Gene-Silencing Pesticides Need to be Stringently Regulated

THIRD WORLD NETWORK BIOSAFETY INFORMATION SERVICE

Dear Friends and Colleagues

Gene-Silencing Pesticides Need to be Stringently Regulated

Using genetic engineering techniques, pesticide companies, including Bayer, BASF, and Syngenta, are developing “gene-silencing pesticides” that exploit a cellular process called RNA interference (RNAi). These pesticides are intended to switch off or “silence” genes that are essential for survival in pests, thus killing them. A recent report highlights the serious environmental, health and socioeconomic risks, and knowledge gaps.

Genetically modifying organisms in the open environment makes controlling exposure difficult or impossible. Entire agroecosystems could be affected, and unintended genetic consequences could be inherited by plants and insects and may persist in the environment for generations. RNAi technologies are widely associated with off-target activity – the silencing of genes that weren’t intended to be silenced – both within the genome of target organisms as well as in related non-target species like honeybees.

To date, national regulations have largely failed to acknowledge RNAi pesticides as a form of genetic engineering and have therefore failed to enact proper assessments or precautions for this technology. In the U.S. and EU, it is expected that RNAi pesticides will be regulated under existing pesticide regulations, which are inadequate to address the novel biosafety and environmental challenges of RNAi pesticides and products.

Based on the latest science, RNAi pesticides should fall within the scope of government regulatory oversight of genetic engineering and GMOs, using the Precautionary Principle to protect human health and the environment. Risk assessments of this novel technology should include genome analyses of beneficial organisms in the regions where they will be sprayed to see if bees and other critical species could be harmed, assessments of the hereditary impacts across generations of organisms, evaluations of how long the pesticides will remain active in ecosystems, and rigorous toxicity analysis to understand potential impacts on human health.

With best wishes,

Third World Network
131 Jalan Macalister
10400 Penang
Malaysia
Email: twn@twnetwork.org
Websites: http://www.twn.my/and http://www.biosafety-info.net/
To subscribe to other TWN information services: www.twnnews.net

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GENE SILENCING PESTICIDES – RISKS AND CONCERNS

Friends of the Earth
October 2020
https://1bps6437gg8c169i0y1drtgz-wpengine.netdna-ssl.com/wp-content/uploads/2020/10/RNAi_ExecSummary.pdf

EXECUTIVE SUMMARY

Introduction

Pesticides have been linked to a range of significant unintended consequences, including harming our health, decimating biodiversity, and damaging the soil and water resources that we need to produce food now and into the future.¹ Now, the pesticide industry is developing a new wave of products using genetic engineering techniques, raising a novel set of risks and concerns. Pesticide companies, including Bayer, BASF, and Syngenta, are developing “gene-silencing pesticides” that exploit a cellular process called RNA interference (RNAi). These pesticides are intended to switch off or “silence” genes that are essential for survival in pests, thus killing them. Rather than these technologies themselves being a genetically modified organism (GMO), gene-silencing pesticides are designed to be applied as an external product that will modify exposed organisms in the open environment. Organisms may start out their life as non-GMO and be modified partway through their life, constituting a vast, open-air genetic experiment.^2,3

Gene-silencing RNAi pesticides would be applied to entire fields, and any exposed organism with a matching or similar gene sequence may potentially become genetically modified, whether it is a target or non-target organism.

Gene-silencing RNAi pesticides are virtually unregulated, both domestically and internationally, and therefore are on track to be commercialized without proper risk assessments or precautions. Given the enormous potential risks and major gaps in knowledge surrounding RNAi pesticides, it is imperative that civil society, farmers, and concerned scientists push for strong regulations and proper risk assessments before this technology is commercialized.

How gene-silencing RNAi pesticides work

RNA interference (RNAi) is a naturally occurring cellular process in plants, fungi, and animals, including insects. The RNAi pathway controls whether a gene is turned off or not. Genetic engineers have figured out how to activate this process in organisms by using synthetic interfering RNA molecules produced in the laboratories. The resulting RNAi pesticides can kill a pest by triggering a process in the organism that turns off genes that are essential for survival. For example, RNAi could be applied as a foliar spray on leaves. After the pest eats the leaves, interfering RNA enters the insect’s stomach and silences a gene that isessential for cell division, following which the pest cannot make functioning new cells, and dies.Gene-silencing RNAi pesticides can be applied to plants or insects directly in agricultural fields or other open-air settings via sprays, root soaks, or trunk injections. RNAi applications could also be designed for various other functions, including as growth enhancers or as agents to reverse herbicide resistance, to modify post-harvest traits such as ripening, to initiate resistance to disease in target crops or animals, and more.

Risks, concerns, and knowledge gaps

The limitations of our knowledge and ability to predict or control the outcomes of this novel technology are profound and varied.

Environmental concerns

• Open-air experimentation: Genetically modifying organisms in the open environment makes controlling exposure difficult or impossible. Entire agroecosystems could be affected, and unintended genetic consequences could be inherited by plants and insects and may persist in the environment for generations.
• Unintended silencing of genes: RNAi technologies are widely associated with off-target activity – the silencing of genes that weren’t intended to be silenced, both within the genome of target organisms as well as in related non-target species.^4,5
• Effects on non-target organisms, including bees and beetles: Interfering RNA targeting a specific pest’s genes may bind to and shut down genes in other organisms as well. This off-target effect may extend beyond closely related species to potentially thousands of different species.^6,7 Research already demonstrates the potential to harm beneficial insects, including honeybees⁸, and beetles.⁵
• Entrenching the pesticide treadmill: There is evidence suggesting that, as with other pesticides, targeted pests will rapidly develop resistance to RNAi pesticides.^9,10

Human health concerns

• Inhalation of synthetic interfering RNAs: Farmers, farmworkers, and rural communities may be exposed to synthetic interfering RNAs via spray drift. The risks pertaining to inhalation exposure are completely unknown.
• Altering crops’ genetic composition: Unwanted gene silencing could occur in target crops as the result of exposure to RNAi pesticides. This could alter the crops’ genetic composition in a way that raises safety concerns, such as altering levels of toxins or allergens.¹¹
• Dietary consumption of synthetic interfering RNAs: Preliminary research suggests that naturally occurring interfering RNAs in our diet play a role in regulating physiological or pathological conditions in our bodies.^{12 ,13} This suggests that synthetic RNAi products may also interfere with human gene regulation, with unforeseen health implications. Further investigation is needed to fully understand the safety implications of consuming synthetic interfering RNAs
• Medical research on interfering RNAs suggesting potential for toxicity: Research investigating therapeutic uses of interfering RNAs has been hampered by the observation that they can cause an immune reaction in the body, triggering an unwanted inflammatory response.^14,15

Socioeconomic concerns

Biotech companies are filing patents for RNAi pesticide products that include claims of property rights to exposed organisms and their offspring, regardless of whether the exposure was intentional.¹⁶ Such patents would make owners of RNAi sprays also the owners of exposed organisms, “potentially including entire fields of conventional crops or long-lived trees and their seeds.”³ This would constitute a massive expansion of property rights over nature, ever more deeply entrenching the power of biotech and agribusiness companies over the food system, farmers and the natural world itself.

Knowledge gaps

Many significant knowledge gaps – from the genome to organism to ecosystem level—limit our ability to adequately assess the potential impacts of RNAi pesticides.

• RNAi pathways are not currently fully understood and are more complex than the simplistic, linear theory that is exploited by developers.
• It is not currently possible to predict off-target effects within organisms’ genomes for a variety of reasons: target gene expression is not always static, but mediated by physiological and environmental factors, some interfering RNAs have hundreds of DNA targets, additional processes can extend the effect of the RNAi pathway across time and space once activated, and sequence-independent factors can influence off-target binding to genes.^2,17,18,19
• It is not currently possible to design adequate bioinformatics tools that could improve our understanding of off-target effects.¹⁷
• We currently lack the ability to answer fundamental questions such as which species could be exposed, what their genome sequences are, or how similar the genomes of non-target organisms are to those of target organisms. Research conducted to date on RNAi mechanisms has primarily been in model organisms, not in the diversity of species that exist in the wild, seriously limiting our understanding of how certain species may respond to being exposed to RNAi pesticides.
• The concentration level of interfering RNAs in a product that result in a modified effect may vary between species and individual RNAs, further complicating exposure and risk assessment.

Responding to industry’s false claims

The biotech and agribusiness companies developing gene-silencing products are creating false distinctions between RNAi and other genetic engineering technologies and are downplaying potential risks in order to avoid regulation and achieve rapid commercialization of RNAi products.

• Effects of RNAi pesticides are not “transient” and sometimes can be inherited across generations. Research demonstrates that RNAi pesticides can result in heritable modifications that last up to 80 generations.^3,20 Industry patent applications for RNAi products have claimed heritability.³
• RNAi pesticides are not “natural.” RNAi pesticide formulations are based on synthetically derived interfering RNA molecules. Developers may add chemicals, nanoparticles and other synthetic materials to RNAi products to enhance their function – for example, to make them degrade more slowly.
• RNAi pesticides are not “precise.” There are significant gaps in our scientific understanding of the underlying mechanisms of the RNAi pathway, and research suggests a host of potential unintended effects from the genome to organism to ecosystem level.

Federal regulations and international guidelines

RNAi pesticide technology presents challenges for regulatory systems that were not originally designed to address the development of genetic modification agents being released into the environment. RNAi pesticides currently fall outside of existing domestic and international regulatory structures and therefore have yet to be regulated in most parts of the world. Based on the evidence detailed in this report, RNAi pesticides should be regulated as a form of genetic engineering. RNAi processes can result in genetic changes in exposed organisms as well as altered traits that can be passed down to offspring. This has been raised by U.N. delegates at the United Nations Convention on Biological Diversity (CBD), in particular under the Cartagena Protocol on Biosafety (CPB).^21,22 To date, country-level regulations have failed to acknowledge RNAi pesticides as a form of genetic engineering and have therefore failed to enact proper assessments or precautions for this novel technology. In the U.S. and EU, it is expected that RNAi pesticides will be regulated under existing pesticide regulations. Such regulations are inadequate to address the novel biosafety and environmental challenges of RNAi pesticides and products.

Conclusion

Gene-silencing RNAi pesticides represent both an extension of an old, failed paradigm of pesticide-intensive agriculture, as well as a completely novel set of potential harms. Based on evidence from available scientific assessments, it is not possible to assure the safe use of RNAi products, designed to induce genetic modifications in organisms in the open environment.

The pesticide industry is pitching RNAi pesticides as a solution to a problem the industry itself created: weed and pest emergence and resistance.²³ Despite drastic and costly increases in pesticide use, some analyses show that farmers are losing more of their crops to pests today than they did in the 1940s.^24,25

Rather than continue on a pesticide treadmill in which farmers use new formulations of toxic pesticides to deal with resistant pests, ecological farming methods offer a true solution.²⁶ A growing body of science shows that farmers who rely on ecological methods for pest management instead of pesticides can meet or outperform their conventional counterparts in terms of yield and profits.^27,28,29,30 Ecological farming techniques build healthy soils that confer greater pest immunity to plants and increase biodiversity in farming systems to disrupt the growth of pests and to foster natural predators. This includes crop rotations, cover cropping, composting, reducing tillage, and planting habitat for beneficial insects.

Over the past decade, a series of expert consensus reports have called for a rapid shift from input-intensive industrial agriculture to agroecological farming methods.^31,32 Business as usual is not an option. Our ability to continue to feed ourselves and future generations is at stake.

1. FAO (2015). Natural Capital Impacts in Agriculture: Supporting Better Business Decision-Making. U.N. FAO: Rome, Italy.
2. Heinemann, J. and Walker, S. (2019). Environmentally Applied Nucleic Acids and Proteins for Purposes of Engineering Changes to Genes and Other Genetic Material. Biosafety and Health, https://doi.org/10.1016/j. bsheal.2019.09.003
3. Heinemann J. A. (2019). Should dsRNA treatments applied in outdoor environments be regulated? Environment International, 132, 104856. https://doi.org/10.1016/j.envint.2019.05.050
4. Jackson, A. L., Bartz, S. R., Schelter, J., Kobayashi, S. V., Burchard, J., Mao, M., Li, B., Cavet, G., & Linsley, P. S. (2003). Expression profiling reveals off-target gene regulation by RNAi. Nature biotechnology, 21(6), 635–637. https://doi.org/10.1038/nbt831
5. Baum, J. A., Bogaert, T., Clinton, W., Heck, G. R., Feldmann, P., Ilagan, O., Johnson, S., Plaetinck, G., Munyikwa, T., Pleau, M., Vaughn, T., & Roberts, J. (2007). Control of coleopteran insect pests through RNA interference. Nature biotechnology, 25(11), 1322–1326. https://doi.org/10.1038/nbt1359
6. Qiu, S., Adema, C. M., & Lane, T. (2005). A computational study of off-target effects of RNA interference. Nucleic acids research, 33(6), 1834–1847. https://doi.org/10.1093/nar/gki324
7. Baum, J. A., Bogaert, T., Clinton, W., Heck, G. R., Feldmann, P., Ilagan, O., Johnson, S., Plaetinck, G., Munyikwa, T., Pleau, M., Vaughn, T., & Roberts, J. (2007). Control of coleopteran insect pests through RNA interference. Nature biotechnology, 25(11), 1322–1326. https://doi.org/10.1038/nbt1359
8. Mogren, C. L., & Lundgren, J. G. (2017). In silico identification of off-target pesticidal dsRNA binding in honey bees (Apis mellifera). PeerJ, 5, e4131. https://doi.org/10.7717/peerj.4131
9. International Herbicide-resistant Weed Database. http://www.weedscience.org/Home.aspx
10. Wu, Z., Mo, C., Zhang, S., & Li, H. (2018). Characterization of Papaya ringspot virus isolates infecting transgenic papaya ‘Huanong No.1’ in South China. Scientific reports, 8(1), 8206. https://doi.org/10.1038/s41598-018-26596-x
11. Mesnage, R., Agapito-Tenfen, S. Z., Vilperte, V., Renney, G., Ward, M., Séralini, G. E., Nodari, R. O., & Antoniou, M. N. (2016). An integrated multi-omics analysis of the NK603 Roundup-tolerant GM maize reveals metabolism disturbances caused by the transformation process. Scientific reports, 6, 37855. https://doi.org/10.1038/srep37855
12. Zhang, L., Hou, D., Chen, X., Li, D., Zhu, L., Zhang, Y., Li, J., Bian, Z., Liang, X., Cai, X., Yin, Y., Wang, C., Zhang, T., Zhu, D., Zhang, D., Xu, J., Chen, Q., Ba, Y., Liu, J., Wang, Q., … Zhang, C. Y. (2012). Exogenous plant MIR168a specifically targets mammalian LDLRAP1: evidence of cross-kingdom regulation by microRNA. Cell Research, 22(1), 107–126. https://doi.org/10.1038/cr.2011.158
13. Tomé-Carneiro, J., Fernández-Alonso, N., Tomás-Zapico, C., Visioli, F., Iglesias-Gutierrez, E., & Dávalos, A. (2018). Breast milk microRNAs harsh journey towards potential effects in infant development and maturation. Lipid encapsulation can help. Pharmacological research, 132, 21–32
14. Meng, Z., & Lu, M. (2017). RNA Interference-Induced Innate Immunity, Off-Target Effect, or Immune Adjuvant?. Frontiers in immunology, 8, 331. https://doi.org/10.3389/fimmu.2017.00331
15. Jackson, A.L., Linsley, P.S. (2010) Recognizing and avoiding siRNA off-target effects for target identification and therapeutic application. Nature reviews. Drug discovery, 9(1), 57-67. doi: 10.1038/nrd3010. PMID: 20043028
16. Huang, A.B. Iandolino, G.J. Peel, U.S.P. Office. Methods and Compositions for Introducing Nucleic Acids into Plants. Monsanto Technology LLC, United States (2018) http://www.freepatentsonline.com/20180163219.pdf
17. Hanning, J. E., Saini, H. K., Murray, M. J., van Dongen, S., Davis, M. P., Barker, E. M., Ward, D. M., Scarpini, C. G., Enright, A. J., Pett, M. R., & Coleman, N. (2013). Lack of correlation between predicted and actual off-target effects of short-interfering RNAs targeting the human papillomavirus type 16 E7 oncogene. British journal of cancer, 108(2), 450–460. https://doi.org/10.1038/bjc.2012.564
18. Shelton, S. B., Reinsborough, C., & Xhemalce, B. (2016). Who Watches the Watchmen: Roles of RNA Modifications in the RNA Interference Pathway. PLOS Genetics, 12(7), e1006139.
19. Csorba, T., Kontra, L., & Burgyán, J. (2015). viral silencing suppressors: Tools forged to fine-tune host-pathogen coexistence. Virology, 479-480, 85–103. https://doi.org/10.1016/j.virol.2015.02.02
20. Houri-Zeevi, L., & Rechavi, O. (2017). A Matter of Time: Small RNAs Regulate the Duration of Epigenetic Inheritance. Trends in genetics: TIG, 33(1), 46–57. https://doi.org/10.1016/j.tig.2016.11.00
21. Ad Hoc Technical Expert Group (AHTEG) on Synthetic Biology (2019). “Report of the Ad Hoc Technical Expert Group on Synthetic Biology.” CBD/SYNBIO/AHTEG/2019/1/3 7 June 2019
22. United Nations Convention on Biological Diversity (2020). Overview of work done in response to decision XIII/17. Adhoc technical expert group on synthetic biology https://www.cbd.int/doc/c/569d/77c1/9ff18af57c187298c981e357/synbio-ahteg-2017-01-02-en.pdf
23. University of Nebraska-Lincoln Institute of Agriculture and Natural Resources. Weed and Insect Resistance a Growing Problem. Online. https://cropwatch.unl.edu/weed-and-insect-resistance-growing-problem
24. Evolution. Pesticide Library. Online. http://www.pbs.org/wgbh/evolution/library/10/1/l_101_02.html
25. Pimentel, D. and Acquay, H. et al. (1992). Environmental and economic costs of pesticide use. BioScience, 42(10), pp.750-760
26. Pesticide Action Network. The Pesticide Treadmill. http://www.panna.org/gmos-pesticides-profit/pesticide-treadmill
27. LaCanne, C.E. and Lundgren, J.G. (2018). Regenerative agriculture: merging farming and natural resource conservation profitably. PeerJ, 6, p. e4428
28. Catarino, R., Bretagnolle, V., Perrot, T., Vialloux, F., & Gaba, S. (2019). Bee pollination outperforms pesticides for oilseed crop production and profitability. Proceedings. Biological sciences, 286(1912), 20191550. https://doi.org/10.1098/rspb.2019.1550
29. Heikki, M,. and Hokkanen., et al. (2017). Long-term yield trends of insect-pollinated crops vary regionally and are linked to neonicotinoid use, landscape complexity and availability of pollinators. Arthropod-Plant Interactions. 11(3): p/ 449-461. 21 April
30. Dainese, M., Martin, E. A., Aizen, M. A., Albrecht, M., Bartomeus, I., Bommarco, R., Carvalheiro, L. G., Chaplin-Kramer, R., Gagic, V., Garibaldi, L. A., Ghazoul, J., Grab, H., Jonsson, M., Karp, D. S., Kennedy, C. M., Kleijn, D., Kremen, C., Landis, D. A., Letourneau, D. K., Marini, L., … Steffan-Dewenter, I. (2019). A global synthesis reveals biodiversity-mediated benefits for crop production. Science advances, 5(10), eaax0121. https://doi.org/10.1126/sciadv.aax0121
31. United Nations (2009). International Assessment of Agricultural Knowledge, Science, and Technology for Development (IAASTD) https://apps.unep.org/redirect.php?file=/publications/pmtdocuments/Agriculture_at_a_Crossroads_Global_Report.pdf
32. International Panel of Experts on Sustainable Food Systems (IPES) (2016). From Uniformity to Diversity. http://www.ipes-food.org/images/Reports/UniformityToDiversity_FullReport.pdf

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Item 2

NEW PESTICIDES WILL MODIFY INSECT GENES: WHAT COULD GO WRONG?

By Kendra Klein, Food Tank
9 March 2021
https://www.ecowatch.com/pesticides-modify-insect-genes-2650992311.html (reposted with permission from Food Tank)

Biden’s election has boosted hopes that scientific integrity will be restored in the federal government. To make good on that promise, the administration will need to take action to safeguard against the risks of an entirely new type of pesticide, one developed by genetic engineers rather than chemists.

These pesticides will broadcast “gene silencing” agents across our farm fields — resulting in an open-air genetic engineering experiment. Among the concerns that scientists have raised are threats to bees and other beneficial insects essential to food production. Others have called out potential impacts on human health, including for some of our most essential frontline workers — farmworkers — and rural communities.

Farmers across the U.S. could soon fill their pesticide spray tanks with a substance known as interfering RNA (RNAi). (RNA is a molecule similar to DNA.) Insects that are exposed to it — either by eating crops sprayed with the substance or by landing on a crop and absorbing it through their bodies — would be genetically modified right there in the field. The pesticide would trigger a process inside the insects’ cells to switch off or “silence” genes that are essential for survival — like those needed to make new, healthy cells — thus killing them.

At least one product has already been submitted to the Environmental Protection Agency for approval. But unless Biden’s administration takes action, companies will be able to commercialize these new RNAi pesticides without submitting meaningful health or environmental risk assessments.

The U.S. Environmental Protection Agency’s pesticide rules were written fifty years ago, long before regulators could imagine a class of pesticides that could genetically modify living organisms. Perhaps most concerning is that once gene-silencing agents are released into the environment, there’s no clean-up process when things go awry. Evidence shows that RNAi-related genetic modifications could be passed on for up to 80 generations in some cases.

What could go wrong? Quite a bit, according to scientific research summarized in a report from Friends of the Earth.

RNAi and the “Insect Apocalypse”

There is little reason to believe that this novel technology would be able to target only the “bad” insects and not the plethora of insects that are vital to farming, like pollinators. Bayer and other companies developing RNAi pesticides assert that they can target specific insects. But the genetic story of an ecosystem is one of interconnection — independent researchers warn that thousands of insect species have genetic sequences that are matching or similar enough that they could be unintentionally modified in a way that results in their death.

A 2017 study indicating that honeybees could be harmed by RNAi pesticides raises a red flag since we rely on pollinators for one in three bites of food we eat. Insects form the basis of the food webs that sustain all life on the planet. We are already in the midst of what scientists call an “insect apocalypse” — forty percent of insect species face extinction in coming decades. This is a loss so severe that it could cause a “catastrophic collapse of nature’s ecosystems” according to leading researchers.

Health Concerns

It’s not just insects that may be harmed. While there are gaping holes in the research about potential human health impacts, what we do know raises concerns. Research indicates that naturally occurring RNAi that we consume in our food could regulate genes in our bodies. This suggests that synthetic RNAi could affect our gene expression, causing unforeseen problems. And medical research investigating therapeutic uses of RNAi has been hampered because some participants in clinical trials have experienced adverse immune reactions in their bodies.

Entrenching a Failed Paradigm

The pesticide industry is pitching RNAi pesticides as a solution to a problem the industry itself created: weed and pest resistance. As Rachel Carson warned in Silent Spring, her groundbreaking book about pesticides in the 1960s, our “relentless war” on insect life will inevitably fail because nature “fights back.” Indeed, over 540 species of insects and over 360 types of weeds have evolved to resist the deadly effects of commonly used pesticides. Despite drastic and costly increases in pesticide use, some analyses show that farmers are losing more of their crops to pests today than they did in the 1940s.

It is foolish to continue down this same path and expect a different outcome. Research already shows the potential for pests to develop resistance to RNAi pesticides.

But pesticide giants like Bayer and Syngenta need new products to sell. A significant portion of their income is tied to pesticides that pose serious hazards to health and the environment. And as the scientific evidence mounts, the industry is facing increasing regulatory, legal, and market pressures.

Not only could RNAi pesticides provide a lucrative new suite of products, companies appear to be using them to extend their ownership over nature in an unprecedented way. Manufacturers are filing patents that claim property rights to the organisms exposed to RNAi pesticides as well as to their progeny.

Farming With Nature — a True Solution

The science shows clearly that pesticide-intensive agriculture is a disastrous dead end. Decades of data point to the same conclusion: we must rapidly shift to ecological farming methods in order to continue to produce food for generations to come.

Ecological farming offers a true solution to pest management with additional benefits. Practices like cover cropping, composting, and rotating crops build healthy soils that strengthen plants’ defenses against pests and fungi while disrupting pest cycles and fostering biodiversity. These same methods, which underpin the success of organic farming, are also the lynchpins of regenerative agriculture, the idea that farmland can serve as a carbon sink.

Follow the Science

Biden has already signaled that he is likely to shy away from making the bold changes we need by appointing Tom Vilsack as head of the U.S. Department of Agriculture (USDA).

But as he rebuilds the scientific backbone of the federal government, advocates hope that he will take steps to update our decades-old pesticide regulations, such as those outlined in this recently introduced bill. In addition, specific criteria need to be added to ensure a science-based approach to regulating RNAi pesticides. Risk assessments of this novel technology should include genome analyses of beneficial organisms in the regions where they will be sprayed to see if bees and other critical species could be harmed, assessments of the hereditary impacts across generations of organisms, evaluations of how long the pesticides will remain active in ecosystems, and rigorous toxicity analysis to understand potential impacts on human health.

If Biden’s EPA does not take these measures, we will soon embark on an open-air genetic experiment, the consequences of which may be felt for generations to come.