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TESTIMONY July 17, 2001 CHARLES F. CONNER PRESIDENT, CORN REFINERS ASSOCIATION, INC. FIFRA SCIENTIFIC ADVISORY PANEL JULY 17, 2001 Dr. Roberts and members of the panel. I am Charles Conner, president of the Corn Refiners Association, Inc. With me is Clausen Ely, Jr., counsel with Covington & Burling and Dirk Rief of Cargill, Incorporated. The Corn Refiners Association represents the corn wet milling industry of the United States. This industry is the nation's largest industry using yellow corn for production of food and industrial products. Food products produced by members of the Association include corn starch, corn sweeteners, corn oil and food additives produced by fermentation of corn-derived dextrose. The industry uses 1.4 billion bushels of corn, approximately 15 percent of the nation's crop, each year. The Association supports the petition of Aventis CropSciences asking EPA to grant a 20 part per billion tolerance for Cry9C protein in food, subject to the Panel's evaluation of the additional data on processing and exposure you requested at your November 2000 meeting. Such a tolerance would remove the ongoing disruptions in the nation's grain markets and, we believe, be fully protective of public health. The current information developed by Aventis CropSciences shows that the potential level of exposure to Cry9C protein is much less than that discussed at the SAP meeting in November and that exposure through products of wet milling is virtually zero. We would like to specifically comment on question two posed to you by the Agency concerning the impact of corn wet milling on the levels of Cry9C protein in human food products. The Agency has drafted, and now finalized, a white paper on this topic that has been provided to the panel. CRA was pleased to cooperate with the Agency in providing background on corn wet milling processes and products during preparation of this white paper, and comments on the draft. We believe the paper's conclusion is sound. The Agency concluded that it "believes it is reasonable to conclude that there is virtually no Cr9C protein in food products made from the food fractions of corn produced by wet milling." This conclusion is based both on extensive literature concerning the removal of protein from food during corn wet milling as well as the additional data provided by Aventis CropScience in their petition. These conclusions are not surprising, given that the primary purposes of the corn wet milling process is to separate protein from the starch fraction used to make most food products of wet milling. The extensive separation, washing and refining steps involved in starch, sweetener and oil production, and the soluble nature of the Cry9C protein, ensure near total removal in the process. The sole food product from corn wet milling in which minute traces of Cry9C protein might be found is corn starch. The Agency estimated potential daily exposure to Cry9C protein from corn starch in a range of one-hundredth of a microgram to five one-thousandths of a microgram. The milling data submitted by Aventis supports a conclusion that any Cry9C protein found in corn starch would always be below 20ppb. In fact, we believe the 13 ppb estimate of Aventis for starch made from 100% StarLink corn is conservative since the separation of starch and protein in their laboratory systems is not as efficient as in commercial factories. We concur in the Agency's suggestion that, even with this negligible possibility of exposure, it is prudent for corn wet mills that produce food starch to continue to test selected conveyances of inbound corn for Cry9C to minimize the possibility of StarLink corn being delivered to wet millers. Because of the minimal risk of exposure, the extensive testing program operated at dry milling facilities is not appropriate for corn starch facilities, and we have suggested to the Agency that such facilities test ten percent of inbound corn shipments to monitor their grain suppliers' deliveries. We also believe that potential exposure will drop dramatically as the 2001 crop begins to enter the market this fall. As this crop enters the market the low level of StarLink in the grain supply will be further diluted by a factor of approximately 10, and it would be appropriate to re-examine the need for continued testing of inbound grain at that time. Thank you the opportunity and we would be glad to answer any questions the panel may have. For more information on the corn refining industry, visit the Corn Capsules newsletter page. 
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