THE GENETIC ENGINEERING DEBATE (v0.32)

compiled by Roberto Verzola

email: rverzola@phil.gn.apc.org

0. MAJOR CHANGES

0.1. Arguments that are specific to particular GE traits like

herbicide-tolerant crops, Bt crops, recombinant hormones,

promoters, antibiotic-resistance markers, etc. have been marked

appropriately (e.g., HT, BT, RBGH, CAMV, ARM, and so on).

0.2. Headers have been modified to reflect industry claims, which have

been put under the following general headings: safety claims,

scientific claims, economic claims, legal claims, moral claims,

and quality claims.

1. ABOUT THIS DOCUMENT

1.1. This document aims to support the campaign against the risks of

genetic engineering (GE). It will try to summarize all claims

made by the proponents of GE, and the responses by the critics of

GE. Supporting data and summaries of scientific studies will be

included as much as possible.

1.2. I welcome suggestions, corrections, improvements and new

information to this document. Most important are corrections to

factual or argumentation errors/weaknesses. Style, syntax and

grammar corrections are also welcome. My real role is to

coordinate what will hopefully be a worldwide group effort.

1.3. Contributions we are most interested in are of two types: a)

facts, together with the source or URL, preferably both; source

can be an email posting or news item, but scientific publications

are preferred; peer-reviewed articles are even better; b)

arguments, whether for or against GE; we also want the strongest

arguments of the other side, so we can research how they may be

answered properly.

1.4. IMPORTANT: When sending me a suggested change or addition, please

do not (repeat: DO NOT) send me back the full edited document.

Send only the paragraph(s) you want to add/change, the version

number of the document you have (e.g., v0.2), and the section

heading of the paragraph (e.g., 1.4).

1.5. Updated versions of this document will be released regularly at

the GENTECH (gentech@ping.de) and BAN (ban@tao.ca) mailing lists.

You are welcome to post this document on any other mailing list

or website, but please post it in its entirety.

1.6. Some conventions: + is an argument in favor; - is against; ++ or

-- means this item is a new entry or is an edited version of its

earlier counterpart; * is for useful data which is neither for or

against GE.

2. SAFETY CLAIMS: GE-FOODS ARE SAFE

+ We have been doing biotech for thousands of years.

- We have been doing traditional biotechnology

(fermentation, conventional breeding, etc.) for a long time; but

modern biotechnology or genetic engineering is a very recent

development, and the first commercial products were released only

in the early 1990s. If we look at our experience at DDT and other

toxic chemicals (produced by the more or less same firms now

engaged in GE), it took some 20-30 years to determine they were

bioaccumulating through the food chain and causing cancers and

around 50 years to determine that they were mimicking some human

hormones and disrupting our endocrine systems.

+ GE is just an extension of conventional breeding.

- GE and conventional breeding are radically different.

Conventional breeding works only within the same or closely

related species (e.g., bacteria to bacteria, corn with corn, pigs

with pigs, etc.) In contrast, GE involves mixing genes from very

distantly related species that in nature will never breed with

each other (e.g., bacteria to corn, or pig to human beings).

- Actually GE is a new, experimental, very dangerous, AND

radical technology. The process causes unnatural mutation and

combination of the DNA in our food in a manner which excludes

nature out of the process. This means we and our children are now

eating lab-created, mutated and experimental "fake" food. They

are experimenting, not only with us and with our children, but

with the entire food chain. (From: pmligotti@earthlink.net)

- Whoever argues that GE is no different from conventional

breeding is probably laying the groundwork for the concept of

"substantial equivalence", that the products of genetic

engineering are as safe as the products of conventional breeding.

This dubious concept is often used as excuse to avoid thorough

and rigorous testing.

+ Horizontal gene tranfer across distant species occurs in

nature. Natural broad-species vectors exist; some do replicate in

Gram- bacteria, others only in Gram+. There are also vectors

which replicate in Gram- and Gram+ bacteria, and some organisms

transfer DNA to plants (eg Agrobacterium tumefaciens, A.

rhizogenes)

- Where horizontal gene transfer occurs in nature, it is

often in connection with the emergence of more virulent or new

pathogens. GE is inherently risky because it uses the same

mechanism to facilitate the insertion of foreign genes through

bacterial or viral vectors.

+ GE is much more precise than conventional breeding.

- GE is only precise in so far as the foreign genes which

will be inserted into a target organism are known. But GE has no

control where into the target organism's genome the foreign genes

will be inserted. The insertion site is totally random and

unpredictable. Since genes do not operate in isolation, but

interact in a complicated way and change their behaviour in

response to influences from nearby and even distant genes, the

behaviour of the transformed target organism is also

unpredictable.

+ There are techniques that ensure a precise integration

into the genome (eg double recombination using a suicide gene or

by using chimeraplasty which precisely changes an already

existing gene)

- The commercially-available GE-crops did not use these new

experimental techniques, but random techniques like the "gene

gun" or bioballistics.

+ Even with random methods, it is possible to determine the

insertion site(s) afterward and choose clones accordingly.

- Even after the insertion site has been determined, the

interaction between the inserted promoter and miscellaneous

foreign genes on the one hand and the neighboring genes on the

other hand must still be determined. We know too little today

about most target genomes to determine these interactions

precisely.

- There is no data documenting the stability of any

transgenic line in gene expression, or in structure and location

of the insert in the genome. Such data must include the level of

gene expression, as well as a genetic map and DNA base sequence

of the insert and its site of insertion in the host genome in

each successive generation. No such information has been

provided by industry, nor requested by regulatory authorities.

(32) (See: "Will genetically engineered crops mean adulterated

and toxic food, bodies, and ecosystems?", Michael W. Fox, Senior

Scholar/ Bioethics, The Humane Society of the United States 2100

L Street, NW Washington, DC 20037)

+ Crop varieties developed through conventional breeding do

not undergo feeding tests. Why should GE varieties?

- GE destabilizes the target genome, so it involves

inherently higher risks than conventional breeding. Thus we

should assume that GE varieties are unsafe unless proven

otherwise through thorough long-term testing. Traditional

varieties of food crops have evolved with us for thousands of

years, and can be assumed to be safe unless proven otherwise.

Modern hybrids may or may not need to be rigorously tested

depending on the situation.

+ Problems attributed to GE-crops may also occur with

conventionally-bred hybrids especially when breeding with wild

relatives.

- GE-crops are inherently riskier, because the results of

the random insertions are unpredictable. When we breed a natural

corn variety that is safe to eat with another natural corn

variety that is also safe to eat, we can reasonably assume that

the result would also be safe to eat, unless proven otherwise. No

foreign genes have been introduced. If we cause mutations through

GE (or even through high-intensity radiation), we cannot

reasonably assume that the mutant is safe to eat, without

thorough testing. If we breed this presumably unsafe mutant with

a natural corn variety, we cannot assume that the result is safe

to eat either.

- By 1992, there were already 7 known instances of

unexpected results from GE. One can only imagine how many more

there have been in the interim. (Bereano, Philip and Nachama

Wilker, "Regulations for Genetically Engineered Foods," Science,

Vol. 258, 4 Dec 1992, p. 1561-2)

- An example of GE unpredictability: Bill Vencill of the

Univ of Georgia examined the effects of heat on GE soya beans

after Georgia farmers alerted him to unexpected crop losses,

esp. during Georgia's two hottest springs since the beans were

launched in 1996. "In the years we saw the problems, the soils

were reaching 40 to 50 C," says Vencill. His team replicated

these conditions in lab growth chambers, comparing the hardiness

of the Monsanto plants with conventional strains. In soils that

reached only 25 C during the day, the GM Monsanto beans grew as

well as other beans. But in warmer soils, the GM plants appeared

stunted. In soils reaching 45 C, the differences were marked.

Vencill described the findings at a British Crop Protection

Council meeting in Brighton this week. "We saw lower heights,

yields and weights in the Monsanto beans," says Vencill. Worse,

stems of nearly all the GE beans split open as the first leaves

began to emerge compared with 50-70% of the other test plants.

This had occurred on farms, but had been blamed on fungal

disease. "Instead, we think the stem splits, and it exposes the

plant to secondary infection," says Vencill. Vencill suspects the

changes in plant physiology caused by the addition of GE

resistance to glyphosate, the herbicide marketed as Roundup by

Monsanto. These herbicide-resistant plants have been shown to

produce up to 20 per cent more lignin, the tough, woody form of

cellulose. "We think it might make the plants more brittle," says

Vencill. (See: Andy Coghlan, New Scientist, 20 Nov 1999)

2.1. CLAIM: GE-FOODS ARE SAFE FOR HUMAN AND ANIMAL CONSUMPTION

- Summary: we do not know enough yet; some studies justify

certain concerns about human and environmental safety; more

studies need to be done; meanwhile, based on the precautionary

principle, we must assume that GE foods are not safe and take the

necessary precautions.

2.1.1. CLAIM: GE- AND CONVENTIONAL FOODS ARE SUBSTANTIALLY EQUIVALENT

+ We have established the substantial equivalence between

commercial GE foods and their conventional counterparts.

Therefore, we can assume that GE foods are as safe as their

conventional counterpart.

+ In September 1996, WHO and the FAO convened an expert

consultation on GE-food safety in Rome, which adopted the same

industry line that: 1) safety issues in GE-foods were "basically

of the same nature" as in foods from conventional breeding; 2)

the substantial equivalence concept can be used to show GE-food

safety; and 3) once substantial equivalence is shown, "no further

safety consideration is needed." (See: "Biotechnology and food

safety: Report of a joint WHO/FAO consultation", Rome, Italy, 20

Sep - 4 Oct 1996)

- The 1996 WHO/FAO report made clear that the participants

were invited "in their individual capacities and not as

representative of any organization, affiliation or government."

So the report describes individual opinions and not official WHO

or FAO position. (See: "Biotechnology and food safety: Report of

a joint WHO/FAO consultation", Rome, Italy, 20 Sep - 4 Oct 1996,

p.1)

- Biotech firms often refer to this 1996 report to falsely

claim that the "WHO/FAO have declared that Bt corn [or some other

GE-product] is as safe as its conventional equivalent for animal

and human consumption." Yet, the WHO and the FAO themselves have

no such official position.

+ The U.S. FDA has declared that GE crops are as safe as

their conventional counterpart.

+ On May 18, 1994, the US FDA announced that a GE tomato

was as safe as conventional tomato. In a nutshell, the FDA

position is that labeling isn't required unless a GE product

"differs significantly from its conventional counterpart" - if

it contains a new sweetener, for example - or if it introduces

an allergen. (Aberdeen American News, S.D.; Knight Ridder/Tribune

Business News)

- Because the FDA accepted the concept of substantial

equivalence, it did not require feeding and other rigorous tests

that pharmaceuticals or food additives normally require. (See

also "Revolving door" under "Government/Industry collusion")

- Confidential documents made public in an on-going class

action lawsuit have revealed that the FDAs own scientists do not

agree with concept of "substantial equivalence between GE and

normal seeds.

- The U.S. Food, Drug and Cosmetic Act prescribes that

additives like the foreign genes in GE foods can only be

recognized as safe based on tests that have shown the foods are

harmless. But no such tests exist for GM foods. So, although the

GRAS exemption was meant for substances whose safety has already

been shown through testing, the FDA is using it to avoid testing

and to approve substances based largely on conjecture - one that

is dubious in the eyes of its own and many other experts. (Steven

M. Druker, J.D., executive director of the Alliance for

Bio-Integrity, coordinator of the lawsuit against the FDA to

obtain mandatory safety testing and labeling of GE foods)

+ GE foods vary from non-GE foods only in the characteristic

that has been modified.

- The random insertion of foreign genes into the genetic

material may cause unexpected changes in the functioning of other

genes. Existing molecules may be manufactured in incorrect

quantities, at the wrong times, or new molecules may be produced.

GE foods and food products may therefore contain unexpected

toxins or allergenic molecules that could harm our health or that

of our offspring. (See: "13 Myths about Genetic Engineering",

Consumers for Education about Genetic Engineering, Dunedin

Polytech, as posted by Deborah E Leech

<dleech@mail.coin.missouri.edu> on the SANET list)

- A study published July 1, 1999 in the Journal of

Medicinal Food presents new information about biologically active

components in GM soybeans resistant to Monsanto's Roundup

herbicide. Dr. Marc Lappe, Director of the Center for Ethics and

Toxics (CETOS) and principal investigator says, "Based on

corporate representations, the phytoestrogen concentrations of

Monsanto's Roundup Ready and conventional soybeans were supposed

to be equivalent. But the initial industry studies were performed

on unsprayed soybeans. We found significant differences when we

examined herbicide-sprayed soybeans analogous to those used in

foods. The study shows an overall reduction in phytoestrogen

levels of 12-14 percent in the genetically altered soybean

strains. Most of this reduction was attributable to reductions

in genistin and to a lesser extent daidzin levels, which were

significantly lower in modified compared to conventional soybeans

in both strains. The apparent differences found may be an

important discovery because consumers tend to buy soy products

for their naturally occurring phytoestrogens which are thought to

protect against breast cancer, heart disease, and osteoporosis.

As GE strains replace conventional ones, any differences in

phytoestrogen levels becomes increasingly important." (See:

"Alterations in Clinically Important Phytoestrogens in

Genetically Modified, Herbicide-Tolerant Soybeans", Maryanne

Liebert Publishers, J. of Medicinal Food, Vol. 1 No. 4, 1999) (6

Jul 1999) <http://www.cetos.org>

+ FDA can demand extensive safety testing if the new gene

"differs substantially" from those generally found in other food.

- That's a hollow promise. All 44 crops that so far have

gained FDA marketing approval have avoided scrutiny because FDA

has accepted the industry's claims that they are "substantially

equivalent" to conventional food. (See: Rick Weiss, Washington

Post, 15 Aug 1999)

<http://www.washingtonpost.com/wp-srv/health/daily/aug99/gmfood15.htm>

- Some scientists have questioned substantial equivalence as

"a commercial and political judgment masquerading as if it were

scientific... primarily to provide an excuse for not requiring

biochemical or toxicological tests." (See: Letter to Nature by

Erik Millstone, Eric Brunner and Sue Mayer, 7 Oct 1999) (http:)

- The Codex Alimentarius itself, the UN agency which WHO and

the FAO defer to on food safety issues, has not adopted the

concept for its food safety assessments. (See: ) (http:)

- The British Medical Association rejected the notion that

GM foods should be assumed to be safe when they are said to be

substantially equivalent to their conventional counterparts,

which is the basis of U.S. regulation of biotech foods. "This

concept does not account for gene interaction of unexpected

kinds, which may take place in GM foods," the BMA asserts. "The

possibility that certain novel genes inserted into food may cause

problems to humans is a real possibility, and 'substantial

equivalence' is a rule which can be used to evade this biological

fact." (See: "The Impact of Genetic Modification on Agriculture,

Food and Health", British Medical Association, May 1999)

- In March 1998 a letter in the UK's Farmers Weekly

reported that livestock on farms from Nebraska to Iowa were not

grazing, as in the past, in fields of Bt corn. Unpalatability of

the Bt stalks was suspected. One farm specialist from Dawson

County, Nebraska, reportedly said: "At first we thought it was a

joke, but I have heard it enough now that we are looking into

what could be going on." (See: Farmers Weekly, UK, Mar 1998)

<http://www.btinternet.com/~nlpwessex/Documents/gmanimalgrazing.htm>

- Animals reject "substantial equivalence"? After four

months of hearing anecdotes from Kansas to Wisconsin, it is time

to collect stories more thoroughly from farmers: About the hogs

that wouldn't eat ration when GMO crops were included. About one

farmer who said "if you want your cattle to go off their feed,

just switch them out to a GMO silage." About another whose cattle

broke through an old fence and ate down the non-GMO hybrids but

wouldn't touch the Roundup Ready corn, though "they had to walk

through the GMOs to get to the Pioneer 3477 on the other side."

About the cattle whose weight-gain fell off when switched over to

GMO sources. About the organic farmer with a terrible deer

problem on his soybeans, who drives out at night, and sees 40 of

them mowing down his tofu beans while across the road not one doe

is eating on the Roundup Readies. About the raccoons romping by

the dozen in the organic corn, while down the road not one ear

has been touched in the Bt fields. Even the mice will move on

down the line if given an alternative to these "crops". (See:

ACRES USA Special Report, 18 Sep 1999 by Steven Sprinkel,

Yankton, South Dakota)

- Rodents reject "substantial equivalence"? Consider the

Flavr Savr tomato, which was given a gene to delay its ripening.

When scientists tried to feed rodents the tomatoes, however, the

animals wouldn't eat them, recalled Roger Salquist, a scientist

involved in creating the Flavr Savr. "I gotta tell you, you can

be Chef Boyardee and mice are still not going to like them." They

went so far as to force-feed the rodents through gastric tubes

and stomach washes. This made the rodents sick, and revealed

nothing about the tomato's safety. The tomato ultimately won

approval from the FDA but failed in the market in part because it

was so expensive. (See: Rick Weiss, Washington Post, 15 Aug 1999)

<http://www.washingtonpost.com/wp-srv/health/daily/aug99/gmfood15.htm>

- Although these novel products are different enough to be

patented, the biotech industry and U.S. regulatory agencies say

they are no different from their natural counterparts. For this

reason, the U.S. FDA requires no pre-market testing on animal or

human subjects (as would be required of new drugs or food

additives) nor any labeling. "There isn't any difference between

a GM product and a natural food in terms of its impact on

consumer health," says Jim Maryanski, biotech coordinator for

FDA, which oversees the safety of fruits, vegetables and other GE

food products. FDA only requires a label if a product contains a

known allergen or is nutritionally different - for example if a

GM orange had more or less vitamin C, he says.

2.1.2. CLAIM: GE-FOODS DO NOT CAUSE ALLERGIC REACTIONS

- One GE product you won't find on the market is a soybean

to which genes from a Brazil nut had been introduced. A New

England Journal of Medicine article in early 1996 suggested the

GM soybean could cause reactions in people allergic to Brazil

nuts. Pioneer Hi-Bred Intl of Johnson, Iowa - which had developed

the soybean and later funded that allergy study - said it won't

market the soybean because of the allergy potential. (Aberdeen

American News, S.D.; Knight Ridder/Tribune Business News)

* Pioneer Hi-Bred, the giant seed company, asked University

of Nebraska scientist Steve Taylor in 1995 to study a new soybean

they had invented. Pioneer had spliced a Brazil nut gene into

soybean, to make it more protein-rich. Taylor was to check if the

GM soybean would affect people allergic to Brazil nuts, a serious

concern because such people wouldn't think to avoid soy. Just one

of the nut's thousands of proteins was put into Pioneers' new

soybean, and the odds of that one causing the nut's allergies

were incredibly low, Taylor said. But one test, then another, and

finally a third showed that the GE protein was indeed a major

cause of Brazil nut allergies. In trying improve the soybean,

Pioneer had made it potentially more deadly; it quickly halted

the soybean project. Taylor's study is symbolic of all that is

both scary and reassuring about GM food. It proved that GM food

could cause an unexpected and potentially fatal reaction. But the

problem was detected before the product was marketed. Symbolic

because it was, and still is, one of the very few studies ever to

look directly for any harm from a GE food or crop. That dearth of

studies is the legacy of a U.S. policy that treats GM plants and

food to be substantially the same as conventional ones. (See:

Rick Weiss, Washington Post, 15 Aug 1999)

<http://www.washingtonpost.com/wp-srv/health/daily/aug99/gmfood15.htm>

+ This was a very predictable situation. The soya allergy

was caused by the same protein that was responsible for allergic

reactions to Brazil nuts.

- If the allergy was predictable, why did Pioneer even

attempt to create that GE-soya?

+ The fact that the soya with the Brazil nut gene was

recalled and not commercialized shows that the regulatory system

worked.

- The system may have worked in that particular case. How

about all the other cases of commercialized GE-soya?

- A study by the York Nutritional Laboratory, Europe's

leading specialists on food sensitivity, found that health

complaints caused by soya - the ingredient most associated with

GM foods - have increased by 50% in 1998. Researchers said their

findings provide real evidence that GE food could have a

tangible, harmful impact on the human body. It is the first time

in 17 years of testing that soya has crept into the laboratory's

top 10 foods to cause an allergic reaction in consumers. John

Graham, spokesman for the York laboratory, said: "We believe this

raises serious new questions about the safety of GM foods because

it is impossible to guarantee that the soya used in the tests was

GM-free." (See: UK Daily Express, 12 March 1999)

- FDA scientists warn that GE foods could "produce a new

protein allergen" or "enhance the synthesis of existing plant

food allergens." Without labeling, people with certain food

allergies will not be able to know if they might be harmed by the

food they're eating. (NYTimes full page ad, 18 Oct 1999)

- BT: A new study of Ohio crop pickers and handlers finds

that Bt can provoke immunological changes indicative of a

developing allergy. With long-term exposure, affected individuals

might develop asthma or other serious allergic reactions, notes

study leader I. Leonard Bernstein of the University of Cincinnati

College of Medicine. (See: Science News Online, Vol 156 No 1, 3

Jul 1999). This means that people must avoid ingesting even

"relatively safe" biopesticides like Bt.

- BT: A health survey evaluated farm workers before the

spraying of Bt pesticides and 1 and 4 months after the spraying.

Two groups of low and medium exposure workers were also assessed.

While there was no evidence of occupationally-related respiratory

disease, positive skin prick tests were seen in exposed workers,

with a significant increase in the number of positive tests to

spores 1 to 4 months after exposure to Bt. The increase was more

significant in high rather than low exposure workers. The study

concluded that exposure to Bt may lead to allergic skin

sensitisation and induction of IgE antibodies or IgG antibodies -

or both. (Bernstein J L et al. 1999. Immune responses in farm

workers after exposure to Bacillus thuringiensis pesticides.

Environmental Health Perspectives. 107 (7): 575-582)

* BT: The EPA has been asked to approve a new kind of Bt

corn toxin called cry9C, seen as a test case of the degree of

risk the EPA is willing to accept. While other versions of Bt

break down harmlessly in the human digestive tract, cry9C can

survive digestion and remains stable in the human stomach. Thus,

its potential to cause allergies is higher. The FDA demands extra

allergy testing for new food with such stable proteins. AgrEvo,

the German firm seeking cry9C approval, has conducted some more

tests, including a comparison of cry9C's molecular structure with

known allergy-causing proteins. So far, no similarities have been

found. But as the EPA evaluates the corn for human ingestion, the

reality is that there is no surefire way of testing new proteins

like cry9C for their potential to trigger allergies. (See: Rick

Weiss, Washington Post, 15 Aug 1999)

<http://www.washingtonpost.com/wp-srv/health/daily/aug99/gmfood15.htm>

2.1.3. CLAIM: GE-FOODS ARE NOT TOXIC

- A case in which a GE-product might have resulted in toxic

contaminants: a Japanese firm that makes the food supplement

L-tryptophan changed its production process and switched to GE

bacteria, at the same time removing some steps in their

purification process. The new process resulted in a toxic

contaminant that could have come from the GE-bacteria used in

producing the L-tryptophan. Before the product could be recalled,

it had killed 37 and hospitalized 1,500.

<http://www.natural-law.ca/genetic/NewsNov-Dec97/GENews12-23Trypt.htm>

- About 37 people died and some 1,500 became sick after

Japanese company Showa Denko K.K. produced the amino acid

tryptophan using GE - and inadvertently introduced a toxin. A Web

site operated by survivors of the 1989 outbreak agrees with those

basic facts, although one of the articles posted there lists only

28 deaths. (Aberdeen American News, S.D.; Knight Ridder/Tribune

Business News)

+ The L-tryptophan contaminant came not from the GE-bacteria

but from a non-GE source which was overlooked due to the change

in the purification process,

- A non-GE contaminant cannot be ruled out. Unfortunately, A

mysterious fire destroyed all samples of the GE-bacteria used for

the production process, making it impossible for investigators to

conclusively determine the real cause. (See: )

- According to some FDA scientists, GE food may bring "some

undesirable effects such as increased levels of known naturally

occurring toxicants, appearance of new, not previously identified

toxicants, increased capability of concentrating toxic substances

from the environment (e.g., pesticides or heavy metals), and

undesirable alterations in the levels of nutrients." In other

words, scientists from the FDA itself suspect that GE could make

foods toxic. (NYTimes full page ad, 18 Oct 1999)

- Dr. Arpad Pusztai found that a diet of potatoes engineered

to express the snowdrop lectin weakened rats' immune systems and

adversely affected the kidney, thymus, spleen, gut and brain of

the animals. If confirmed, Pusztai's conclusions will reinforce

concerns that gene insertion itself may create new toxins; it

will also implicate the toxin commonly used in other GE-crops -

the Bt toxin which, Pusztai says, is also a lectin.

+ The Royal Society of London reviewed Pusztai's study and

found it flawed and unworthy of publication.

- After the Royal Society's review, however, Pusztai

submitted the results of his study to The Lancet, one of the

world's most prestigious medical journal, which decided to

publish the study. (See: The Lancet, Oct 1999)

* The UK's Royal Society has written to the Natural Law

Party indicating that it has called for Dr Pusztai's work to be

repeated because of the outstanding uncertainties it considers

arise from it. (From: "NLP Wessex" <nlpwessex@bigfoot.com>, 19

Nov 1999) In a way, this is a recognition by the Royal Society

that Pusztai's work deserves to be taken seriously, a reversal of

their earlier condemnation of Pusztai's work.

- The concern of pediatric neurologist Dr. Martha Herbert of

the Council for Responsible Genetics is "the immature gut and

immature body of infants." If introduced too early, even proteins

that are normally part of our diet can lead to auto-immune and

allergic reactions later on, she said. "If a substance harms

adults, it may well harm babies, the sick and the elderly more

severely, and after smaller exposures," Dr. Herbert warned in her

June 1999 statement. (See: ) <http://>

+ BT: The Bt formulation has been in use as a biopesticide

for decades and is not considered harmful to human beings. It is

one of the few insecticides that organic farmers are allowed to

use.

- BT: The Bt biopesticide is relatively safe, compared to

chemical pesticides, but it is not completely safe. The dried Bt

spores, for instance, may be harmful to the human immune system.

French scientists at le Bouchet army research labs found that the

spores caused lung inflammation, internal bleeding and death in

lab mice. Last year, French scientists isolated a Bt strain that

destroyed tissue in the wounds of a French soldier in Bosnia. The

strain, known as H34, also infected wounds in immuno-suppressed

mice. Now the same team has found that H34 can kill mice with

intact immune systems if they inhale the spores. Francoise

Ramisse of le Bouchet and her colleagues found that healthy mice

inhaling 108 spores of Bt H34 died within eight hours from

internal bleeding and tissue damage. (See: New Scientist, 29 May

1999)

+ BT: Spores from mutants of the Bt H34 strain which did not

produce the toxin were equally lethal to mice, suggesting that

the Bt toxin was not to blame. Researchers think the symptoms are

caused by other toxins. The bacterium's close cousin, Bacillus

cereus, produces a toxin that ruptures cell membranes. And in

1991, Japanese researchers showed that B. thuringiensis produces

the same toxin. (See: New Scientist, 29 May 1999)

+ BT: Since the natural Bt toxin is relatively safe, then

the GE-toxin in corn is safe too.

- BT: The Bt corn toxin is not identical to the natural

toxin. The natural Bt gene which produces the toxin was

substantially modified before it was transferred to corn. The

toxin gene in Bt corn is a truncated version (at both 5' and 3'

ends) of the Bt toxin and is the smallest fragment that still

possesses toxicity to insects. (See: M. Vaeck et al. Nature 328,

33-37, 1987, as cited by Heine Deelstra).

* BT: Why is it a bad thing if they are not identical?

- BT: This means that, unlike the natural Bt toxin, the Bt

corn toxin has never existed in nature, until Bt corn started

synthesizing it. It is risky to put into our gut any substance

which our gut has never seen before, because we have not evolved

to handle such a substance. In our experience with synthetic

chemicals, this has led to various long-term problems like

cancers.

+ BT: The Bt natural gene produces a large, inactive

pro-toxin that is about 1200 amino acids in length. This

pro-toxin releases upon digestion by proteases (in the insects

gut) an active 68,000 Dalton fragment. So the pro-toxins of

plants and Bt may differ in length, while the active toxic

fragment is exactly the same in size and mode of action.

Truncation of sequences before and after the 'toxic fragment'

might affect, due to folding differences, (1) the crystallisation

properties and (2) the susceptibility to proteases of the

pro-toxin. The occurrence of (1) and/or (2) are not known to me.

(Heine J. Deelstra <h.j.deelstra@bioledu.rug.nl>, on GENTECH

list)

- BT: The Bt corn toxin is up to 100 times more powerful

than the natural toxin. This is part of the high-dose strategy

which supposedly delays the development of resistance in corn

borers. However, such high doses may also be riskier to

non-target species, including human beings who ingest the toxin

when they eat Bt corn.

- BT: The expression of the full-length [Bt] toxin was too

low to achieve pest resistance in plants other than tobacco

(against the tobacco hornworm) and tomato plants. Toxin levels

were so low that protection was not attained against less

sensitive, but agronomically-important insect pests. Researchers

then modified part of the Bt toxin coding sequence so that it was

efficiently expressed (and translated) in plants. This was done

by using a synthetic toxin gene for amino acids 1-453 (coding for

the same amino acids as the natural Bt toxin gene but using

codons preferred by plants) and fusing this with the (natural)

gene fragment encoding for amino acids 454-615. The rest of the

bacterial gene (amino acids 616-1178) was not used. Expression of

this gene in cotton plants showed that Bt toxin levels were

increased by 100 times and that Bt toxin constituted 0.02% of the

protein in the plant. (See: Recombinant DNA, 2nd edition by James

D. Watson et al. and Moleculaire Biologie van Schimmels en

Planten (in Dutch), 1998 by Prof. J.G.H Wessels, as cited by

Deelstra)

- The genetically engineered sweetener Aspartame has caused

thousands of documented disease cases worldwide. (From:

pmligotti@earthlink.net)

2.1.4. CLAIM: GE-FOODS DO NOT CAUSE CANCER

- HT: Since herbicide-resistant GE-crops lead to greater

herbicide use, cancer risk can also come from exposure to higher

levels of herbicides like bromoxynil (Rhone-Poulenc's Buctril)

and glyphosate (Monsanto's Roundup). Authors Marc Lappe and Britt

Bailey (Against the Grain, 1998) warn that bromoxynil

bioaccumulates, because it is fat-soluble. Rat and rabbit studies

have shown birth defects, other developmental disorders in

fetuses, tumors, and carcinomas at levels ranging from 20 to 300

parts per million. (See: Lappe, Marc and Britt Bailey; Against

the Grain, 1998) (http:)

- HT: Glyphosate exposure, on the other hand, can triple the

risk of non-Hodgkin's lymphoma, say cancer specialists Dr.

Lennart Hardell and Dr. Mikael Eriksson of Sweden's Orebro

Hospital, in a study published in the American Cancer Society

journal (See: Cancer, 3/15/99) (http:)

- RBGH: U.S. food campaigner Robert Cohen warns about the

hormone Insulin-like Growth Factor-1 (IGF-1), identical versions

of which occur in cows and humans. In 1994, Cohen says, the U.S.

FDA approved the use of a GE-hormone (rBGH) in cows to stimulate

milk production. Using rBGH raises IGF-1 levels in cows' milk by

80%. IGF-1, Cohen warns, is a key factor in prostrate cancer

(Science, 1/98), breast cancer (The Lancet, 5/98), and lung

cancer (Journal of the NCI, 1/99). Most recently, Cohen cites a

report in the Journal of the American Dietetic Association

(10/99, p.1231), which found IGF-1 levels in the blood of milk

drinkers 10% higher than in non-drinkers. The implication:

GE-milk exposes its drinkers to higher cancer risks. (See: )

- RBGH: On December 15, 1998, the Center for Food Safety, on

behalf of a broad coalition, filed a legal petition in

Washington, D.C. against the FDA to have rBGH taken off the

market. The CFS petition cites mounting evidence that the

original testing of rBGH was flawed. In 1990 the FDA said BGH was

"safe for human consumption." Part of its findings were based on

90-day rat feeding studies in which they reported "no

toxicologically significant changes..." Based largely on this

conclusion, FDA did not require human toxicological tests usually

required for a veterinary drug. However in April 1998,

researchers from Health Canada, the Canadian equivalent to FDA,

issued a report contradicting FDA's findings. Canadian

researchers found studies showing that rats were absorbing rBGH

after all. In fact, between 20 and 30 percent of the rats were

developing distinct immunological reactions. Additionally, cysts

formed in the thyroid of some male rats and infiltrated the

prostate - both warning signs for potential cancer hazards.

- RBGH: Milk from cows injected with rBGH, which is not

analogous to normal BGH (7), has elevated insulin-like growth

factor that is implicated as a risk factor in human breast cancer

(8,9). (See: "Will genetically engineered crops mean adulterated

and toxic food, bodies, and ecosystems?", Michael W. Fox, Senior

Scholar/ Bioethics, The Humane Society of the United States 2100

L Street, NW Washington, DC 20037)

- RBGH: The EU Scientific Committee on Animal Health and

Animal Welfare on Animal Health Aspects of the Use of Bovine

Somatotropin, rBST, (adopted March 10th 1999) has recommended

that, due to foot problems, mastitis and injection site reactions

in dairy cows, rBST from an animal welfare and health point of

view, should not be used. This is an important recommendation

given the upcoming vote on rBST in International Trade.

- RBGH: At the previous 22nd Codex session, the Codex

Alimentarius Commission decided to suspend the consideration of

Maximum Reside Limits for rBGH. The reason for the suspension was

so that scientific data could be re-evaluated. Since then, there

has been more evidence that rBGH is not safe. The 23rd Session of

the Codex Alimentarius Commission was held in Rome, June 28 -

July 3, 1999. Since the U.S. realized that they were not going to

win on this issue, they essentially dropped it.

+ These examples are not due to the effect of GE but rather

the use of the chemicals or hormones.

- HT:/RBGH: But the higher cancer risks are the consequence

of GE products (more herbicide residues in food, higher IGF-1

levels in milk, etc.). People would not have been exposed to

these risks if HT crops or rBGH had not been developed.

2.1.5. CLAIM: GE-FOODS DO NOT GIVE RISE TO PATHOGENS

- "The evidence is now overwhelming that horizontal gene

transfer has been responsible for both the rapid spread of

antibiotic resistance and for the emergence of virulent strains

of pathogens in recent years... One main contributing factor to

the recent increase in the scope and frequency of horizontal gene

transfers may be the deliberate acts of genetic engineers to

break down species barriers. They do so by constructing a range

of chimaeric vectors for cloning, and transferring genes... Thus,

genetic engineering biotechnology has opened effectively opened

up highways for horizontal gene transfer and recombination, where

previously, there was only restricted access through narrow,

tortuous footpaths." (See: Mae Wan-Ho, Terje Traavik, Orjan

Olsvik, Tore Midtvedt, Beatrix Tappeser, C. Vyvyan Howard,

Christine von Weizsaecker, and George C. McGavin; Gene Technology

in the Etiology of Drug-resistant Diseases, 1998.

+ Their conclusion is unsupported by there data; no recent

increase of transfer has been observed.

- In May 1999, the British Medical Association, which

counts some 80% or nearly 115,000 of Britain's medical doctors,

issued an official statement in May 1999 expressing concern over

the safety of GE-foods. The BMA recommended a moratorium on

planting commercial GE-crops in the UK "until there is scientific

consensus (or as close agreement as reasonably achievable) about

the potential long-term environmental effects." The BMA also

called for 1) segregation at source, "to enable identification

and traceability" of GE-foods; 2) labelling GE-imports and

banning unlabelled ones, if the industry refuses to segregate;

and 3) more robust systems of disease surveillance, to deal with

"potential emergence of new diseases associated with GM material

which will be obscure and difficult to diagnose". (See: "The

Impact of Genetic Modification on Agriculture, Food and Health",

British Medical Association, May 1999)

- Mae Wan-Ho and Angela Ryan of the UK Open University

warned last July 1999 that "no transgenic plant containing the

CaMV promoter should be released," because the Cauliflower Mosaic

Virus (CaMV) promoter is "very likely to recombine with other DNA

in the host genome, including dormant viral DNA, as well as with

other viruses in the host cell." The problem covers practically

all GE-plants released so far. These GE-plants, according to

Ryan, "have the potential to create new viruses or other invasive

genetic elements." (See: )

- There is potential for vector recombination to generate

new virulent strains of viruses, especially in transgenic plants

engineered for viral resistance with viral genes. In plants

containing coat protein genes, there is a possibility that such

genes will be taken up by unrelated viruses infecting the plant.

In such situations, the foreign gene changes the coat structure

of the viruses and may confer properties such as changed method

of transmission between plants. The second potential risk is that

recombination between RNA virus and a viral RNA inside the

transgenic crop could produce a new pathogen leading to more

severe disease problems. Some researchers have shown that

recombination occurs in transgenic plants and that under certain

conditions it produces a new viral strain with altered host

range. (Steinbrecher, R.A. (1996) From Green to Gene Revolution:

the environmental risks of genetically engineered crops. The

Ecologist 26, 273-282. As cited in: "Ten reasons why

biotechnology will not ensure food security, protect the

environment and reduce poverty in the developing world"; Miguel

A. Altieri, UC Berkeley and Peter Rosset, Institute for Food and

Development Policy, Oakland, CA)

- The Cauliflower Mosaic Virus (CaMV) and HIV have

interchangeable components, according to five researchers of the

John Innes Centre and Sainsbury Laboratory (UK). (See John Innes

Centre Annual Report, 1998/1999) If they meet in nature, they

could recombine to form chimeric viruses with potentially

devastating properties. (jcummins@julian.uwo.ca, 6 Nov 1999) This

can happen, for instance, if pollen from a GE plant is inhaled by

an HIV-positive or AIDS-stricken person.

- The 1999 UK John Innes Centre and Sainsbury Laboratory

Annual report specifically acknowledges that this particular

viral promoter is prone to 'recombination' events (see

http://www.btinternet.com/~nlpwessex/Documents/camv.htm for more

information).

- One must consider not only the "fate" of GMOs but also the

genes and viruses or parts thereof, that have been inserted into

them. Such "naked DNA", in the form of recombinant and modified

nucleic acids, has been found capable of surviving and remaining

functional longer after organisms' death than was assumed

previously.(6,30) Furthermore, xenobiotics, especially dioxins

and various agrichemicals, can act as mutagens (31), altering the

structure and sequence of DNA and also increasing the

permeability of cells and the incorporation of foreign DNA into

living organisms. (See: "Will genetically engineered crops mean

adulterated and toxic food, bodies, and ecosystems?", Michael W.

Fox, Senior Scholar/ Bioethics, The Humane Society of the United

States 2100 L Street, NW Washington, DC 20037)

- The use of the Cauliflower Mosaic Viral promoter (CaMV)

has the potential to reactivate dormant viruses or create new

viruses in all species to which it is transferred. CaMV is known

to be found in practically all current transgenic crops released

commercially or undergoing field trials. This transgenic

instability increases the possibility of promotion of an

inappropriate over-expression of genes to the transferred

species. The development of cancer may be one consequence of such

inappropriate over-expression of genes. The scientists behind the

research "strongly recommend that all transgenic crops containing

CaMV 35S or similar promoters which are recombinogenic should be

immediately withdrawn from commercial production or open field

trials. All products derived from such crops containing

transgenic DNA should also be immediately withdrawn from sale and

from use for human consumption or animal feed". (See: Mae-Wan Ho,

Angela Ryan, and Joseph Cummins, "Cauliflower Mosaic Viral

Promotor - A recipe for Disaster?", Microbial Ecology in Health

and Disease (Dec 1999).

2.1.6. CLAIM: GE-FOODS DO NOT CAUSE ANTIBIOTIC-RESISTANCE

- Many GE-foods contain antibiotic-resistance marker (ARM)

genes. These genes can be acquired by harmful bacteria through

horizontal gene transfer, making it more difficult to cure

diseases.

+ There is very low probability that ARM genes in GE-plants

can transfer to pathogenic bacteria.

- In May 1999, The British Medical Association called for a

"ban on the use of antibiotic resistance marker genes in GM food,

as the risk to human health from antibiotic resistance developing

in micro-organisms is one of the major public health threats that

will be faced in the 21st Century." (See: "The Impact of Genetic

Modification on Agriculture, Food and Health", British Medical

Association, May 1999) (http:/)

+ Modified DNA quickly breaks down in the gut, so it cannot

transfer antibiotic resistance

- Using an "artificial gut", Dutch researchers showed that

DNA remains intact for several minutes in the large intestine. If

the GE bacteria were a type normally found in the gut, such as

Enterococcus, the experiment showed each had a 1 in 10 million

chance of passing DNA containing ARM genes to an native gut

bacterium when they came in contact. There are normally around a

thousand billion gut bacteria, suggesting that many would be

transformed. If some normal gut bacteria were killed off - as in

the guts of people or animals in antibiotics - the transfer rate

from gut-type bacteria increased tenfold. (See: New Scientist, 30

Jan 1999)

- Safer New Screen for GM Crops: Rockefeller University and

University of Singapore researchers can now screen for GM crops

without having to insert an ARM gene. The new method, described

in Nature, uses a gene that enhances a plant's use of its own

growth hormones. (Irish Times, 13 Sep 1999) If ARM genes are

safe, why are so much research funds being spent looking for

alternatives to these genes?

+ Because plants with ARM genes won't sell, that's why.

- They won't sell because medical doctors, like members of

the British Medical Association, have warned against their

dangers.

- Countries which have banned the use of ARM genes: Norway

- Countries where a ban on the use of ARM genes has been

proposed: Europe (See:)

2.1.7. CLAIM: GE-FOODS DO NOT AFFECT OUR IMMUNE SYSTEM

- Twenty two leading scientists recently declared that

animal test results linking GE foods to immuno-suppression are

valid. (NYTimes full page ad, 18 Oct 1999)

2.1.10. OTHERS

- HT: Lappe and Bailey also noted the "remarkably high

estrogenic activity of soy isoflavones," elevated levels of which

have been found in herbicide-treated GE-soya. "If ingested by

nursing infants, these isoflavones can produce circulating levels

equivalent to 13,000 to 22,000 times the normal plasma estradiol

concentrations found in babies, with unknown and potentially

dangerous secondary effects," they warned. Early exposure to