of observer monitoring activities are acted upon. Of course, in some cases the observed effect may be so dramatic that it would justify immediate action, which would later be followed by a verification process. In addition to the various feedback functions described above, there should be serious consideration given for a process that allows clear regulatory responses to findings from environmental monitoring. For example, one of the possible responses should be to disallow continued planting of the transgenic crop. Such a response could consist of a two-step process. First, the problem should be identified, described, and a probationary warning issued that specifies an observation period during which, if the problem continues, planting will be disallowed. Second, during that observation period, mitigation efforts could be attempted and evaluated. At this time, the burden of proof should shift, so that one must prove that mitigation is successful or planting will be disallowed. Such a response to environmental disruption would require regulatory decision making to match different levels of risk or types of hazards to the timing of the response, mitigation and evaluation periods, the mitigation goal required, and the degree of evidence required. Under the present USDA regulatory system, such matching of a measured regulatory response to the degree of identified risk is not possible.

Recommendation 6.9: The committee recommends that a process be developed that allows clear regulatory responses to findings from environmental monitoring.


Sustaining the quality of the nation’s ecological and natural resources requires effective management of those resources (Grumbine 1994, Olsen et al. 1999). Effective resource management relies on accurate, timely, and complete information on the extent, condition, and productivity of those resources. To obtain this information, federal, state, and local agencies have established ecological and natural resource monitoring programs (Olsen et al. 1999). Monitoring is also used in the identification and definition of environmental problems yet to be recognized or that may emerge in the future.

Major monitoring programs such as the NRI and the NASS provide valuable long-term datasets relevant to agriculture, but they are not sufficiently detailed or focused to allow an independent assessment of the environmental effects of transgenic plants. Currently the environmental monitoring of agricultural and natural ecosystems in place in the United States is inadequate for assessing the potential impacts of commercialized transgenic crops.

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