GM Free Cymru


OPEN LETTER 10th February 2010

Rt Hon Hilary Benn Secretary of State for the Environment

cc Rt Hon Andy Burnham Secretary of State for Health

10th February 2010

Dear Mr Benn,

GM safety issues -- 70 key papers

Given the comments we have recently seen attributed to you that the Government is unaware of any evidence showing that GM crops and foods are harmful, we would like to remind you that you have, over the last few years, received information about many studies that do indeed demonstrate harm. Presumably you have simply passed them over to FSA and ACNFP and asked them for clarification? About a year ago, when Gundula Azeez of the Soil Association brought some published material to your attention, you said: "if you would let me have details of the research I'd be very happy to have a further look at it." We assume that that indicates a willingness on your part to examine personally the literature that relates to GM crop and food safety.

We therefore enclose for you a list of around 70 research papers which, individually and when taken together, indicate unequivocally that GM crops and foods trigger off certain predictable physiological changes in mammals and must therefore be assumed (by all the rules of medical science) to be damaging to humans. Please feel free to pass this list over to your scientific advisers and invite them to look at the TOTALITY of what is contained. We fully expect them to say "Ah yes, that person has been discredited", and "That journal is not peer- reviewed" (as we can do with much of the literature cited in support of GM safety) -- but we also expect them to demonstrate a basic scientific capacity to see common themes and trends, and to advise you accordingly.

Please forgive any small errors or discrepancies in the list, which has been compiled from many different sources. If you would like further details of any particular paper, we will be happy to oblige; we do have most abstracts on file, and also many PDFs.

We now ask you for an immediate moratorium on all GM consents. Further, will you and your colleague Andy Burnham ask the FSA to commission a definitive GM feeding study designed to confirm or contradict the American Academy of Environmental Medicine findings? The researchers should include both government scientists and independent scientists, who will together design and perform the trial and analyse the results. All the scientists must be satisfied at every stage that the experiment is being carried out correctly. The independent scientists must be truly independent, with no present or previous interests in the GM industry, either financial or related to career or funding.

This is now a matter of urgency. We look forward to a positive response.

Yours sincerely,

Dr Brian John GM-Free Cymru

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Briefing Note from GM-Free Cymru, 10 February 2010


In 2009 the American Academy of Environmental Medicine issued a paper containing the following: “several animal studies indicate serious health risks associated with GM food consumption including infertility, immune dysregulation, accelerated aging, dysregulation of genes associated with cholesterol synthesis, insulin regulation, cell signalling, and protein formation,and changes in the liver, kidney, spleen and gastrointestinal system”. The Executive Committee concluded that: “There is more than a casual association between GM foods and adverse health effects. There is causation as defined by Hill's Criteria in the areas of strength of association, consistency, specificity, biological gradient, and biological plausibility. …........”

"I believe that the major hazards of the highly mutagenic plant transformation techniques are the potentials for a decrease in nutritional content or an increase in dangerous metabolites." (Prof David Schubert, 2005)

It has to be concluded that the UK Government is not in possession of any safety research into GM foods. In 2003 the UK Government (which claimed to be impartial on GM issues) placed huge pressure on the Zambian Government to persuade it to accept GM food aid shipments from the USA, but refused frequent requests from the Zambian Chief Scientist to see the UK’s actual research into the safety of GM foods. As we are all aware, 2003 was the year of the most recent review of GM safety in the UK, and the Government has certainly not commissioned any safety research since then.

Below we have listed 70 or so papers which are frequently cited in reviews of GM health effects and safety studies. The list is by no means exhaustive. Most of the papers are in peer-reviewed journals, but some are not. Other papers are reviews of the literature or in- depth analyses of the evidence. They all make important points and present crucial data. What is striking is that many of the authors are very cautious indeed in drawing conclusions or in attaching significance to the physiological changes they have discovered; but almost universally they urge research replication, follow-up studies, and longer feeding trials. In some ways it is a miracle that there are so many studies showing up things that are "inconvenient" from the point of view of the GM industry and the UK government, given the scenario that we are all familiar with -- the blocking of research by companies which will not provide research and reference materials, the intimidation and vilification of scientists who dare to challenge the safety dogmas of the biotech industry, and the hostility of referees and journal editors towards people whom they consider to be "mavericks." Behind every one of these papers there is a story -- sometimes involving the sort of skulduggery that we are more familiar with in conspiracy movies or crime thrillers. But in spite of everything, these papers keep on appearing, and as long as they do, the pro-GM governments of USA, UK, Canada, Australia and many other countries will find it increasingly difficult to continue to exist in a state of denial..........

Some will criticise this list (as they have done with other lists and citations) because there are some papers that are not published in peer-reviewed journals. As we all know, the great bulk of papers that supposedly "confirm the safety of GM crops and foods" are not in peer- reviewed journals either -- and the fact that a paper is peer-reviewed does not mean that it is a competent study or that its referees were impartial. Others will protest because the list contains the names of "known anti-GM activists." Perhaps these critics will explain why these people are supposed to be untrustworthy, or scientifically incompetent, as compared, for example, with Monsanto employees or scientists who have obtained their research funding from the biotechnology industry, or even academics whose future career prospects depend upon the promotion of GM crops and foods as "entirely harmless"??



(1) Agodi, A. et al. (2006) "Detection of genetically modified DNA sequences in milk from The Italian market". International Journal of Hygiene and Environmental Health, 209, 81-88.

(2) Benachour N, Sipahutar H, Moslemi S. et al. "Time- and dose- dependent effects of roundup on human embryonic and placental cells". Arch Environ Contam Toxicol. 2007;53:126-133

(3) Benachour, N. and Seralini, G-E. 2008, "Glyphosate Formulations Induce Apoptosis and Necrosis in Human Umbilical, Embryonic, and Placental Cells", Chemical Research in Toxicology, DOI: 10.1021/ tx800218n. Publication Date (Web): December 23, 2008

(4) Bernstein, I.L., Bernstein, J.A., Miller, M., Tierzieva, S., Bernstein, D.I., Lummus, Z., Selgrade, M.K., Doerfler, D.L. and Seligy, V.L. (1999). "Immune responses in farm workers after exposure to Bacillus thuringiensis pesticides", Environmental Health Perspectives 107, 575-582

(5) Chowdhury, EH., et al (2003) "Detection of corn intrinsic and recombinant DNA fragments and Cry1Ab protein in the gastrointestinal contents of pigs fed genetically modified corn Bt11". Journal of Animal Science 81, 2546-2551.

(6) Cisterna B, Flach F, Vecchio L, Barabino SM, Battistelli S, Martin TE, Malatesta M, Biggiogera M. 2008, "Can a genetically- modified organism-containing diet influence embryo development? A preliminary study on pre-implantation mouse embryos". Eur J Histochem. 2008 Oct-Dec; 52(4):263-7.

(7) Duggan et al., 2003, "Fate of genetically modified maize DNA in the oral cavity and rumen of sheep", British Journal of Nutrition, 2003,

(8) Dutton, A., H. Klein, J. Romeis, and F. Bigler, 2002, “Uptake of Bt-toxin by herbivores feeding on transgenic maize and consequences for the predator Chrysoperia carnea,” Ecological Entomology 27 (2002): 441–7

(9) Ermakova, I.V. 2006, “Genetically modified soy leads to the decrease of weight and high mortality of rat pups of the first generation. Preliminary studies,” Ecosinform 1 (2006): 4–9.

(10) Ermakova, I.V. 2009. "Influence of soy with gene EPSPS CP4 on the physiological state and reproductive functions of rats in the first two generations," Russian Academy of Natural Sciences, "Modern problems of science and education" № 5, 2009. UDC: 612.82, 57.02

(11) Ewen S.W. and Pusztai A., 1999 “Effect of diets containing genetically modified potatoes expressing Galanthus nivalis lectin on rat small intestine’”, Lancet, vol. 354, pp. 1353–1354.

(12) Fares NH, El-Sayed AK. 1998 "Fine structural changes in the ileum of mice fed on delta-endotoxin-treated potatoes and transgenic potatoes". Nat Toxins. 6: 219-33.

(13) Finamore A, Roselli M, Britti S, Monastra G, Ambra R, Turrini A and Mengheri E. (2008). "Intestinal and peripheral immune response to MON810 maize ingestion in weaning and old mice". J Agric Food Chem, 16 November 2008

(14) Fu, TJ. et al. (2002) "Digestibility of food allergens and nonallergenic proteins in simulated gastric fluid and simulated intestinal fluid – A comparative study". Journal of Agricultural Food Chemistry, 50, 7154-7160.

(15) Guerrero, GG. W.M. Russel and L. Moreno-Fierros, 2007: "Analysis of the cellular immune response induced by Bacillus thuringiensis Cry1Ac toxins in mice: Effect of the hydrophobic motif from diphtheria toxin". Molecular Immunology 44, 1209-1217 (2007)).

(16) Kilic, A. and M. T. Akay (2008). "A three generation study with genetically modified Bt corn in rats: Biochemical and histopathological investigation". Food Chem. Toxicol. 46(3): 1164-1170.

(17) Kroghsbo S, Madsen C, Poulsen M, Schrøder M, Kvist PH, Taylor M, Gatehouse A, Shu Q, Knudsen I. "Immunotoxicological studies of genetically modified rice expressing PHA-E lectin or Bt toxin in Wistar rats". Toxicology. 2008 Mar 12;245(1-2):24-3

(18) Lutz, B. et al. (2005) "Degradation of Cry1Ab protein from genetically modified maize in the bovine gastrointestinal tract". Journal of Agricultural Food Chemistry, Published on Web, 10.1021/ jf0492222x, American Chemical Society.

(19) Malatesta, M., F Perdoni, G Santin, S Battistelli, S Muller, M Biggiogera (2008). "Hepatoma tissue culture (HTC) cells as a model for investigating the effects of low concentrations of herbicide on cell structure and function". Toxicol In Vitro. 2008 Sep 18; : 18835430

(20) Malatesta M, Caporaloni C, Gavaudon S. et al. 2002, "Ultrastructural morphometrical and immunocytochemical analyses of hepatocyte nuclei from mice fed on genetically modified soybean". Cell Struct Function. 2002; 27:173-180

(21) Malatesta M, Biggiogera M, Manuali E. et al. 2003, "Fine structural analyses of pancreatic acinar cell nuclei from mice fed on genetically modified soybean". Eur J Histochem. 2003; 47:385-388

(22) Manuela Malatesta, Federica Boraldi, Giulia Annovi, Beatrice Baldelli, Serafina Battistelli, Marco Biggiogera, Daniela Quaglino. (2008) "A long-term study on female mice fed on a genetically modified soybean: effects on liver ageing". Histochem Cell Biol. 2008 Jul 22; : 18648843

(23) Malatesta, M. et al. (2002b) "Ultrastructural analysis of pancreatic acinar cells from mice fed on genetically modified soybean". Journal of Anatomy, 201, 409-446.

(24) Mazza R, Soave M, Morlacchini M, Piva G, Marocco A.(2005) "Assessing the transfer of genetically modified DNA from feed to animal tissues". Transgenic Res. 2005 Oct;14(5):775-84.

(25) Netherwood, T. (2004) "Assessing the survival of transgenic plant DNA in the human gastrointestinal tract". Nature Biotechnology, 22, 204-209.

(26) Nordgård L , Grønsberg IM, Hegge B, Fenton K, Nielsen KM, Bardocz S, Pusztai A and Traavik T. 2009. An examination of the fate of feed-derived DNA in various tissue samples of actively growing rats, pregnant rats and their foeti. Submitted

(27) Prescott V.E., Campbell P.M., Moore A., Mattes J., Rothenberg M.E., Foster P.S., Higgins T.J. and Hogan S.P. 2005, “Transgenic expression of bean alpha-amylase inhibitor in peas results in altered structure and immunogenicity”, J Agric Food Chem., vol 53, pp. 9023– 9030, ., 2005

(28) Pryme, IF and Rolf Lembcke, 2003, “In Vivo Studies on Possible Health Consequences of Genetically Modified Food and Feed—with Particular Regard to Ingredients Consisting of Genetically Modified Plan Materials,” Nutrition and Health 17(2003): 1–8.

(29) Séralini GE, de Vendômois JS, Cellier D, Sultan C, Buiatti M, Gallagher L, Antoniou M, Dronamraju KR. "How Subchronic and Chronic Health Effects can be Neglected for GMOs, Pesticides or Chemicals". Int J Biol Sci 2009; 5:438-443.

(30) Seralini GE, Cellier D, Spiroux de Vendomois J. 2007, "New analysis of a rat feeding study with a genetically modified maize reveals signs of hepatorenal toxicity". Arch Environ Contam Toxicol. 2007;52:596-602

(31) Sharma R, Alexander TW, John SJ, Forster RJ, McAllister TA. 2004, "Relative stability of transgene DNA fragments from GM rapeseed in mixed ruminal cultures". Br J Nutr. 2004 May;91(5):673-81.

(32) Sharma R, Damgaard D, Alexander TW, Dugan ME, Aalhus JL, Stanford K, McAllister TA. (2006) "Detection of transgenic and endogenous plant DNA in digesta and tissues of sheep and pigs fed Roundup Ready canola meal". J Agric Food Chem. 2006 Mar 8;54(5): 1699-709.

(33) Tayabali AF and Seligy VL. 2000, "Human cell exposure assays of Bacillus thuringiensis commercial insecticides: production of Bacillus cereus-like cytolytic effects from outgrowth of spores". Environ Health Perspect 108: 919-930, (2000).

(34) Trabalza-Marinucci M, Brandi G, Rondini C, Avellini L, Giammarini C, Costarelli S, Acuti G, Orlandi C, Filippini G, Chiaradia E, Malatesta M, Crotti S, Antonini C, Amagliani G, Manuali E, Mastrogiacomo AR, Moscati L, Haouet MN, Gaiti A, Magnani M (2008). "A three year longitudinal study on the effects of a diet containing genetically modified Bt176 maize on the health status and performance on sheep". Livestock Sci 113:178–190

(35) Tudisco R, Lombardi P, Bovera F, d’Angelo D, Cutrignelli MI, Mastellone V, Terzi V, Avallone L, Infascelli F (2006) "Genetically modified soya bean in rabbit feeding: detection of DNA fragments and evaluation of metabolic effects by enzymatic analysis." Anim Sci 82:193–199

(36) RI. Vázquez, L. Moreno-Fierros, L. Neri-Bazán, G.A. De la Riva and R. López-Revilla: "Bacillus thuringiensis Cry1Ac protoxin is a potent systemic and mucosal adjuvant". Scandinavian Journal of Immunology 49, 578-584 (1999);

(37) Vazquez Padron, R.I., Moreno Fierros, L., Neri Bazan, L., De la Riva, G.A. and Lopez Revilla, R. "Intragastric and intraperitoneal administration of Cry1Ac protoxin from Bacillus thuringiensis induces systemic and mucosal antibody responses in mice". Life Sciences 64, 1897-1912. (1999);

(38) Vazquez-Padron, R.I., Moreno-Fierros, L., Neri-Bazan, L., Martinez-Gil, A.F., de la Riva, G.A. and Lopez-Revilla, R.(2000) "Characterization of the mucosal and sytemic immune response induced by Cry1Ac protein from Bacillus thuringiensis HD 73 in mice". Brazilian Journal of Medical and Biological Research 33, 147-155 (2000);

(39) Vazquez Padron, R.I., Gonzalez Cabrera, J., Garcia Tovar, C., Neri Bazan, L., Lopez Revilla, R., Hernandez, M., Morena Fierros, L. and De la Riva, G.A. (2000) "Cry1Ac protoxin from Bacillus thuringiensis sp. kurstaki HD73 binds to surface proteins in the mouse small intestine". Biochemical and Biophysical Research Communications 271, 54-58 (2000)).

(40) Vazquez-Padron, RI. Et al. (2000) "Characterization of the mucosal and systemic immune response induced by Cry1Ac protein from Bacillus thuringiensis HD 73 in mice". Brazilian Journal of Medical and Biological Research 33, 147-155.

(41) Vecchio L, Cisterna B, Malatesta M, Martin TE, Biggiogera M (2004) "Ultrastructural analysis of testes from mice fed on genetically modified soybean". Eur J Histochem 48:449–453

(42) Velimirov A, Binter C and Zentek J. (2008) "Biological effects of transgenic maize NK603xMON810 fed in long term reproduction studies in mice". Report, Forschungsberichte der Sektion IV, Band 3. Institut für Ernährung, and Forschungsinttitut für biologischen Landbau, Vienna, Austria, November 2008.

(43) Vendômois, JS, François Roullier, Dominique Cellier and Gilles- Eric Séralini. 2009, "A Comparison of the Effects of Three GM Corn Varieties on Mammalian Health" . International Journal of Biological Sciences 2009; 5(7):706-726

(44) Yum, HY. (2005) "Genetically modified and wild soybeans: An immunologic comparison". Allergy and Asthma Proceedings, 26, 210-216.


(45) Carman J. 2004, "Is GM Food Safe to Eat?" In: Hindmarsh R, Lawrence G, editors. Recoding Nature Critical Perspectives on Genetic Engineering. Sydney: UNSW Press; 2004. p. 82-93.

(46) Cummins J and Ho MW. 2006. "GM crops for health?" ISIS Report, 24 September 2006, submitted to Codex Alimentarius public consultation

(47) Domingo, JL. (2000) Health risks of genetically modified foods: many opinions but few data. Science 288, 1748-1749.

(48) Domingo JL. 2007, "Toxicity studies of genetically modified plants: a review of the published literature". Crit Rev Food Sci Nutr. 2007;47(8):721-33

(49) Dona, A. and Arvanitoyannis, IS, 2009, "Health Risks of Genetically Modified Foods", Critical Reviews in Food Science and Nutrition, 49:164–175 (2009)2

(50) Ermakova, I.V. 2007, “Experimental Evidence of GMO Hazards,” Presentation at Scientists for a GM Free Europe, EU Parliament, Brussels, June 12, 2007

(51) Freese, W. "GE crop impacts health evaluation: a critique of US regulation of GE crops........ a case study of BT corn." FoE, US publication.

(52) Freese, W. 2001. “The StarLink Affair, Submission by Friends of the Earth to the FIFRA Scientific Advisory Panel considering Assessment of Additional Scientific Information Concerning StarLink Corn,” July 17–19, 2001.

(53) Doug Gurian-Sherman, “Holes in the Biotech Safety Net, FDA Policy Does Not Assure the Safety of Genetically Engineered Foods,” Center for Science in the Public Interest, pdf/fda_report__final.pdf

(54) Heinemann, J.A. 2009 "Report on animals exposed to GM ingredients in animal feed" (July 2009) Gendora / Commerce Commission of New Zealand

(55) Ho, Mae-wan (2002) THE BEST KEPT SECRET OF GM CROPS, Witness Statement to ACRE (Open hearing on the T25 GM maize risk assessment.)

(56) Ho MW and Cummins J. 2004, "GM food and feed not fit for man or beast”. ISIS Report, ISP Briefing to UK Parliament, 7 May 2004.

(57) Ho, Mae-wan and Cummins, Joe, 2009, "New evidence links CaMV 35S promoter to HIV transcription," Microbial Ecology in Health and Disease. 2009; 21: 172–174

(58) Ho, Mae-Wan, Cummins, Joe and Saunders, Peter , 2007, 'GM food nightmare unfolding in the regulatory sham', Microbial Ecology in Health and Disease, 1 - 12 (2007)

(59) Ho MW and Steinbrecher RA. 1998. "Fatal flaws in food safety assessment: critique of the joint FAO/WHO Biotechnology and Food Safety Report. Environmental & Nutritional Interactions 1998, 2, 51-84.

(60) Marshall, A. 2007. GM soybeans and health safety—a controversy reexamined. Nature Biotechnology 25, 981 - 987 (2007) doi:10.1038/ nbt0907-981

(61) Maessen, GDF. 1997. Genomic stability and stability of expression in genetically modified plants. Acta Botanica Neerlandica 46(1) pp 3-24

(62) Novotny E. 2004. "Animals avoid GM food, for good reasons". Science in Society 21, 9-11, 2004.

(63) Pusztai, A and S.Bardocz, 2006: "GMO in animal nutrition: potential benefits and risks". In: “Biology of Nutrition in Growing Animals” (ed. Mosenthin, R. Zentek, J.and Zebrowska, T.) 2006 Elsevier Limited, pp. 513-540).

(64) Pusztai, A. et al. (2003) Genetically Modified Foods: Potential Human Health Effects. In: Food Safety: Contaminants and Toxins (ed. JPF D’Mello) pp. 347-372. CAB International, Wallingford Oxon, UK.

(65) Quist, D., and Traavik, T., 2006. Safety assessment of GMOs: Human risks and research needs. Proceedings of the International workshop on biosafety: Environmental Impacts and Safety Regulation of Genetically Modified Organisms, Nanjing, China, China Environmental Press, p. 11-21.

(66) Seralini, G-E 2005. "Genome fluidity and health risks for GMOs." Epigenetics, Transgenic Plants and Risk Assessment, Conference Proceedings, Frankfurt, 2005.)

(67) Snow, A. et al. (2005) "Genetically engineered organisms and the environment: Current status and recommendations". Ecological Applications, 15, 377-404.

(68) Traavik T. 2008. "GMOs and their unmodified counterparts: substantially equivalent or different?" Pp 32-34, in: Breckling B, Reuter H and Verhoeven R: Implictions of GM-Crop Cultivation at Large Spatial Scales. Theorie in der Ökologie vol. 14, Peter Lang, Frankfurt, 2008 (ISBN 978-3-631-58939-7)

(69) Traavik, T. and Jack Heinemann, (2006) “Genetic Engineering and Omitted Health Research: Still No Answers to Ageing Questions", 2006. Genok -- Centre for Biosafety

(70) Wilson, AK, Latham, JR and Steinbrecher, RA, 2006. "Transformation-induced mutations in transgenic plants: Analysis and biosafety implications." Biotechnology and Genetic Engineering Reviews – Vol. 23, December 2006, pp.209-237

(71) Wolfanberger, LL. & Phifer, PR. (2000) The ecological risks and benefits of genetically engineered plants. Science, 290, 2088-2093.


The above papers relate only to the direct and indirect effects of the consumption of GM food and feed -- ie evidence of (1) GM plant toxicity (this would include all animal feeding, immuntoxicity, inhalation etc trials) and (2) evidence of potential harm from the indirect effects of GM plants through inseparable or unavoidable production methods (e.g. the effects of added Roundup residues which are unique to Roundup Ready plants or possibly other HT plants). Some papers discuss the survival of DNA from GM plants in the mammal digestive system, since there are obvious health implications.

We do not include papers which show environmental damage, relating to GM plant toxicity to animals in the food web (these may result in environmental harm or increase the evidence of potential human toxicities) and relating to potential harm to the food web from the indirect effects of GM plants through inseparable or unavoidable production methods (this could include the rise in glyphosate resistant weeds that also increase the chance of their toxins contaminating human food supplies).

The papers towards the end of the list are recommended reviews which summarise earlier published raw data -- and look for cause and effect relationships -- but which do not necessarily report new experimental data.