the new cropping practices on soil characteristics. These long-term experiments were sponsored by nonprofit groups and local governments. Today, most efforts at examining environmental impacts of transgenic crops emphasize short-term laboratory and field plot experiments. While such experiments are useful, there is a need to examine effects that cannot be seen at such small scales. For example, short-term and small-scale experiments would not have predicted the effects of Green Revolution practices on lowering the water table in semiarid regions of India or the rise in water tables in other areas that has been accompanied by salinization of the soils in the root zones of crops.

Finding 7.12: The environmental impacts of transgenic plants and other new agricultural practices can be studied at a number of ecological scales ranging from the specific toxicological effects of a newly produced compound to the large-scale and long-term spatial and temporal effects of changes in agricultural practices induced by the introduction of a novel crop variety.

Finding 7.13: Currently APHIS environmental assessments focus on the simplest ecological scales, even though the history of environmental impacts associated with conventional breeding points to the importance of large-scale effects, as seen in the impacts of Green Revolution cultivars.

Recommendation 7.1: APHIS should include any impact on regional farming practices or systems in its deregulation assessments.

Society demands that commercial products are deemed safe for health and the environment. The public trusts government regulators to assess risks adequately, to exclude from commerce products posing unacceptable risks, and to impose appropriate risk management strategies to reduce risks. Some people want regulators to test “everything for everything” prior to commercial release. All regulatory agencies, including APHIS, must work with limited financial, temporal, and human resources, so testing everything is not feasible. Instead, prudence and fiscal reality dictate that regulators identify those products most likely to be hazardous and concentrate scrutiny on them, applying a science-based approach to risk assessment.

Currently, one of the risk-based triggers for assessment of a crop by APHIS is that it is a transgenic crop variety (see Chapter 2). This trigger captures all products of genetic engineering but excludes potentially hazardous products derived from conventional methods. This regulatory trigger is imperfect because it does not provide regulatory scrutiny for certain conventional crop plants that may have environmental risks. As discussed more thoroughly in Chapter 2, it fails to capture potentially



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