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Invited papers - Friday 14.11.2003 Certified seed production Management of varietal purity in seed production in France:
organisation and cost GM/non-GM wheat co-existence in Canada: Roundup Ready® wheat
as a case study H. Klein Abstract Certified seed is genetically stable quality seed produced in tested multiplication conditions. Strict obligations concerning maintenance breeding and the production of pre-basic and basic seed ensure that the value-added properties of a variety as concerns quality, resistance and yield remain on the same high level. Certified seed is officially tested and approved seed. The
certifying agencies ensure that the multiplication of certified seed was done in
conformity with the seed marketing requirements. In particular, they inspect the
field plots, taking into account volunteer plants, plant health and minimum
distances as well as the minimum requirements of the seed lot with respect to
germination, moisture, sorting quality, technical purity and health conditions. Certified seed has guaranteed quality. Legal certainty for the farmer is ensured on the basis of the seed marketing law as well as the "General Conditions for the Trade and the Distribution of Seeds". Certified seed is subject to continuous official inspection. The official control of legal minimum standards in form of supervision of the seed marketing as well as the control of certified seeds for varietal purity, health and the other requirements mentioned is a means to ensure customer protection. Certified seed is the basis for a successful cultivation and market-oriented processing of the harvest. Co-existence of different farming systems with or without
genetically modified varieties is manageable, provided workable and feasible
thresholds will be laid down for seed as well as for food and feed for all
purposes. This enables seed suppliers, farmers and other participants of the
entire food and feed chain to meet the requirements of the markets they choose. Quality seed is an asset of outstanding importance with decisive influence on the success in agricultural plant production. In the future, its role in shaping a plant production adapted to market needs will even get more decisive. Seed production - faithful to the original The entire food chain profits from the progress achieved by breeding. The certified seed production system ensures that only seed of highest quality will be produced and marketed. The multiplication and marketing of quality seeds are set forth in the Seed Marketing Act and the regulations thereto. The seed industry goes even beyond the already strict legal requirements in form of voluntary supplementary efforts in order to achieve even further improvement of the already high quality level. The seed production takes place in selected farms, the so-called seed multiplication companies. They produce basic seed from pre-basic seed, or certified seed from basic seed for the breeders. Distribution is done by specialized distribution companies, mostly agricultural co-operatives or private companies trading in agricultural goods. They determine the quantities of seeds needed in their catchment area and select quality seed of the varieties, which are of particular interest for the cultivation in this region, in co-operation with the official advisors. Seed certification as a means of customer protection Seed production is carried out according to the official certification guidelines. This is to ensure that the legally guaranteed quality standards for certified seed must conform to a wide range of requirements and pass numerous tests. It may only be descended from listed seed, normally basic seed. In field inspections and quality testings, this basic seed is subject to even stricter standards than certified seed. The seed multiplication farm and the fields used for seed multiplication also must fulfil well-defined requirements. The seed producer must have the technical equipment and the skills necessary for the production of quality seed. The state of cultivation on the production area must be properly treated and prepared. The official certification agencies carry out field inspections in order to test the seed multiplication crops for varietal purity, for presence of volunteer plants and seed borne diseases as well as minimum distances. Experienced seed certifiers inspect each individual seed multiplication field plot for conformity with the legal minimum standards and maximum tolerances. Only a small number of plants of other species or deviating from the variety properties may be found in the samples taken. Very strict standards apply to seed-borne diseases. In the case of cross-pollinating crops, minimum distances to neighbouring field plots cultivated with the same crop are to be respected. An important task of the seed multiplier is therefore not only to carefully select the multiplication field plot, but also to keep these plots free of plants of other crops or weeds, continuous inspection of the seed multiplying crop, their protection against diseases and rouging of undesirable plants. After the harvest, the seed will be treated and an official sample will be taken for testing at the official regional testing agencies. This is to ensure that the legal requirements for germination rates, health, varietal purity and presence of volunteer plants are fulfilled. If the samples conform to the standards established by the seed marketing regulations, the seed certification agency grants official certification. Only then may the seed lot be marketed in closed or defined containers marked with the blue label for certified seed. The seed industry surpasses the legal standards for seed quality in crucial points as e.g. technical purity, volunteer plants and germination rates. For customer protection purposes, the rules and regulations on seed marketing only allow seed to be marketed in closed packaging as e.g. bags, containers, cardboard boxes or small packages. The regulations do not only provide for the nature and the closing of the packaging, but also for the labelling of the seed. It may only be marketed with the appropriate labels. In certain cases an additional inside slip is necessary. The label gives information to the seed consumer on the
category of seed. A white label is for basic seed, a blue label for certified
seed. Regarding certified seeds, information is provided as follows: applicable EC-Standard, certifying country, reference to the certifying agency, crop, variety denomination, seed category, certification number, closing date (month and year), country of origin, package weight or nominal number of grains as well as additional information. The additional information in the case of cereals may be e.g. the thousand seed weight, the germination rate and information on seed treatment. They enable the farmer to calculate exactly the amount of seed to be sown and give data on protection of the seeds against diseases and pests. And finally, legal requirements as to the closing of the package are in place for the protection of the seed consumer. In general, they must be sealed with official lead seals, bands, sealing labels or other forms of adhesive labels. The farmer can refuse to accept opened or damaged packages. The farmer buying certified seed enjoys a high level of customer protection. The following is guaranteed to him:
Certified seed of high quality - one of the measures for management of co-existence High quality certified seed is one of the measures for the
management of co-existence. Co-existence of different farming systems with or without
genetically modified varieties is manageable, provided workable and feasible
thresholds will be laid down for seed as well as for food and feed for all
purposes. This enables seed suppliers, farmers and other participants of the
entire food and feed chain to meet the requirements of the markets they choose. In crop production, farmers make use of a lot of measures in conformity with the rules of integrated crop management. There is a complex interaction between the selection of a variety on the one hand and climatic conditions, soil preparation, plant protection, fertilisation, harvesting and crop rotation on the other hand (genotype-environment-interaction). Depending on the intended quality, farmers may adopt additional practices like optimised harvesting, field inspections, keeping field records. Every introduction of an innovative new variety into crop production results in changes of this interplay of rules, measures, conditions and objectives. An example is the introduction of oil seed rape hybrids in comparison to open-pollinating varieties. In seed production, additionally some legal obligations like e. g. minimum distances and regulations on crop rotation are applied to meet general quality criteria. Other measures traditionally used like special field inspections and elimination of off-types, taking care of the ratio of male and female plants in hybrid production, barrier crops and many others are voluntary requirements set up for the special purpose of producing seeds for very specific market demands which could define the seed production as a "premium market" in comparison to the commodity market of crop production. All participants of the supply chain have to observe the rules of good practice and to take all reasonable measures to meet the given thresholds. Even today, conformity with the principles of good practice is a genuine interest of all market players and is a responsibility of each individual company. Examples for codes of good practice are the Quality Management (QM) systems of the different processing stages and the descriptions of good agricultural practice. Co-existence: the seed industry's expertise Today, the European seed industry operates under a wide range of legislative as well as voluntary rules of production. These rules and regulations are foremost designed to assure the purity levels set by the European Seed Marketing Directives. To do so, specific requirements as regards isolation distances from other seed or crop production areas, rotation cycles and many other requirements are established at national level and in conformity with existing European legislation. When required by specific market segments and possible under the natural conditions, product qualities even beyond the legal requirements can sometimes be produced, of course with adequate supplementary compensation for premium quality. At the same time, the quality requirements set forth in the Seed Marketing Directives are frequently lowered on demand of individual Member States in cases in which the usual product qualities cannot be supplied in sufficient quantities due to bad harvest conditions or other natural or unforeseeable factors. Plant breeders and seed producers have also a proven track record of supplying all crop production with the seed of their choice, be it conventional, organic or GM, provided the legislative and market conditions allow for an economic production. The seed industry is convinced that the existing European and national legislative provisions in connection with the expertise and experience of seed producers in their respective production environment have successfully guaranteed to all European farmers the high quality seed necessary for competitive crop production in all forms of production and markets. In connection with the taking on of the new technology of GM in seed and crop production, seed producers therefore require solely the additional setting of practical thresholds for all possible sources of adventitious presence of GMOs in conventional seed. The setting of such thresholds alone will be sufficient to continue to supply the different markets and consumers with the seed of their choice. Co-existence: Recommendations from the breeders' point of view In comparison to crop production, seed production obviously is carried out on quite limited areas and under very strict quality assurance policies of companies and seed producers. Following the existing approach of seed and crop production achieving the highest possible purity levels right at the beginning of the crop production cycle and under conditions which cannot be transferred to the field, i.e. to general crop production, the approach to co-existence must be proportionate to the objective and economically viable if one is to prevent that particular forms of agriculture and especially particular farm or enterprise sizes are placed at an impossible competitive disadvantage. The seed industry therefore recommends to
Conclusions
G. Sicard Abstract An important challenge for seed growers is to achieve the varietal purity standards required by the regulation or the market. For many species, mainly allogamous seed crops, varietal purity depends on the management of the surroundings of the farm. Therefore, a collective organisation, on a large scale, is needed. To help growers to resolve co existence between seed production of different cultivars and other commercial crops, several "protected areas" were created in France, according to the law set up in December 1972. The management of seed crops within this protected areas and the organisation evolution during the past years, due to the use of new tools, are described in this paper. Introduction The seed grower is responsible for the varietal purity of the seed lot he produces on his farm. For most of the species, varietal purity requirements are defined by the certification standards and vary from 90 to 99.7% (for agricultural crops). Concerning vegetable seeds, for which certification is not compulsory, very high varietal purity levels are often required by the seed companies (99.9 or 100%), to satisfy the needs of the professional market. Insuring the right varietal purity has always been a real challenge for the growers. Many factors affecting varietal purity are linked to good management of the seed production crop itself and good practices on the farm: accurate rotation, control of volunteers, good concordance of flowering (in case of hybrid production), management of pollinator insects, machineries and storage facilities cleaning. For many allogamous species, the risk of undesirable cross-pollination is coming from both cultivated and wild plants growing in the vicinity and must also be controlled. This risk, linked to the environment, varies a lot according to the biology of the species. It is always much more important in hybrid productions than in populations. Different isolation distances have been edicted by National or interprofessional rulings, mainly based on practical experience. Those distances can be revised by the actors of seed sector, like in 1998 for vegetables when the new "standard convention" was agreed. When the isolation distances involve a scale or area much bigger than an average farm, an individual farmer management is not sufficient. Collective management of isolation has therefore been organised for a long time by the growers in different seed production areas in France. The 22 December law on "Protected Area" During the sixties, the difficulties to manage co-existence with non-growers in seed production areas raised the need of reglementation. Its aim was to give higher priority to seed crops in specific areas. In December 1972, a law was voted by the French parliament, which gives the profession the opportunity of applying for the creation of "protected areas for seed production". Since 1972, more than one hundred protected areas were created for maize, sunflower, beets, various vegetable and recently also for hybrid rye. In these areas, all the crops of the designated species must be declared to the Public Authority. The same crop for grain production (and not for seed) is not allowed in the area, except if it is in accordance with isolation requirement defined for the seed production fields. Public Authorities can destroy a crop if the isolation policy is not respected. Legal penalties can be inflicted to farmers who do not respect the law. New protected areas are created at profession request. Public inquiries are opened at a regional level and the agricultural organisations are involved. If everybody agrees, the new protected area is officially created by order of the Ministry of Agriculture. The administration of the seed plots in the protected area is directly managed by the seed sector, organised within the GNIS (Groupement National Interprofessionnel des Semences), and local public authority. Management of isolation in protected areas The management of isolation distances within a protected area is based on a compulsory declaration of seed plots location several months before sowing date. Formerly drawn on paper maps, this "cartography" is now more and more computerized. After recording all proposed seed production plots, the computer lists automatically the fields, which are not well isolated, according to the standard or particular isolation, distances. Meeting with representatives of seed companies and seed growers are organised to find a solution to each problem. Once accepted by all parts, the cartography become official and all the crops can be sown. Consultation of the cartography is possible at any time on an Internet site. Management costs This management has a cost, mainly in terms of time spent by different actors. A rough estimate of that time was made on 2 different protected areas in Anjou (Maine et Loire): the protected area for maize seed production and the protected area for several vegetable seed productions. In maize, an approximate 210 days were devoted to that management, which means for about 4000 hectares an average of 25 minutes per hectare. 2/3 of that time is spent by the farmers themselves (in fact, benevolent representatives) to prepare the isolation at a very local level. For vegetable seed, an approximate 200 days were spent for 2800 hectares (35 minutes per hectare). In that case, seed companies, GNIS and public administration spend the biggest part of that time. Conclusion Management of varietal purity can be considered as efficient in seed production in France, due to several factors.
References Loi n° 72-1140 du 22 décembre 1972 relative à la création
des zones protégées pour la production de semences ou plants. Journal Officiel,
23 décembre 1972.
R.C. Van Acker, A.L. Brûlé-Babel, L.F. Friesen & M.H.
Entz Abstract The pending approval of the unconfined release of Roundup Ready wheat in North America has brought to the attention of regulators and scientists in North America the issue of co-existence of genetically engineered (GM) and non-GM crops. In Canada, there has been great adoption by farmers of Roundup Ready and other GM canola varieties. At the time of commercial release of GM canola in Canada no specific GM, non-GM co-existence plans were considered or implemented. GM traits (transgenes) have since become ubiquitous in canola crops in Canada and this has led to some problems. For example, although Roundup Ready canola provides direct operational value to adopting farmers, controlling volunteer Roundup Ready canola in low disturbance direct seeding systems adds cost for farmers. The spread of the Roundup Ready trait in canola means that this added cost is borne by both adopters and non-adopters of the technology. The factors and conditions which led to the spread of the Roundup Ready transgene in canola in Canada appear to be similar for wheat if Roundup Ready wheat were to be released in Canada in the same way that Roundup Ready canola has been. To minimize potential negative impacts from movement of the gene conferring glyphosate (Roundup) tolerance among volunteer wheat populations after the release of Roundup Ready wheat, a co-existence plan must be created and implemented. The plan must be species and trait specific and based on knowledge of biology, ecology and agronomy. The plan must be made functional by legislation and regulation and must provide formal routes of recourse for non-adopters affected by transgene movement. Co-existence plans are progressive and will facilitate the introduction of new traits into crops both by GM and non-GM means. Introduction In Canada and the United States, approvals for the unconfined release of Roundup Ready spring wheat (Triticum aestivum L.) are pending. Roundup Ready wheat is modified through recombinant DNA technology to be herbicide-tolerant and is considered genetically engineered wheat (GM wheat). There has been some debate and controversy in North America surrounding the pending approval of Roundup Ready wheat. Proponents of this product suggest that it will simplify weed control in spring wheat, reduce herbicide injury to wheat, improve control of current herbicide-resistant weed biotypes, eliminate off-type wheat within a given wheat crop, and increase in-crop opportunities for the control or suppression of perennial weeds (Harker et al., 2003; Van Acker & Entz, 2002). Those concerned about the unconfined release of Roundup Ready wheat suggest a number of risks associated with its release including difficulty and cost of controlling volunteer Roundup Ready wheat in low-disturbance direct seeding (no tillage prior to seeding) cropping systems, the evolution of glyphosate resistant weeds in glyphosate dependent cropping systems, the loss of farm saved seed for wheat (Ogg & Jackson, 2001; Van Acker et al., 2003), and the adventitious presence of GM-wheat in non-GM wheat segregated for sale to satisfy domestic and export customers of North American wheat who are unwilling to purchase GM wheat (Rosher, 2003). At the core of most of the concerns are questions about movement of the transgene conferring Roundup tolerance from GM to non-GM wheat crops and whether co-existence of Roundup Ready and non-Roundup Ready wheat is possible. In western Canada, Roundup Ready canola (Brassica napus L.) has been grown commercially for 8 years on large acreages. Experiences with Roundup Ready canola can be used as a valuable reference for consideration of possible intraspecific transgene movement in wheat and the creation of a functional co-existence plan for Roundup Ready and non-Roundup Ready wheat. Intraspecific transgene movement in canola in western Canada GM canola is very popular with western Canadian farmers. In 2003, 48% of the canola grown in western Canada (2.25 of approximately 4.7 million ha in 2003) was Roundup Ready, and since it's commercial release in 1996, more than 8 million ha of Roundup Ready canola have been grown by western Canadian farmers (M. Lawton, Monsanto Canada Inc, pers. comm.). Farmers value the operational benefits of this product citing simplicity and effective weed control as key values they capture by growing Roundup Ready canola. At the time of unconfined commercial release of Roundup Ready canola in Canada, it was known that there was significant potential for out-crossing within the canola (Brassica napus L.) genome and that transgene movement from canola crop to canola crop would occur (Canadian Food Inspection Agency 1995). Work after the release and massive adoption of GM-canola in western Canada has shown that pollen mediated gene flow in canola can be an effective cause of transgene movement. Beckie et al. (2001) and Rieger et al. (2002) found that out-crossing in canola (B. napus) occurred to a distance of 800 and 2500 m, respectively. These studies helped in part to explain why Friesen et al. (2003) and Downey and Beckie (2002) found that a majority of the western Canadian grown pedigreed non-GM canola (B. napus) seedlots they tested contained genetically engineered herbicide tolerance traits. This adventitious presence of transgenes was not caused by pollen flow alone. Thirty-three percent of the seedlots (9 of 27) tested by Friesen et al. (2003), and 18% of the seedlots tested by Downey and Beckie (2002) (13 of 70) had the Roundup Ready transgene present at levels above 0.25%. Given current knowledge of pollen mediated gene flow in B. napus, it is unlikely that pollen flow would cause greater than 0.1% presence in a single generation of pedigreed seed production given strict seed production protocols. Adventitious presence levels above 0.25% were likely the result of inadvertent mechanical mixing of certified seedlots during harvest or handling, or contamination occurring in earlier generations of pedigreed seed production (i.e., Breeder or Foundation seed). The general spread of transgenes among canola crops within a region such as western Canada is a function of canola biology and ecology and the environmental and agronomic conditions under which it is grown. The species characteristics and agronomic conditions interact to create opportunities for genes to move from crop to crop. The characteristics and conditions which have combined to create effective transgene movement for the Roundup Ready trait in canola in western Canada include:
Sometimes gene movement matters The result of Roundup Ready transgene movement in western Canada is that essentially all volunteer canola populations in western Canada contain some proportion of Roundup Ready volunteers. This is true even if Roundup Ready canola cultivars have never been intentionally planted in a given field. Farmers now cannot be certain of the herbicide tolerance status of their volunteer canola population. When Roundup Ready volunteer canola is present in a field, pre-seeding weed control in low-disturbance direct seeding systems requires the addition of another herbicide as well as glyphosate, adding cost and complication in the crop rotation because of the pre-seeding residue left by some herbicides (Van Acker et al., 2003). Farmers who choose to grow Roundup Ready canola balance the added costs and complications against the measurable benefits they receive from this technology. However, because of the ubiquitous presence of the Roundup Ready trait in volunteer canola populations, the added costs and complications in rotation are also borne by farmers who choose not to grow Roundup Ready canola (non-adopters). The impact of gene movement depends upon the crop. For example, controlling Roundup Ready wheat volunteers in a low-disturbance direct seeding system would cost more than controlling Roundup Ready canola volunteers (Harker et al., 2003; Van Acker et al., 2003). If the transgene conferring glyphosate tolerance became ubiquitous in volunteer wheat populations in a manner similar to what we have witnessed in canola, then the cost associated with low-disturbance direct seeding systems in western Canada would rise significantly. This would threaten the economic viability of these systems and in turn threaten Canadian farmers' ability to capture the environmental, resource conservation and economic value of low-disturbance direct seeding (McRae et al., 2000). In this manner, a production economics issue related to the movement of one trait within a crop species can become an environmental issue. The potential for damage resulting from gene movement also depends upon the gene (trait) that is moving (Gealy et al., 2003). Other novel herbicide tolerance traits in canola (glufosinate tolerance and imidazolinone tolerance in the Liberty Link and Clearfield canola systems, respectively) also move into conventional non-herbicide resistant canola varieties in western Canada (Hall et al., 2000). The movement of these traits does not create problems for non-adopting farmers in western Canada because they do not currently depend on glufosinate or imidazolinone herbicides for pre-seeding weed control to replace pre-seeding tillage in low-disturbance direct seeding systems. However, if there were a segregated market for GM and non-GM canola for Canadian farmers, then the movement of transgenes conferring either glufosinate or glyphosate tolerance would matter because these are both GM traits. It should be noted as well, that gene (trait) movement can be a problem whether or not the trait is considered GM. For example, if the Roundup Ready trait had been incorporated into wheat using conventional breeding means, the movement of this trait among volunteer wheat populations would still pose a threat to the economics of low-disturbance direct-seeding systems in western Canada because of the dependence of these systems on Roundup herbicide for inexpensive, non-selective, non-residual, pre-seeding weed control. The potential for intraspecific transgene movement in wheat Pollen movement in wheat is facilitated by wind and gravity. In wheat, anthers normally open within the floret, followed by filament elongation and extrusion of the anthers outside of the floret. A small amount of pollen is shed on the stigma within the floret, while 80% of the pollen is shed outside of the floret. Florets that have not been successfully self-pollinated will remain open and be receptive to pollen from other sources for up to 13 days after flowering (de Vries, 1971). Estimates of out-crossing rates in wheat are dependent on synchrony of flowering between pollen donors (males) and pollen receptors (females), the presence of receptive females, and the availability of single dominant nuclear marker genes to facilitate detection of out-crossing. Waines and Hegde (2003) stated that "...there is enough evidence to show that cross-pollination [in wheat] regularly occurs and the reproductive biology of wheat is favourable to facilitate varying degrees of gene flow in a variety of situations." The factors and conditions that facilitated movement of the Roundup Ready transgene in canola in western Canada appear to be similar for wheat. These include:
Co-existence planning for Roundup Ready wheat and non-Roundup Ready wheat The appearance of the Roundup Ready trait in non-Roundup Ready pedigreed canola seedlots in Canada was arguably predictable (Warwick et al., 1999). In Canada, the experience with canola can be used as the basis for planning for Roundup Ready and non-Roundup Ready wheat co-existence. Currently, industry led stewardship plans are being proposed to prevent potential negative impacts resulting from transgene movement after the release of Roundup Ready wheat in western Canada. These plans are functionally problematic because industry has limited ability to demand, monitor, or enforce adherence to such plans. In the case of non-adopters, industry may have no ability to demand adherence to these plans. This is especially problematic for the containment of the Roundup Ready trait because prevention of transgene movement via pollen flow in wheat relies critically on management of receptor wheat crops (Waines & Hegde, 2003), and in many (and perhaps most) cases receptor wheat crops will be grown by non-adopters of the Roundup Ready technology. To be effective, co-existence plans for Roundup Ready and non-Roundup Ready wheat need to have certain characteristics. The co-existence plan must:
Conclusion The need for co-existence plans and the stringency of a given plan is a function of the crop and the genes (trait). In some cases gene (trait) movement matters. Whether the movement matters is not necessarily a function of whether the trait is considered GM or not. For those traits for which movement matters, co-existence plans must be created which are based on biology, ecology, agronomy, and competitive advantage of the trait (selection pressure). These plans must be made functional and enforceable through regulation arising from legislation and they must include a formal route of recourse for those affected by gene movement. Effective and functional co-existence plans will protect choice for farmers and consumers. For GM and non-GM crops, or more generally, for crops, which contain traits that must be contained, co-existence planning is progressive. It will facilitate the introduction of new traits in crops using either recombinant DNA (GM) or non-GM means. References Beckie H.J., Hall L.M. & Warwick S.I. 2001. Impact of
herbicide resistant crops as weeds in Canada. 2001. Proceedings of the British
Crop Protection Conference-Weeds. Pages 135-142.
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