INSECT RESISTANCE MANAGEMENT COMPLIANCE ASSURANCE PROGRAM BACKGROUNDER Adherence by growers to the Insect Resistance Management (IRM) requirements mandated by EPA is an important factor for preventing the development of resistance to Bt by key corn insect pests such as the European corn borer. Preserving the effectiveness of this technology will allow U.S. corn growers to continue to enjoy its economic and environmental benefits. Consequently, promoting compliance with IRM requirements is of great importance to the Environmental Protection Agency (EPA), Bt corn registrants, and growers alike. Therefore, the registrants of Bt corn products (Dow AgroSciences, Monsanto Company, Pioneer Hi-Bred International, Inc., and Syngenta Seeds, Inc.) registered by EPA in October 2001, working through the Agricultural Biotechnology Stewardship Technical Committee (ABSTC), are implementing a multifaceted strategy for promoting grower compliance with the IRM requirements and preserving the effectiveness of Bt corn, consistent with the terms and conditions of registration for those products. Bt corn growers have been following the IRM requirements since 1999. Highlights of the program include: The IRM Compliance Assurance Program has been approved by the EPA and is effective immediately. All Bt corn growers must follow the same IRM requirements and will be subjected to consistent compliance standards regardless of the registrants and/or seed companies with whom they choose to do business. Growers who do not comply with the IRM requirements in two consecutive years will be denied access to Bt corn the third year. Although the Compliance Assurance Program is intended to allow for flexibility in the specific methods that are employed by the individual registrants, each company must: 1) provide a mechanism for evaluating the extent of IRM compliance among Bt corn growers, and 2) provide a mechanism for responding to instances of noncompliance in a manner that brings noncompliant growers back into compliance with the IRM requirements. In particular, the IRM Compliance Assurance Program must contain the following four elements: An Annual IRM Survey — The registrants are required to sponsor an annual survey of Bt corn growers, to be conducted by an independent third party. A Mechanism for Handling Tips and Complaints — Each registrant must implement a program for investigating "legitimate tips and complaints" about growers who may be out of compliance with their IRM obligations. Training of Seed Company Representatives — Seed company representatives who make on-farm calls are required to be trained to assess grower adherence to IRM requirements. A Phased Compliance Approach — The registrants must establish and publicize a phased compliance approach describing how instances of noncompliance with IRM requirements will be addressed. Some additional components of this multifaceted IRM compliance strategy are highlighted below: Grower Education. Bt corn registrants are engaging in an aggressive and broad-based educational campaign aimed at ensuring that Bt corn growers understand their IRM obligations, including extensive efforts that have been undertaken by the registrants individually, as well as coordinated efforts among the registrants and other stakeholders, such as the National Corn Growers Association (NCGA) and cooperative extension services. Grower Agreements. In order to obtain access to Bt corn technology, growers are required to sign stewardship agreements to comply with all applicable IRM requirements. Annual Affirmation. Growers purchasing Bt corn products must annually affirm their contractual obligation to comply with the IRM requirements. The IRM requirements in the terms and conditions of registrations for Bt corn events issued by EPA in October, 2001, are as follows: A Bt grower must plant at least a 20 percent (20%) non-Bt corn refuge, except in certain cotton growing areas where at least a 50 percent (50%) non-Bt corn refuge is required. Refuge planting options include: blocks within fields; strips across the field at least four rows wide (preferably six rows wide); or as separate fields. Bt corn fields must be planted within ½ mile (preferably ¼ mile) of a refuge. For additional information on the IRM Compliance Assurance Program, go to www.ncga.com. To discuss the program with an official from the EPA, please contact David Deegan at (202) 564-7839.