THE GLOVER EPISTLES
Date Added to website 17th February 2014
(1) ORIGINAL LETTER FROM BRIAN JOHN
To Anne Glover:
Your claim that there is no evidence of adverse GMO impacts is a lie
Professor Anne Glover Chief Scientific Adviser to the EC President Office of José Manuel Barroso President of the European Commission 1049 Brussels, Belgium
via: jan.mueller@ec.europa.eu
14th February 2014
Dear Professor Glover,
Your claim that there is no evidence of adverse GMO impacts is a lie
I look on myself as a member of the global scientific community, with a background in environmental research and a long list of contacts in academia and within environmental, health and consumer NGOs. Many of my colleagues are directly involved in research in the GM field, and between them they have contributed hundreds of articles to the peer-reviewed literature.
In 2012 you wrote: "If we look at evidence from [more than] 15 years of growing and consuming GMO foods globally, then there is no substantiated case of any adverse impact on human health, animal health or environmental health............" (1) This statement has been repeated (as you knew it would be) by many individuals and organizations interested in the promotion of GM crops and foods, but it is nonetheless a lie.
In 2013 you wrote: "There is no evidence that GM technologies are any riskier than conventional breeding technologies and this has been confirmed by thousands of research projects. Food produced with GM technology is very common in other parts of the world, without any evidence that this has been harmful to the people that consumed it or to the environment at large." (2) With all due respect, that is a repetition of the same lie.
What literature do you read? And from whom do you obtain your scientific advice?
I wish to place on record that there is abundant and unequivocal published evidence, within and outside the peer-reviewed literature, of real harm to living organisms in the plant and animal kingdoms arising from the growing of GMO crops and the consumption of GMO foodstuffs. This material is freely available to any scientist who chooses to examine it; and many of the key publications are found within a list recently compiled and published by GMO Free USA (3). I am not impressed when somebody in your position purports to be unaware of this very large body of evidence.
Of course, there are others lists of publications, some purporting to demonstrate harm associated with GMOs, and others purporting to show that they are safe. You refer to "thousands of research projects" and pretend that they all reach the same conclusion. That is of course nonsense. It is a sterile exercise to weigh up numbers and quality of papers for or against a proposition, and to claim that one set of papers is published in higher-ranking journals than another set. The point is that there is no consensus in the scientific community (4), and that it is absurd to retreat into a debate on what is "substantiated" and what is not. The fact of the matter is that there is a powerful case showing that GMOs are harmful, with the findings of many early papers substantiated and confirmed by subsequent research. To deny that case is to perpetrate a falsehood.
Will you please now retract your 2012 statement and accept that there is abundant evidence showing adverse impacts (both direct and indirect) on human and animal health and on the environment arising from the growing and consumption of GMO products?
And will you also issue an apology to those members of the research community whose publications (in peer-reviewed journals showing harm arising from the use of GMOs) you have so studiously ignored?
I look forward to your positive response on this matter.
Yours sincerely,
Dr Brian John
Note
(1) http://www.euractiv.com/innovation-enterprise/chief-scientifc-adviser-policy-p-interview-514074
(2) http://www.euractiv.com/science-policymaking/eu-chief-scientist-unethical-use-interview-530692
(3) http://gmofreeusa.org/gmos-are-top/gmo-science/
(4) http://www.ensser.org/media/0713/
http://gmwatch.org/index.php/news/archive/2013/15210-nearly-300-experts-agree-gmos-not-proven-safe
http://www.i-sis.org.uk/Scientists_Declare_No_Consensus_on_GMO_Safety.php
(2) RESPONSE FROM ANNE GLOVER
From: Anne.GLOVER@ec.europa.eu Date: 14 February 2014 15:33:29 GMT To: brianjohn4@mac.com Cc: Jan.MUELLER@ec.europa.eu, Suzanne.Speer@ec.europa.eu, Xameerah.MALIK@ec.europa.eu Subject: GMO
Dear Dr John
Thank you for your email of 14th February. As a molecular biologist, I can legitimately be regarded as an expert in the science of genetically modified organisms and as such, I am very familiar with the literature on GMOs. In addition, I also rely on the expert opinion of, amongst others, the scientific committees of the European Food Safety Authority (EFSA) and the European Academies Science Advisory Council (EASAC) which represents scientists from 29 learned academies in Europe as well as the Joint Research Centre (JRC), the European Commission's in house science service which has over 2000 active researchers.
I am also aware of the danger of confirmation bias in only reading sources that confirm our existing views or potentially being less critical of research conclusions that confirm our existing views and I make every effort to avoid this. As EASAC has published a timely (2013) report on crop genetic improvement technologies (see http://www.easac.eu/biosciences/reports-and-statements/detail-view/article/planting-the.html ), I would like to quote from this as follows as it reflects my views and addresses your questions:
"In aggregate, the conclusion from the scientific literature is that there is no validated evidence to associate the first generation of GM crops, that have been cultivated for more than 15 years worldwide (and commercialisation was dependent on more than 20 years of prior art in plant sciences), with higher risks to the environment or for food and feed safety compared with conventional varieties of the same crop (DG Research, 2010a; Fagerstrom et al., 2012). Statements about the adverse impacts of GM crops have too often been based on contested science, (exemplified by the recent controversy associated with the experimental assessment of GM maize NK603 (Academies nationales, 2012).1 Some controversies have also confounded trait-specific effects and GM crop-related issues. Deploying herbicide-resistant varieties, for example, may have indirect beneficial or detrimental environmental effects irrespective of whether such varieties have been produced by GM technology or not … Any new tool or technology can cause unintended effects if used unwisely by adopting poor agronomic practice and it is vital to share lessons learned from the implementation of innovation. For the future, it is important not to generalise about the safety of conferred traits based on the technology used. Each new product must be assessed according to consistent risk assessment principles that examine the trait rather than the means by which the trait was conferred (see Chapter 4).
1 This particular controversy relates to research published on GM maize NK603 where the study authors (Seralini et al., 2012) claimed a strong tumorigenic and toxic effect in rats. However, analysis of this research by the French academies, by EFSA (2012a) and the European Society of Toxicological Pathology (2013) raised many concerns about the initial publication in terms of its unclear objectives, inadequate disclosure of detail on study design, conduct and analysis, and small group sizes used. EFSA concluded that the study was of insufficient scientific quality for safety assessment. Criticisms of the original research publication, its methodology and reporting procedures have also been made by several other advisory bodies, for example the Federal Institute for Risk Assessment in Germany (2012) and the Italian Federation of Life Sciences (Federazione Italiana Scienze della Vita, 2013), and have been discussed in the scientific literature (see, for example, Butler, 2012). A comprehensive review of the literature on animal research, including long-term and multigenerational studies (Snell et al., 2012) had previously concluded that no such adverse effects were demonstrable. Recently, EFSA has made public its data and documents relating to the initial authorisation of GM maize NK 203 (Butler, 2013). "
I hope you find this report interesting.
I should also make you aware, as I understand your own academic specialism was originally Geography, that although I have not examined the list of papers you referred to in "GMO Free USA" exhaustively, I notice several that make no statement about the negative impact of GMO on health or environment e.g. Barbosa ER, Leiros da Costa MD, Bacheschi LA, Scaff M, Leite CC. (2001) Parkinsonism after glycine-derivate exposure. Mov Disord. May;16(3):565-8. http://www.ncbi.nlm.nih.gov/pubmed/11391760 : Barceló, D. & Hennion, M.-C. (1997) Trace determination of pesticides and their degradation products in water. Elsevier, ISBN 0-444-81842-1, Amsterdam. http://store.elsevier.com/Trace-Determination-of-Pesticides-and-their-Degradation-Products-in-Water-BOOK-REPRINT/Damia-Barcelo/isbn-9780444818423/ : Bartsch, K and C. Tebbe (1989) Initial steps in the degradation of phosphinothricin (glufosinate) by soil bacteria Applied Environmental Microbiology Vol. 55 pp 711-716
http://www.ncbi.nlm.nih.gov/pmc/articles/PMC184185/ - there are many more. Yours sincerely Anne Glover Professor Anne Glover CBE Chief Scientific Adviser to the President of the European Commission European Commission Berlaymont 08/039 Rue de la Loi 200 B-1049 Brussels/Belgium Phone: +32 2 2995021 e-mail: anne.glover@ec.europa.eu Twitter @EU_ScienceChief
(3) RIPOSTE FROM BRIAN JOHN TO ANNE GLOVER
Professor Anne Glover CBE Chief Scientific Adviser to the President of the European Commission
European Commission Berlaymont 08/039 Rue de la Loi 200 B-1049 Brussels/Belgium Phone: +32 2 2995021 e-mail: anne.glover@ec.europa.eu Twitter @EU_ScienceChief
17th February 2014
Dear Professor Glover
Your claim that there is no evidence of adverse GMO impacts is a lie
Thank you for your prompt reply. I am of course aware of your background, and do not doubt your expertise in molecular biology. As you point out, I am but a humble Geographer -- but thankfully, one who was taught to think critically, to reject nonsense, and to respect the scientific process.
I fear that I have serious reservations about the contents of your letter, and about your reliance upon organizations which have long since decided that GMOs are entirely safe and which devote much of their energy to the task of confirming that position through carefully managed or manipulated science. Shall I refer to them as key parts of the "scientific / political / commercial establishment"? Well, why not? I fear that I have no time whatsoever either for EASAC or for EFSA -- especially the latter, which has become widely despised for its incompetence and its bias towards the GM industry and its apparent disregard for public health issues.
Of course I am familiar with the written outputs of EASAC, which always represents the interests of the GM research and academic community whose priorities are naturally enough to ensure a flow of research funding and to maintain some sort of status in the face of public hostility. When I was an academic that was my priority too, except that I had no public hostility to deal with! EASAC publications do not inspire confidence. Your chosen section from the report is a classic of its kind, and is very carefully manufactured. A few points immediately come to mind:
1. "No validated evidence.........." What arrogance! Validated by whom? Research can only be validated or rejected by the duplication or improvement of observations and experiments. As you should know, whenever a paper appears which proves "uncomfortable", the first priority of the GM industry is to ensure that the authors are vilified, and its second priority is to ensure that the research is never repeated. We are still waiting for the seminal Pusztai work of 1998 to be repeated -- but we know why it never will be. You should also be aware that it is incredibly difficult for genuinely independent research to be conducted by researchers using patented GMO materials -- and this problem has attracted its fair share of attention in the media. It is an ongoing scandal -- and it is a small miracle that the Seralini team was able to undertake any of its work on NK603 and Roundup, given the outright hostility and obstructiveness of Monsanto. It was another miracle that it was written up and published without further mishap. And please don't bother to raise the issue of paper retraction! In these circumstances, if you are looking for true scientific validation, you are NEVER going to get it.
2. That having been said, we come to this: "Statements about the adverse impacts of GM crops have too often been based on contested science." Again, what incredible arrogance! All science should be contested, and if it is not, there is something wrong. That is where I have a fundamental disagreement with the Commission, and with you. You appear to want some sort of scientific orthodoxy. The idea that EFSA is -- in its infinite wisdom -- the final arbiter of science with respect to the safety of GMOs is ridiculous. So is the idea that once EFSA has made a decision on the safety of a GMO, that is the end of it. EFSA has shown itself, over and again, to be incapable of admitting to past shortcomings in the assessment process, and it HAS to be true that the member states of the European Union will have perfectly valid scientific grounds for disagreeing with EFSA that certain GMOs are (or are not) safe. These divergent views must be accepted and built into the process, and if they are not, that demonstrates, in my view, a fundamental misunderstanding of how science works.
3. Another point is this. It there were no evidence in the literature of increased risks associated with GMOs, why would ~165 countries (including the EU and its member states) have negotiated and ratified the Cartagena Protocol? And why would all the nations of the world assembled in the Codex have unanimously adopted special risk assessment procedures for GMO foods? The reason is that GMOs are DIFFERENT and have unique risks associated with them in theory and practice. EASAC and the Commission seem to be blissfully unaware of this point.
4. Back to contested science. What makes you -- or EASAC -- think that the science purporting to demonstrate "no harm" with respect to GMO crops and foods is not contested? It is contested just as strenuously (1) as the science which shows harm to animals and to the environment -- and quite rightly so, since the great bulk of papers produced in support of GMO applications are classic examples of "advocacy science" funded by industry and included in application dossiers by industry with the specific objective of obtaining consents. It is not surprising that in those circumstances laboratory protocols have been manipulated, and that other techniques (including sampling bias, the use of invalid comparators, and statistical manipulation) are resorted to in order to give the predetermined results required by patent holders. As you will -- or should -- be only too aware, scientific fraud has been exposed in many instances in the past in GMO "safety assurance" papers, and we have highlighted many cases of such fraud on our web site.
5. You cite another nonsensical point from EASAC, and we hope you do not agree with it. It is the point about trait-specific and herbicide-related issues. To the best of my knowledge, independent researchers are perfectly aware of pleiotropic / combinatorial effects and seek to identify them, since it is totally dishonest to pretend that herbicide-tolerant GMO crops (for example) exist in a world free of herbicides! To the eternal credit of the Seralini team, that is what they tried to do in their rat feeding trial involving the use of NK603 and Roundup, and it is the main reason why the trials were so complex. I should not need to remind you that EU Directives demand that both the direct and indirect effects of GMO plantings and use in food and feed MUST be considered at all times -- and it is an ongoing scandal that bodies like EASAC and EFSA can pretend that we should just be concerned about trait-specific characteristics in GMO crops, while leaving the herbicide / pesticide issue to some other body at some other time. What sort of world do they think we inhabit? If I am going to eat cornflakes that have come from a GM maize crop, I want to know whether it has Roundup residues on it, and what they might be doing to the health of my family.
6. To quote again: "Each new product must be assessed according to consistent risk assessment principles that examine the trait....." Fine words, but what happens in reality? In purporting to examine the risks associated with "the trait" how often is an actual crop -- as it will find its way into the food supply -- actually tested and risk-assessed? The answer is "hardly ever." The GM industry effectively evades risk assessment in the USA and Canada through the use of the nonsensical concept of "Substantial Equivalence" and by using the equally nonsensical label of GRAS (generally accepted as safe) particularly for stacked varieties. It also evades careful scrutiny through the use of surrogate proteins for testing, rather than the actual proteins as expressed in GMO varieties -- so many of their "safety assurance" papers are not worth the paper they are written on.
7. I am highly entertained by the references cited in the EASAC extract. These are DG Research, 2010; Fagerstrom et al., 2012; European Society of Toxicological Pathology (2013); Academies Nationales, 2012; EFSA 2012; Federazione Italiana Scienze della Vita, 2013; and Butler, 2012 and 2013. I am familiar with all of them. Some of these were parts of the concerted and cynical attempts by the GM industry and its research community to limit the damage done by the Seralini paper when it was published in FCT. Butler reports on the attempts -- not before time -- by EFSA to be more transparent. Do these papers provide me with reassurance? Far from it.
8. As for the paper by Snell et al (2012) you must surely be aware that it is a classic of its kind, full of hypocrisy and double standards. The authors, in their review of 24 animal feeding trials with GM plant-derived feed, identified severe methodological shortcomings in a majority of the analysed publications. Isogenic lines were used as controls in only 10 studies. Nonetheless, they dismissed only those studies stating negative effects –and appeared happy with those "affirming" safety. Based on this asymmetrical, result-triggered approach, the authors incorrectly concluded that no health hazards were found in the 24 analysed publications.
9. The impression is given by the unnamed EASAC authors that there is a scientific consensus that GMO crops and foods are perfectly safe. That assertion is totally unfounded. As I pointed out in my earlier letter, there is NO consensus in the scientific community about the safety of GMO crops, the widespread use of Roundup and other herbicides, and the reliability of EFSA opinions. I repeat the point that large numbers of scientists are outraged by the concerted vilification of Seralini and his team (and have said so, on the record); and I repeat that hundreds have now signed up to a brief letter condemning the assertion that there is "a scientific consensus regarding GM safety." (1)
10. Your citation of various papers from the GMO-Free USA list is interesting. I am not going to get into a futile exercise in trading citations with you. I admire the US list (2) because it interprets and assesses the significance of each article as part of a case that becomes, in aggregate, more and more persuasive. There are many other lists as well. Of course not all listed papers state baldly that "this GMO / herbicide study shows a negative impact on health or environment." Many of the papers had much more limited hypotheses and objectives; and as you know, authors in very specialised fields are careful not to overstate the significance of their findings. You should be aware that this "tendency towards timidity" is especially marked in papers relating to GMOs, since authors have to assume a very hostile peer review process especially in high-status journals which have a long history of publishing pro-GM papers and opinion pieces. You must also have been around long enough to know that some perfectly respectable independent papers dealing with GMO animal feeding studies (for example) find it almost impossible to gain publication because of the publishing bias which we see in (for example) Nature Publications and in FCT. Many editors simply will not publish findings which are liable to prove inconvenient to the GM industry. This mirrors the bias that exists within EFSA -- and this is one of the reasons why that body is so despised. We know from bitter experience that papers critical of GMOs are subjected to intense and even hypercritical scrutiny within the GMO Panel, whereas papers affirming the "no harm" scenario are often accepted without question. That is a form of scientific corruption which is insidious and dangerous -- and we hope that you and your colleagues within the EC do not condone it.
All in all, I am far from reassured by your letter. I have been around a long time, and I know the way the world works. As you probably know, my two Petitions (3) to the EU petitions Committee are still alive, and I will persist with them until I am satisfied that the EC and EFSA are taking my health and security seriously.
I therefore repeat my conviction that your statements on the matter of GMO safety are lies, and I ask you once again to retract them as a matter of urgency.
Yours sincerely,
Dr Brian John
(1) For example: http://earthopensource.org/files/pdfs/GMO_Myths_and_Truths/GMO_Myths_and_Truths_1.3b.pdf
(2) http://gmofreeusa.org/gmos-are-top/gmo-science/ http://earthopensource.org/files/pdfs/GMO_Myths_and_Truths/GMO_Myths_and_Truths_1.3b.pdf Domingo JL, Bordonaba JG. A literature review on the safety assessment of genetically modified plants. Environ Int. Feb 4 2011; 37: 734–742.
(3) http://www.gmfreecymru.org/petition/petition_June2013.html Title of Petition 813-08: The importance of impartiality within EFSA & the food safety rights of EU citizens Title of Petition 436-10: Formal protest from scientists against the Commission's draft regulation on implementing rules concerning the applications for authorisation of GM food and feed.