This letter follows one sent earlier by GM-Free Cymru to Commissioner John Dalli, in which we asked him to order an urgent review of all existing GM soy consents within the EU, with our concerns arising from the mounting evidence of harm associated with GM soy and the Roundup herbicide which is an inevitable component in the toxic mix. Our letter was also triggered by the "Danish Dossier" which outlined the very worrying findings of pig farmer Ib Pedersen and his colleagues who have been using GM soy in their animal feed rations.
The Danish Dossier is here: http://www.gmfreecymru.org/pivotal_papers/danish_dossier.html
Our original letter to Commissioner Dalli is here: http://www.gmfreecymru.org/open_letters/Open_letter01May2012.html
and his reply is here: http://www.gmfreecymru.org/open_letters/Open_letter28June2012.htm
In view of the complacency and evasiveness of this response, we are now convinced that the Commission is operating a "Don't Look, Don't See" policy with respect to GM soy. We suspect that Europe is now so deeply entrenched in its policy of dependence on imported GM soy from Argentina and Brazil that it does not know how to extricate itself -- but if the GM soy/Roundup cocktail is demonstrated unequivocally to be harmful to the animals that consume it, what then? This is the "perfect storm" that we have warned about........
Here is our response to the Commissioner's letter:
John Dalli Commissioner for Health and Consumer Policy European Commission Brussels Belgium
18th July 2012
Dear Commissioner Dalli,
On 1st May 2012 we wrote to you with an urgent request for an EFSA reappraisal of all EU consents issued thus far for GM soya varieties which are imported for food and feed into Europe. We did this in response to the accumulating evidence of harm to the health of people and animals arising from the production and consumption of both the crops themselves and the associated residues of Roundup and other chemicals. We gave you specific references to support the case we were making, and brought to your attention the disturbing findings of Danish pig farmers who have been using GM soya products in the feed given to their animals.
Your response (on 28 June) was profoundly disappointing. We found it complacent and disingenuous, and we are now quite convinced that the Commission's refusal to address the very serious toxic effects of GM soy and Roundup herbicide is both complacent and wilfully negligent, in the light of abundant scientific evidence published in the peer- reviewed scientific literature. This is a very serious matter indeed.
We now turn to some of the points from your letter.
1. You say that according to the regulatory framework "any genetically modified organism, before being placed on the market within the EU, has to undergo a specific safety assessment of the highest possible standard by the European Food Safety Authority (EFSA) in order to protect human and animal health and environment." We do not accept that statement. EFSA does not undertake safety assessments itself; it simply gives consideration to the studies presented by the applicants for GM consents and which they choose to call "safety assessments." Many of them are simply nutritional studies, designed by the applicants to demonstrate the equivalence of the GM crop with its non-GM isoline. We are not aware of any feeding studies which have been conducted for more than 90 days; and we are not aware of any multi-generational studies submitted in support of a GM soy application. EFSA has never, to the best of our knowledge, considered the health impact of glyphosate or glufosinate residues (which are always present) which are consumed whenever GM soy is in the diet. This is contrary to the Regulations which quite specifically require "indirect" effects to be borne in mind, especially where GM crops are engineered to be herbicide tolerant. Further, we are aware of a great deal of fraudulent science included in applicants dossiers, and we are also aware that this has not been picked up or commented upon by EFSA. Far from being "of the highest possible standard", we fear that the safety assessments to which you refer are inadequate and often quite useless for demonstrating the safety of GM soy and other crops for human consumption.
2. With respect to the "safety assessments" of GM soy, we are not aware of a single study that shows that GM soy (with its associated chemical residues) is safe for consumption either by domesticated animals or human beings. EFSA presumes to know that "stacked" GM soy varieties are perfectly safe simply because it thinks that the GM lines used in the plant breeding process are safe; that is, as many correspondents have pointed out, unscientific and irresponsible. EFSA steadfastly refuses to consider the environmental and health effects arising from GM soy cultivation in the areas where it is grown, pretending that such things are "none of its business". We have argued in the past, and will continue to argue, that such sophistry does EFSA no credit at all; and the public knows that if animals and people are harmed in the areas where GM soy is grown (as they are) they are probably going to be harmed as well in the places where GM soy -- and its residues -- are consumed. Will you please tell us which studies show unequivocally that GM soy and its residues are safe to eat?
3. Your comments on plant protection products demonstrate that nobody -- least of all EFSA -- is doing any joined-up thinking on GM soy and Roundup residues. It is a handy get-out device to simply state that Member States are supposed to look after the implementation of the pesticide regulations. But we all know that Roundup, for example, was approved for specific uses in 2002 -- and that neither EFSA nor the Commission appear to have paid any attention at all to the wealth of information in the peer-reviewed journals which show damage at very low concentrations to non-target organisms. Roundup is a highly toxic and very dangerous substance, and it is incredible that the Commission still seems to think that the judgements about its "safety" that applied in 2002 still apply today, after a further decade of research. Over and again this material has been brought to your attention; and over and again you simply appear to ignore it or dismiss it.
4. You say: "....... once a GMO is authorised for food and feed or cultivation uses, the potential effects of GM plants on the environment and health, even unforeseen ones, are monitored." We are not aware of any monitoring being done on the 8 GM soy varieties already approved for import into the EU for food and feed uses. Who does this monitoring? Where are the reports and the results? Where are the EFSA comments on the information submitted? We will appreciate chapter and verse.
5. We refer to this statement: "As regards your allegations about negative effects of glyphosate on human and animal health, it must be observed that, to date, this view is not shared by the competent Member States' authorities...." Again we find this statement disingenuous. Member states appear to be winding down their regulatory activities in deference to the supposedly more efficient EU regulatory system, and indeed as a cost-cutting measure. In the UK it has been stated that certain regulatory bodies do not want to "duplicate" EU regulatory activity within EFSA and other bodies. This trend is, we believe, encouraged by the Commission, for political and other reasons. You cannot have it both ways. If the Member States are increasingly deferring to the Commission, it is now down to the Commission to take a lead by looking at the evidence presented to you by Earth Open Source and many other independent bodies, and to take decisive action for the protection of the consumer.
6. You say: "........ so far, none of the findings reported in the press has been considered robust enough to overrule the existing marketing and use conditions set out when the substance had been originally approved in 2002." We find that a quite extraordinary statement. Findings reported in the press are irrelevant, and we all know that. What matters are published scientific studies in reputable journals -- and as we have said before, in the last decade they are increasingly showing that Roundup is unsafe and harmful outside and within the food supply. These studies exist. We know about them -- and, we suspect, so do you and your advisers.
7. We are not quite sure what you are trying to say about the 30 million tonnes of GM soy imported into the EU each year from countries like Argentina and Brazil. Are you suggesting that even if it is dangerous to the health of animals and human beings, you are still intent on continuing with this large-scale importation? The over- dependence upon a source which has not been adequately assessed or regulated is exactly what we are warning about -- and we used the phrase "perfect storm" advisedly. In our view the EU is already tied in to the large-scale importation of a demonstrably harmful product, and the Commission has to take full responsibility for that state of affairs. You MUST phase out GM soy and replace it with non-GM supplies which are readily available in large quantities -- and we urge you to use all diplomatic means possible to get the growers in South America to switch to non-GM varieties if they wish to continue to supply the European market. RTRS is an irrelevance set up for the convenience of the GM corporations, and designed to give some sort of "respectability" to GM soy; but GM soy is harmful, and when that is fully confirmed by new studies -- as it will be -- the instinct of those involved in RTRS will be to pretend that the studies are somehow flawed. We trust that the EC will not be suckered into that campaign of denial, since that will compound an already serious situation.
8. You conclude: "I am confident that the regulatory framework provides for the assurance of a high-level of protection of human and animal health and the environment. The Commission will continue to fulfil its responsibilities in the implementation of this legislation which we constantly monitor for possible improvements." We do not share your confidence, and we are constantly dismayed to discover more and more about the shortcomings of the regulatory process and to discover just how serious is the risk to the health of the people of Europe as a consequence.
We therefore return to the conclusion of our earlier letter, and urge you once again to invoke the Precautionary Principle -- as you are required to do in the Regulations -- and to act as follows:
(a). Please immediately suspend all ongoing assessments of GM soy varieties that may be in the approvals pipeline.
(b). We also urge you immediately to instruct EFSA to conduct a thorough reassessment of all the GM soy consents that are currently valid, for varieties ACS-GM005-3, MON-89788-1, MON-04032-6, MON-87701-2, DP-356043-5, and AG-GM006-4 and any others that we might have missed.
(c). Further, we ask you to take urgent steps to instigate an in-depth study of the causes of the toxic effects observed by Mr Pedersen and Mr Christensen so that measures can be put in place across Europe to address very serious animal welfare and human health issues. Monitoring is not enough -- a comprehensive trial must be started at once.
(d). Please set up a dialogue between your officials and the scientists who have for so long been demonstrating through their studies that GM soy is damaging to the health of animals that consume it, and that Roundup / glyphosate even in very low concentrations may be triggering off chronic but measurable toxic effects in animals, causing reduced fertility, and leading to a greater and greater use of antibiotics and other medications. The bottom line, as these scientists will tell you, is increased health damage in the human population of Europe, reduced food security, and reduced farm profitability.
(e). Please take steps to reduce the dependence of European farming on imported GM soy, initially by securing large-scale supplies of certified GM-free soy, and then by incentivising the planting of non- GM protein crops within Europe.
You have effectively refused to take seriously any of these points. It is not too late to take action, but we fear that it soon will be.
Thank you for your consideration. We look forward to hearing of the steps which you now propose to take.
Dr Brian John