Farm Progress

Corn growers found to be out of compliance with refuge requirements will be checked more frequently by the Bt corn registrants and have a higher probability of losing access to Bt corn if compliance is not established and maintained. 

February 9, 2012

4 Min Read


As planting for the 2012 season approaches, the National Corn Growers Association notes that newly revamped on-farm refuge assessments are part of the enhanced Compliance Assurance Program (CAP) implemented last year, which is designed to improve compliance with Insect Resistance Management (IRM) requirements. Corn growers found to be out of compliance with refuge requirements will be checked more frequently by the Bt corn registrants and have a higher probability of losing access to Bt corn if compliance is not established and maintained.  

The Agricultural Biotechnology Stewardship Technical Committee (ABSTC), a consortium of Bt corn registrants, submits an annual CAP report to the U.S. Environmental Protection Agency (EPA) describing industry-coordinated compliance assurance efforts for Bt traits. The year’s report is the first following the implementation of the enhanced CAP.

“To implement the CAP, technology providers made some major changes to their procedures last year as directed by EPA,” said Mike Smith, ABSTC IRM subcommittee co-chairman. “One of the changes was the selection process for on-farm assessments. In past years, we’ve randomly selected those participants, but in 2011 we used a more targeted approach and conducted assessments based on purchase history, and, as anticipated, using this methodology resulted in the identification of more non-compliant growers than in years past. Changes were also made to the grower survey and included more Bt corn products with differing refuge requirements.”

The survey results include compliance with refuge requirements for corn borer traits and rootworm traits, either alone or in stacked Bt corn products, regardless of refuge size differences.
Highlights of the report include:

  • The CAP for all Bt corn products with structured refuge requirements continues to be effective.  In 2011, the majority of growers surveyed planted the required refuge size on their farms and the majority of growers surveyed planted a refuge within the required distance for all of their Bt corn fields. Furthermore, the survey indicates that the vast majority of all Bt corn fields have an associated refuge.

  • The majority of growers found out of compliance in 2010 were found to be complying with the IRM requirements during the 2011 growing season. This result is consistent with previous years and confirms that the CAP’s phase compliance approach in which non-compliant growers were provided additional educational materials and re-assessed in 2011 is working.

  • As in previous years, adherence to refuge requirements in the cotton growing region was lower than in the Corn Belt. Factors contributing to lower adherence in the cotton region include larger required refuge size, smaller field sizes, more diverse cropping systems, and greater complexity of operations. The cotton region will receive increased focus for on-farm assessments in 2012. Education programs continue to highlight the specific refuge requirements in the cotton region and, in tandem with the on-farm assessment program, growers have the opportunity to correct individual instances of non-compliance for future growing seasons.

  • As anticipated, targeted on-farm assessments identified more than three times as many corn growers who were out of compliance than in years past. Each member company independently reviewed available sales data for its Bt corn customers and assessments were conducted with growers who, according to the sales records, may have purchased little or no refuge seed. All non-compliant growers will undergo a second on-farm assessment to help ensure compliance in 2012.

“The objective of the on-farm assessment program is to identify individual non-compliant growers and bring them back into compliance through a phased approach,” said Joanne Carden, ABSTC IRM subcommittee co-chairwoman. “The new approach to conducting IRM on-farm assessments has resulted in more non-compliant growers being identified, demonstrating that the enhanced CAP is working as planned.”

Carden added that the ABSTC is pleased with the outcomes from the phased compliance approach. “The goal of these enhancements is to help growers understand the importance of following refuge requirements, provide clarity on how to meet the minimum refuge requirement for each product and ultimately improve compliance,” she said.

IRM Refuge Calculator Helps Growers Develop Plans for Refuge Compliance

“Since the introduction of biotech traits, the vast majority of corn growers have followed refuge requirements to help protect the efficacy of this important technology,” said Chad Blindauer, Chairman of the National Corn Growers Association Trade Policy and Biotechnology Action Team. “All growers must follow these requirements to help preserve the long-term value of this technology. We encourage growers to work with their seed dealers and trait developers to understand the enhanced requirements under the CAP and improve refuge compliance.”

To assist farmers in developing an IRM plan and a refuge strategy for their farms, Blindauer said NCGA has established a number of resources, including recently launching an updated IRM calculator to clarify refuge system options and show growers how to execute the requirements properly.  The IRM calculator was developed in collaboration with ABSTC companies to ensure it reflects all Bt products available in the industry.  Farmers can access the IRM calculator via computer or a smart phone by simply logging on to

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