An ecological risk assessment of Cry1F maize pollen impact to pale grass blue butterfly

The intrinsic toxicity of lepidopteran-active Bt proteins necessitates assessment of non-target risks associated with environmental release of transgenic crops expressing these proteins. Principles of ecological risk assessment provide a means for assessing non-target risks when information regarding exposure to the toxin and species-specific effects are lacking. This is shown for the case of Bt Cry1F maize release in Japan, where off-field pollen dissemination and effect on butterfly species is of concern. The specific ecological entity of concern for the assessment of the non-target impact of Cry1F maize pollen was Yamato-shijimi (pale grass blue butterfly), Pseudozizeeria maha (Kollar), a commonly occurring, susceptible species. Yamato-shijimi is widely adapted in Japan where it occurs in both rural and metropolitan settings, corresponding to the distribution and habitat of katabami (Oxalis corniculata (L.)), the larval host plant. The northern extent of Yamato-shijimi habitat lies to the south of major maize production regions in Japan, but exposure may occur elsewhere where maize and Yamato-shijimi co-occur. Screening level assessment of potential adverse effects to Yamato-shijimi in the field environment considered the probability for spatial-temporal co-occurrence of the life stages of concern (1st and 2nd instars) and the stressor (Cry1F protein expressed in maize pollen) at environmentally relevant concentrations. In the event of exposure to maize pollen, early instars of Yamato-shijimi feed exclusively on the underside of katabami leaves, which further limits the portion of the butterfly population that would be exposed. Projected levels of exposure to Cry1F pollen are below the toxicity level of concern and, thus, indicate negligible risk. Most sensitive species characterization (intergenera sensitivity) similarly shows negligible risk to other Japanese butterfly species of concern when distributed beyond the maize field or field margin