Ongoing FSA bias in favour of GM food and animal feed
Open Letter 5th November 2007
Dame Deirdre Hutton Chair, FSA UK Headquarters Food Standards Agency Aviation House 125 Kingsway London WC2B 6NH
Dear Dame Deirdre,
Ongoing FSA bias in favour of GM food and animal feed
We had hoped, in the light of recent developments related to the GM varieties MON863 and MON810, and the news about the health benefits of organic products, that the FSA's long-standing and stubborn support for GM food and animal feed might have been somewhat ameliorated. So it was a great disappointment to us when a GM Free Cymru member came across this new item on the FSA web site:
http://www.food.gov.uk/gmfoods/gm-animal
"There have been some concerns that functional transgenes from GM- derived feed material might be incorporated into livestock products for human consumption (milk, meat and eggs). However, in a report published on 20 July 2007, the EFSA's GMO Panel advised that ‘a large number of experimental studies with livestock have shown that recombinant DNA fragments or proteins derived from GM plants have not been detected in tissues, fluids or edible products of farm animals like broilers, cattle, pigs or quails’. Food from animals fed on GM crops is therefore considered to be as safe as food from animals fed on non-GM crops."
This is a carefully crafted paragraph which can only have been designed to mislead the public. You are using the old techniques of selective citation and word play. The EFSA GMO Panel's statement (1) is simply a literature survey, and a very partial one at that. It is NOT a report worthy of the name, and it is anything but independent. Every GM scientist must know that negative results can be explained by the sensitivity limits of the techniques used, or other variables. Furthermore, there is NOT a "large number" of experimental studies showing zero traces of recombinant DNA fragments in tissues and animal products. Such studies are thin on the ground, and Dr Judy Carman showed in her literature survey last year (2) that many of the reports cited as demonstrating "no harm" associated with GM crop safety were not peer reviewed or were studies quite unrelated to human health issues. Some of those studies cited in support of the "no harm" scenario did in fact show the potential of GM crops to be harmful to health. Furthermore, we understand that there are at least three peer-reviewed papers in the literature that DO show that recombinant DNA fragments are traceable in tissues, fluids and edible products from farm animals fed on GM feed (3). These studies are of course well known among scientists working in this field -- and must have been known to the EFSA GMO Panel, who simply chose to ignore them. Sadly, this is not the first time that EFSA has broken a fundamental rule of good science by simply ignoring "uncomfortable" or "disagreeable" scientific results.
The findings from these ignored studies are not unexpected, given that GM DNA is specifically designed to cross species barriers and to jump into other genomes. Given this evidence above, one might wonder why anybody should seek to deny that components of GM food could be taken up by microbes in the gut or tissues of the body (4).
Your actions in placing this cited paragraph on your web site are, we think, deceitful in the legal understanding of this word (5), in that the words used are designed to mislead the public and to falsify a situation known to scientists. We will not speculate as to your motives.
We therefore ask you as a matter of urgency to revise this paragraph, and to remove these words: "‘a large number of experimental studies with livestock have shown that recombinant DNA fragments or proteins derived from GM plants have not been detected in tissues, fluids or edible products of farm animals like broilers, cattle, pigs or quails’." We ask you to insert these words instead: "‘a number of experimental studies with livestock have shown that recombinant DNA fragments or proteins derived from GM plants can pass into the tissues, fluids or edible products of farm animals like broilers, cattle, pigs or quails."
Please give us an assurance that this change will be made immediately. Please do not tell us that you are simply reporting on the EFSA view, and that you bare not qualified to question it. We assume that you are capable of reading the literature for yourselves, and capable of understanding it. Now that we have pointed out to you that the EFSA view is based upon the perpetration of a lie, you are under a duty of care to deviate from the EFSA line and to tell the truth. This is specially important, given your commitments to greater caution and greater transparency in your reporting of GM matters (6) following the mistakes which you made during the LL rice fiasco.
We now come to the last sentence in the extract quoted above: "Food from animals fed on GM crops is therefore considered to be as safe as food from animals fed on non-GM crops." This statement is dependent upon the preceding one, and you are making this construction: since DNA fragments and proteins do not transmit into animal tissues and products, food from animals that have ingested GM feed is as safe as conventional food. Logically, therefore, it must also be concluded that since DNA fragments and proteins DO in reality transmit into said animal tissues and products, food from animals that have ingested GM feed must be LESS SAFE than conventional food. We therefore ask you to remove that sentence from your site and to replace it with the following: "Food from animals fed on GM crops is therefore considered to be less safe than food from animals fed on non-GM crops."
We look forward to hearing from you in the near future, and look forward to seeing the necessary changes made to the offending web page.
We are copying this letter to a number of MPs who have an interest in GM matters.
Yours sincerely,
Dr Brian John GM Free Cymru
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(1) EFSA statement dated
19 July 2007
(2) Report on a List of Abstracts On GM Crop Safety, Dr Judy Carman, July 2006 (IHER Inc)
(3) Three peer-reviewed papers that should have been cited by EFSA: Sharma et al, 2006; Duggan et al, 2000; Mazza et al (2005).
(4) Carman J. "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.
(5) This is a careful definition of the words "deceit" and "deception": The legal understanding of 'deceive' in Britain is 'to induce a person to believe that thing is true which is false, or a thing false which is true, contrary to that which the person practising the deceit knows or believes to be the case (see Welham VDPP(1961)AC 103). The subtlety of the definition is that it acknowledges a deceit is not only caused by lying or concealing-a person is simply 'induced' to believe something false, and that has a wide meaning. It can cover a wide spectrum of tricks including concealing information and presenting ambiguous information. In contract law, 'misrepresentation' entails a 'false statement which misrepresents a material fact......which is made with the intention that the person to whom it is addressed shall act on it (see UK Misrepresentation Act 1967). An offence shall be committed deliberately, through neglect or innocently, if the miscreant has 'no reasonable grounds for believing that the statement to be true'. A further clarification by a British law lord, Lord Denning, holds that 'any behaviour, by words of conduct, is sufficient to be misrepresentation if it is such as to mislead the other party. If it conveys a false impression, that is enough' (Curtis v Chemical Cleaning and Dyeing Co.Ltd(1951) 1 KB 805).
(6) Report of the High Court case relating to FSA mistakes and pro- GM bias
on the 2006 LL rice contamination incident:
http://www.ens-newswire.com/ens/feb2007/2007-02-27-04.asp