Dear President Clinton,
8/18/99

The Sierra Club, the largest grassroots conservation group in the United States, is joining the many environmental, consumer, religious, and community groups concerned with the safety of genetically engineered organisms (GEOs), particularly in regards to their use in agriculture. Our purpose is to protect the ecosystem and we believe that the rate of application of this technology far exceeds our ability to understand the environmental and public health risks and to avoid potentially serious impacts.

The biotechnology industry makes the misleading claim that genetic engineering is a simple extension of the traditional crossbreeding that nature and farmers have been using for thousands of years. However, there is a drastic difference. While conventional breeders face natural barriers that prevent unrestricted gene transfer between unrelated species, genetic engineers bypass this protective barrier by combining genes from totally unrelated species. Furthermore, the technology involved in transferring foreign genes is imprecise, unstable, and unpredictable, so that engineers have no way of predicting how GEOs will behave once released into the environment.

The Sierra Club calls for:

• Extensive, rigorous research on the potential long term environmental and health impacts of GEOs before they are released into the environment.

• Use of the precautionary principle, whereby: (1) harm is avoided before scientific certainty has been established, and (2) the burden of proof is shifted to those with the power and resources to prevent harm.

• Mandatory environmental impact statements to be made for every ecosystem into which any new GEO is to be introduced. These should be based on rigorous science and open public debate.

• An end to the concept of "substantial equivalence" by our regulatory agencies as a ploy to sidestep safety studies and oversight responsibilities. For example, toxins meant to kill insects are being genetically engineered into plants, yet the consequences of these toxins in the diets of humans, livestock, beneficial insects, and wildlife are unknown.

• Mandatory labeling of genetically altered products after full safety assessment is completed and doing so in a manner that is easily discernible. All consumers, both citizen and corporate, should be given the right to chose what they buy.

• Removal of antibiotic resistance genes from all food crops, which are routinely placed in genetically engineered crops. It is recognized that such extensive use of antibiotic marker genes is unnecessary and will likely hasten the development of antibiotic resistant pathogens, depriving us of one of the most profound accomplishments of 20th century medicine.

• U.S. commitment not to use trade negotiations or agreements to override the rights of countries to regulate GEOs. The launch of new talks on biotechnology at the upcoming Seattle Summit of the World Trade Organization should not take place without thorough, open, and participatory environmental assessments conducted parallel to the negotiations.

• Full U.S. ratification of the Convention on Biological Diversity, already ratified by 175 other nations, and forceful leadership to support its goal of protecting the diversity of life on Earth. Recognition that biodiversity is not a luxury but a foundation of life on our planet.

  We contend that the risks posed by the current trajectory of genetic engineering in the field of agriculture are profound. We note that:

• Pollen blowing in the wind or carried by pollinator species can transfer genetically engineered traits, such as herbicide resistance and pest resistance, to wild plants. This outward gene flow into nature has the potential to significantly alter ecosystems and create scenarios that would pose enormous dilemmas for farmers.

• Pollinator species, such as bees, may themselves be harmed, with disastrous consequences to the food supply. The killing of Monarch butterfly larvae by corn pollen genetically engineered to express a bacterial toxin was discovered after millions of acres of such corn were planted. This is a dramatic example of adverse secondary effects from a technology that is inadequately understood.

• The use of Bacillus thuringiensis (Bt) toxin engineered into plants will inevitably hasten the evolution of insect resistance, thus rendering the Bt bacterium useless to organic farmers as a natural insecticide.

  The Sierra Club calls for the expansion of research into the risks that recombinant DNA technology and its products pose to the natural environment. In the meantime, in the absence of scientific knowledge, the Sierra Club asks that we take a precautionary approach. Until rigorous research is conducted to discern and address the long term impacts of GEOs, particularly in regards to their use in agriculture, such organisms should not be released into the environment.

  Respectfully submitted,

  Carl Pope

  CC: Jane Henney, FDA; Carol Browner, EPA; Dan Glickman, USDA; Jamie Rappaport Clark, U.S. Fish and Wildlife Service; Al Gore, VP of the U.S.; representatives to Congress and Senate