Stewardship: Actions to be Taken Prior to Launching Special Traits

Dear Secretary Vilsack:

For the past 15 years, agricultural products derived from modern biotechnology have provided significant agronomic benefits to America's farmers. From increased yields, to reducing the impact of agriculture on the environment, biotechnology is providing important tools that enhance U.S. competitiveness and help address global challenges, such as food and energy security in a sustainable way. While the agricultural biotechnology industry continues to expand the development of new agronomic traits, it also is bringing to the forefront traits providing benefits to end users and consumers. These "special use" traits provide improvements to nutritional composition of foods, efficiencies to biofuel production, and more.

In support of encouraging the continued adoption of agricultural biotechnology and to bring value to the marketplace, BIO's Food and Agriculture Section Governing Board recently approved a new policy encouraging technology developers to take certain stewardship actions prior to launching special use traits. Specifically in the case of special use traits, the BIO policy recommends that BIO members anticipate, consider and develop approaches to help manage and mitigate any potential significant, unintentional processing, product functional or compositional negative effects in crop use or processing streams. In conducting a market and trade assessment, consultation with relevant stakeholders is encouraged as is communication of management plans as appropriate.

BIO and its members firmly believe that industry stewardship complements science-based government regulations allowing for the full potential of agricultural biotechnology to be realized for the benefit of farmers, stakeholders and consumers. We hope that the U.S. Department of Agriculture will recognize the value of BIO's Product Launch Stewardship Policy, a copy of which is enclosed, as USDA reviews petitions for deregulation of special use traits.

Please do not hesitate to contact me or Sharon Bomer, BIO's Executive Vice President for Food and Agriculture, if you or your staff have any questions.

Thank you for your consideration.

Sincerely,

James Greenwood

President and CEO