Coexistence and Market Assurance for Production of Non–Genetically Engineered Alfalfa Hay and Forage in a Biotech Era

Abstract

The introduction of genetically engineered (GE) alfalfa requires a mechanism for producers to successfully grow and market alfalfa ( Medicago sativa L.) hay destined for GE‐sensitive markets such as organic and export. A process of coexistence includes elements of respect for diverse agricultural systems, improved communication, scientific knowledge, and market clarity. A definition for “non‐GE alfalfa forage” is proposed, along with suggested production protocols. These protocols include securing non‐GE‐detect seed, steps to reduce the probability of gene flow in hay fields, equipment sanitation, hay‐lot identification, and hay testing for low‐level presence. The largest risk for low‐level presence in hay is likely to originate from unwanted GE presence in the planting seed. Secondary risks include accidental mixing of hays during harvest or storage, followed by gene flow between forage fields. The tolerance for low‐level presence in non‐GE hay must meet specific market sensitivities. Promoting absolute zero GE hay (e.g., GMO free) is a practical and analytical impossibility, creates difficulties for farmers, and makes no sense for a nontoxic, unwanted market factor. Regulatory‐based tolerances, driven largely by countries that do not permit a GE trait, may require non‐GE determination to a limit of detection of approximately 0.1%. Market‐based tolerance thresholds may differ greatly depending on the sensitivity of markets. For market purposes, a definition of non‐GE alfalfa as having a low‐level presence of less than 0.9% of dry matter is suggested. Coexistence strategies for alfalfa forage require an understanding of the sources of low‐level presence, market tolerances of diverse markets, and market assurance processes.