GM CROPS:

Reduced profits

The greater expense of GM seeds and increased herbicide costs can already hit farmers' pockets. Add to these the costs of yield drag and technology fees, and it is bad news for profitability. For example, the added costs for soya producers can be more than 12% of gross income per acre [1]. The Leopold Center for Sustainable Agriculture, Iowa State University, interviewed 800 Iowa farmers in 1998 to determine if growing GM crops was more profitable [5]. Random surveys of 62 continuous cornfields, 315 rotated cornfields, and 365 soya fields concluded that the difference in profitability was non-significant for both crops. Thus, the farmers who raised GM crops did not gain any competitive edge. The first farm-level economic analysis of Bt corn, demonstrates less net profit, lower corn prices, and lost corn exports, questioning whether planting GM corn is worth the cost [18]. From 1996-2001, American farmers paid at least $659 million in price premiums to plant Bt corn,while boosting their harvest by only 276 million bushels -worth $567 million in economic gain. The bottom line for farmers is a net loss of $92 million - about $1.31 per acre. Furthermore, the US has foregone about 350 million bushels of corn export sales to the European Union since 1996/97 because the EU doesn't want GMOs. This is thus part of a triple negative for farmers - lost corn exports, lower corn prices and less net profit from Bt corn. In addition, while transgenic cotton varieties may make pest control easier, they are not always worth the added expense when it comes to yield and fibre quality. Research by the University of Arkansas shows that many conventionals are the highest yielding varieties [19].Comparing the economics of a Bollgard/Roundup Ready variety with a conventional variety, "in a year when insect pressure was low the farmer spent about $10 an acre less for insect control with the conventional variety than he did with the more expensive stacked gene variety". And can we put a price tag on the environment? While, research points to the popularity of GM crops with many North American farmers because of their "convenience", a University of Nebraska report shows that farmers are using the technology to needlessly destroy weeds to get a "weed-free" field [2]. The study demonstrates not only reduced profits, but also destruction of biodiversity.

Lessons from the South

We would do well to draw on the experiences of farmers in the South.The viability of non-GM alternatives has been demonstrated in a review of 208 projects/initiatives from 52 countries, adopted by 8.98 million farmers on 29 million hectares of land in Asia, Africa, and Latin America [20]. Using a range of sustainable agriculture technologies -none of which involved GM - farmers have achieved yield increases of 50-100% for rainfed agriculture, and 5-10% for irrigated crops. Low-tech innovations by Southern farmers have boosted production [21].For example, in East Africa, corn faces two major pests - stem borer and Striga, a parasitic plant. By planting a local weed (napier grass) that the stem borer prefers, pests are lured away from the corn into a honey trap - the grass produces a sticky substance that kills stem borer larvae. By planting another weed, Desmodium, between rows of corn,Striga won't grow, as it is adverse to Desmodium. Pesticides are replaced by natural predators, and fertilisers by natural dung, crop wastes and plants that fix nitrogen from the air. What's more, going organic, entailing a restriction in the use of synthetic fertilisers and pesticides while excluding GM technology, could be more beneficial for the economies of developing countries. The FAO has recently urged poor nations to boost exports of organic produce to take advantage of booming markets in developed countries [22]. Sustainable agriculture and organic farming are not a panacea. They however offer alternative approaches to GM technology that have been demonstrated to provide increased yields and more income, while remaining environmentally friendly. No myths about that.

References

[1]Benbrook, C.M. (1999) Evidence of the magnitude and consequences of the Roundup Ready soybean yield drag from university-based varietal trials in 1998, Ag BioTech InfoNet Technical Paper Number 1,

http://www.biotech-info.net/RR_yield_drag_98.pdf

[2]University of Nebraska (2000) Research shows Roundup Ready soybeans yield less, IANR News Service,

http://www.biotech-info.net/Roundup_soybeans_yield_less.html

[3]See Griffiths, M. (1999) The emperor's transgenic clothes; Are GMO lemmings in the US leading all of us over the biotechnology cliff?

http://www.btinternet.com/~nlpwessex/Documents/gmlemmings.htm

[4]See www.btinternet.com/~nlpwessex/Documents/wisconsinRRsoyatrials98.htm [5]Duffy, M. (1999) 1998 crop survey shows equal returns for GMO,non-GMO crops, http://www.leopold.iastate.edu/news/9-22-99gmorel.html

[6]Oplinger, E.S., M.J. Martinka, and K.A. Schmitz (1999) Performance of transgenetic soybeans - Northern US, presented to
the ASTA Meetings,Chicago, cited in [8].
[7]Reported in Farmers Weekly (UK), 4th December 1998.
[8]Clark, E.A. (1999) '10 reasons why farmers should think twice before growing GE crops,

http://www.plant.uoguelph.ca/faculty/eclark/10reasons.htm

[9]Benbrook, C.M. (2001) Troubled times amid commercial success for Roundup Ready soybeans: glyphosate efficacy is slipping and unstable transgene expression erodes plant defenses and yields, Ag BioTech InfoNet Technical Paper Number 4,

http://www.biotech-info.net/troubledtimes.html

[10]'Economist: Biotech has not made impact yet', Farm Progress, 21 November 2000. [11]See the Jakarta Post.com, Pests attack genetically modified cotton,29 June 2001,

http://www.thejakartapost.com/yesterdaydetail.asp?fileid=20010629.A06

[12]See http://www.biotech-info.net/Aussie_bt_cotton_problems.html [13]Resistance management plan for INGARD Cotton 2001-2002, Transgenic and Insect Management Strategy (TIMS) Committee of the Australian Cotton Growers Research Association,

http://www.cotton.pi.csiro.au/Publicat/Pest/IRMS/irms0102.htm

[14]See Thalmann, P. & V. Kung (2000) No reduction of pesticides use with genetically engineered cotton, for WWF International, http://www.biotech-info.net/WWF_inter_update.pdf ; and Thalmann, P. & V.Kung (2000) Transgenic cotton: Are there

benefits for conservation? A case study of GMOs in agriculture, with special emphasis on freshwater

http://www.panda.org/resources/publications/water/cotton/transgenic.html

[15]Benbrook, C.M. (2001) Do GM crops mean less pesticide use?,Pesticide Outlook, October 2001.
[16]Hall, L.M., J. Huffman, and K. Topinka (2000), Pollen flow between herbicide tolerant canola (Brassica napus), Weed
Science Society of America Abstracts 40: 48,

http://www.mindfully.org/GE/Multiple-Resistant-Volunteers.htm

[17]Westwood, J. (2001) Cross-pollination leads to triple herbicide resistance, ISB News Report [extract only] March 2001, covering Agricultural and Environmental Biotechnology Developments,

http://www.biotech-info.net/cross_pollination2.html

[18]See Benbrook, C.M. (2001) When does it pay to plant Bt corn:farm-level economic impacts of Bt corn, 1996-2001 http://www.gefoodalert.org/library/admin/uploadedfiles/When_Does_It_Pay_To_Plant_Bt_Corn.pdf">www.gefoodalert.org/ library/admin/uploadedfiles/When_Does_It_Pay_To_Plant_Bt_Corn.pdf</A> or http://www.biotech-info.net/Bt_corn_FF_final.pdf; press release from the Institute of Agriculture and Trade Policy (IATP), http://www.gefoodalert.org/library/admin/uploadedfiles/Benbrook_Bt_Press_Release.doc

[19]See Conventional vs. transgenic cotton, edited by AgWeb.com Editors,12/3/2001,

http://www.agweb.com/news_show_news_article.asp?articleID=81926&newscat=GN

[20]Pretty, J. and R. Hine (2001) Reducing food poverty with sustainable agriculture: a summary of new evidence, Occasional Paper 2001-2, Centre for Environment and Society, University of Essex,

http://www2.essex.ac.uk/ces/ResearchProgrammes/CESOccasionalPapers/SAFErepSUBHEADS.htm

[21]Pearce, F. (2001) An ordinary miracle, New Scientist, Vol. 169,Issue 2276, p. 16, 3 February 2001.

[22]Brough, D. (2001) FAO urges poor nations to boost organic food sales, Reuters, 4 December 2001,

http://www.planetark.org/dailynewsstory.cfm/newsid/13562/story.htm

The Institute of Science in Society. PO Box 32097, London NW1 OXR Telephone: 44-20-8731-7714 44-20-7383-3376 44-20-7272-5636

ISIS WEBSITE MATERIAL MAY BE REPRODUCED IN ANY FORM WITHOUT PERMISSION, ON CONDITION THAT IT IS ACCREDITED ACCORDINGLY AND CONTAINS A LINK TO:

http://www.i-sis.org/

Open Letter from World Scientists to All Governments 1.9.2000

(see http://www.i-sis.org/)

Summary

We, the undersigned scientists, call for the immediate suspension of all environmental releases of GM crops and products, both commercially and in open field trials, for at least 5 years; for patents on living processes, organisms, seeds, cell lines and genes to be revoked and banned; and for a comprehensive public enquiry into the future of agriculture and food security for all.

Patents on life-forms and living processes should be banned because they threaten food security, sanction biopiracy of indigenous knowledge and genetic resources, violate basic human rights and dignity, compromise healthcare, impede medical and scientific research and are against the welfare of animals. GM crops offer no benefits to farmers or consumers. Instead, many problems have been identified, including yield drag, increased herbicide use, erratic performance, and poor economic returns to farmers. GM crops also intensify corporate monopoly on food, which is driving family farmers to destitution, and preventing the essential shift to sustainable agriculture that can guarantee food security and health around the world. The hazards of GMOs to biodiversity and human and animal health are now acknowledged by sources within the UK and US Governments. Particularly serious consequences are associated with the potential for horizontal gene transfer. These include the spread of antibiotic resistance marker genes that would render infectious diseases untreatable, the generation of new viruses and bacteria that cause diseases, and harmful mutations which may lead to cancer. In the Cartegena Biosafety Protocol negotiated in Montreal in January 2000, more than 130 governments have pledged to implement the precautionary principle and to ensure that biosafety legislations at the national and international levels take precedence over trade and financial agreements at the World Trade Organization. Successive studies have documented the productivity and the social and environmental benefits of sustainable, low-input and organic farming in both North and South. They offer the only practical way of restoring agricultural land degraded by conventional agronomic practices, and empower small family farmers to combat poverty and hunger.

We urge the US Congress to reject GM crops as both hazardous and contrary to the interest of family farmers; and to support research and development of sustainable agricultural methods that can truly benefit family farmers all over the world. We, the undersigned scientists, call for the immediate suspension of all environmental releases of GM crops and products, both commercially and in open field trials, for at least 5 years; for patents on living processes, organisms, seeds, cell lines and genes to be revoked and banned; and for a comprehensive public enquiry into the future of agriculture and food security for all.

1 Patents on life-forms and living processes should be banned because they threaten food security, sanction biopiracy of indigenous knowledge and genetic resources, violate basic human rights and dignity, compromise healthcare, impede medical and scientific research and are against the welfare of animals(1). Life-forms such as organisms, seeds, cell lines and genes are discoveries and hence not patentable. Current GM techniques which exploit living processes are unreliable, uncontrollable and unpredictable, and do not qualify as inventions. Furthermore, those techniques are inherently unsafe, as are many GM organisms and products.

2. It is becoming increasingly clear that current GM crops are neither needed nor beneficial. They are a dangerous diversion preventing the essential shift to sustainable agricultural practices that can provide food security and health around the world.

3. Two simple characteristics account for the nearly 40 million hectares of GM crops planted in 1999(2). The majority (71%) are tolerant to broad-spectrum herbicides, with companies engineering plants to be tolerant to their own brand of herbicide, while most of the rest are engineered with bt-toxins to kill insect pests. A university-based survey of 8200 field trials of the most widely grown GM crops, herbicide-tolerant soya beans - revealed that they yield 6.7% less and required two to five times more herbicides than non-GM varieties(3). This has been confirmed by a more recent study in the University of Nebraska(4). Yet other problems have been identified: erratic performance, disease susceptibility(5), fruit abortion(6) and poor economic returns to farmers(7).

4. According to the UN food programme, there is enough food to feed the world one and a half times over. While world population has grown 90% in the past 40 years, the amount of food per capita has increased by 25%, yet one billion are hungry(8). A new FAO report confirms that there will be enough or more than enough food to meet global demands without taking into account any yield improvementsthat might result from GM crops well into 2030 (9). It is on account of increasing corporate monopoly operating under the globalised economy that the poor are getting poorer and hungrier(10). Family farmers around the world have been driven to destitution and suicide, and for the same reasons. Between 1993 and 1997 the number of mid-sized farms in the US dropped by 74,440(11), and farmers are now receiving below the average cost of production for their produce(12). The farming population in France and Germany fell by 50% since 1978(13). In the UK, 20 000 farming jobs were lost in the past year alone, and the Prime Minister has announced a £200m aid package(14). Four corporations control 85% of the world trade in cereals at the end of 1999(15). Mergers and acquisitions are continuing.

5. The new patents on seeds intensify corporate monopoly by preventing farmers from saving and replanting seeds, which is what most farmers still do in the Third World. In order to protect their patents, corporations are continuing to develop terminator technologies that genetic engineer harvested seeds not to germinate, despite worldwide opposition from farmers and civil society at large(16).

6. Christian Aid, a major charity working with the Third World, concluded that GM crops will cause unemployment, exacerbate Third World debt, threaten sustainable farming systems and damage the environment. It predicts famine for the poorest countries(17). African Governments condemned Monsanto's claim that GMOs are needed to feed the hungry of the world: "We..strongly object that the image of the poor and hungry from our countries is being used by giant multinational corporations to push a technology that is neither safe, environmentally friendly, nor economically beneficial to us… we believe it will destroy the diversity, the local knowledge and the sustainable agricultural systems that our farmers have developed for millennia and … undermine our capacity to feed ourselves.(18)" A message from the Peasant movement of the Philippines to the Organization for Economic Cooperation and Development (OECD) of the industrialized countries stated, "The entry of GMOs will certainly intensify landlessness, hunger and injustice.(19)"

7. A coalition of family farming groups in the US have issued a comprehensive list of demands, including ban on ownership of all life-forms; suspension of sales, environmental releases and further approvals of all GM crops and products pending an independent, comprehensive assessment of the social, environmental, health and economic impacts; and for corporations to be made liable for all damages arising from GM crops and products to livestock, human beings and the environment(20). They also demand a moratorium on all corporate mergers and acquisitions, on farm closures, and an end to policies that serve big agribusiness interests at the expense of family farmers, taxpayers and the environment(21). They have mounted a lawsuit against Monsanto and nine other corporations for monopolistic practices and for foisting GM crops on farmers without adequate safety and environmental impact assessments(22).

8. Some of the hazards of GM crops are openly acknowledged by the UK and US Governments. UK Ministry of Agriculture, Fisheries and Food (MAFF) has admitted that the transfer of GM crops and pollen beyond the planted fields is unavoidable(23), and this has already resulted in herbicide-tolerant weeds(24). An interim report on UK Government-sponsored field trials confirmed hybridisation between adjacent plots of different herbicide tolerant GM oilseed rape varieties, which gave rise to hybrids tolerant to multiple herbicides. In addition, GM oilseed rape and their hybrids were found as volunteers in subsequent wheat and barley crops, which had to be controlled by standard herbicides(25). Bt-resistant insect pests have evolved in response to the continuous presence of the toxins in GM plants throughout the growing season, and the US Environment Protection Agency is recommending farmers to plant up to 40% non-GM crops in order to create refugia for non-resistant insect pests(26).

9. The threats to biodiversity from major GM crops already commercialized are becoming increasingly clear. The broad-spectrum herbicides used with herbicide-tolerant GM crops decimate wild plant species indiscriminately, they are also toxic to animals. Glufosinate causes birth defects in mammals(27), and glyphosate is linked to non-Hodgkin lymphoma(28). GM crops with bt-toxins kill beneficial insects such as bees(29) and lacewings(30), and pollen from bt-corn is found to be lethal to monarch butterflies(31) as well as swallowtails(32). Bt-toxin is exuded from roots of bt-plants in the rhizosphere, where it rapidly binds to soil particles and become protected from degradation. As the toxin is present in an activated, non-selective form, both target and non-target species in the soil will be affected(33), with knock on effects on species above ground.

10. Products resulting from genetically modified organisms can also be hazardous. For example, a batch of tryptophan produced by GM microorganisms was associated with at least 37 deaths and 1500 serious illnesses (34). Genetically modified Bovine Growth Hormone, injected into cows in order to increase milk yield, not only causes excessive suffering and illnesses for the cows but increases IGF-1 in the milk, which is linked to breast and prostate cancers in humans(35). It is vital for the public to be protected from all GM products, and not only those containing transgenic DNA or protein. That is because the process of genetic modification itself, at least in the form currently practised, is inherently unsafe.

11. Secret memoranda of US Food and Drug Administration revealed that it ignored the warnings of its own scientists that genetic engineering is a new departure and introduces new risks. Furthermore, the first GM crop to be commercialized - the Flavr Savr tomato - did not pass the required toxicological tests(36). Since then, no comprehensive scientific safety testing had been done until Dr. Arpad Pusztai and his collaborators in the UK raised serious concerns over the safety of the GM potatoes they were testing. They conclude that a significant part of the toxic effect may be due to the "[gene] construct or the genetic transformation (or both)" used in making the GM plants(37).

12. The safety of GM foods was openly disputed by Professor Bevan Moseley, molecular geneticist and current Chair of the Working Group on Novel Foods in the European Union's Scientific Committee on Food(38). He drew attention to unforseen effects inherent to the technology, emphasizing that the next generation of GM foods - the so-called 'neutraceuticals' or 'functional foods', such as vitamin A 'enriched' rice - will pose even greater health risks because of the increased complexity of the gene constructs.

13. Genetic engineering introduces new genes and new combinations of genetic material constructed in the laboratory into crops, livestock and microorganisms(39). The artificial constructs are derived from the genetic material of pathogenic viruses and other genetic parasites, as well as bacteria and other organisms, and include genes coding for antibiotic resistance. The constructs are designed to break down species barriers and to overcome mechanisms that prevent foreign genetic material from inserting into genomes. Most of them have never existed in nature in the course of billions of years of evolution.

14. These constructs are introduced into cells by invasive methods that lead to random insertion of the foreign genes into the genomes (the totality of all the genetic material of a cell or organism). This gives rise to unpredictable, random effects, including gross abnormalities in animals and unexpected toxins and allergens in food crops.

15. One construct common to practically all GM crops already commercialized or undergoing field trials involves a gene-switch (promoter) from the cauliflower mosaic virus (CaMV) spliced next to the foreign gene (transgene) to make it over-express continuously(40). This CaMV promoter is active in all plants, in yeast, algae and E. coli. We recently discovered that it is even active in amphibian egg(41) and human cell extract(42). It has a modular structure, and is interchangeable, in part, or in whole with promoters of other viruses to give infectious viruses. It also has a 'recombination hotspot' where it is prone to break and join up with other genetic material(43).

16. For these and other reasons, transgenic DNA - the totality of artificial constructs transferred into the GMO -may be more unstable and prone to transfer again to unrelated species; potentially to all species interacting with the GMO(44).

17. The instability of transgenic DNA in GM plants is well-known(45). GM genes are often silenced, but loss of part or all of the transgenic DNA also occurs, even during later generations of propagation(46). We are aware of no published evidence for the long term stability of GM inserts in terms of structure or location in the plant genome in any of the GM lines already commercialized or undergoing field trials.

18. The potential hazards of horizontal transfer of GM genes include the spread of antibiotic resistance genes to pathogens, the generation of new viruses and bacteria that cause disease and mutations due to the random insertion of foreign DNA, some of which may lead to cancer in mammalian cells(47). The ability of the CaMV promoter to function in all species including human beings is particularly relevant to the potential hazards of horizontal gene transfer.

19. The possibility for naked or free DNA to be taken up by mammalian cells is explicitly mentioned in the US Food and Drug Administration (FDA) draft guidance to industry on antibiotic resistance marker genes(48). In commenting on the FDA's document, the UK MAFF pointed out that transgenic DNA may be transferred not just by ingestion, but by contact with plant dust and air-borne pollen during farm work and food processing(49). This warning is all the more significant with the recent report from Jena University in Germany that field experiments indicated GM genes may have transferred via GM pollen to the bacteria and yeasts in the gut of bee larvae(50).

20. Plant DNA is not readily degraded during most commercial food processing(51). Procedures such as grinding and milling left grain DNA largely intact, as did heat-treatment at 90deg.C. Plants placed in silage showed little degradation of DNA, and a special UK MAFF report advises against using GM plants or plant waste in animal feed.

21. The human mouth contains bacteria that have been shown to take up and express naked DNA containing antibiotic resistance genes, and similar transformable bacteria are present in the respiratory tracts(52).

22. Antibiotic resistance marker genes from GM plants have been found to transfer horizontally to soil bacteria and fungi in the laboratory(53). Field monitoring revealed that GM sugar beet DNA persisted in the soil for up to two years after the GM crop was planted. And there is evidence suggesting that parts of the transgenic DNA have transferred horizontally to bacteria in the soil(54).

23. Recent research in gene therapy and nucleic acid (both DNA and RNA) vaccines leaves little doubt that naked/free nucleic acids can be taken up, and in some cases, incorporated into the genome of all mammalian cells including those of human beings. Adverse effects already observed include acute toxic shock, delayed immunological reactions and autoimmune reactions(55).

24. The British Medical Association, in their interim report (published May, 1999), called for an indefinite moratorium on the releases of GMOs pending further research on new allergies, the spread of antibiotic resistance genes and the effects of transgenic DNA.

25. In the Cartegena Biosafety Protocol successfully negotiated in Montreal in January, 2000, more than 130 governments have agreed to implement the precautionary principle, and to ensure that biosafety legislations at the national and international levels take precedence over trade and financial agreements at the WTO. Similarly, delegates to the Codex Alimentarius Commission Conference in Chiba Japan, March 2000, have agreed to prepare stringent regulatory procedures for GM foods that include pre-market evaluation, long-term monitoring for health impacts, tests for genetic stability, toxins, allergens and other unintended effects(56). The Cartegena Biosafety Protocol has now been signed by 68 Governments in Nairobi in May, 2000.

26. We urge all Governments to take proper account of the now substantial scientific evidence of actual and suspected hazards arising from GM technology and many of its products, and to impose an immediate moratorium on further environmental releases, including open field trials, in accordance with the precautionary principle as well as sound science.

27. Successive studies have documented the productivity and sustainability of family farming in the Third World as well as in the North(57). Evidence from both North and South indicates that small farms are more productive, more efficient and contribute more to economic development than large farms. Small farmers also tend to make better stewards of natural resources, conserving biodiversity and safeguarding the sustainability of agricultural production(58). Cuba responded to the economic crisis precipitated by the break up of the Soviet Bloc in 1989 by converting from conventional large scale, high input monoculture to small organic and semi-organic farming, thereby doubling food production with half the previous input(59).

28. Agroecological approaches hold great promise for sustainable agriculture in developing countries, in combining local farming knowledge and techniques adjusted to local conditions with contemporary western scientific knowledge(60). The yields have doubled and tripled and are still increasing. An estimated 12.5 million hectares worldwide are already successfully farmed in this way(61). It is environmentally sound and affordable for small farmers. It recovers farming land marginalized by conventional intensive agriculture. It offers the only practical way of restoring agricultural land degraded by conventional agronomic practices. Most of all, it empowers small family farmers to combat poverty and hunger.

29. We urge all Governments to reject GM crops on grounds that they are both hazardous and contrary to ecologically sustainable use of resources. Instead they should support research and development of sustainable agricultural methods that can truly benefit family farmers the world over.

For references (the figures in brackets) and scientists names see web site: http://www.i-sis.org/

Glyphosate resistance is showing a worldwide rise

Farmers Weekly 23 November 2001

New Products, new advice and new problems were debated in detail at last week's International "Weeds Conference" staged by the British Crop Protection Council in Brighton. Over the following four pages Charles Abel, Andrew Blake and Andrew Swallow report the highlights. Resistance to glyphosate (Roundup) is emerging all around the world, potentially jeopardising the 2.5 billion dollar market for genetically modified herbicide tolerant crops. The latest discovery is glyphosate resistant ryegrass in South African vineyards where growers have used Roundup for 23 years.

"Monsanto is very sensitive because half the soya and maize is in GM herbicide tolerant varieties, creating a market worth $2.5b," said Andrew Cairns, of Natal University, Pietermaitzburg.

Resistance has also been found in ryegrass in New South Wales and Western Australia, a grass-weed in Malaysia, a broad-leaved weed in Delaware and ryegrass in California. In one US case, the repeat use of Roundup in GM herbicide tolerant maize has been blamed for the development of resistant weeds.

"I agree with the technology, it's a very good idea," said Prof Cairns. "But they need to have the stewardship in place to prevent this becoming a bigger issue."

Resistance problems are predicted to increase but a simple change in herbicide use should offer a solution, said Michael Owen of Iowa State University. "I don't see that the shifts on establishment of resistant populations is going to be a big issue." Using an alternative mode of action should solve the problem, although the number of new modes of action becoming availableis decreasing, he said.

Over-use of glyphosate by growers is to blame for the rapid development of resistance in common waterhemp and horseweed. One or two applications would often be enough to give economic control, but growers frequently use three or even four applications to keep fields cosmetically clean, said Mr Owen. That puts a strong selection pressure on the weed population. In one case in the eastern corn belt, horseweed became resistant to glyphosate after just three years of growing glyphosate tolerant crops. A desire to show spotlessly clean fields to non-farming landlords adds to the problem, he said.

"Growers do not look at the economics of weed escapes. They view GM crops as an excellent chance to go out late season with the sprayer just to clean the crop up. This aesthetic weed management is a real problem for us."

University researchers find fungi buildup in glyphosate-treated soybean fields

Columbia, Mo. A four-year study by University of Missouri researchers has found that Roundup herbicide applications change the microbial composition of soil in the field. They observed increases in fungi on the roots and in the soil around the roots of soybean plants, with "potential implications in future management."

"Experiments conducted in 1997 through 2000 at two Missouri locations revealed that Roundup Ready soybeans receiving glyphosate at recommended rates had significantly higher incidence of Fusarium on roots within one week of applica-tion compared with soybeans that did not receive glyphosate², reported Pat Donald, MU plant pathologist, and Robert Kremer, an MU soil scientist and USDA Agricultural Research Service microbiologist.

In research plots at MU Delta Research Center in Portageville, Mo., and at MU Bradford Farm near Columbia, the scientists detected major colonization by several distinct types of the fungus in the glyphosate-treated fields. "Although soil Fusarium populations varied among locations, glyphosate significantly increased numbers at each location." "There is a natural ebb and flow, but with Roundup Ready beans treated with Roundup, there was always a spike in the levels of the fungi studied," Kremer said.

Fusarium fungi are almost always found in soybean fields, but at elevated levels some can become pathogenic on susceptible plants and lead to lost yields through such diseases as Osudden death syndrome¹ [SDS] and other root rots, Donald said.

Kremer said studies of ecological impact from transgenic plants should include an analysis of effects on the microbial makeup of the soil. "Right now, that's an ecological assessment that hasn't received much attention. The tests are often limited to small soil insects and earth-worms. We think it's been an oversight." "All of the ecological assessment is above ground," Donald said, adding that such assessments should measure plants' and products' impact on the soil system, "especially if they're going to potentially increase pathogens."

Initially, the researchers believed the increased Fusarium through glyphosate application could provide a biological control for soybean cyst nematode as well as suppressing weed growth. "We thought it might be a double whammy," Donald said. "It didn't work out that way."

She and Kremer emphasized that soybean yields in their experiments were not affected by application of glyphosate as opposed to conventional herbicide treatments. However, "potential yield impacts in subsequent seasons due to high soil Fusarium populations, resulting from continued use of glyphosate, needs further investigation."

Kremer said the study shows the fungi "build up over the growing season. We need to look at it more and see whether there's a buildup of the organism from year to year." He noted that more than half of Missouri soybeans are Roundup Ready. "When you think about it, you have to wonder what's happening in the soil." Donald said soil micro-organisms such as fungi and nematodes have both detri-mental and beneficial associations with crops and the environment. "We need to have all the information that we can."

An abstract of the study can be found at the American Society of Agronomy website:

http://www.asa-cssa-sssa-org/cgi-bin/abstract_database_search.cgi?objective=

Kremer Source: Robert Kremer (573) 882-6408; Pat Donald (573) 882-2716

Bt Corn Linked to Hog Breeding Problems

Submitted by Jim Riddle Rt. 3 Box 162C Winona, MN 55987 May 20, 2002

In its April 29, 2002, edition, the Iowa Farm Bureau Spokesman contained an alarming story on sow breeding problems related to the feeding of genetically engineered Bt corn.

According to the article, Shelby County, Iowa, farmer Jerry Rosman was alarmed when farrowing rates in his sow herd plummeted nearly 80 percent. Rosman, who has nearly 30 years of farrowing experience, checked and double-checked all of the usual suspect causes. He tested for diseases, verified his artificial insemination methods were being properly implemented, and poured over his nutritional program. But he found nothing out of the ordinary.

Eventually, Rosman became aware of four other producers within a 15-mile radius of his farm whose herds had nearly identical pseudopregnancies. The herds had different management styles, different breeding methods and different swine genetics. A common denominator, Rosman says, is that all of the operations fed their herds the same Bt corn hybrids.

Laboratory tests revealed their corn contained high levels of Fusarium mold. Rosman says researchers typed the Fusarium down to four strains, and two of them (Fusarium subglutinans and Fusarium monlliforme) were consistent in all of the producers' samples.

One of the producers subsequently switched back to regular non-Bt corn, and pseudopregnancy is no longer a problem within that herd. Rosman believes the problem manifested itself on his farm because he planted 100 percent of the same brand of genetically engineered Bt seed corn and fed 100 percent of that corn to his livestock. According to the article, Rosman isn't sure whether or not he'll be planting any corn on his land this year. An agronomist has told him that a regular rotation of corn and soybeans might not get rid of whatever gene has contaminated his corn ground.

In a follow up article on May 13, 2002, the Iowa Farm Bureau Spokesman reported that shortly after the story detailing Rosman s situation appeared, he was flooded with phone calls. It hadn t even hit the mailboxes and the phone started ringing, Rosman says.

By late last week he had received calls from 12 other producers from various parts of the state detailing situations very much like his own. The calls primarily came from smaller producers who, like Rosman, feed their own corn and noticed a sharp decline in farrowing rates recently. The Rosman article sparked the interest of Norm Smith, who farms east of Winterset, Iowa. Smith says he started experiencing breeding problems within a few weeks of feeding the new corn hybrids he planted for the first time last spring.

‘I started feeding Bt corn in late September, and within 30 days I wasn’t getting anything bred’, Smith said, adding that his brother encountered similar problems.

The Spokesman articles illustrate the fact that genetically engineered crops have been rushed to market without proper testing. There have been no mandatory tests on the long term effects of these crops on livestock or human health. For example, the EPA, which regulates Bt corn, requires no tests to determine how the crop impacts the reproductive systems of the animals that eat it.

Genetically engineered materials, such as products manufactured from Bt corn, are now commonly found in conventional foods. Due to a political decision made in 1992 by the Bush/Quayle administration, genetically engineered foods are not required to be segregated or labeled. Anyone who eats foods containing conventional corn, soy, canola, and/or cottonseed products is an unwitting guinea pig in a vast, uncharted ecological experiment. From: "Jim Riddle" <jriddle@luminet.net>

Modified Crops Could Lead To "Superweeds," Study Suggests

nationalgeographic.com - January 26, 2002

Genetic engineering holds great potential payoffs for farmers and consumers by making crops resistant to pests, diseases, and even chemicals used to kill surrounding weeds. But new research raises concerns that altering crops to withstand such threats may pose new risks from none other than the weeds themselves.

The threat comes from the weeds' ability to acquire genes from the neighboring agricultural crops. Researchers found that when a weed cross-breeds with a farm-cultivated relative and thus acquires new genetic traits possibly including artificial genes engineered to make the crop hardier the hybrid weed can pass along those traits to future generations.

"The result may be very hardy, hard-to-kill weeds," said Allison Snow, a plant ecologist at Ohio State University in Columbus who conducted the experiments over the past six years along with two colleagues. They presented their results last week at the annual meeting of the Ecological Society of America in Madison, Wisconsin. The findings suggest that genetic engineering done with the aim of improving crops giving them new genetic traits such as resistance to herbicides or pests could ultimately have unintended and harmful consequences for the crops if weeds acquire the same trait and use it to out-compete the crops. "Gene movement from crops to their wild relatives is an ongoing process that can be ultimately harmful to crops," said Snow.

Long-Term Legacy

The scientists conducted the experiments at the University of Michigan Biological Station in Pellston. They used two species of radish: one a common edible radish, the other a wild relative. The wild version is a tenacious weed that reproduces more readily than the crop and can take over agricultural fields if not controlled. The scientists began by cross-breeding the cultivated radishes and the weedy radishes to produce hybrid, weed-like radishes. Then they designed studies to measure and compare the reproductive success and other traits of the hybrid and non-hybrid radishes.

The original crop radishes used to produce the hybrids had not been genetically engineered. But the scientists wanted to monitor the effects of the "borrowed" genes in weed populations over subsequent generations. They did this by selecting several genetic traits in the cultivated radishes, including flower color and fertility, to serve as "markers" indicating thespread of crop genes into the hybrid population.

When the two groups of plants were grown in pots under the same conditions, the non-hybrid radishes had more seeds and reproduced more than the hybrid plants, especially in the first generation of the experiment. Nonetheless, the scientists found that traits acquired from the crop radishes, such as their flower color, showed up in subsequent generations of hybrids. "Even though the effects of delayed flowering and reduced fertility inhibited the movement of certain crop traits to later generations, we did find evidence of crop genes in every generation," Snow said.

A second experiment, conducted in field plots, supported these findings and will be published soon.

Need for Caution

The results of the experiments challenge a common belief that hybrids gradually die out over several generations, Snow explained. "There has been an assumption that [crop] genes wouldn't persist in crop-weed hybrids" because hybrids are thought to be less successful at reproducing, she said. Not so, Snow concluded after reviewing her team's data: Hybrid wild radishes survived in all six generations that were grown since the study began.

Although the genetic traits the scientists monitored were natural and not genetically engineered, the findings nonetheless suggest that artificial improvements introduced into crops through genetic engineering could spread to weeds and become permanent traits of the weed population. So strengthened, the weeds may pose a serious risk to the long-term health of agricultural crops. The danger exists in a number of crop plants including canola, rice, sunflower, sorghum, squash, and carrots that are closely related to weeds with which they compete.

Snow is concerned that the transfer of genes from crops to related weeds could rapidly render many herbicides ineffectual. That situation, she said, would be much like bacterial diseases acquiring resistance to antibiotics. Because plant hybrids arise in a single generation, however, it could happen much more quickly.

"Modern agriculture is heavily dependent on herbicides," she said, "so people will notice when those don't work anymore."

originated: lhopwood@earthlink.net

Announcing the availability of the video: "Genetically Engineered Seeds of Controversy".

This video is a taping of the event, "Genetically Engineered Seeds of Controversy: Biotech Bullies Threaten Farmer and Consumer Rights", held Oct, 10, 2001, in Austin, TX.

The keynote speakers were Jim Hightower, former Texas Agricultural Commissioner, and farmers Percy Schmeiser and Rodney Nelson.

For information about the video and/or to obtain a copy, please email the event organizers at: <info@saynotogmos.org>

Canadian organic farmers sue Monsanto on GM crops

Story Date: 11/1/2002

WINNIPEG, Manitoba - A group of Canadian organic farmers launched a lawsuit against biotech giants Monsanto Co. and Aventis SA on Thursday seeking compensation for damages caused by genetically modified canola they say is blowing into their fields. "Organic farmers in Saskatchewan have said that the time has come for this legal challenge and we're here today to let the world know that," Marc Loiselle, a board member of the Saskatchewan Organic Directorate (SOD), a group representing organic producers in the province, told a news conference. "We claim that the two companies, Monsanto and Aventis, are responsible for GE (genetically engineered) contamination on multiple grounds and we're confident that this will be proven in the court of law," Loiselle told reporters in Saskatoon. Two organic farmers filed the class action lawsuit in Saskatoon court on behalf of all organic farmers in the province, the heart of Canada's bread basket. The legal action is also aimed at halting plans to introduce transgenic wheat in the region. There are about 1,000 organic growers in Saskatchewan, whose farms represent about 1 million acres (405,700 hectares). SOD alleges that genetically engineered crops threaten the environment and their industry. "Any kind of science, whatever it is, if it's infringing on our rights, they don't have a right to do it, said Arnold Taylor, an organic grower and president of SOD. The amount of compensation being sought has yet to be determined, but Taylor estimates it will be "in the millions." Organizations that certify crops as organic have zero tolerance for genetically modified organisms (GMOs) in the seed supply. They also prohibit organic farmers from applying most crop chemicals. Instead, organic farmers rely on crop rotation, which includes the staggered planting of canola and wheat, to control weeds. SWITCH TO TRANSGENIC CANOLA Many farmers across Western Canada have switched to transgenic canola since GM varieties were introduced in Canada in the mid 1990s, citing better weed control and yields. Today, about 60 percent of the canola grown in Saskatchewan is genetically modified to resist weeds. Canola, the Canadian variant of rapeseed, is used mainly to produce processed food ingredients, cooking oils, and livestock feed. Canada is the world's largest canola exporter. Organic producers say that pollen from GM canola, which is patented by Monsanto and Aventis, is blowing on to their fields, contaminating their crops and their seed supply, and driving away premium-paying customers, most of whom are in Europe. "They're trying to make these companies pay for their losses that were sustained by them from having removed a crop, an entire crop from their selection of crops," Terry Zakreski, the farmers' lawyer told Reuters, noting that this is believed to be the first lawsuit of its kind in Canada. "They want to stop them from introducing another crop that could economically destroy them if it's allowed to happen," said Zakreski. Agricultural sciences company, Monsanto, which produces Roundup Ready canola, one of the most widely grown GM varieties, has recently conducted field trials across Western Canada to develop genetically modified Roundup Ready wheat. The plants are genetically modified to be unaffected when the herbicide Roundup in used on the fields to control weeds. "To me it's just a matter of continuing to give farmers choice in terms of what they grow. And farmers make choices whether they grow organic or conventional or transgenic, and they make those choices based on what works for them on their farm," said Monsanto Canada spokeswoman Trish Jordan. Monsanto has said that it will not commercially release GM wheat until concerns about segregation and market acceptance are addressed. SOD announced its intention to sue the biotech companies last year, but said new legislation in Saskatchewan permitting class action lawsuits paved the way for Thursday's announcement.

Story by Kanina Holmes
Story Date: 11/1/2002
national farmers union (of Canada) in union is strength

NFU Policy on Genetically Modified (GM) Foods Preamble

The NFU believes that all Canadians--farmers and non-farmers alike--must engage in an informed debate on the genetic modification of food. Citizens must examine genetically modified (GM) food in the largest possible social, historical, environmental, economic, and ethical context. After that debate, citizens--not the corporations that promote these products--must decide whether to accept or reject GM food. Squeezed by falling incomes, farmers look to technologies that claim higher returns or reduced costs. Over the past decades, however, farmers have embraced a wide range of technologies, only to watch net farm incomes fall. Between 1974 and 2000, gross farm income tripled. Net farm income, however, fell. Input suppliers were able to capture 100% of farmers' increased gross returns. Because fertilizers, chemicals, and other technologies failed to fulfill their promises of farm profitability, many farmers rightly question the economic benefits of genetically modifying crops and livestock. While the benefits are questionable, risks and costs are real. Consumers are rejecting GM foods. Markets in Europe, Japan, and elsewhere are closing and domestic markets are likewise threatened. This is driving prices down. Closing markets and falling prices threaten to overwhelm any small, short-term economic benefits that GM crops or livestock may offer. Further, the proliferation of some GM crops has effectively deprived many organic farmers of the option to grow those crops. Further, GM seeds and livestock give corporations increased control over family farms. Any initial economic benefits will be quickly outweighed as farmers are drawn further under corporate control. More than any previous technology--such as fertilizers or tractors--patented seeds sold through contract and multi-page technology use agreements clearly erode farmers' autonomy. Turning to human health, there has not been a systematic, scientific investigation of the health effects of GM foods. The unscientific assumption of "substantial equivalence" is insufficient reason to forgo comprehensive, independent health testing. There are also many unanswered questions about the environmental risks of GM crops and livestock. Genetic modification threatens to unbalance the biosphere, create "super-weeds," endanger beneficial insects, and erode bio-diversity. Bio-diversity is a vital source of raw materials for agriculture and an essential component of environmental well-being. The NFU policy on GM foods recognizes that almost all of the questions surrounding this technology remain unanswered. The policy attempts to introduce precaution and prudence into a process of GM food proliferation driven by profit. Because this technology has the potential to threaten the environment, human health, and the economic wellbeing of farmers, Canadians should debate and study before we plant and eat.

General policy and action plan

1. The federal government must impose a moratorium on the production, importation, distribution, and sale of GM food until questions regarding consumer acceptance, human health, environmental implications, technology ownership, and farmer profitability are answered to the satisfaction of the majority of Canadians.

2. Until the federal government respects the wishes of the people and introduces a moratorium, the following interim measures will help protect farmers and other citizens.

Ownership and control of GM food technology

3. All genetic resources and GM technology must be subject to democratic control, collective ownership, and not-for-profit distribution.

4. Citizens through their governments, not corporations, must control genetic research and the development of GM products.

5. Public money directed to agricultural research must serve the interests of Canadians. Such money must be spent on research into sustainable systems of agriculture which improve the nutrition and safety of food, the health of the environment, and the incomes of farmers.

6. "Terminator", "Traitor", and similar Genetic Use Restriction technologies, along with the WTO's Trade-Related Intellectual Property Rights (TRIPs) agreement, restrict farmers' right to save, trade, and reuse seed. Thus, they are unacceptable.

7. Canada must work to end the export of GM foods and seeds to countries which lack adequate regulation, safety, and inspection regimes to deal with such imports.

Genetic Pollution

8. It is unreasonable to allow genetic modification companies to privately reap profits and not require that they also assume all costs. Genetic pollution is one such cost. Companies producing genetically modified seeds admit that some plants can "outcross" in an uncontrolled fashion. Genetic pollution seriously erodes the incomes of organic farmers and those who do not use GM seeds. Government must hold genetic modification companies accountable for the costs their products create for other farmers and the general public.

9. The federal government must compel companies which own patents on GM seeds or livestock to set up contingency funds to compensate for product liability and legislate efficient and accessible mechanisms to enable liability claims to be effectively pursued.

Markets and consumer acceptance

10. Food products which contain GM ingredients must be subject to clear, consistent, mandatory labelling.

11. Labelling, information, and ready access to alternatives are the three essential elements of consumers' right to choose. Consumers and farmers must have access to non-GM food alternatives.

12. The federal government must establish and enforce strict and effective segregation programs for cropping, transportation, storage, and marketing of GM crops.

13. No GM crops, livestock, or food products should be licensed or introduced until major domestic and international customers have indicated their acceptance.

Health effects

14. Food--genetically-modified and non-modified alike--must be adequately tested, regulated, and inspected. These critical tasks must be performed by a sufficient number of adequately-funded, independent, publicly-paid inspectors.

15. Independent scientists at publicly-funded and operated labs under the jurisdiction of the Federal Minister of Health must conduct exhaustive long-term human health testing on GM foods. The assumption that GM foods are "substantially equivalent" to their non-GM analogs is unproven.

16. The Precautionary Principle must be the basis for assessing the human health effects of GM food. Where human health and safety are concerned, mere "risk assessment" is not acceptable.

Environmental effects

17. Prior to environmental release, GM seeds, animals, and organisms must be subject to environmental assessment. The Precautionary Principle must form the basis for assessing environmental effects.

18. Given that the negative environmental effects of GM crops--super-weeds, displacement of species, destruction of habitat, loss of genetic diversity--may be huge, and that the existence and magnitude of these effects are largely unknown, the Precautionary Principle clearly indicates that we should not introduce GM plants, livestock, or other organisms into our biosphere.

GMO LIABILITY THREATS FOR FARMERS

David R. Moeller Farmers’ Legal Action Group, Inc. (FLAG) St. Paul, Minnesota November, 2001 (Introduction and conclusion only. For full article see web site below.)

(http://www.agobservatory.org/)

Introduction

As giant agribusiness corporations control more and more of the genetics that go into farmers’ crops, the entire food supply may face yet-to-be-discovered risks. This article focuses on possible legal risks of farmers in relation to genetically modified organisms (GMOs). It is not intended, however, to be a comprehensive analysis of the multitude of legal issues farmers must take into account when making decisions related to GMOs. The introduction of GMOs into commercial crop production alters the risks farmers must consider when making decisions about buying seed and planting and marketing their crops. These include the possible loss of export markets and other market risks, as well as potential legal liability. Legal issues raised by the production of crops containing GMOs include tort-based liability, such as those claims arising when genetic drift and crop contamination occur; contract-based liability, such as might arise under farmers’ Technology Agreements with seed companies or farmers’ assurances to crop purchasers; and regulatory liability, such as might arise if farmers’ actions or circumstances result in violations of statutes or regulations. The discovery by Genetically Engineered Food Alert of genetically modified StarLink corn in taco shells and other food products starting in September 2000 caused ripple effects throughout the grain handling and food industries. StarLink corn had only been approved by the U.S. Environmental Protection Agency (EPA) for animal feed or industrial uses (non-food consumption) because the corn contains a biopesticide that may cause allergic reactions in humans. For farmers who planted StarLink corn and any neighbors whose crops were contaminated, the introduction of StarLink corn into human foods has had lasting effects. Aventis CropScience, the company that engineered StarLink corn, instituted a buy-back program intended to compensate farmers for their extra costs and lost markets resulting from the funneling of StarLink corn into the entire corn distribution chain. However, despite a buy-back agreement worked out between Aventis and 17 state Attorneys General, farmers encountered problems finding a location to deposit their StarLink or StarLinkcontaminated corn, experienced delays in making debt repayments due to late buy-back payments, and face the continuing possibility of civil litigation by neighbors or grain elevators over contamination issues. At present, at least nine class action lawsuits in six states have been filed against Aventis over the StarLink debacle. On September 17, 2001, thousands of Taco Bell restaurant franchises and other Mexican food companies sued Aventis in Arkansas state court. The lawsuit claims that the discovery of StarLink corn in Taco Bell products resulted in Taco Bell becoming the “poster child” for concerns about StarLink and other GMOs. Missouri Attorney General Jay Nixon has also sued Aventis on behalf of Missouri farmers and elevators, claiming that Aventis did not adequately teach farmers how to keep corn intended only for animal feed out of the human food supply.

Conclusion

This article can only speculate about the potential liabilities farmers may face as a result of growing StarLink corn and other GMO crops. The reason for this is that courts are just beginning to address the complex legal and regulatory issues that GMO crops present. The present abundance of class action and antitrust lawsuits and the potential for individual farmers suing their neighbors and seed companies for GMO contamination problems may begin to sort out these legal issues and provide farmers a better assessment of the legal risks involved in growing GMO crops. State Attorneys General have taken the lead, seeking economic protections for farmers damaged by the StarLink corn situation, but these efforts do not fully address Aventis’s implementation of the buy-back program or clarify legal liability issues. Legislation has been introduced in Congress and state legislatures that attempts to impose legal liability on the companies that market and sell GMOs. Until legislation is enacted, however, it is premature to assume that these efforts will eliminate farmers’ legal liabilities related to GMO crops. The potential for GMO products to cause damage to neighboring farmers and the entire grain handling system is evidenced not only by the StarLink example, but also in the increasing number of questions raised by GMOs including genetic drift distances, insect and weed resistance, and the inability of the current system to segregate GMO and non-GMO crops. Farmers assessing the costs and the benefits of growing GMO crops should base their decisions not only on production costs and expected yields, but also on the legal liability they may incur by planting, growing, and marketing GMO crops. For those farmers who choose not to grow GMO crops, especially organic farmers, caution still needs to be exercised in ensuring that their crops are protected from genetic contamination and that any promises made about the non-GMO crops are accurate representations of factors within the farmers’ control.

AMERICAN NFU RAISES MAJOR CONCERNS ABOUT GM PLANTINGS

From the following web site

http://www.nfu.org/index.cfm?category=legislative&title=issues&id=48

Date of Website entry 21 Sept 2001, following the ACAB meeting, August 1-2, 2001, as follows:

''National Farmers Union Position: NFU recognizes GMOs have created a series of ethical, environmental, food safety, legal, market, and structural issues that impact everyone in the food chain. Consumer and producer concerns need to be addressed. NFU acknowledges concerns that biotechnology is being used as a trade barrier; NFU respects all nations' sovereignty and urge open dialogue in trade negotiations relating to biotechnology. The National Farmers Union supports:

u a moratorium on the patenting and licensing of new transgenic animals and plants developed through genetic engineering until broader legal, ethical, and economic questions are thoroughly explored;

u a moratorium on the introduction, certification and commercialisation of genetically engineered wheat, including all classes of wheat until issues of cross-pollination, liability, commodity and seed stock segregation and market acceptance are adequately addressed;

u legislation to exempt farmers from paying royalties on patented farm animals and technical fees on seeds that have been genetically modified;

u ending further use of tax dollars in developing terminator technology,a.go., a gene to insure that seed will not reproduce;

u prohibiting the development and selling of seed that is sterile;

u the right of farmers to plant seed derived from proprietary organisms on the their own land; the removal of GMOs from the Food and Drug Administration's (FAD) Generally Recognized as Safe (GRAS) list;

u prior to FAD certification, the safety testing of new GMO technologies at the expense of the patent holders seeking to market them;

u holding patent holders or owners of GMO technology - not farmers - strictly liable for safety, health and environmental affects, including cross pollination, related to the use of GMOs as long as generally accepted crop production practices are followed;

u the full reimbursement of farmers by the producer of the GM product for any damages caused through lower prices, lost markets, or contamination;

u making all data used in the analysis of the health and environmental effects of GMOs public record, and implementing criminal penalties for withholding or altering such data;

u a ban on government licensing of genetically modified products that are not acceptable for both human consumption and animal feed;

u ensuring that farmers have been informed by government regulatory agencies and input suppliers of all potential risks and segregation requirementsassociated with planting any licensed GM crop;

u consideration by government regulatory agencies of domestic and foreign consumer acceptance when licensing GM products;

u clearly labeling GM seed with markets where the product is not accepted and all planting restrictions;

u development of a paper verification system and a storage and marketing plan to aid farmers with non-GMO grains; and

u appropriate labeling of products that contain GMOs in a manner that informs consumers.'' Background notes: National Farmers Union, officially called the Farmers Educational andCooperative Union of America, was founded in 1902 in Point, Texas by Newt Gresham. National Farmers Union is a general farm organization with a membership of nearly 300,000 farm and ranch families throughout the United States. National Farmers Union is a federation, with the presidents ofthe 24 state and regional Farmers Union organizations serving as its board of directors. For nearly 100 years, National Farmers Union's primary goal has been to sustain and strengthen family farm and ranch agriculture. The key to this goal has been Farmers Union's grassroots structure in which policy positions are initiated locally. The policy process includes the presentation of resolutions by individuals or a group of Farmers Union members, followed by possible adoption of the resolutions at the local, state and national levels.

1. LACK OF SCIENTIFIC CREDIBILITY OF GM SAFETY TESTS - Ann Clark

2. GENETICALLY MODIFIED FOODS: ARE THEY A RISK TO HUMAN/ANIMAL HEALTH? - Arpad Pusztai

INTRODUCTION from THIRD WORLD NETWORK INFORMATION SERVICE ON BIOSAFETY

15 September 2001 Dear friends and colleagues, We are pleased to share with you two important articles that deal with the safety problems of genetically modified (GM) food and crops. The first article, by Ann Clark, an associate professor of plant agriculture at Guelph University, originally appeared in the Canadian newspaper, Toronto Star, on March 12, 2001. The second article, a review of all the published scientific studies relating to GM food safety by Dr. Arpad Pusztai, was published by BioScience Productions in June 2001. Clark's article reveals the disturbing lack of scientific credibility in the biotechnology industry's claims about the safety of genetically modified organisms (GMOs). Clark points out that there is a "near absence of credible scientific evidence on which to assess environmental and food safety risks" of GM foods and crops. She cites the much publicised detailed database search by Jose Domingo which only found "a grand total of just eight refereed journal articles dealing with any aspect of the safety of GM foods. The eight included only four actual feeding trials, of which three were from Monsanto's teams." She also highlights the fact that the report of the EU-US Biotechnology Consultative Forum states that, "There is a lack of substantial scientific data and evidence, often (presented) more as personal interpretations disguised as scientifically validated statements." Pusztai's review shows that GM crops and food are being deemed safe for public consumption even though few scientific studies have been carried out on the risks to human and animal health. In fact, there are no peer-reviewed publications of clinical studies on the human health effects of GM food. In his review of the few tests and studies done, Pusztai concludes that current scientific data is "woefully inadequate" to assess the potential harm of GM crops and food and that the scientific quality of what has been published "is in most instances not up to expected standards". Pusztai also reveals some frightening results from studies done on the effects of GM food on animal health. In the case of the FLAVR SAVR tomato, 7 out of 20 female rats, and none in the controls, showed stomach lesions. Despite this, no further experiments were conducted. 7 out of 40 rats fed with GM tomatoes died within two weeks. But despite these results, the FLAVR SAVR tomato was declared to be safe for human consumption. Pusztai's own research found that rats fed with GM potatoes suffered abnormal intestinal growth. These two articles highlight the need for more and better testing of GM food and crops based on sound science. In the absence of independent and credible GM food safety tests, the precautionary principle must be applied.

THE LACK OF SCIENTIFIC CREDIBILITY OF GM FOOD SAFETY TESTS

By Ann Clark

Until recently, people tended to identify most of the concern about genetically modified (GM) agriculture with groups such as the Council of Canadians, Greenpeace and Friends of the Earth. Industry proponents wasted little time in painting these people as misinformed, hysterical greenies. But thanks to those groups, informed citizen opposition has slowed adoption of GM crops to a crawl, providing much-needed breathing space for senior scientists, lawyers, and physicians to reflect upon the issues and begin to speak out. Proponent efforts to paint the opposition as ill-informed malcontents and luddites sound increasingly silly in the face of the significant doubts now reaching the public media from prestigious scientific analysts. One common criticism in many such studies is the near absence of credible scientific evidence upon which to assess environmental and food safety risks. Last June, the prestigious journal Science reported a detailed database search by Jose Domingo, who could find a grand total of just eight refereed journal articles dealing with any aspect of the safety of GM foods. The eight included only four actual feeding trials, of which three were from Monsanto teams. The final report of the elite, hand-picked EU-U.S. Biotechnology Consultative Forum, which came out in December, 2000, stated, "There is a lack of substantial scientific data and evidence, often (presented) more as personal interpretations disguised as scientifically validated statements." The full report is available at http://europa.eu.int The Royal Society of Canada just came out with a new report entitled The Future of Food Biotechnology. Elements of Precaution: Recommendations for the Future of Food Biotechnology in Canada. This group of distinguished senior scientists identified numerous critical failings in the Canadian GM regulatory process, and were particularly critical of the pivotal role accorded the unscientific concept of "substantial equivalence." The report is available at http://www.rsc.ca In another recent issue of Science, U.S. government scientists LaReesa Wolfenbarger and Paul Phifer noted that "key experiments on both the environmental risks and benefits are lacking." They identified numerous critical deficiencies whether GM crops are indeed safe for the environment. Each of these studies calls for substantially increased research to figure out whether any risk exists, let alone how to test for such risk or to do about it. In effect, governments have authorized the commercial release of almost 50 GM crops, which were sown over 100 million acres in 1999 (71 per cent in the U.S., 17 per cent in Argentina, and 10 per cent in Canada), and yet we still don't know enough even to identify the food safety and environmental risks, let alone tests for them. In a nutshell, we don't know enough about basic gene function, the complexity of metabolic pathways, and the ecological implications of even modest genetic modifications to be doing what we are doing, commercially. As stated colloquially by Craig Venter, head of the Celera team that recently decoded the human genome, "We don't know s--t about biology." With a virtual absence of refereed support for heir beliefs, industry proponents insist there is still ample evidence of the safety of GM crops, pointing to voluminous internal industry and government reports. But how credible are these reports if they are not of a sufficient caliber to be published in a refereed journal? The requirement for publishing in a refereed journal is universally accepted in the scientific community. Authors are required to submit their work to review and critical comment from peers in the field to ensure the quality and integrity of the research. This is neither academic trivia nor overblown rhetoric, but is deadly earnest. Careers have been destroyed by this very issue, strange though it may seem. Two years ago, Arpad Pusztai, a world-renowned authority on plant proteins and nutrition, with nearly 300 refereed publications to his credit was fired and treated disgracefully by his own colleagues for committing the unforgivable sin of speaking publicly about his concerns about GM food safety prior to publishing his findings in a refereed journal. Pusztai had conducted meticulous studies that found organ size and intestinal integrity were hurt in rats fed potatoes that had been genetically modified to include genes from snowdrop lectin. Worse yet, rats fed plain potatoes sprinkled with snowdrop lectin did not show these effects. The study suggested that the problem related to the transgenic process, not the product. Does it seem odd to fire a scientist for expressing his concerns? Incomprehensible? Bizzare? There's more. The same Canadian proponents who just two years ago loudly affirmed Pusztai's firing because he had not published his work in a refereed journal are now loudly proclaiming the legitimacy of unpublished internal documents promoting GM safety. You can't have it both ways. Either research must be published in refereed journals to have scientific credibility, as was Pusztai's eventually, or not. And if not, if unpublished internal reports are to be accepted as credible and authoritative scientific information, one must conclude that the shameless destruction of Pusztai's career and he termination of his entire research program had little to do with refereed journal publishing, and everything to do with what he found.

GENETICALLY MODIFIED FOODS:
ARE THEY A RISK TO HUMAN/ANIMAL HEALTH?

By Arpad Pusztai, Ph.D.

Scarcity of safety tests

How can the public make informed decisions about GM foods when there is so little information about its safety? The lack of data is due to a number of reasons, including:

* It's more difficult to evaluate the safety of crop-derived foods than individual chemical, drug, or food additives. Crop foods are more complex and their composition varies according to differences in growth and agronomic conditions.

* Publications on GM food toxicity are scarce. An article in Science magazine said it all: "Health Risks of Genetically Modified Foods: Many Opinions but Few Data".1 In fact, no peer-reviewed publications of clinical studies on the human health effects of GM food exist. Even animal studies are few and far between.

* The preferred approach of the industry has been to use compositional comparisons between GM and non-GM crops. When they are not significantly different the two are regarded as "substantially equivalent", and therefore the GM food crop is regarded as safe as its conventional counterpart. This ensures that GM crops can be patented without animal testing. However, substantial equivalence is an unscientific concept that has never been properly defined and there are no legally binding rules on how to establish it.2 When food-crops are genetically modified, ("genetically modified" food is a misnomer!) one or more genes are incorporated into the crop's genome using a vector containing several other genes, including as a minimum, viral promoters, transcription terminators, antibiotic resistance marker genes and reporter genes. Data on the safety of these are scarce even though they can affect the safety of the GM crop. For example:

* DNA does not always fully break down in the alimentary tract.3,4 Gut bacteria can take up genes and GM plasmids5 and this opens up the possibility of the spread of antibiotic resistance.

* Insertion of genes into the genome can also result in unintended effects, which need to be reduced/eliminated by selection, since some of the ways the inserted genes express themselves in the host or the way they affect the functioning of the crop's own genes are unpredictable. This may lead to the development of unknown toxic/allergenic components, which we cannot analyze for and seriously limiting the selection criteria. Currently, toxicity in food is tested by chemical analysis of macro/micro nutrients and known toxins. To rely solely on this method is at best inadequate and, at worst, dangerous. Better diagnostic methods are needed, such as mRNA fingerprinting, proteomics and secondary metabolite profiling.6 However, consuming even minor constituents with high biological activity may have major effects on the gut and body's metabolism, which can only be revealed from animal studies. Thus novel toxicological/nutritional methods are urgently needed to screen for harmful consequences on human/animal health and to pinpoint these before allowing a GM crop into the food chain.7 Safety tests on commercial GM crops GM tomatoes: The first and only safety evaluation of a GM crop, the FLAVR SAVRTM tomato, was commissioned by Calgene, as required by the FDA. This GM tomato was produced by inserting kanr genes into a tomato by an 'antisense' GM method. The test has not been peer-reviewed or published but is on the internet.8 The results claim there were no significant alterations in total protein, vitamins and mineral contents and in toxic glycoalkaloids.9 Therefore, the GM and parent tomatoes were deemed to be "substantially equivalent." In acute toxicity studies with male/female rats, which were tube-fed homogenized GM tomatoes, toxic effects were claimed to be absent. In addition, it was concluded that mean body and organ weights, weight gains, food consumption and clinical chemistry or blood parameters were not significantly different between GM-fed and control groups. However:

* The unacceptably wide range of rat starting weights (±18% to ±23%) invalidated these findings.

* No histology on the intestines was done even though stomach sections showed mild/moderate erosive/necrotic lesions in up to seven out of twenty female rats but none in the controls. However, these were considered to be of no importance, although in humans they could lead to life-endangering hemorrhage, particularly in the elderly who use aspirin to prevent thrombosis.

* Seven out of forty rats on GM tomatoes died within two weeks for unstated reasons.

* These studies were poorly designed and therefore the conclusion that FLAVR SAVRTM tomatoes were safe does not rest on good science, questioning the validity of the FDA's decision that no toxicological testing of other GM foods will in future be required. GM maize: Two lines of Chardon LL herbicide-resistant GM maize expressing the gene of Phosphinothricin Acetyltransferase Enzyme (PAT-PROTEIN) before and after ensiling showed significant differences in fat and carbohydrate contents compared with non-GM maize and were therefore substantially different. Toxicity tests were only performed with the PAT-PROTEIN even though with this the unpredictable effects of the gene transfer or the vector or gene insertion could not be demonstrated or excluded. The design of these experiments was also flawed because:

* The starting weight of the rats varied by more than ± 20% and individual feed intakes were not monitored.

* Feed conversion efficiency on PAT-PROTEIN was significantly reduced.

* Urine output increased and several clinical parameters were also different.

* The weight and histology of the digestive tract (and pancreas) was not measured.Thus, GM maize expressing PAT-PROTEIN may present unacceptable health risks. Compositional studies GM soybeans: To make soybeans herbicide resistant, the gene of 5-enolpyruvylshikimate-3-phosphate synthase from Agrobacterium was used. Safety tests claim the GM variety to be "substantially equivalent" to conventional soybeans.10 The same was claimed for GTS (glyphosate-resistant soybeans) sprayed with this herbicide.11 However, several significant differences between the GM and control lines were recorded10 and the statistical method used was flawed because:

* Instead of comparing the amounts of components in a large number of samples of each individual GTS with its appropriate parent line grown side-by-side and harvested at the same time, the authors compared samples from different locations and harvest times.

* There were also differences in the contents of natural isoflavones (genistein, etc.) with potential importance for health.12

* Additionally, the trypsin inhibitor (a major allergen) content was significantly increased in GTS.10Because of this, and the large variability (± 10% or more), the lines could not be regarded as "substantially equivalent." GM potatoes: There is only one peer-reviewed publication on GM potatoes that express the soybean glycinin gene.13 However, the expression level was very low and no improvements in the protein content or amino acid profile were obtained. GM rice: The kind that expresses soybean glycinin gene (40-50 mg glycinin/g protein) has been developed14 and is claimed to contain 20% more protein. However, the increased protein content was probably due to a decrease in moisture rather than true increase in protein putting a question mark over the significance of this GM crop. GM cotton: Several lines of GM cotton plants have been developed using a gene from Bacillus thuringiensis subsp. kurstaki providing increased protection against major lepidopteran pests. The lines were claimed to be "substantially equivalent" to parent lines15 in levels of macronutrients and gossypol, cyclopropenoid fatty acids and aflatoxin levels were less than those in conventional seeds. However, because of the use of inappropriate statistics it is questionable whether the GM and! non-GM lines were truly equivalent, particularly as environmental stresses could have unpredictable effects on antinutrient/ toxin levels.16 Nutritional/toxicological studies Herbicide-resistant soybean: Studies have been conducted on the feeding value17 and possible toxicity18 for rats, broiler chickens, catfish and dairy cows of two GM lines of glyphosate-resistant soybean (GTS). The growth, feed conversion efficiency, catfish fillet composition, broiler breast muscle and fat pad weights and milk production, rumen fermentation and digestibilities in cows were claimed to be similar for GTS and non-GTS. However:

* These experiments were poorly designed since the high dietary protein concentration and the low inclusion level of GTS could have masked any GM effect.

* No individual feed intakes, body or organ weights were given and no histology was performed, except some qualitative microscopy on the pancreas.

* The feeding value of the two GTS lines was not substantially equivalent either because the rats grew significantly better on one of the GTS lines than on the other.

* The experiment with broiler chicken was a commercial and not a scientific study.

* The catfish experiment showed again that the feeding value of one of the GTS lines was superior to the other.

* Milk production and performance of lactating cows also showed significant differences between cows fed GM and non-GM feeds.

* Moreover, testing of the safety of 5-enolpyruvylshikimate-3-phosphate synthase which renders soybeans glyphosate-resistant18 was irrelevant because in the gavage studies an E. coli recombinant and not the GTS product was used. Their effects could be different as the differences in posttranslational modification could have impaired their stability to gut proteolysis. Thus, the claim that the feeding value of GTS and non-GTS lines was substantially equivalent is at best premature. In a separate study19 it was claimed that rats and mice which were fed 30% toasted GTS or non-GTS in their diet had no significant differences in nutritional performance, organ weights, histopathology and production of IgE and IgG antibodies. However, under the unphysiological -- basically, starvation --conditions of these experiments when, instead of the normal daily growth of 5-8 g per day, the rats grew less than 0.3 g and mice not at all, no valid conclusions could be drawn. GM corn: One broiler chicken feeding study with rations containing transgenic Event 176 derived Bt corn (Novartis) has been published.20 However, the results of this trial are more relevant to commercial than academic scientific studies. GM peas: The nutritional value of diets containing GM peas expressing bean alpha-amylase inhibitor when fed to rats for 10 days at two different (30% or 65%) dietary inclusions, was shown to be similar to that of parent-line peas.21

* Even at 65% level the difference was small mainly because the alpha-amylase inhibitor expressed in the peas was quickly digested in the rat gut and its antinutritive effect abolished. Unfortunately no gut histology was done or lymphocyte responsiveness measured.

* Although some organ weights, mainly the caecum and pancreas were different, those of others were remarkably similar suggesting that GM peas may be used in the diets of farm animals at low/moderate levels if their progress was carefully monitored. However, to establish its safety for humans a more rigorous specific risk assessment will have to be carried out with several GM lines. This should include:

* An initial nutritional/toxicological testing on laboratory animals

* If no harmful effects are then detected, it should be followed by clinical, double-blind, placebo-type tests with human volunteers, keeping in mind that any possible harmful effects would be particularly serious with the young, old, and disabled. A protocol for such testing was given at the OECD conference in Edinburgh, February 2000 and subsequently published.22 GM potatoes: In a short feeding study to establish the safety of GM potatoes expressing the soybean glycinin gene, rats were daily force-fed with 2 g of GM or control potatoes/kg body weight.23 Although no differences in growth, feed intake, blood cell count and composition and organ weights between the groups was found, the potato intake of the animals was too low and unclear, whether the potatoes were raw or boiled. Feeding mice with potatoes transformed with a Bacillus thuringiensis var. kurstaki Cry1 toxin gene or the toxin itself was shown24 to have caused villus epithelial cell hypertrophy and multinucleation, disrupted microvilli, mitochondrial degeneration, increased numbers of lysosomes and autophagic vacuoles and activation of crypt Paneth cells. The results showed that despite claims to the contrary, CryI! toxin was stable in the mouse gut and therefore GM crops expressing it need to be subjected to "thorough tests...to avoid the risks before marketing.24 In another study, young, growing rats were pair-fed on iso-proteinic and iso-caloric balanced diets containing raw or boiled non-GM potatoes and GM potatoes with the snowdrop (Galanthus nivalis) bulb lectin (GNA) gene.25 The results showed that the mucosal thickness of the stomach and the crypt length of the intestines of rats fed GM potatoes was significantly increased. Most of these effects were due to the insertion of the construct and not to GNA which had been been pre-selected as a non-mitotic lectin unable to induce hyperplastic intestinal growth26 and epithelial T lymphocyte infiltration. Although there is controversy about the tests, most of the adverse comments on this Lancet paper were personal, non-peer reviewed opinions and, as such, of limited scientific value. The findings, on the other hand, were published in a peer-reviewed publication25 and t! he criticism replied to.7 The work, however, has not been repeated nor results contradicted and it is therefore imperative that the effects on the gut structure and metabolism of all other GM crops developed using similar techniques and genetic vectors should be thoroughly investigated before their release into the food chain. GM tomatoes: This study with a GM tomato expressing B. thuringiensis toxin CRYIA(b) gene was published in a book and not in a peer-reviewed journal. However, its importance was underlined by the immunocytochemical demonstration of in vitro binding of Bt toxin to the caecum/colon from humans and rhesus monkeys.27 Although in vivo the Bt toxin was not bound by the rat gut, this was possibly due to the authors' use of recombinant Bt toxin.

Allergenicity studies

One of the major health concerns with GM food is its potential to increase allergies and anaphylaxis in humans eating unlabeled GM foodstuffs.

* When the gene is from a crop of known allergenicity, it is easy to establish whether the GM food is allergenic using in vitro tests, such as RAST or immunoblotting, with sera from individuals sensitised to the original crop. This was demonstrated in GM soybeans expressing the brasil nut 2 S protein28 or in GM potatoes expressing cod protein genes.29

* It is also relatively easy to assess whether genetic engineering affected the potency of endogenous allergens.30 Some farm workers exposed to B. thuringiensis pesticide were shown to have developed skin sensitization and IgE antibodies to the Bt spore extract. With their sera it may now therefore be possible to test for the allergenic potential of GM crops expressing Bt toxin.31 It is all the more important because Bt toxin Cry1Ac has recently been shown to be a potent oral/nasal antigen and adjuvant.32 Assessment of the allergenicity of a GM foodcrop, however, is difficult when the gene is transferred from a source not eaten before or with unknown allergenicity or on gene transfer/insertion a new allergen or adjuvant is developed or the expression of a minor allergen is increased. Unfortunately, while there are good animal models for nutritional/toxicological testing, no such models exist for allergenicity testing.

* Presently only indirect and rather scientifically unsound methods, such as finding SHORT sequence homologies (at least 8 contiguous amino acids) to any of the about 200 known allergens, are used for the assessment of allergenicity.

* The decision-tree type of indirect approach based on factors (such as size and stability) of the transgenically expressed protein33 is even more unsound, particularly as its stability to gut proteolysis is assessed by an in vitro (simulated) testing34 instead of in vivo (human/animal) testing and this is fundamentally wrong. The concept that most allergens are abundant proteins is also misleading because for example Gad c 1, the major allergen in codfish, is not a predominant protein.29

* However, when the gene responsible for the allergenicity is known, such as the gene of the alpha-amylase/trypsin inhibitors/allergens in rice, cloning and sequencing opens the way for reducing their level by antisense RNA strategy.35 Thus, in the absence of reliable methods for allergenicity testing, it is at present impossible to definitely establish whether a new GM crop is allergenic or not before its release into the human/animal food/feed chain.

In conclusion

One has to agree with the piece in Science1 that there are many opinions but scarce data on the potential health risks of GM food crops, even though these should have been tested for and eliminated before their introduction. Our present data base is woefully inadequate. Moreover, the scientific quality of what has been published is, in most instances not up to expected standards. If, as claimed, our future is dependent on the success of the promise of genetic modification delivering wholesome, plentiful, more nutritious and safe GM foods, the inescapable conclusion of this review is that the present crude method of genetic modification has so far not delivered these benefits and the promise of a superior second generation is still in the future. Although it is argued by some that small differences between GM and non-GM ! crops have little biological meaning, it is clear that most GM and parental line crops fall short of the definition of "substantial equivalence." In any case, this crude, poorly defined and unscientific concept outlived its possible previous usefulness and we need novel methods and concepts to probe into the compositional, nutritional/toxicological and metabolic differences between GM and conventional crops and into the safety of the genetic techniques used in developing GM crops if we want to put this technology on a proper scientific foundation and allay the fears of the general public. We need more science, not less.6,7

(c) 2001, BioScience Productions, Inc., an organization promoting bioscience literacy. Educators have permission to reprint articles for classroom use; other users, please contact editor for reprint permission.
The full references will be placed on our website: http://www.twnside.org.sg/bio_7.htm

Evidence with special emphasis on the use of
GLUFOSINATE AMMONIUM (PHOSPHINOTHRICIN)

Professor Malcolm Hooper Ph.D, B.Pharm., MRIC, C Chem

Presented at the Chardon LL T 25 Maize Hearing, May 2002

1. Introduction

In the major part of my evidence I shall deal with important questions associated with-♦___ The presence of the PAT gene that confers resistance to glufosinate ammonium. ♦___ The obligatory use of glufosinate ammonium as a broad-spectrum herbicide as part of the strategy for

growing GM crops, especially Chardon LL T 25 that is the subject of this hearing.

♦___ The relationships between glufosinate and the important biological molecules glutamine and glutamate. ♦___ I have not considered any significant genetic aspects of Chardon LL as these have been covered experts in this field ( Ho, 2002; FoE, 2000a)

I shall deal briefly with some aspects of other evidence presented to the hearing in a closing paragraph.

2. The PAT (phosphorthricin acetyl transferase) Gene

(a) This gene, which is part of the five-gene construct, confers resistance to glufosinate ammonium that is used as a broad-spectrum herbicide with the Chardon LL T 25 maize crop.

(b) The gene-protein is a completely novel protein/enzyme and has been found only in a mutant bacterium. This has important implications for food safety (FoE, 2001a,b). It provides the GM plant with the ability to metabolically inactivate, by N-acetylation, the glufosinate molecule thereby rendering it ineffective as a herbicide.

(c) However, the N-acetylated glufosinate molecule is not further destroyed but is stored in the plant as the inactive N-acetylphosphinothricin.

(d) It is very important to recognise that this is a feature only of the GM crop. Although the only reported studies, I have been able to find, concern only, plant cell cultures of sugarbeet, carrot, purple foxglove and thorn apple (Muller et al. 2001), or canola (rape) (Beriault et al. 1999) it is reasonable to assume that this also occurs in the Chardon LL maize.

(e) If a similar study of Chardon LL has not been done it represents a significant failure by the Company and must be done forthwith. If the data is only in Company files then it must be released immediately.

(f) N-acetylphosphinothricin is not found in the natural crop and represents a very significant difference in bio-equivalence between the transgenic and non-transgenic crops- see also below.

(g) Critically, data supplied by AgrEvo, now Aventis, demonstrates that micro-organisms, in the digestive tract of warm-blooded animals, can remove the inactivating acetyl group and regenerate the active and toxic phosphinothricin (glufosinate) (Jewell and Buffin, 2001).

(h) This is clearly very serious and means that ALL transgenic crops, incorporating the PAT gene, and materials obtained from them, eg. oils and manufactured products, must be fully evaluated for the presence of this metabolite of phosphinothricin.

In my judgement, all field trials must be halted immediately until critical questions about the metabolism, storage and reconversion of the N-acetylphosphinothricin have been fully answered for all PAT gene containing products.

3. Glufosinate Ammonium (Phosphinothricin)

(a) This is a novel metabolite isolated from soil bacteria, various Streptomyces spp., (Merck Index, 1996).

(b) Its acts by inhibiting the enzyme, glutamine synthetase, which converts the essential amino acid, glutamic acid to glutamine. There are clear molecular similarities between phosphinothricin, glutamate and glutamine-see Appendix 1 for more details. The enzyme, glutamine synthetase is ubiquitous and occurs in plants, insects and animals including humans and farm animals.

(c) The net result of the action of glufosinate is that ammonia and glutamate accumulate whilst glutamine is limited. It is the accumulation of ammonia that is the lethal action in plants. However the action is limited by the distribution of glufosinate in plants where it is restricted to the leaves and the stem which come into direct contact with the sprayed material (Jewell and Buffin, 2001). Deep rooted plants and stolons are not destroyed. Glufosinate is not a universal herbicide.

(d) In mammals the consequences of inhibition of glutamine synthetase are more associated with the increased levels of glutamate, and decreased levels of glutamine, see below. Circulating ammonia is removed in the liver by, an alternative mechanism, the urea cycle. However, the brain is highly sensitive to the toxic effects of ammonia and the removal of excess ammonia depends on its incorporation into glutamine (Zonehome, 2002).

4. Toxic Effects of Glufosinate

(a) In Humans-

i. Most of this information comes from acute overdoses taken accidentally or as a means of committing suicide. Since 1989 many such cases have been reported from Japan (Watanabe and Sano, 1998).

ii. Such poisonings involve not only glufosinate, the pharmacologically active compound, but also other components of the formulated product such as surfactants which may be present in very large amounts and may not have been tested for their toxicological properties. From studies in rats the surfactant was found to have cardiostimulatory and vasodilative effects at low doses but cardiosuppressive effects at high doses. These changes were consistent with the cardiovascular changes found in clinical situations (Koyama, Koyama and Goto, 1997).

iii. Neurotoxicity is characteristic of glufosinate poisoning although the mechanism is not clear. Generalised convulsions, mental disturbances and short-term memory loss have all been observed
(Watanabe and Sano, 1998; Tanaka et al., 1998).

iv. Impaired respiration, gastrointestinal effects and haematological changes were also observed.

v. Analysis of previously published cases appears to indicate that the toxic effects arise from both the active ingredient and the surfactant (sodium polyoxyethylene alkylether sulphate, AES) in the formulation (Koyama, Koyama and Goto, 1997).

vi. A toxico-kinetic analysis in a patient with acute glufosinate poisoning found that there were various neurological symptoms, disturbances of consciousness, convulsions and apnea which appeared after an asymptomatic interval of several hours. Four and a half hours after ingesting around 300 ml of a 20% solution of glufosinate the patient showed speech ataxia and systemic tremor and was intubated prior to serious respiratory failure. Five days later he was discharged without any sequalae. Changes in urinary excretion were monitored and from the data it was concluded that excretion could be modelled by a two-compartment model that showed glufosinate was eliminated from the first compartment with a T1/2 of 1.84

hours and the second compartment with a T1/2 of 9.59 hours (Hirose et al. 1999). A similar study in rabbits proposed a similar two-compartment model although renal clearance values were much higher –a common feature with small animals. Glufosinate appears to be handled in a manner similar to that for theophylline, caffeine and pentobarbital (Koyama et al. 1998).

vii. In vitro studies of glufosinate binding to human serum albumin concluded that glufosinate was rapidly eliminated by the renal route but such studies cannot be expected to mimic the much more complex situation which involves whole blood in the whole animal; many other binding molecules and cells are present (Hori et al, 2001).

viii. A transient diabetes insipidus was observed in one case together with disturbed consciousness, convulsions and apnea (Takahashi et al. 2000).

ix. A case-referent study of 261 matched pairs examined the possible relationship between pesticide exposures and congenital malformations. It found an odds ration of 2.45(95% CI 0.78-7.70) for glufosinate exposure. The wide confidence intervals show the study did not reach statistical significance and that it needs to be extended. Nevertheless, it is reasonable to conclude that “there is a possible risk of congenital malformations for paternal exposure to …….. Glufosinate”. This is a deeply worrying finding and must be followed up as a matter of urgency. No further trials of glufosinate associated transgenic crops can be allowed until this issue is resolved (Garcia et al., 1998).

x. The mammalian metabolite of glufosinate, 3-methylphosphinylpropionic acid (MPPA-3) is also a known neurotoxin and needs to be considered in assessing the human toxicology of glufosinate (US EPA, 1988).

xi. In my judgement, a further metabolite, methylphosphinlyacetic acid, MPAA, might also have toxic effects. I could find no studies on this important topic.

xii. It is important to note that oral administration of glufosinate has major effects on the brain. This indicates that the blood-brain barrier, which prevents access of many compounds to the brain, is readily crossed by glufosinate.

xiii. Many of the toxic effects of glufosinate are consistent with the known pharmacology and physiology of glutamine and glutamate- see below. A recently drug introduced to treat epilepsy, lamotrigine, acts by blocking glutamate receptors in the brain.

(b) In Laboratory Animals-

i. Rats and mice are the most common laboratory animals used to study the pharmacology and toxicology of novel compounds being developed for human use. Although species variations do occur it is possible to extrapolate data from studies with these small animals to man. The drug industry is adept at making such extrapolations. Most drugs have come into common usage following the identification of important pharmacological properties in these and other small animals. Similarly toxicological studies routinely involve small animal work. On ethical grounds the use of cell culture systems is being rapidly extended to reduce the volume of work with small laboratory animals.

ii. Glufosinate Ammonium induces convulsions in mice via N-methyl-D-aspartate, NMDA, receptors. This is consistent with the observed response in humans when glufosinate is ingested, see above, and the induced aggressiveness, wet dog shakes and limbic seizures in rats (Matsumura et al. 2001). The drug was administered by intraperitoneal injection showing again that peripherally administered glufosinate readily enters the brain. Glufosinate has been shown to bind to L-glutamate binding sites in rat brains. This study clearly demonstrates that the main mechanism of action of glufosinate is by its agonist effect at glutamate receptors- see below.

iii. Stimulation of the NMDA receptors has been shown to stimulate nitric oxide production in vivo (Nakaki et al. 2000). Nitric oxide has many roles in the body and affects blood flow, the immune response and serves as a neurotransmitter. It is a free radical and in excess would exert oxidative stress in the tissues involved.

iv. Using whole embryo culture techniques glufosinate ammonium was found to induce apoptosis (programmed cell death) in neuroepithelial cells in the developing mouse embryo. This teratogenic action is extremely disturbing and would undoubtedly result in a drug being withdrawn from the further development (Watanabe, 1997).

v. Maternal exposure to a single exposure of glufosinate during the time of neurogenesis in the hippocampus lead to a decrease in the wet dog shakes response to kainic acid. This indicates that a different set of glutamate receptors were affected leading to functional abnormalities in the brains of the offspring (Fujii 1997). Yet again such a property would lead to withdrawal of a drug from development. I have no where found any response by Aventis or its precursor company to this damning evidence published some 5 years ago.

vi. The mortality in mice to high doses of glufosinate was significantly increased depending on which stage of the circadian cycle the compound was given. Mortality was greatest when administration took place in the light phase. This is disturbing since the glufosinate will, generally, be applied in daylight (Yoshiyama et al., 1995).

i. In a complex process L-glutamate in the moulting fluid of the Brazilian skipper butterfly in converted to glutamine by the enzyme glutamine synthetase. The toxic effects of glufosinate towards the pupae of this butterfly are caused by inhibition of this process (Yarema et al. 2000). Since this process appears to be general for all Lepidoptera it is likely that glufosinate will damage related insects in a similar manner.

ii. Glufosinate is also toxic to the fifth instar of the skipper butterfly, causing cessation of feeding, neurotoxic as indicated by proleg tremors, body convulsions and complete paralysis that results in death. The toxic dose was below that normally delivered during spraying. These effects were shown to be due to glutamine depletion in the caterpillar (Kutlesa and Caveney, 2001).

iii. Some developmental forms of insects that perform a valuable predatory role against plant pests, such as Tetranychus urticae, are adversely affected by glufosinate which however is more toxic towards the developmental stages of the pest insect. It seems that there is a similar mechanism of action in both the predatory and pest insects. Further study of this complex web of relationships is needed (Ahn et al., 2001).

iv. Glufosinate is highly toxic to some beneficial insects such as phytoselids and bagworm moths (Jewell and Biffin, 2001).

(d) Other Life Forms

i. Glufosinate is toxic towards the larvae of clams and oysters, daphnia and some freshwater fish; the rainbow trout is the most sensitive species of those tested (Jewell and Biffin, 2001). Run off from sprayed areas into streams and lakes could be damaging to some fisheries.

ii. Inhibition of some beneficial soil bacteria and fungi by glufosinate is known. Some 37% of the organisms tested were sensitive to and adversely affected by glufosinate. In boreal forest soils 20% of the fungi and 40% of the bacteria were sensitive to glufosinate. Nitrogen fixing soil bacteria and rhizobial nodulation rates were reduced, in some cases drastically, in tests in sterile soils. Although soils are not sterile the possible impact of glufosinate on nitrogen fixation rates is worrying and needs much more detailed investigation (Jewell and Biffin, 2001).

iii. Cellulose decomposition is also inhibited by glufosinate even at low concentrations. Burial of cellulose substrates in soils sprayed with 150 ppm of glufosinate resulted in a 78% reduction in cellulose decomposition rates (Jewell and Biffin, 2001).

iv. Some plant pathogens were found to be highly resistant to glufosinate but, in contrast, organisms antagonistic to these pathogens were seriously and adversely affected. The loss of these antagonistic organisms could have far reaching effects (Jewell and Biffin, 2001).

v. Glufosinate which is a broad spectrum herbicide would be expected to damage all plants that it came in contact with thereby reducing the biodiversity of the environment in which it was used.

vi. The knock-on effect of loss of insects and plants would affect bird and small animal life as well as agriculture.

5. Glufosinate Residues (from Jewell and Biffin)

(a) In Food

i. Glufosinate ammonium as well as being sprayed on to crops to combat weed growth is also used as a pre-harvest desiccant. MAFF has found that consumers are most likely to be exposed to residues in potatoes, dried and processed peas, and liver and kidney from animals fed contaminated cereal straw.

ii. Spraying with glufosinate in apple orchards is at 540 ppm (Ahn et al., 2001)

iii. The WHO/FAO recommended ADI (Allowed Daily Intake) is 0.02mg/kg of body weight, ie. 20 ppb (parts per billion). Equivalent to a total dose of 1.4 mg for a 70 kg person.

iv. The highest likely residue levels were considered to be ; 3 mg/kg = 3 ppm (parts per million) dried peas. 1 mg/kg wheat grain.

0.5 mg/kg oilseed rape seeds.Edible parts of spinach, radishes, wheat and carrots were found to contain residues some 120 days after the application of glufosinate. In potatoes 0.1 mg/kg were found but the toxic metabolite MPPA-3 was found at 0.07 mg/kg (single application) and 2.4 mg/kg (double application- this is more common) some 77 days after treatment.

Flour contained 10-100 % of the wheat residues
Bran contained 10 –600 % of wheat residues.

In animal feed
50 mg/kg in barley straw and pea stalks.
20 mg/kg in wheat straw and field bean stalks.
(b) Drinking Water

Although Aventis claim that glufosinate is unlikely to leach into drinking water supplies it is classed as a persistent and mobile contaminant by the USA Environmental Protection Agency. The company’s claims are spurious. Despite the growing awareness of potent pharmacological compounds finding their way into drinking water only limited testing is done by the Environment Agency; glufosinate is not included in the present testing regimen.

6. Persistence in Soil and Water

(a) This is very variable depending on the nature of the soil and its organic content. The half-life varies from 3 to 42 days in some studies but reached up to 70 days in others. Soil coverage was also important as was temperature and soil moisture content. Glufosinate was most persistent in sandy soils overlying aquifers where its transport through soil was “essentially unretarded” (Richelle et al., 1995).

(b) The metabolite, MPPA-3, has been found to be more persistent and mobile than glufosinate and in soil column leaching experiments was leached some 20 times faster than glufosinate (Jewell and Biffin, 2001).

7. Glutamine

This amino acid is important for homeostatic functions, body fluid and pH balance, body temperature, and heart rate, and the optimum functioning of a number of body systems particularly the brain, immune system and the gut. It is best described as a “conditionally essential amino acid”.

♦___ It is the most abundant free amino acid in the human body.
♦___ Constitutes 50-60% of the total free amino acid pool in skeletal muscle.
♦___ Constitutes 20% of the plasma amino acid pool.
♦___ Readily crosses the blood brain barrier and enters the brain which has 10 to 15 times the concentration in
the blood.
♦___ Modulates key neurotransmitter molecules in the brain, the excitatory glutamate and inhibitory γ-
aminobutyrate, GABA.
♦___ Is the major fuel for cells

• In the gut which utilises 40% of the body’s glutamine.

• Brain

• Immune cells

• Kidneys

• Liver ♦___ Has a major role in assisting detoxification processes in these and other organs. ♦___ In the immune system it raises circulating lymphocyte and macrophage levels increasing resistance to infection ♦___ Plays an important role in the regulation of glucose metabolism- increasing glucose production and muscle glycogen storage. ♦___ Plays a key role in nucleic acid synthesis. ♦___ Restores protein in skeletal muscle by anabolic and anti-catabolic mechanisms. ♦___ Protects against stress whether derived from burns and trauma, illness or overtraining in athletes. ♦___ Is produced in the body by glutamine synthetase the primary site being skeletal muscle with the liver, lungs and brain being secondary sites.

Major references Horleys, 2001, Occhipinti, 2001, IoM 1999.

It is difficult to conceive of a more potentially damaging target, for compounds destructive to human health and well-being, than the glutamate-glutamine and glutamine synthetase system. Any disruption of this finely balanced and essential system by compounds such as glufosinate will have far-reaching and long-term consequences.

Because of the ubiquitous nature of this system, which is highly conserved throughout nature, almost every kind of living organism will be open to extensive damage from compounds like glufosinate.

8. Glutamate and its Receptors

Information about glutamate and its receptors has been available in all pharmacology,
biochemistry, and medicinal chemistry books over many years (see for example, Wingard et al. 1991, Stryer 1988,
Krogsgaard-Larsen and Bundgaard 1991).
Glutamate is

♦___ The premier excitatory neurotransmitter in the brain.
♦___ A key compound in the development of the foetal and neonatal brain.
♦___ Important in memory and learning in the adult brain.
♦___ An initiator of programmed cell death, apoptosis, in brain cells.
♦___ Part of an essential balance between excitatory and inhibitory amino acids in the brain.
♦___ A key component of the energy producing cycle, the Kreb’s cycle, in all mammalian cells.
♦___ Glutamate is also an excitotoxic neurotransmitter in the enteric nervous system where it can induce
apoptosis and cell death. This could result in damage to the gut and loss of structural and functional integrity
(Gershon, 1999). The broiler chicken study could be indicative of such damage since the weight gain with T
25 maize falls off in the final stages of the study and death rates are increased (Leeson, 1996; Howard, 2000,
FoE, 2001a).

Disruption of the levels of this essential amino acid will have extensive and long-term effects in many living organisms.

9. Associated Significant Issues

(a) Other submissions to this Hearing have shown that the scientific studies supporting the claims of the manufacturers supporting the use of glufosinate and transgenic crops is

i. Often badly conceived and inadequately assessed

ii. Does not provide substantive evidence for the claims being made

iii. Is surrogate science that avoids the crucial experiments that are demanded for the proper
understanding of the impact of these new technologies (Howard, 2000; FoE, 2001a,b,c).

(b) The treatment of some major scientists in the field of GM crops has been outrageous and quite contrary to the spirit of scientific search for truth and understanding (Pusztai, 2002).

(c) There is now clear evidence of attempts to mislead the public and discredit good science by major
companies involved in the development and sales of GM maize (Monbiot, 2002).

(d) The whole political process, in Europe and the United Kingdom has been subverted in the way Chardon LL T 25 has been handled and key evidence ignored (FoE, 2001a,d). T25 maize has been introduced into the food chain illegally (FoE, 2000). Deception and deceit appear to be the order of the day.

(e) There is no consideration of the impact of other genetic material which is part of the gene-construct necessary to introduce the glufosinate resistance gene. In particular the use of an ampicillin resistant gene derived from E coli. This gene will ensure the even greater and faster spread of penicillin resistance–now a major clinical problem. The wilful and calculated spread of such resistance is irresponsible and foolhardy. The use of such genes has been strongly advised against by various key groups, including the British Medical Association (FoE, 2001).

(f) Although my evidence is limited to key questions surrounding Chardon LL T25 maize the same criticisms can be levelled against any crops that use the glufosinate resistance gene construct, sugarbeet and rape, or where glufosinate is used as a desiccant.

(g) Similar transgenic systems using glyphosate as the broad spectrum herbicide are open to the same kinds of criticism.

10. Conclusions

Glufosinate is not only a broad spectrum herbicide but also a highly selective and active compound that undoubtedly adversely affects many other organisms because of the ubiquity of the target enzyme system. In particular glufosinate seriously damages the same system in humans with consequences for foetal, child, and adult health. It is difficult to imagine a compound with greater potential threat to human and environmental health than glufosinate. Glufosinate, if it were a drug candidate, would have been withdrawn from development years ago on account of its teratogenic and neurotoxic properties. Many more well-designed scientific studies are required to investigate the known as well as the potential effects of glufosinate on humans and the wider environment. Scientific study has been prostituted to support the claims of manufacturers and interests of global organisations intent upon dominating world food production. This has lead to poor science that is partial, generally ill-designed, and does not address the key questions. Very disturbing are attempts to discredit good science, that does not provide conclusions that are acceptable to company claims, and threatens their product(s). Equally disturbing are attempts to manipulate scientific and other literature in order to mislead the public. The truth is not being told. The widespread testing of GM maize and other crops in field trials is premature and irresponsible in the extreme. Almost every assumption underlying their testing has been shown to be wrong. The use of the UK countryside as an open laboratory for these studies is unacceptable at the present time and must end immediately. It should only resume when sound independent scientific studies have been fully completed and with the agreement of the local communities involved. The introduction of GM foods into the human and animal food chains at the present time is utterly irresponsible and foolhardy in the light of our present scientific knowledge of these crops and their effects on human health and the environment. All such crops should be withdrawn immediately to allow essential and independent scientific studies to be carried out. In particular, the mixing of produce from GM and non-GM crops must cease. Such mixing, for the purpose of sales and to hoodwink the public, must stop. The support of the USA and UK Governments for such practices is reprehensible and dangerous.

References

Ahn YJ, KimYJ, Yoo JK. Toxicity of the herbicide glufosinate-ammonium to predatory insects and mites of
Tetranychus urticae (Acari:Tetranychidae) under laboratory conditions. J Economic Entomology 2001, 94, 157-61.
Beriault J, Horsman G, Devine M. Phloem transport of D,L-glufosinate and acetyl-L-glufosinate ammonium in
glufosinate-resistant and susceptible brassica napus. Plant Physiology 1999, 121, 619-628. Quoted in Cummins J.
(Norfolk Genetic information Network) Ignored side effects of glufosinate herbicide.
http://members.tripod.com/~ngin/160202a.htm.
FoE 2000, Illegal GM Food available at http:/www.foe.co.uk/pubsinfo/briefings/html/20001106170722.html
FoE 2001 Antibiotic Resistance Genes in GM Foods available at http:/www.foe.co.uk/resource/briefing/antibiotic_resistant_genes.html
FoE 2001a, Sound Science? The evidence against Aventis’ GM maize see www.foe.co.uk
FoE, 2001b, Environmental Audit Committee Briefing available at http:/www.foe.co.uk/resource/briefing/
environmental_audit_committee.html
FoE, 2001c, GMOs: The Case for a Moratorium available at http:/www.foe.co.uk/resource/briefing/
gmos_case_for_moratorium.html
FoE, 2001d, GMOs: Scientific reasons for concerns in The Case for a Moratorium available at http:/www.foe.co.
uk/resource/briefing/gmos_case_for_moratorium.html
Fujii T. Transgenerational effects of maternal exposure to chemicals on the functional development of the brain in
the offspring. Cancer Causes and Control: CCC 1997, 8, 524-28.
Garcia AM, Benavides FG, Fletcher T, Orts E. Paternal exposure to pesticides and congenital malformations.
Scandinavian Journal of Work , Environment and Health 1998, 24, 473-480.
Gershon MD. The Second Brain. Harper Perennial, New York, 1999.
Hirose Y, Kobayashi M, Koyama K, Kohda Y, Tanaka T, Honda H, Hori Y, Yoshida K. A toxicokinetic analysis
in a patient with acute glufosinate poisoning. Human and Experimental Toxicology 1999, 18, 305-8.
Ho M-W. Promoting Critical Public Understanding of Science and Enhancing the GM Debate. Institute of
Science in Society available at www.i-sis.org Many other key publications are available at this site.
Hori Y, Koyama K, Fujisawa M, Nakajima M, Shimada K, Hirose Y, Kohda Y, Akuzawa H. Protein binding of
glufosinate and factors affecting it revealed by an equilibrium dialysis technique. J Analytical Toxicology 2001,
25, 439-442.
Horleys. What is Glutamine. http://www.horleys.com/html/article_glutamine_body.html Download 13th May
2002. This report includes many useful references.
Howard CV. Analysis of key documents relevant to the safety of Chardon LL for animal feed purposes. Chardon
LL Hearing, October 2000.
Institute of Medicine. The Role of protein and Amino Acids in Sustaining and Enhancing Performance.
Committee on Military Nutrition Research. National Academy Press, Washington DC 1999. Available at

http://www.nap.edu/openbook/0309063469/html/R1.html

Jewell T, Buffin D. Health and environmental impacts of glufosinate ammonium. Pesticides Action Network,
2001.
Koyama K, Kohda Y, Hisashi H, Koyama Ky, Goto K. Toxicokinetics of glufosinate, an herbicide structurally
analogous to glutamic acid, that causes severe CNS disorders in human acute oral poisoning. Toxicology Letters
1998, 95 (Suppl 1), 140.
Koyama K, Koyama K, Goto K. Cardiovascular effects of a herbicide containing glufosinate and a surfactant: in
vitro and in vivo analyses in rats. Toxicology and Applied Pharmacology 1997, 145, 409-414.
Krogsgaard P and Bundgaard H (editors). A Textbook of Drug Design and Development, Harwood Academic
Publishers, Chur, 1991.
Kutlesa NJ, Caveney S. Insecticidal activity of glufosinate through glutamine depletion in a caterpillar. Pest
Management Science 2001, 57, 25-32.
Leeson S. The Effect of Glufosinate-Resistant Corn on the Growth of Male Broiler Chickens. Report No A56379,
July 1996.
Matsumura N, Takeuchi T, Hishikawa K, Fujii T, Nakaki T. Glufosinate ammonium induces convulsions through
N-methyl-D-aspartate receptors in mice. Neuroscience Letters 2001, 304, 123-5.
Merck Index 12 edition Entry 7495. Merck and Co Inc. Whitehouse Station NJ, 1996.
Monbiot G. Guardian !5th May 2002.
Muller BP, Zumdick A, Schuphan I, Schmidt B. metabolism of the herbicide glufosinate-ammonium in plant cell
cultures of transgenic (rhizomania-resistant) and non-transgenic sugarbeet (Beta vulgaris), carrot (Daucus carota), purple foxglove (Digitalis purpurea) and thorn apple (Datura stramonium). Pest management Science 2001, 57, 46

56.
Nakaki T, Mishima A, Suzuki E, Shintani F, Fujii T. Glufosinate ammonium stimulates nitric oxide production
through N-methyl-D-aspartate receptors in rat cerebellum. Neuroscience Letters 2000, 290, 209-212.
Occhipinti MJ. Learn how to maximise your physical and psychological potential with the “wonder nutrient” L-
Glutamine. http://www.afpafitness.com/Glutamin.htm Download 13th May 2002. Despite its title this report has
some useful references.
Pusztai A. GM Food Safety: Scientific and Institutional Issues. Science as Culture 2002, 11, 69-92.
Richelle M A-K, Butler BJ, Reichert B. Fate of the herbicide glufosinate-ammonium in the sandy low-organic-
carbon aquifer at CFB Borden, Ontario Canada. J Contaminant Hydrology 1995, 18, 161-179.
Stryer L. Biochemistry, 3rd Edition, WH Freeman, New York, 1988.
Takahashi H, Toya T, Matsumiya N, Koyama K. A case of transient diabetes insipidus associated with poisoning
by a herbicide containing glufosinate. J Toxicology. Clinical Toxicology 2000, 38, 153-6.
Tanaka J, Yamashita M, Yamashita M, Matsuo H, Yamamoto T. Two cases of glufosinate poisoning with late
onset convulsions. Veterinary and Human Toxicology 1998, 40, 219-222.
US EPA (United States Environmental Protection Agency) 1988. Quoted in Jewell and Biffin.
Watanabe T, Sano T. Neurological effects of glufosinate poisoning with a brief review. Human and Experimental
Toxicology 1998, 17, 35-9.
Watanabe T. Apoptosis induced by glufosinate ammonium in the neuroepithelium of developing mouse embryos
in culture. Neuroscience Letters 1997, 222, 17-20.
Wingard LB, Brody MB, Larner J, Schwartz A. (editors) Human Pharmacology Molecular to Clinical. Wolfe
Publishing, London, 1991.
Yarema C, McLean H, Caveney S. L-Glutamate retrieved with the moulting fluid is processed by a glutamine
synthetase in the pupal midgut of Calpodes ethlius. J Insect Physiol. 2000, 46, 1497-1507.
Yoshiyama Y, Kobayashi T, Kondo R, Tomonaga F, Ohwada T. Chronotoxicity of glufosinate ammonium in
mice. Veterinary and Human Toxicology 1995, 37, 22-3.
Zonehome Protein and Nitrogen Homeostasis http://www.zonehome.com/met/metprotnit.htm

Appendix

structural relationships between glutamate, glutamine and glufosinate

Feeding the world?

Jules Pretty examines the myths and realities of sustainable farming's quiet revolution

Statements of fact

Ever since we started farming some 10,000 years ago, there has been a constant struggle to make sure that enough food is produced to feed everyone. This challenge has become ever more acute in the last half of this century. Even though we can put people on the moon, we simply cannot find a way to feed the world's population And the problem will get worse before it gets better. This much is agreed, but what we do about it is highly contested. Let's start with some facts. The world population is now 5.9 billion people. It is still increasing, and will eventually stabilise somewhere between 8 and 11 billion. Most of this growth will occur in the poorer countries of the world. Today, a seventh of all the world's people are hungry, 800 million of them. A quarter of these are children.

Food production will have to increase, otherwise we could be faced with crises of epic proportions. But it is not a simple problem. We actually produce enough food in the world to feed everyone with a nutritious and adequate diet now - on average 350 kg of cereal per person. A good deal of cereal is turned into meat, milk and other animal products which in energy terms is inefficient. This reduces the total amount of food available. But a more important factor is that most hungry people are poor and cannot afford to buy food. Poor farmers cannot afford expensive modern technologies that could increase their yields. What they need are readily available and cheap means to improve their farms.

And there are signs that a quiet revolution in the world food system is beginning to occur.

Sustainable highlights

* some 223,000 farmers in southern Brazil using green manures and cover crops of legumes and livestock integration have doubled yields of maize and wheat to 4-5 tons/ha;

* some 45,000 farmers in Guatemala and Honduras have used regenerative technologies to triple maize yields to some 2-2.5 tons/ha and diversify their upland farms, which has led to local economic growth that has in turn encouraged re-migration back from the cities;

* more than 300,000 farmers in southern and western India farming in dryland conditions, and now using a range of water and soil management technologies, have tripled sorghum and millet yields to some 2-2.5 tons/hectare;

* some 200,000 farmers across Kenya who as part of various government and non-government soil and water conservation and sustainable agriculture programmes have more than doubled their maize yields to about 2.5 to 3.3t/ha and substantially improved vegetable production through the dry seasons;

* 100,000 small coffee farmers in Mexico who have adopted fully organic production methods, and yet increased yields by half;

* a million wetland rice farmers in Bangladesh, China, India, Indonesia,Malaysia, Philippines, Sri Lanka, Thailand and Vietnam who have shifted to sustainable agriculture, where group-based farmer-field schools have enabled farmers to learn alternatives to pesticides whilst still increasing their yields by about 10%.

The myth makers

First, though, it's important to look at the myth makers who believe in the 'techno-fix' of genetic engineering as a solution to the looming crisis.

One of the biggest advocates for genetically engineered crops is the American company, Monsanto. Their public relations campaign, 'Let the Harvest Begin' (sic), states that Europeans should stop being selfish in refusing to accept GMOs (genetically-modified organisms) because that is "a luxury our hungry world cannot afford" They say that "agricultural biotechnology will play a major role in realising the hope we all share. Accepting this science can make a dramatic difference in millions of lives".

Also, advocates have not been slow to play the environmental card. But this is done in a remarkably naive way. It is a vital part of the public relations management to persuade citizens in the North to accept the GM technologies, yet it betrays a lack of understanding of developing country agricultural, economic and social systems. Michael Wilson of the Scottish Crops Research Institute said in 1997 - "to feed 10.8 billion people by 2050 will require us to convert 15 million square miles of virgin forest, wilderness and marginal land into agro-chemical dependent arable land. GM crops hold the most important key to solve future problems in feeding an extra five billion mouths over the next 50 years".

"We actually produce enough food in the world to feed everyone with a nutritious and adequate diet now"

To anyone who comes from developing countries or has worked in them, this is simply nonsense. Replying to a comment in late 1997 by a British scientist who said that "those who want it [GMOs] banned are undermining the position of starving people in Ethiopia", Tewolde Berhan Gebre Egziabher of the Institute for Sustainable Development in Addis Ababa, said that "there are still hungry people in Ethiopia, but they are hungry because they have no money, no longer because there is no food to buy... we strongly resent the abuse of our poverty to sway the interests of the European public".

The huge number of people in severe poverty and hunger is a dreadful indictment of all of us. Something must be done.

But that something is not to say we must pursue a path of genetic modification and hang the consequences. I am perfectly open to be persuaded of the benefits of genetic modification - such as for novel treatment of cystic fibrosis or cancers - but not when the feeding the world myth is trundled out again and again.

Perhaps a cereal crop will be engineered to have bacteria in the roots that fix free nitrogen from the air. This would be a tremendous benefit for poor farmers. But unless this technology is cheap or freely available, it seems very unlikely that the people who need it most would ever have access. And what about the plans for 'terminatortechnology'? These are seeds that die after one year so that farmers cannot save the seed and use it again. Will this really benefit the 2 billion people in developing countries currently relying on largely 'unimproved' agricultural systems?

Biotechnology is not currently a necessary precondition for feeding the world. However, it is fair to say that improvements to farming will arise from genetic engineering if the research is public-funded and for the public good. Biotechnology is therefore unlikely to benefit the poor in the short term. These technologies are expensive to develop, estimated at $1 million per gene, and companies are expecting to recoup costs as well as make large profits on sales.

So who will feed all those people in developing countries? The answer to this question is simple - farmers in those countries, using sustainable methods of production.

Sustainable agriculture - the quiet revolution has started

Quietly, slowly and very significantly, sustainable agriculture is sweeping the farming systems of the world.

Put simply, sustainable agriculture is 'farming that makes the best use of nature's goods and service whilst not damaging the environment.' It does this by integrating natural processes such as nutrient cycling, nitrogen fixation, soil regeneration and pest predators into food production processes. It minimises the use of nonrenewable inputs (pesticides and fertilisers) that damage the environment or harm the health of farmers and consumers. And third, it makes better use of the knowledge and skills of farmers, so improving their self-reliance and capacities.

"We strongly resent the abuse of our poverty to sway the interests of the European public"

This sequence is very important. During this century, modern agriculture has seen external inputs of pesticides, inorganic fertiliser, animal feedstuffs, energy, and machinery become the primary means to increase food production. These external inputs, though, have substituted the free, natural control processes and resources. Pesticides have replaced biological, cultural and mechanical methods for controlling pests, weeds and diseases; inorganic fertilisers have substituted for livestock manures, composts. Nitrogenfixing crops and fertile soils; and fossil fuels have substituted for locally-generated energy sources. What were once valued local resources have all too often become waste products.

The basic challenge for sustainable agriculture is to maximise the use of locally-available and renewable resources.

This sounds good - but does it work? Are there sufficient resources and opportunities to turn unproductive farms into surplus-producing ones?

Remarkably, the best evidence comes from those very countries of Africa, Asia and Latin America that are said to need most the 'modern' technologies produced by large companies. Where whole communities have been involved in the complete redesign of farming and other local economic activities, the sustainability dividend is very large. The regenerative technologies and practices are hugely beneficial for both farmers and rural environments. There is more natural capital from fewer external inputs. More food output from fewer fossil-fuel derived inputs.

The improvements are of two basic types. First, sustainable farming is taking root in the resource-poor areas, those that have remained largely untouched by modern technologies of the past 40 years. Here there is a two to threefold increase in food output.

The second is occurring in the higher-input systems where the so-called 'Green Revolution' has already had an impact on food output, but where there are concerns that yield increases have slowed or stopped and where high use of pesticides causes damage to human health and environments. Here the dividend comes from a greatly reduced use of pesticides - they are replaced by natural predators, habitat redesign, multiple cropping and the like whilst increasing yields by a small amount, typically 10%.

Recent evidence from 20 countries has found more than 2 million families farming sustainably on more than 4-5 million hectares. This is no longer marginal. It cannot be ignored. What is remarkable is not so much the numbers, but that most of this has happened in the past 5-10 years. Moreover, many of the improvements are occurring in remote and resource-poor areas that had been assumed to be incapable of producing food surpluses.

The myths and beyond

Another cog in the myth makers' wheel is the expected response of industrialised countries to sustainable agriculture.

At the beginning of the 1990s, the former US Secretary of Agriculture, Earl Butz, said we could move to more sustainable farming, but "before we move in that direction, someone must decide which fifty million of our people will starve. We simply cannot feed, even at subsistence levels, our 250 million Americans without a large production input of chemicals, antibiotics and growth hormones".

Again, this view is simply nonsense, as it once again ignores what is happening right now. In a study for my new book The Living Land, I looked at projects in seven industrialised countries of Europe and North America. Farmers are finding that they can cut their inputs of costly pesticides and fertilisers substantially, varying from 2080%, and be financially better off. Yields do fall to begin with (by 10-15% typically), but there is compelling evidence that they soon rise and go on increasing. In the USA, for example, the top quarter sustainable agriculture farmers now have higher yields than conventional farmers, as well as a much lower negative impact on the environment.

The challenge is still massive. Sustainable farming can greatly improve the productivity of the land. It has already done so for more than two million families in the past five to ten years. Yet there is still a very long way to go. And we need to inform our citizens about what is happening, so that they can form fair judgements on the alternatives we may or may not seek to promote in the name of 'feeding the world'.

Jules Pretty is Director of the Centre for Environment and Society at the University of Essex. His most recent book, "The Living Land.- Agriculture, Food and Community Regeneration in Rural Europe", is published this month [August 1998] by Earthscan Publications of London. An earlier book"Regenerating Agriculture: Policies and Practice for Sustainability and Self-Reliance" (Earthscan, 1995) deals mainly with sustainable agriculture in developing countries.

BIOTECHNOLOGY: NOT THE ANSWER TO HUNGER

By Devinder Sharma (From: The Hindu Business Line, New Delhi/Chennai/Mumbai/Bangalore; July 21, 2000)

The genetic engineering industry has been claiming that at a time when more than 800 million people go to bed hungry, and their number is likely to swell to over 1.5 billion in the next ten years, biotechnology provides the only hope to feed the burgeoning population. Jumping on to the biotechnology bandwagon are many of the Nobel laureates, distinguished agriculture scientists, corporate bigwigs and of course the economists. After all, the cutting-edge technology, as biotechnology is fondly called, provides them with a perfect tool to distract the decision-makers from the more pressing problems of alleviating hunger and poverty.

The fact is that even at present the world has enough food to feed these 800 million hungry mouths. If the food that is currently available is to be evenly distributed among the 6.4 billion people on the planet (providing each individual with a minimum intake of 2,500 calories), there would still be a surplus left for 800 million people. The problem, therefore, is not of production but clearly of access and distribution. It involves more of politics than technology, with biotechnology having virtually no role to play.

More than a third of the world's 800 million hungry live in India. How grim is the poverty scenario is clearly evident from a recent World Bank poverty update: in absolute terms, the number of those below the poverty line who cannot manage two-square meals a day shows a significant increase in the post-reform era (after 1991). The number of the hungry and malnourished in India alone have been steadily rising. In the rural areas, from 224 million in the early 1990's to 250 million in the mid 1990's. This corresponds to an almost constant increase in the incidence of rural poverty and a slow decline in the incidence of urban poverty, the report states.

Eradicating hunger from India, therefore, would alleviate much of the problem at the global level. Successive governments, especially in the past three decades following the advent of green revolution, have, however, very conveniently abdicated their constitutional responsibility to feed the nation. Year after year, the governments have managed a sizeable buffer stock essentially by depriving the poor of their basic human right --- food.

India is once again faced with an unmanageable food glut. From a foodgrain surplus of ten million tonnes in 1999, the stocks have multiplied to 44 million tonnes of wheat and rice this year, some 20 million tonnes more than the annual buffer requirement of about 24 million tonnes. Instead of distributing the surplus grain among those who desperately need it, the government is toying with the idea of either finding an export market or releasing it in the open market (read the private trade) at a subsidised price.

Much of the plentiful stocks are lying in the open for want of adequate storage space, and by the time the next harvest flows into the markets, considerable quantity would have been rendered unfit for human consumption. Is the biotechnology industry competent to address the problems arising from over-production and its lack of distribution? Even if we were to buy the industry's argument that the technology will increase food production, how will it solve India's hunger crisis has never been spelled out and for obvious reasons.

In 1999, India had produced a bumper harvest of wheat, some six million tonnes more than what it produced a year before. It already had a carryover stock of four million tonnes. In effect, the country was saddled with a "surplus' wheat stock of ten million tonnes, above the buffer requirements. Aware that at least 250 million people were going to bed hungry every night, still the government had allowed the surplus stocks to be exported.

Although the country is "self-sufficient" in foodgrain production, reports of hunger and starvation pour in regularly from the infamous Kalahandi region of Orissa. The region, with a population of 20 million, suffers from the pangs of hunger and malnutrition despite any visible signs of ecological devastation. Kalahandi is otherwise a fertile tract and has traditionally been food surplus. So much so that in 1943, at the time of the great Bengal
famine, Kalahandi had come to the rescue of the famine stricken Bengal. Even in Kalahandi, the problem is not of
production. What is not known is that Kalahandi region is the biggest contributor of surplus rice to the central
food reserves. In the past five years, Kalahandi has provided some 50,000 tonnes of rice on an average to the food
reserves of the government of India, the highest from the State. People die of starvation and hunger for the simple
reason that they cannot afford to buy the food they produce.

Meanwhile, an American company, RiceX, has entered into a joint collaboration with the multinational agri-
business giant, Monsanto, to produce and test its patented technology for nutritious food, converting the
traditionally used cattle feed - rice bran - into a human food. While the surplus grains are being exported - much
of it goes for the cattle in the west, the government has invited the American companies to convert cattle feed into
a nutritious food for its ever-growing population of the poor and hungry.

This is merely an attempt to provide a clean cover-up to the collective guilt of the nation, which fails to find a
solution of hunger, malnutrition and starvation. One doesn't know for sure how many Kalahandis' are tucked in
different parts of the country. The only way to escape the humiliation and shame that is associated with governing
over a country where at least a third of the population is deprived of food, is to find solace and escape in cosmetic
measures. Biotechnology is yet another cosmetic tool, which is being attempted in the name of eradicating hunger.

Faulty policies have ensured that food reserves are built essentially by keeping the food away from the reach of
the poor. But with food prices continuously rising, and with the percentage of the population earning less than a
dollar a day also keeping pace, more and more people are finding it difficult to meet their daily food needs. How
will biotechnology provide food to those who are desperately in need? In fact, given the high seed cost, royalty
and the cost of other inputs that the farmers will have to use (for instance, more herbicides in the herbicide-
tolerant plants), the cost of cultivation will go up and so will the market price. Food will then go out of the reach
of still more people. Biotechnology will ultimately subject more people to hunger and starvation. #

(Devinder Sharma is a well-known food and trade policy analyst. He also chairs the New Delhi-based Forum for
Biotechnology and Food Security.
Responses can be emailed at: dsharma@ndf.vsnl.net.in)

EU SUPPRESSES STUDY SHOWING GENETICALLY ENGINEERED CROPS ADD HIGH COSTS FOR ALL FARMERS AND THREATEN ORGANIC

16 May 2002

Brussels - A secret EU study leaked to Greenpeace states that all farmers would face high additional, in some cases unsustainable costs of production if genetically engineered (GE) crops were commercially grown in a large scale in Europe. The study predicts that the situation would become particularly critical for organic farming of oilseed rape as well as for intensive production of conventional maize.

The EU Commission ordered the study on the co-existence of GE and non-GE crops in May 2000 from the Institute for Prospective Technological Studies, of the EU Joint Research Centre. The study was delivered to the EU Commission in January 2002 with the recommendation that it not be made public. (1)

"The European Commission has tried to keep this study secret", said Lorenzo Consoli, Greenpeace EU policy advisor, "because it was afraid of its political implications. The question is, if the introduction of GE crops on a commercial scale in Europe increases costs of production for all farmers, makes them more dependent on the big seed companies, and require complicated and costly measures to avoid contamination, why should we accept GE cultivation in the first place?" The EU study states that in oilseed rape production the co-existence of GE and non-GE crops in a same region, even when "technically possible", would be "economically difficult" because of the additional costs and complexity of changes required in farming practices in order to avoid genetic contamination. Both organic and conventional farmers "would probably be forced to stop saving seed and instead buy certified seed", because of the increased risk of GE impurity for seeds that have been exposed to field contamination. The study predicts that smaller farms would face relatively higher costs compared to larger entities, and that cultivation of GE and non-GE crops in the same farm "might be an unrealistic scenario, even for larger farms".

The main specific findings of the report were:

· Commercialisation of GE oilseed rape and maize and to a lesser extent potatoes will increase costs of farming for conventional and organic farmers at a range between 10 and 41 per cent of farm prices for oilseed rape and between one and nine percent for maize and potatoes.

Coexistence of GE farming and organic farming would be actually impossible in many cases.

Generally, coexistence would only be possible with massive changes in farming practices, especially for conventional farmers; it would also require co-operation between farmers in a region and the willingness of all farmers concerned to participate in such co-operation; it is not clear who would implement these changes, who would be responsible for controlling their correct implementation, who would shoulder their costs.

Seed and crop purity from GE at a detection level of 0.1 percent would be virtually impossible in most cases, i.e. all products and seeds of oilseed rape and maize would be contaminated with GE to a certain extent.

The study, based on a combination of computer modelling and expert opinion, analysed the consequences of an increase in the share of GE crops. It focused on the three crops of which GE varieties are currently available: oilseed rape for seed production, maize for feed production and potatoes for consumption. The study covered several farm types, both organic and conventional farming. It also considered three different threshold levels for genetic contamination: 0.1 percent (analytical detection level) for all the three crops, 0.3 percent for oilseed rape and 1 percent for maize and potatoes. "The fault with GM policy is that test crops are within other agricultural land, therefore cross contamination occurs. Secondly, the findings of these experiments are held by private bodies, so the public don't know whether they are safe or not. Thirdly, the overwhelming practice of such companies is not to use scientific knowledge for the benefit of mankind, but to control it for profit."

Alex Bell, The Herald, 3rd June 2002

This booklet has been produced by GM Free Cymru, which is an alliance of farmers, environmentalists, and other concerned individuals who seek to use lawful democratic processes to keep Wales entirely free of GM crops. The alliance was formed at the time of the successful protest movement at Mathry in Pembrokeshire in the spring of 2001, and has subsequently attracted support from all parts of Wales and further afield. We are not opposed to genetic engineering per se, but believe that the consequences of mixing of genetic material from species that would not normally interbreed are far from fully researched.

The debate on the issue of GM crops is a complex one covering biotechnology, health, big business, politics, economics, and the future of food and farming world-wide. It is a debate that needs to be lengthy and well informed before any decisions are made that might well lead to irreversible agronomic and environmental disruption.

GM CROPS:
WHAT YOU SHOULD KNOW

INTRODUCTION

What are Genetically Modified Organisms?

New Report Challenges Fundamentals of Genetic Engineering; Study Questions Safety of Genetically Engineered Foods

The Market for Genetically Modified Crops

Do GM Crops Mean Less Pesticide Use?

GM Crops Have Failed to live up to expectations

Glyphosate resistance is showing a worldwide rise

University researchers find fungi buildup in glyphosate-treated soybean fields

Bt Corn Linked to Hog Breeding Problems

Modified Crops Could Lead To "Superweeds," Study Suggests

Canadian organic farmers sue Monsanto on GM crops

NFU Policy on Genetically Modified (GM) Foods Preamble

GMO LIABILITY THREATS FOR FARMERS

GENETICALLY MODIFIED FOODS:
ARE THEY A RISK TO HUMAN/ANIMAL HEALTH?

Evidence with special emphasis on the use of
GLUFOSINATE AMMONIUM (PHOSPHINOTHRICIN)

Feeding the world?

The myths and beyond

BIOTECHNOLOGY: NOT THE ANSWER TO HUNGER

EU SUPPRESSES STUDY SHOWING GENETICALLY ENGINEERED CROPS ADD HIGH COSTS FOR ALL FARMERS AND THREATEN ORGANIC

GM CROPS: WHAT YOU SHOULD KNOW

What are Genetically Modified Organisms?

GM Crops Have Failed to live up to expectations

Glyphosate resistance is showing a worldwide rise

University researchers find fungi buildup in glyphosate-treated soybean fields

Bt Corn Linked to Hog Breeding Problems

Modified Crops Could Lead To "Superweeds," Study Suggests

GMO LIABILITY THREATS FOR FARMERS

GENETICALLY MODIFIED FOODS: ARE THEY A RISK TO HUMAN/ANIMAL HEALTH?

The myths and beyond

GM CROPS:
WHAT YOU SHOULD KNOW

GENETICALLY MODIFIED FOODS:
ARE THEY A RISK TO HUMAN/ANIMAL HEALTH?