100 Iowa L. Rev. 825 (2015)

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Abstract

The most notorious escapes of genetically modified organisms (“GMOs”) included products still in the testing phase that the U.S. Department of Agriculture (“USDA”) had never approved for sale or consumption. The USDA, more specifically, its subdivision, the Animal and Plant Health Inspection Service (“APHIS”), must change the current culture of noncompliance among growers. Changes in the regulation of field trials of GMO products would allow U.S. growers to certify to food distributors and importers of U.S. agricultural products that crops are what growers purport them to be and that unwanted and never-approved GMOs have not contaminated their products. Better regulation would shift the costs of preventing the escapes of these seeds on to the producers rather than farmers, who might suffer economic loss if GMO seed contaminates their crops, or the public, which suffers when agricultural markets across the globe are disrupted by discovering unwanted GMO strains in food or other agricultural products.