“…Subsequent studies under conditions more relevant to agricultural fields have supported earlier conclusions about the degradation of Cry1Ac with a half life of approximately 9-40 days (Accinelli et al, 2008;Marchetti et al, 2007). In at least one field experiment, Cry1Ac was not detected by ELISA or bioassay in agricultural fields where Cry1Ac expressing cotton (MON-00531-6) had been grown and tilled into soils for three to six consecutive years (Head et al, 2002). Regulatory approvals of Cry1Ac events have considered information on Cry protein rates of degradation in a range of soil types, but have not required additional soil organism toxicity testing for Cry1Ac (CFIA, 1997;CTNBio, 2005;Japan BCH, 1997, 2007OGTR, 2002aOGTR, , 2003bOGTR, , 2003cOGTR, , 2005OGTR, , 2006bUSDA APHIS, 1994, 1997a, 1997b, 1997cUSEPA, 2001).…”