Protest against GM potato application by BASF
Press Notice from GM Free Cymru Date: 19 October 2006 14:18:34 BDT
To: gm-regulation@defra.gsi.gov.uk
APPLICATION FOR A PART B CONSENT FROM BASF PLANT SCIENCE TO RELEASE GENETICALLY MODIFIED POTATOES WITH IMPROVED RESISTANCE TO Phytophthora infestans
APPLICATION REFERENCE: 06/R42/01
BASF Plant Science has applied to Defra for consent to perform a deliberate release of genetically modified organism for research and development purposes.
Dear GM Unit,
We wish to protest in the strongest possible terms about this application, and after looking at the relevant papers and reviewing recent events, we are convinced that GM contamination, and other undesirable consequences, would be inevitable if BASF is given consent to proceed. Until coexistence and liability issues have been sorted out (cf the ongoing coexistence consultation) it would be irresponsible to issue a consent in this case. The GM rice fiasco also confirms that GM contamination is effectively impossible to control.
We are persuaded by the following points made by various of our colleagues with respect to this application and a similar one in Ireland:
• There is clear risk of cross-contamination of UK potatoes.
• The transfer of genes between the potato Solanum tuberosum and its wild relative Solanum bulbocastanum may lead to novel proteins with powerful or fatal immune responses, potential inflammation as well as allergenicity effects.
• If the GM potato proves to be immunologically active, the impact on both human and animals may be severe.
• It appears that no animal feeding studies have been done.
• It appears that no environmental or health impact studies are planned.
• The expression of the modifiying genes in glasshouse experiments was not studied under real outdoor weather conditions such as drought, waterlogging, heat, cold, nitrogen excess or starvation which could lead to unexpected toxicity.
• Risk assessments of the impact of the experiment on non-target organisms seem to be based on an assumption of safety, and do not provide for an adequate monitoring scheme.
• The isolation distance 20 meters to cultivated potatoes is totally inadequate.
• Post-release treatment of the test site does not seem adequately monitored nor will it achieve a clean post-harvest site.
• The considerations of human and environmental safety seem primarily based on wishful thinking rather than on on any serious efforts to gather or obtain factual information on the safety of the GM constructs.
• Monitoring also seems based on wishful thinking rather than serious efforts to detect negative impacts.
• Field testing of broad spectrum NBS-LRR genes has begun with the potato blight resistant strains. Broad spectrum pest resistant strains of rice, maize, soybean, and numerous food crops will soon follow. It is imperative that the safety of these genetic modifications to humans and the environment be fully evaluated before the GM crops are commercialized.
• The proposition that the NBS-LRR family of plant pest resistance genes and their products provide safe transgenes for human consumption and for environmental release because they are found in food crops (and for that reason require no further testing) is simply foolhardy.
• The suggestion that NBS-LRR genes can be assumed safe until proven hazardous certainly appeals to greedy promoters of GM crops but does not serve the public good.
• Has BASF provided a karytopye (microscopic picture) of the potato chromosomes?
• Has BASF provided information on the segregation of particular genes in the potato "volunteers" for your consideration?
• BASF's claim that "there are no compoments of the vectors [genes] known to code for harmful substances" can not be justified only by comparison of data bases for evidence of toxicity, because inflammation (a potent immune response) is not considered in allergy data bases, and would likely be ignored because available data bases do not include information about inflammation from plant proteins.
• Regulatory genes in the GMO potatoes may produce a strong response without producing a great deal of protein, which may contribute to pest resistance. This should have been studied in glasshouse rather than field experiments to provide a controlled study environment.
• BASF claims that the occurence of epigenetic and pleiotropic effects (control by a single gene of several distinct effects and changes in cellular biochemistry) caused by the introduded genetic material is "remote". The modified DNA is bound to produce both of these phenomena because they govern a range of responses leading to cell death, and that such impacts need to be considered.
• BASF admits that none of the GMO potato lines intended for release have been analysed for the main toxic and anti-nutritional substances found in potatoes, but that this does not matter because none of the genes introduced from the wild potato species are "known to exert any toxic or allerenic effects on human health." But inter-specific gene transfer has led to the formation of a toxin causing inflammation in mammals, and it seems unwise to ignore that finding and proceed based on blind supposition. Certainly the regulatory proteins are known to be immunologically active but these and toxic effects of the proteins from S. bulbocastanum have not been studied adequately regarding their impact on mammals.
* In response to BASF's claim that the overall impact on human health is negligible, it should be noted that The Canadian Food Inspection Agency reviewed a mutant ahas gene used to confer resistance to imidazolinones in spring wheat. That mutant was not a transgene but was a mutation selected in spring wheat. There is no real justification in implying that the mutation and its consequences are the same as the results of an inter-species transgene transfer between Arabidopsis (bearing a different mutation) and potato. At any rate the Canadian Agency assumed that mutant and natural ahas were substantially equivalent but did not do any experiments to support their superstition.
• In response to BASF's admission that no animal feeding trials have been carried out on any of the GMO potatoes intended for the release, have any animal feeding experiments been initiated or completed using material from the Swedish field trials? Those trials should have provided more than enough material for animal feeding studies and would have provided useful information about the impact of two of the three genes.
• In response to BASF's claim that "none of the genes are known to exert any toxic or allergenic effects to human health" Prof Cummins states "the search of DNA sequence data is necessary but not sufficient to establish safety of transgenes. Even interspecies plant gene transfers can lead to toxic products. In one reported case the plant to plant gene transfer led to protein modifications that cause immunotoxicity leading to inflammation. Common sense leads us to the need for direct animal feeding experiments for all of the transgenic crops, whether plant to plant, bacteria to plant, fungus to plant or human to plant."
• BASF told the Irish EPA that the likelihood of a change in the pathogenicity of the late potato blight fungus "is considered negligible." That may be the BASF view, but the basic question is 'how soon will the fungus grow resistant to the transgenic potato?' Appropriate glasshouse experiments should provide a useful estimate as to the time to resistance. Turning to the S. bulbocastanum-S.tuberosum somatic hybrids, Prof Joe Cummins concluded that the hybrids proved too unstable to produce commercial lines. If the lines were stable then there would not likely be any need for BASF to promote transgenic lines.
To quote Prof Joe Cummins: "It is worth pointing out that there do not appear to be any published reports on the experiments where the somatic hybrid potatoes were fed to mammals in a laboratory situation. Since breeding clones of blb2 have been grown in the Netherlands since 1999 it is surprising that no effort has been reported on the tests of such clones in animal feeding experiments. Of course, it would be negligent to withhold such studies, should they exist."
It is regrettable that although the purpose of the release is 'to compile data on agronomical performance and environmental effects and evaluate resistance against Phytophthora infestans and collect material for further (and unspecified) analyses...', we have very little information on the scope of these studies, or the methods to be employed. This is just not good enough.
We are particularly worried in view of the accumulating evidence for the potential negative health effects observed with many other GM potato lines. Every part of the potato plant is toxic for human and animals and even the tuber may become toxic when exposed to sunlight, etc. Thus because all cells of the potatoes carry the same genetic information, the importance of the exclusion of possible unintended alterations resulting from gene-splicing ought to have featured prominently in the submission. This is not even mentioned by the applicant, so far as we can see. As pointed out by Dr Arpad Pusztai, this is further aggravated by the fact that most experimental work reported in science journals is full of negative findings and most GM potato lines do not even satisfy the conditions of substantial equivalence with their isogenic parent lines.
In a submission to the Irish EPA, Dr. Pusztai concluded: "In view of all the accumulating data showing that GM potatoes of all kinds investigated to date have shown unacceptable compositional, metabolic, immunological effects and potentially toxic behaviour, it is imperative for the Irish EPA to reject this request by BASF for field trial of their GM potatoes until and unless they are first subjected to independent environmental and health risk assessments using a scientific protocol openly agreed and approved by independent scientists and representatives of the public and consumer groups."
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Our conclusion is that the BASF proposal to release transgenic potatoes in the UK is premature and even foolhardy since there is still a need for proper laboratory and glasshouse studies to insure the safety of the recombinant organisms. In particular, BASF has made little or no reference to evidence that plant to plant gene transfer may lead to formation of proteins toxic to mammals.
Please register our protest, send us an acknowledgement, and keep us informed of the progress of this application.
Yours sincerely,
Dr Brian John
GM Free Cymru