 sugarbeets intended for seed production via permit conditions where the seed company (permit holders) will acknowledge and adhere to these mandatory conditions:
1) Planting of H7-1 sugarbeets is not allowed in the state of California and the following counties in Washington State: Clallam, Clark, Cowlitz, Grays Harbor, Island, Jefferson, King, Kitsap, Lewis, Mason, Pacific, Pierce, San Juan, Skagit, Skamania, Snohomish, Thurston, Wahkiakum and Whatcom.
2) A four-mile separation distance shall be maintained between male fertile H7-1 sugarbeets and all other commercial Beta seed crops (i.e., table beets, Swiss chard) U.S. wide.
3) An inventory of H7-1 male fertile planting locations shall be provided to APHIS within two weeks of planting.
4) A four-mile separation distance shall also be maintained between male sterile H7-1 sugarbeets and all other commercial Beta seed crops U.S. wide. During flowering, fields shall be scouted for male sterile H7-1 plants that shed pollen and such plants shall be destroyed.
5) A visual identification system, such as labeling, that accompanies the regulated material (e.g. basic seed, stock seed, stecklings and commercial seed) throughout the production system, is required.
6) A companion seed-lot based tracking and tracing system that is fully auditable shall be maintained. Records must be retained for five years.
7) Other than non-GE Beta seed material used in the production of hybrid-seed, all H7-1 material shall be physically separated from non-regulated material to prevent commingling at all points throughout the production process.
8) Planting, cultivation and harvesting equipment shall be cleaned to prevent H7-1 steckings or seed from being physically transferred out of production areas or mixed with non-GE Beta material by inadvertent means.
9) All unused H7-1 stecklings shall be treated as regulated articles until devitalized and discarded.
10) All H7-1 seed and steckling material shall be moved in contained transport systems to avoid inadvertent release into the environment. Vehicles or movement containers shall be thoroughly cleaned after transport and any regulated material recovered shall be devitalized.
11) Sexually compatible varieties (e.g. chard/red beet) cannot be planted or produced in the same location (the same field) as H7-1 in the same growing year.
12) Planting/cultivating/harvesting equipment that might be used in chard/red beet seed production shall not be used for regulated GE material in the same growing year.
13) Measures to force same-year sprouting of H7-1 seed left in production fields are required. Any seed that sprouts from such leftover seed shall be destroyed. Fields shall be monitored for three years and any volunteer beet plants shall be destroyed. If the same land is used for crop cultivation during the three-year volunteer monitoring period, that crop shall be visually distinct from sugarbeets or the fields left fallow.
14) A management plan shall be submitted and followed. The management plan will set forth best practices for oversight of the movement, transportation and confined field production of H7-1 seed. The management plan shall include, but not be limited to, required resources, training of relevant personnel, monitoring of growers, record-keeping and verifying compliance with the permit conditions. The applicant shall also provide the SOPs that will be utilized to conduct the field trials and comply with the permit and permit conditions.
15) No H7-1 seed shall be cleaned or processed in any processing facility that also cleans and processes red beet or Swiss chard seed.
16) Interstate movement of H7-1 sugarbeet stecklings and seed may only be authorized with a movement notification or permit consistent with regulations described in 7 CFR 340.
17) The applicant shall ensure that all site cooperators/growers have received the permit conditions and are trained in all the processes and procedures.
18) The applicant shall maintain records of all the activities authorized under the permit to demonstrate adherence to 7 CFR 340, the permit and the permit conditions. These records shall be made available to APHIS/BRS.
2011 ASGA Annual Meeting
The 2011 ASGA Annual Meeting will be in Tucson, Ariz., at the Westin La Paloma. It promises to be highly informative, covering a broad range of timely topics that impact the industry. A distinguished lineup of speakers has been selected to address those issues, making it a "can't miss" meeting for beet growers and industry suppliers.
Visit the website for more information and to register for this very important meeting.