control lepidopteran pests have less than 60% molecular similarity to the toxin which is active against Colorado potato beetle (Feitelson et al. 1992). This beetle-active toxin has only been used in spray form since the mid-1980s on limited acreage of potatoes. Also, the sprayed beetle toxin is not applied to the tuber; whereas, in the transgenic potato varieties, it is present in the tuber (Rogan et al. 1993).

As indicated in section 2.6, field studies that compared the biodiversity of insects in fields with transgenic pest-protected potatoes and in fields with nontransgenic potatoes treated with synthetic insecticides found higher densities of above ground beneficial arthropods in the transgenic Bt fields. USDA referred to the findings in its positive response to Monsanto 's request for nonregulated status of transgenic Bt potato (USDA 1995a). EPA's pesticide fact sheet for Bt potatoes (EPA 1995a) did not refer to those field data but concluded that no negative ecological effects of Bt potatoes were expected on the basis of a series of laboratory tests conducted by Monsanto (for example, Sims 1993; Keck and Sims 1993).

Details of methods and results of the laboratory tests were voluntarily provided to the committee by Monsanto. Examination of this information indicated that most of the procedures and conclusions were valid. However, in some cases, the approach to testing seemed inefficient. For example, tests for nontarget effects on honeybee larvae used a bioassay in which 5 uL of a Bt-toxin solution was pipetted into the bottom of larval cells and observations for potential mortality were made (Maggi 1993b); this approach would be better for a contact toxin than for toxins such as Bt toxin, which must be ingested. In the tests for adult honeybees (Maggi 1993a), the amount ingested was estimated by weighing the solution before and after presentation to honeybees and controlling for evaporative loss; however in the larval study (Maggi 1993b) the amount ingested was not estimated and it is unclear how much of the solution was consumed by the larvae. A positive control (that is, a group of larvae presented with a solution that will definitely kill them) was not mentioned in the study provided to the committee.

For some other tests, the absence of information made interpretation of results less clear. For example, tests with ladybird beetles used adults and provided the Bt toxin in a honey solution (Hoxter and Smith 1993). Consumption was measured by comparing the weight of the test diet before and after presentation to the beetles. However, the measurement of consumption was not useful, because there was no control for evaporative loss. Without knowledge of the amount consumed, it would be better to gather data on egg production which is more sensitive to stress. Tests of larval ladybird beetles would also offer a more sensitive toxicity test for Bt.

The ladybird beetle test and other tests for EPA used Bt toxin produced by bacteria instead of plants. In some of the nontarget testing, that



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