GM Free Cymru

Title of Petition 813-08: The importance of impartiality within EFSA & the food safety rights of EU citizens

Name: Brian John Postal Address: Trefelin, Cilgwyn, Newport, Pembrokeshire SA42 0QN, Wales, UK Nationality: Welsh


Thank you for the opportunity to speak to you again. My concerns arise out of the fact that EFSA's GMO Panel routinely makes decisions affecting the health of millions of EU citizens, without any effective checks or balances (1). Last April (2) I raised many issues of concern, but in its response the Commission simply repeated its usual assurances onEFSA protocols and decisions. When I made specific points on how matters might be improved (3), the Commission failed to respond. As a concerned citizen I now feel that the Commission lacks the ability to respond creatively to criticism. I hope therefore that the Petitions Committee will now come to a final view on this matter, on the basis of the evidence currently on file.

I respectfully point out that the latest Eurobarometer poll (4) showed that public oppositionto GM crops and food has risen to 61%. Further, in December the Avaaz Citizen's Petition (5), with more than 1.2 million signatures, was presented to Commissioner Dalli. He hastaken no action to meet the citizens' valid requests.
I further respectfully point out that many scientific papers have now been published whichshow evidence of direct and indirect harm to the vital organs of animals (and particularly tothe reproductive system) arising from the cultivation and consumption of GM products.EFSA does not acknowledge these papers as a valid cause for concern (6) and the Commission appears to share this complacency.


  1. 1. EFSA still issues positive "opinions" on GMOs which are based on untested assumptions and confidential and unpublished data provided by the applicants. Their studies cannot be repeated or tested by independent scientists. This goes against the principles of sound science (7).
    1. 2. The composition of EFSA's GMO Panel and its management board is still heavilybiased towards industry in general, and the GM industry in particular. The conflict of interests involving the International Life Sciences Institute and EFSA personnel is well documented. On EFSA's "stakeholder platform" of 24 members, 16 are industry
    2. representatives, balanced by only one consumer group and three environmental NGOs.That means that the comments and advice coming to EFSA are heavily skewed in favour of economic interests and away from the public interest (8).
  2. 3. EFSA still does not insist on safety tests on the whole GM plant -- as it will be planted or consumed. EFSA assumes that surrogate proteins can be used to prove the safety of a GM plant; and it pretends that there are no important synergistic or unpredicted side-effects (possibly with chronic toxic consequences) in multiple or stacked events (9).
  3. 4. Neither EFSA nor the Commission has done anything to improve public access to GM dossiers, and their complacency over the industry's abuse of confidentiality rules meansthat independent and timely scrutiny of EFSA decisions is virtually impossible (10).
  4. 5. The Commission seems to think that once EFSA has ruled on the safety of a GM variety, then that is the end of the matter. However, science is full of uncertainties and is dependent upon open research and hypothesis testing and modification. In the case of GM studies, scientists who discover "uncomfortable" things are routinely marginalised andvilified; and no matter what emerges, EFSA has NEVER changed its opinion on any GM product initially declared to be safe (11).
  5. 6. EFSA still does not insist that all research contained in dossiers must be conducted at least to Codex standards. Animal feeding trials of GM materials are still too short to reveal chronic toxic effects (12). And now EFSA, in its new Guidance for Applicants, wants sweeping powers of discretion which will allow some GM applicants to get away with nosafety or feeding studies at all (13).

Since neither EFSA nor the Commission has taken action to address my concerns, I respectfully ask the Committee once again to bring forward the following suggestions toParliament:

  1. 1. Please place it on the record that Parliament will insist that EFSA must be reformed to eliminate "revolving doors" and include a much broader base of representation.
  2. 2. Please place it on record that all research contained in application dossiers MUST be transparent, replicable and verifiable, and that applicants will henceforth be required toconfirm in writing, in advance, that they will make their GM products, comparator isolines and reference materials accessible to independent researchers. Independent studies must ALWAYS be brought into the risk assessment process and given due respect. This will greatly enhance public trust.
  3. 3. Please encourage greater involvement by Member States in risk assessments, andremind the Commission that where there is disagreement and uncertainty on health andsafety matters, the Precautionary Principle must always come into play.

I am very grateful to the Committee for allowing me to bring this Petition forward, and Irespectfully ask for careful consideration of the points I have raised.
Dr Brian John GM-Free Wales


  1. (1)
  2. (2)
  3. (3)
    1. (4) Europeans are not in favour of the development of genetically modified food. 61% ofEU citizens think that development of GM food shouldn't be encouraged, 83 % feel thatspecial labelling of food products is necessary, 59 % thinks that GM food is not safe for their health.
  4. (5) To EC President Jose Manuel Barroso: We call on you to put a moratorium on the introduction of GM crops into Europe and set up an independent, ethical, scientific body toresearch the impact of GM crops and determine regulation.
Current number of signatures: 1,225,226
Ethics and the GM approval process for import and processing

Kremer, R.J., Means, N.E., 2009. Glyphosate and glyphosate-resistant crop interactions
with rhizosphere microorganisms. Eur. J. Agron. 31, 153–161.
Knight CJ, Bailey AM, Foster GD. Investigating Agrobacterium-mediated transformation of
Verticillium albo-atrum on plant surfaces. PLOS ONE 2010, 5(10): e13684. Doi:10.1371/

EFSA also appears to be determined to ignore the environmental, health, and socio
­economic damage suffered in the countries where (for example) RR soy and other crops
are grown for import into the EU. This "ethical deficit" goes against both the spirit and the
letter of the relevant Directives.

(7) Pro-GM Science Community - Public Enemy or Its Own Worst Enemy? Open Letter to Sir Paul Nurse
Perverted Science -- the manipulation of GM researchHow "inconvenient" GM research is stifled, starved, marginalized and patronized
No seeds, no independent research
Companies that genetically engineer crops have a lock on what we know about their safety
and benefits.
by Doug Gurian-Sherman

Serial conflicts of interest on EFSAʼs management boardEuropean Food Safety Authority: A playing field for the biotech industry Testbiotech Background Report 1-12-2010Standards for risk assessment massively influenced by industry
German Court upholds publication of pamphlet exposing GM Mafia
(9) Ten crucial elements in the environmental risk assessment of genetically engineered plants
Testbiotech comment on Selection of Comparators for risk assessmentTestbiotech demands new concept for risk assessment of genetically engineered plants
Then, C. & Potthof, C., 2009, risk reloaded – risk analysis of genetically engineered plantswithin the European Union, Testbiotech report,
Norway's Centre for Biosafety slams MON87705 dossier defects
(10) GM Food Nightmare Unfolding and the Regulatory ShamHow our regulators are ignoring the precautionary principle, manipulating and corruptingscience, sidestepping the law, and helping to promote GMOs in the face of massive public opposition and damning evidence piling up against the safety of GM food and feed
EFSA back in bed with GMO industryMON810 opinion shown to Monsanto but not to public
(11) Hired thugs seek to silence CarrascoArgentina: Threats deny community access to research News from Amnesty International 12 August 2010
Nature Biotechnology facilitates premeditated GM Rottweiler Attack How a well-known scientific journal "set up" an honest scientist through a conspiracy oflies and deception
Independent GM researcher wins court victory for defamation
NB. The regulatory process continues to be founded upon the simplistic understanding of gene function in place in the 1990's. Unintended and deleterious side-effects - metabolic, physiological, and ecological - caused by the randomness of forcible transgene packetinsertion are now well established in the scientific literature.
(12) feeding-study-available-
New Analysis of a Rat Feeding Study with a Genetically Modified Maize Reveals Signs of Hepatorenal Toxicity Journal Archives of Environmental Contamination and ToxicologyGMO risk assessment procedures are woefully inadequateSéralini 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.
(13) Testbiotech comment on EFSA´s draft Guidance for risk assessment of GMO EFSA´s Guidance needs clarification and cut off criteria
EFSA Panel on Genetically Modified Organisms (GMO); Scientific Opinion on Guidance onthe risk assessment of genetically modified microorganisms and their derived food andfeed products. EFSA Journal 20YY;volume(issue):NNNN. doi:10.2903/j.efsa.20YY.NNNN Commission's cunning plan for fast-track GM approvals is rumbledPress Notice from GM-Free Cymru 12th June 2010


I hereby ask the Parliament to condemn, by resolution, the following:

(a) over-dependence upon scientific evidence produced entirely under the control of the applicant;

 (b) the use of any results from scientific experiments that are, for whatever reason, non-replicable;

(c) the blocking of independent research through "non-cooperation" by GM corporations and patent holders.

 (d) any actions by EFSA to prevent full pre-approval release of research dossiers;

 (e) any attempts by EFSA to water down or speed up application / assessment procedures for future GM products;

(f) any attempts to "simplify" the safety study requirements for "stacked" GM events;

(g) the vilification and intimidation of independent scientists who happen to discover GM-related health and safety effects.