effects on lacewings or other aboveground beneficial insects (EPA 1997a and 1998a).

It is difficult to reconcile the different findings of the studies conducted for EPA by Monsanto (for Cry1Ac and Cry1Ab toxins) and the studies by Hillbeck and colleagues (Cry1Ab). In the first study by Hilbeck et al. (1998a), lacewings were fed on small larvae of Bt-sensitive and Bt-nonsensitive herbivores that had eaten vegetative-stage Bt or non-Bt corn. The concentration of toxin to which the lacewings were exposed could have been above the 50 parts per million (50 ppm) expected in an ecologically realistic system. A total of 200 lacewings were used per treatment. The second Hillbeck et al. study (1998b) fed larvae purified bacterially-produced Bt at a concentration of 100 ppm in an artificial diet. In the Monsanto studies, the concentration of toxin was 20 ppm and involved coating lepidopteran eggs with bacterially produced toxin (Hoxter and Lynn 1992). In each Monsanto study, 30 lacewings were used per treatment. The Hilbeck et al. (1998a) and Monsanto studies followed larvae to pupation. The Hilbeck studies found more than a 50% increase in mortality; the Monsanto studies found no difference in mortality or lower mortality associated with Bt treatment. Because lacewings typically feed only on the internal content of the eggs, they may not have ingested much of the toxin which was deposited on the shells of the eggs in the Monsanto study. Given that Bt corn is already planted over millions of acres in the United States, it seems appropriate for EPA, USDA, or registrants to sponsor careful field tests to determine whether lacewings or other natural enemies of crop pests are adversely affected by Bt corn. One preliminary study of this type found no differences between Bt and non-Bt corn in effects on any natural enemies of crop pests (Pilcher et al. 1997), but more detailed studies would be useful. Likewise, the committee recommends that

EPA should provide guidelines for determining the most ecologically relevant test organisms and test procedures for assessing nontarget effects in specific cropping systems.

Peer-reviewed studies (for example, MacIntosh et al. 1990) demonstrated that the Bt toxin in corn could affect many lepidopteran species. A laboratory study showed that pollen from some Bt corn cultivars can kill and slow growth of monarch caterpillar larvae if enough pollen is placed on the milkweed leaves fed to the caterpillars (Losey et al. 1999)(see section 2.6.2). If monarchs are indeed being killed in nature by this pollen, the non-Bt corn planted as a refuge for susceptible pest insects could be planted around the edges of corn fields so that adjacent milkweed would be dusted only with pollen from non-Bt corn. It might also be possible to



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