26 October 2000

Table of Contents

(US):Govt. Said To Violate Endangered Species Act
A drug to change the genes
Concerns over GE Wheat and Cross-Polination
Health Aspects of Bt Plant-Pesticides (Allergenicity, Toxicity etc. – quite long!)
Bacillus thuringiensis and its Toxins as Biopesticides
Stray genes highlight superweed danger
Dutch RaboBank Code of Conduct re: transgenic technologies
Belgium to Boost Organic Farming by 60% a year
GM crop – Bee Disease link etc.
GMO on Bees: testimony by Joe Rowland to the N.Y. Assembly
A Lesson for current Reviews on GM crops: "Mad cows cast long shadows"

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Date: 19 Oct 2000 04:30:12 +0100

(US):Govt. Said To Violate Endangered Species Act

By PHILIP BRASHER, AP Farm Writer, October 19, 2000

WASHINGTON (AP) via NewsEdge Corporation -

Groups opposed to genetically engineered crops accused the government of violating the Endangered Species Act in considering whether to renew licenses for gene-altered crops that are toxic to insects.

The groups, which notified the Environmental Protection Agency on Wednesday of their intent to sue the agency, said the crops may harm a number of endangered insects such as the Karner Blue butterfly, sometimes found near corn fields.

Registrations for several varieties of genetically engineered corn and cotton are due to expire next year.

The EPA has been gathering research data and consulting with a panel of scientists about the impact of the crops on human health and the environment.

In a preliminary assessment released last month, the agency concluded there was little risk to butterflies or any other insects which the toxin is not supposed to harm. A three-day meeting by the agency's scientific advisory panel began Wednesday in Arlington, Va.

Under the Endangered Species Act, the EPA would be required to consult with the Fish and Wildlife Service and to take actions to protect the threatened species from the crops. We're certainly open to new scientific information and will take that into consideration as we complete our said Steve Johnson, a senior EPA official.

A Cornell University study released last year raised concerns about biotech corn after finding that the pollen was toxic to Monarchs in the laboratory. The butterfly feeds on milkweed, which often grows in and around corn fields in the Midwest. EPA has had its head in the sand since it learned that genetically engineered corn could be killing Monarch said Charles Margulis of Greenpeace, one of the groups planning to sue the EPA.

Although pollen from biotech corn can kill Monarch butterflies, there is probably little risk to them around corn fields, based on the latest research, according to the EPA study.

The agency said some scientists even believe the corn may even turn out to be beneficial to the butterflies because farmers are using less chemical pesticides.

The corn and cotton contain a bacterium gene that is inserted into the plant to produce a toxin that kills a major pest, the European corn borer.

The EPA has been concerned that the corn borer and other pests may become resistant to the toxin, which is also used in an insecticide popular with organic farmers.

So far, there has been no evidence of resistant insects, although some insects have shown a temporary tolerance to the toxin, agency scientists said Wednesday.

To prevent the development of resistant insects, the agency requires farmers to plant sections of non-biotech crops within or around the gene-altered varieties

On the Net: Environmental Protection Agency:


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Date: 19 Oct 2000 22:42:05 +0100
From: "jcummins"

A drug to change the genes

The paper below describes a drug that changes the genes. Such drugs can be used on humans, animals and plants.

Science Oct 20 2000: 530-533.

Specific Mutations Induced by Triplex-Forming Oligonucleotides in Mice

Karen M. Vasquez, Latha Narayanan, Peter M. Glazer

Triplex-forming oligonucleotides (TFOs) recognize and bind to specific duplex DNA sequences and have been used extensively to modify gene function in cells. Although germ line mutations can be incorporated by means of embryonic stem cell technology, little progress has been made toward introducing mutations in somatic cells of living organisms. Here we demonstrate that TFOs can induce mutations at specific genomic sites in somatic cells of adult mice. Mutation detection was facilitated by the use of transgenic mice bearing chromosomal copies of the supF and cII reporter genes. Mice treated with a supF-targeted TFO displayed about fivefold greater mutation frequencies in the supF gene compared with mice treated with a scrambled sequence control oligomer. No mutagenesis was detected in the control gene (cII) with either oligonucleotide. These results demonstrate that site-specific, TFO-directed genome modification can be accomplished in intact animals.

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Date: 21 Oct 2000 06:06:17 +0100
Originated from: Biotech Activists
Posted: 10/20/2000 By

Concerns over GE Wheat and Cross-Polination

Edited by Ron Daines, Idaho Farmer Stockman, a Farm Progress publication , 10-20-2000

Researchers in Idaho and Oregon will use $900,000 over the next four years to develop ways to prevent the escape of genes from genetically modified wheat into the closely related weed, jointed goatgrass.

Project leaders Robert Zemetra, a University of Idaho wheat breeder in Moscow, and Carol Mallory-Smith, Oregon State University weed scientist at Corvallis, found that wheat and jointed goatgrass could cross naturally and form partially fertile hybrids. They published their findings in the 1998 journal Weed Science.

While genetically modified wheat has yet to be approved for production in the United States, some fear that when it is, new genes could escape into the crop's wild relatives, creating super weeds. Zemetra says the research is geared to preclude the problem from arising in the first place. Jointed goatgrass, an introduced weed, is found in 48 states and is particularly troublesome for winter wheat growers, infesting 5 million acres planted to the grain and another 2.5 million fallow acres. The estimated loss to growers is $45 million a year from reduced production and grain value.

Idaho and Oregon are already part of an 11-state research program with Montana, Texas, Colorado, Kansas, Nebraska, Oklahoma, Wyoming, Utah and Washington to combat the weed.

"Jointed goatgrass is a major problem for wheat farmers in the western United States," says Zemetra. "And part of the problem is because it is so closely related to wheat, it is difficult to control once it gets established in a field."

The difficulty results from a shared genome. Wheat has six sets of chromosomes, two from each of its ancestors. Jointed goatgrass has four sets of chromosomes, two of them from a parent species it shares with wheat. Their similarities mean herbicides that killing jointed goatgrass kills wheat, too. Cultivation and other strategies to kill the weed also kill the crop.

The problem has increased interest in the development of herbicide resistant-wheat varieties through genetic engineering. That way, a herbicide could be sprayed on a wheat field, killing the weed and leaving the resistant wheat plants to grow without competition.

A problem that could occur with a genetically modified plant is a gene crossing from crops to weeds. "One of the ideas is, could gene placement minimize or prevent the movement of a transgenic gene from wheat into a weedy species?" says Zemetra. He notes that it may be possible to prevent the herbicide-resistance gene from leaping from wheat to weed by inserting it into the two wheat genomes not shared by goatgrass.

The research will test the mechanisms at work in gene transfers between wheat and jointed goatgrass. The team will also develop management strategies growers can use to minimize the chances of gene transfers from wheat to weed, says Zemetra. The research could also apply to other polyploid crops, those with multiple sets of chromosomes, like canola and rapeseed.

"You could potentially extrapolate what we find out about the genome work from wheat to something like canola for determining how easy would a gene move and be retained in its weedy relatives," Zemetra says. Joining Zemetra and Mallory-Smith on the project, funded by the U.S. Department of Agriculture, will be UI weed scientist and extension specialist Don Morishita at Twin Falls and OSU crop scientist Oscar Riera-Lizarazu.

Developed for by Farm Progress. Copyright 2000, Farm Progress.


"GM crops are not developed for the benefit of farmers or consumers, but for the benefit of multinational agrochemical companies which promise so much from the development of biotechnology but have so far delivered very little. We have survived very well for 2,000 years in this country using conventional plant breeding methods, but I am not convinced that there is now a compulsion to grow GM crops. I would prefer to give up farming than to be forced into adopting new biotechnology..."

- UK farmer, Arnold Pennant, quoted in The Times (London) September 25, 2000,

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Date: 23 Oct 2000 06:07:22 +0100
Via: Biotech Activists
Posted by: 10/23/2000 By

Presented to the EPA Science Advisory Panel Arlington, VA October 20, 2000

Very long article!

Health Aspects of Bt Plant-Pesticides (Allergenicity, Toxicity etc.)


Comments on the human health and product characterization sections of EPA's Bt Plant-Pesticides Biopesticides Registration Action Document

By Michael Hansen, Ph.D., Consumer Policy Institute/Consumers Union

Antibiotic resistance marker genes
Acute toxicity testing
Product Characterization
Need for Long-term Toxicity Tests

Thank you for the opportunity to present the comments of the Consumer Policy Institute/Consumers Union on a subset of the Environmental Protection Agency's Bt Plant-Pesticides Biopesticides Registration Action Document. We would like to comment on two questions: human health questions and product characterization. We believe that the human health data that EPA presently requires are inadequate and that more data need to be taken. Below, we propose some of the additional data that should be required before any of these crops can be reregistered.

Please provide comment on whether the human health data is an adequate evaluation of the risk from the Bt proteins. What, if any, additional data is necessary to assess the risk from the Bt-expressing plant-pesticide products?

We would particularly like to address the issues of allergenicity, antibiotic resistance marker genes and acute toxicity testing.


We do not think that the human health data that EPA currently has are adequate. In particular, EPA seems to have ignored a crucial study that suggests that the Bt delta endotoxin is an inhalant allergen, which could present risks, in an occupational sense, to farmworkers and millworkers that are exposed to dust from the processing of Bt crops.

EPA maintains that "After decades of widespread use of Bacillus thuringiensis as a pesticide (it has been registered since 1961), there have been no confirmed reports of immediate or delayed allergic reactions to the delta-endotoxin itself despite significant oral, dermal and inhalation exposure to the microbial product" (EPA, 2000: pg. IIB6). We believe that this statement is at best misleading. Last year, an EPA-funded study was published in Environmental Health Perspectives titled "Immune responses in farm workers after exposure to Bacillus thuringiensis pesticides." The article pointed out that more work needs to be done to evaluate the allergenic potential of Bt sprays, as there have been 3 studies that are suggestive of the Bt sprays having an effect. The authors are concerned because, as they point out, "approximately 75 percent of asthma cases are triggered by allergens and mordibity and mortality due to asthma have increased considerably over the past 20 years" (Bernstein et al, 1999: 570).

The study consisted of a surveillance program of farm workers before and after exposure to Bt pesticides. This study does not show a definitive link between exposure to Bt sprays and occupationally related respiratory symptoms, but did find that a number of the workers exhibited skin sensitization and presence of IgE and IgG antibodies with those responses being more numerous in those workers with higher levels of exposure. Both skin sensitization and IgE antibodies are components of an allergic response.

As part of the study, the scientists were able to show that 2 of the farm workers studied had a positive skin-prick test to the Btk spore extract containing the pro-delta-endotoxin active component, as well IgE antibodies. This means that there are now skin and serologic agents that could be used to test the potential allergenicity of the various delta-endotoxins that have been engineered into Bt crops.

Although the authors say that their results should allay some of the concerns about the allergenicity of transgenic foods from Bt crops, they clearly say that they now have the skin and serologic agents to do such tests: "Because reactivity to the Btk pro-delta-endotoxin was only encountered in 2 of 123 workers sensitized by the respiratory route, it is unlikely that consumers would develop allergic sensitivity after oral exposure to transgenic foods (e.g., tomatoes, potatoes) that currently contain the gene encoding this protein. However, future clinical assessment of this possibility is now feasible because of the availability of reliable Bt skin and serologic reagents developed during the course of this investigation" italics added (Bernstein et al., 1999: 581).

Given that such Btk skin and serologic agents exist, we feel that all the Bt crops should be retested using these skin and serologic reagents. Although the reaction was to the pro-delta-endotoxin, separate genetic studies (gel electrophoresis and hybridized blot analysis) demonstrated the presence of genes for the Cry 1Ab and Cry1Ac delta endotoxins in both spray formulations (Javelin and Agree) to which the workers had been exposed. Truncated version of the Cry1Ab and Cry1Ac are present in the Bt corn and Bt cotton events, respectively.

Unless the allergenic epitopes are all found in the part of the delta endotoxin that is removed during truncation, one could reasonably expect that the Bt corn and cotton crops would contain an allergenic epitope.

Indeed, Furthermore, use of these reagents would be superior to the current criteria presently used to evaluate the allergenicity of these crops: amino acid sequence homology to known allergens; resistance to acid and gastric digestion; heat stability/heat resistance; and molecular size. None of these criteria are exact as the state of science in the field of allergenicity is still in its infant stages. (SAP, 2000: 7;

Clearly, if skin and serologic reagents from humans exist for a given protein, then any allergenicity testing must use such reagents. If the reagents become available after the crops have been approved, the companies should be required to retest those crops because the human reagents are far more accurate than the four criteria presently being used.

Since one of the co-authors of the paper, Dr. Donald Doerfler, is an EPA scientist, we wonder why the EPA hasn't already moved to conduct these tests. With the use of these skin and serologic reagents, the testing of Bt crops would not take that long and would be relatively inexpensive. So why hasn't such a test been carried out?

EPA has argued that there occupational exposure to the Cry9C protein (or the other Cry proteins inserted into corn, cotton) is negligible, or presents no risk because the Cry proteins are not toxic to people (Biopesticide Fact Sheet, 1999). Yet the EPA presented no study to substantiate the claim of negligible exposure.

In fact, there is scientific evidence that occupational exposure to grain dust can lead to allergic symptoms, with the classic case being bakers' asthma (Baur, 1998). Recent studies have also implicated corn dust in respiratory dsyfunctions including acute respiratory inflamation (Park et al., 1998; Wohlford-Lenane et al., 1999) and in glove-lubricant-powder derived allergy (Crippa et al., 1997). Thus, corn dust can clearly convey allergens, and the pro-delta-endotoxin is potentially allergenic, so there is ample evidence to be concerned about occupational exposure to grain dusts, especially corn.

Interestingly, while the authors of that study found that farm workers had skin reactions and IgE antibodies to Bt spray, they could not link any respiratory symptoms to the occupational exposure. However, this could be a result of the fairly low levels of Bt that the farm workers were exposed to. The concentration of delta-endotoxin in the Bt crops, particularly corn, is between one to two orders of magnitude higher compared to Bt sprays.

That's why the insect resistance management strategy is called the "high dose" strategy. Furthermore, the concentration of the Cry9C protein in the seed is one to two orders of magnitude higher than the concentration of Cry1Ab or Cry1Ac in corn and cotton, respectively-18.6 ug/gm (kernal) for Cry9C vs. 1.4 ug/gm (kernel), 0.19-0.39 ug/g (grain), and 1.62 ug/g for Cry1Ab-Bt11, Cry1Ab-MON810, and Cry1Ac, respectively (EPA, 2000: pg. IIC17). So, the concentration of Cry9C in corn dust could conceivably be 2 to 3 orders of magnitude higher than they level of endotoxin found in foliar Bt sprays.

So, the Bt crops have far higher levels of endotoxin in the grain and leaves than do the foliar Bt sprays. Furthermore, while farm workers are exposed to the foliar Bt sprays, workers in mills or other areas where grains are being processed would be exposed to grain dust and so could conceivably be exposed to far higher quantities of the Bt endotoxin than a farm worker would.

Antibiotic resistance marker genes

In 1991-1992, when FDA was developing its policy of GE plants, the conventional wisdom in the scientific community was that DNA was a very fragile molecule that would be readily broken down in the environment and would not survive digestion in the gut. We now know that both assumptions may not always be valid (Traavik, 1998).

Even though DNases (molecules that break down DNA) are widely distributed in the environment, free DNA has been found in all ecosystems (marine, fresh water, sediments) studied (Lorenz and Wackernagel, 1994).

Indeed, pooled data suggest that free DNA is present in significant amounts in the environment. Larger amounts of DNA are extracted from soil than can be extracted from the cells in the soil (Steffan et al., 1988).

Further studies have shown that this free DNA in the soil comes from microorganisms that no longer occur in that habitat (Spring et al., 1992) thus demonstrating that DNA can out-survive the organism it came from and still be capable of being taken up and expressed by microorganisms. Finally, yet other studies have found that pollution (i.e. xenobiotics) can affect the survivability of DNA and the possibility of its transfer to other organisms (Traavik, 1998).

These data lead to serious concerns about the antibiotic resistance marker genes that are present in virtually all engineered plants presently on the market. These genes code for proteins that confer resistance to a given antibiotic. The possibility therefore exists that these genes for antibiotic resistance could be taken up by bacteria, thus exacerbating the already very serious problem of antibiotic resistance in disease causing organisms.

In mammalian system, the question is whether foreign DNA can survive digestion, be taken up through the epithelial surfaces of the gastrointestinal or respiratory tract or not, or be excreted in feces. Studies in the 1970s (Maturin and Curtiss, 1977) and 1980s (McAllan, 1982) in rats and ruminants, respectively, suggested that nucleic acids (e.g. DNA and RNA) failed to find evidence that DNA survived digestion. Consequently, many scientists assumed that DNA was readily digested. However, the methods used to detect DNA were not very sensitive.

In the mid-1990s, researchers in Germany, re-investigated the issue, using far more sensitive methods (Schubbert et al., 1994). Mice were fed DNA from the M13 bacteriophage either by pipette or by adding it to the feed pellets. Using sensitive hybridization methods and PCR (polymerase chain reaction) the authors found 2-4% of the M13 DNA in feces and 0.01-0.1% in the blood-both in serum and cell fraction. Sizeable DNA fragments (almost a quarter of the M13 genome) could be found up to 7 hours after uptake.

If free DNA is not immediately digested in the gastrointestinal tract, the possibility also exists that it can be transferred to bacteria that live there. A recent study utilizing a simulated human gut demonstrated that naked DNA had a half-life of 6 minutes, more than enough time for such DNA to transform bacteria (ref to come).

In another experiment, a genetically engineered plasmid was found to survive (6 to 25%) up to an hour of exposure to human saliva (Mercer et al., 1999). Partially degraded plasmid DNA also successfully transformed Streptococcus gordonii, a bacteria that normally lives in the human mouth and pharynx although the frequency of transformation dropped exponentially with time. Transformation occurred with either filter-sterilized human saliva or unfiltered saliva.

The study also found that human saliva contains factors that increase the ability of resident bacteria to become transformed by "naked" DNA. Since transgenic DNA from food is highly unlike to be completely broken down in the mouth, it may be able to transform resident bacteria. Of particular concern would be the uptake of transgenic DNA containing antibiotic resistance marker genes, which are found the majority of GE crops presently on the market. It should be pointed out that the antibiotic marker gene present in Novartis' Bt corn, which codes for resistance to ampicillin, is under the control of a bacterial promoter rather than a plant promoter which would further increase the possibility of expression of the ampicillin resistance gene if it were taken up by bacteria.

In September, 1998, the British Royal Society put out a report on genetic engineering that called for ending the use of antibiotic resistance marker genes in engineered food products (Anonymous, 1998). In May, 1999, the British Medical Association, which represents some 85% of the doctors in Britain, released a report calling, in part, for a prohibition on the use of antibiotic resistance mark genes in genetically engineered plants: "The BMA believes that the use of antibiotic resistance marker genes in GM foodstuffs is a completely unacceptable risk, however slight, to human health. . . Recommendations . . . 6. There should be a ban on the use of antibiotc resistance marker genes in GM food" (BMA, 1999).

In the European Union Directive 90/220/EEC deals with the deliberate release of GEFs into the environment. The European Commission is in the process of coming with a revised version of the Directive. This revised version contains a provision which would phase out the use of antibiotic resistance marker genes by 2005 (European Commission Services, 2000)

We therefore urge EPA to prohibit use of antibiotic resistance marker genes as there is no consumer benefit for the presence of such genes in engineered foods and a potential risk.

Acute toxicity testing

At present, EPA requires only an acute toxicity feeding test. Furthermore, the delta-endotoxin that is used in these feeding tests come from a genetically engineered bacteria rather than from the transgenic plant itself. The EPA assumes that there are no real difference between a delta-endotoxin produced by an engineered bacteria and one produced in a plant.

We believe this ignores the phenomenon of post-translational processing, which consists of the modification of a protein after it has been translated from the genetic message. And such post-translational processing can have a significant impact on the structure and function of a gene. Furthermore, post-translational processing can differ between organisms, so that the same gene expressed in different genetic backgrounds may have the same amino acid sequence but may differ in structure and function. Examples of such processing includes glycosylation and acetylation.

Glycosylation consists of the addition of sugar groups (usually oligosaccharides) and can dramatically affect the three-dimensional structure and thus, function of a protein. Indeed, glycosylation is thought to be connected to allergenic and immunogenic responses (Benjuoad et al., 1992). The data presented to the EPA suggest that the delta-endotoxins are not glycosylated in the plants.

Acetylation of proteins consists of the addition of acetyl groups to certain amino acids, thereby modifying their behavior. Although incompletely understood, acetylation of the amino acid lysine has been most studied in certain groups of proteins that bind with DNA-histones and high-mobility group proteins-and such acetylation appears to be involved with the regulation of interaction of these proteins with negatively charged DNA molecules (Csordas, 1990).

However, it has been discovered that some the lysine residues in rbGH are acetylated, to form epsilon-N-acetyllysine when it is produced in E. coli . Harbour et al. (1992) found this to occur at lysine residues 157, 167, 171 and 180 or rbGH, while Violand et al. (1994) found it at residues 144, 157, and 167. The creation of this mutant amino acid may be overlooked because "(T)he identification of this amino acid cannot be determined by simple amino acid analysis because the acetyl group is labile to the acidic or basic conditions normally used for hydrolysis" (Violand et al, 1994: 1089). The effect this has on the safety, structure and function of rbGH is not known as it hasn't been actively studied.

The differences in glycosylation and acetylation that can happen when transgenes are expressed in plants or bacteria can possibly affect toxicity and therefore lend further support to the need for toxicity testing using the whole engineered food. Even if there are no differences in glycosylation (as appears to be the case for the delta-endotoxins), acetylation of lysine residue(s) could cause differences.

The presence of such mutant lysine residues could easily be missed as routine amino acid analysis will remove the acetyl group; to find if there are mutant lysine residues, one must specifically look produce the transgene of interest (gene for herbicide tolerance or Bt endotoxin, for example). Thus, whenever possible, EPA should require the companies to use material derived from the transgenic plants themselves in toxicity studies rather than bacterially-derived proteins.

Product Characterization

Please provide comment on the quality and thoroughness of the product characterization review. What additional data, if any, should be evaluated in order to adequately characterize the Bt-expressing plant-pesticide products?

Information has appeared in the scientific literature related to the safety of foods derived from genetically engineered (GE) plants which collectively suggests that the EPA's present regulatory approach is insufficient to ensure that foods from Bt crops not pose health risks to those who consume it.

This information relates to unexpected and unpredicted effects of gene insertions, and instability of the genetic characteristics that are introduced. This information leads to the view that EPA must scrutinize genetically engineered foods more closely than it has so far, and in particular should require long-terms (one to two year) animal feeding studies of the whole engineered food. Requiring a more detailed molecular characterization for each genetic transformation event will also help EPA evaluate the potential for risk and may provide a means for EPA to decide how much additional testing is needed. At present the level of molecular characterization data required by the EPA is very inadequate.

The studies which lead to greater concern about unexpected effects can be put into two categories: unpredictability of the location and expression of transgenic DNA inserts; and differences resulting from post-translational processing (e.g. proteins from the same gene are not identical in differing organisms).

Need for Long-term Toxicity Tests

Unpredictability of the location and expression of transgenic DNA underlines need for long-term toxicity tests of engineered food.

The process of insertion of genetic material via GE is unpredictable with regard to a number of parameters, including: the number of inserts of transgenic DNA, their location (chromosome, chloroplast, mitochondria), their precise position (i.e. where and on which chromosome), their structure, and their functional and structural stability. While all of these parameters can have consequences, perhaps the most important is the random or semi-random nature of the physical location of the genetic insert. The inability to control where the insertion happens is of key importance. This means that each transformation event is unique and cannot be replicated because the precise location of the insertion of genetic material always will be different.

The variable insertion site can have a number of unpredictable, and potentially negative, consequences (Doerfler et al., 1997). The insertion site can affect expression of the inserted transgene itself as well as the expression of host genes (i.e. genes in the recipient organisms). The former is known as the "position effect".

A classic example involved attempting to suppress the color of tobacco and petunia flowers via the transfer of a synthetically created gene designed to turn off (via anti-sense technology) a host pigment gene (van der Krol et al., 1988). The expected outcome was that all the transformed plants would have the same color flowers. However, the transformed plants varied in terms of the amount of color (or pigmentation) in their flowers as well as the pattern of color in the individual flowers. Not only that, but as the season changed (i.e. in different environments), some the flowers also changed their color or color pattern. The factors contributing to the position effect are not fully understood.

The expression of host genes can be influenced by the location of the genetic insertion as well. If the material inserts itself into "the middle" of an important gene, that gene would functionally be turned off. In one experiment, insertion of viral genetic material into a mouse chromosome lead to disruption of a gene which resulted in the death of the mouse embryos (Schnieke et al., 1983). If the "turned off" gene happened to code for a regulatory protein which prevented the expression of some toxin, the net result of the insertion would be to increase the level of that toxin.

The genetic background of the host plant can also affect the level of expression of the transferred gene, which explains the common observation that varieties of the same plant species varied widely in the ease with which they can be genetically engineered (Doerfler et al., 1997; Traavik, 1998). In some varieties, the trait can be expressed at high enough levels to have the desired impact. In others, the expression level is too low to have the desired impact. In general though, scientists do not really understand why some plant varieties yield more successful results in GE than other varieties.

To get around the common problem of an insufficient level of expression of a desired gene product, powerful regulatory elements-particularly promoters/enhancers-are inserted along with the desired transgene and used to maximize gene expression. The promoter has numerous elements that enable it to respond to signals from other genes and from the environment which tell it when and where to switch on, by how much and for how long. When inserted into another organism as part of a "genetic construct," it may also change the gene expression patterns in the recipient chromosome(s) over long distances up- and downstream from the insertion site.

If the promoter (plus associated transgenes) is inserted at very different places on a given chromosome or on different chromosomes, the effects may be very different; it will depend on the nature of the genes that are near the insertion site. This uncertainty of insertion site, along with the promoter means that for all transgenic plants, there will be a fundamental unpredictability with regard to: expression level of the inserted foreign gene(s); expression of a vast number of the recipient organism's own genes; influence of geographical, climate, chemical (i.e. xenobiotics) and ecological changes in the environment; and transfer of foreign genetic sequences within the chromosomes of the host organism, and vertical and/pr horizontal gene transfer to other organisms.

Such unpredictability explains the common observations that different insertion events in the same variety can vary greatly in terms of the level of expression of the desired transgene and that the majority of transformation events do not yield useful results (i.e. the transgenic plant is defective in one way or another).

The unpredictable influence of the environment may explain what went wrong in Missouri and Texas with thousands of acres of Monsanto's glyphosate tolerant cotton and Bt cotton, respectively. In Missouri, in the first year of approval, almost 20,000 acres of this cotton in malfunctioned. In some cases the plants dropped their cotton bolls, in others the tolerance genes were not properly expressed, so that the GE plants were killed by the herbicide (Fox, 1997).

Monsanto maintained that the malfunctioning was due to "extreme climatic conditions." A number of farmers sued and Monsanto ended up paying millions of dollars in out-of-court settlements. In Texas, a number of farmers had problems with the Bt cotton in the first year of planting. In up to 50% of the acreage, the Bt cotton failed to provide complete control (a so-called "high dose") to the cotton bollworm (Helicoverpa zea). In addition, numerous farmers had problems with germination, uneven growth, lower yield and other problems.

The problems were widespread enough that the farmers filed a class action against Monsanto. Last fall, Monsanto settled the case out of court, again by paying the farmers a significant sum (Schanks [plaintiffs attorney], personal communication). If there could be this unexpected effect on the growing characteristics of the cotton, it is theoretically possible that their could be changes in the plant itself which affect the nutritional or safety characteristics of the plant (used as cattle feed) or the seed (the oil from which is used in a number of food products). This raises the question of whether EPA should establish procedures for assuring safety in the long term.

The unpredictability associated with the process of genetic engineering itself could lead to unexpected effects such as the production of a toxin that doesn't normally occur in a plant or the increase in a level of a naturally occurring toxin. An example of the former occurred in an experiment with tobacco plants engineered to produce gamma-linolenic acid. Although the plants did produce this compound, another metabolic pathway ended up producing higher quantities of a toxic compound, octadecatetraenic acid, which does not exist in non-engineered plants (Reddy and Thomas, 1996).

An example of the latter occurred in an experiment involving yeast where genes from the yeast were duplicated and then reintroduced via genetic engineering (Inose and Murata, 1995). The scientists found that a three-fold increase in an enzyme in the glycolytic pathway, phoshofructokinase, resulted in a 40-fold to 200-fold increase of methylglyoxal (MG), a toxic substance which is know to be mutagenic (i.e. tests positive in an Ames test).

This unexpected effect occurred even though the inserted genetic material came from the yeast itself. As the scientists themselves concluded, "Although, except for the case of microbes, we have no information as to the toxic effect of MG in foods on human beings, the results presented here indicate that, in genetically engineered yeast cells, the metabolism is significantly disturbed by the introduced genes or their gene products and the disturbance brings about the accumulation of the unwanted toxic compound MG in cells.

Such accumulation of highly reactive MG may cause a damage in DNA, thus suggesting that the scientific concept of "substantially equivalent" for the safety assessment of genetically engineered food is not always applied to genetically engineered microbes, at least in the case of recombinant yeast cells. . . . Thus, the results presented may raise some questions regarding the safety and acceptability of genetically engineered food, and give some credence to the many consumers who are not yet prepared to accept food produced using gene engineering techniques" (Inose and Murata, 1995: ).

Another study published in Lancet in late 1999 used potatoes that were genetically engineered to contain a chemical from the snow drop plant (a lectin, Galanthus nivalis agglutinin [GNA]) to increase resistance to insects and nematodes. Feeding experiments with rats demonstrated a number of potentially negative effects (Ewen and Pusztai, 1999).

The study found variable effects on the gastrointestinal tract, including proliferation of the gastric mucosa. Interestingly, the potent proliferative effect on the jejunum was seen only in the rats fed GE potatoes with contained the GNA gene but not in rats fed non-transgenic potatoes to which GNA had been added. Indeed, a previous feeding study utilizing GNA with a 1,000-fold higher concentration than the level expressed in the GE potatoes had found no proliferative effect (Pusztai et al., 1990).

The authors proposed "that the unexpected proliferative effect was caused by either the expression of other genes of the construct or by some form of positioning effect in the potato genome caused by GNA gene insertion" (Ewen and Pusztai, 1999: 1354). Such a fine-grained feeding study, which involved utilizing young rats which were still growing and involved weighing various organs and looking very carefully for effects on various organ systems and the immune system is far more detailed than the general feeding studies done utilizing GE plants. While many criticisms have been leveled at this study, we believe it raises important questions that merit further research.

Because of the unexpected effects that are theoretically possible and which have been seen in various experiments, we feel EPA should require long-term animal feeding studies using the whole food product. Such testing should be done on growing animals, so that effects on various organ systems can be readily observed. In addition, fairly extensive data should be taken on the weights of various organs and on histopathology and immunology. In addition, there should be follow-up feeding studies if any data from the lab or field demonstrates that the genetic insert is unstable. FDA should propose its procedures for public comment so that it can get further input from the scientific community and others.

The most commonly used promoter in plant genetic engineering is one from the cauliflower mosaic virus (CaMV); all GE crops on the market contain it. A promoter has numerous elements that enable it to respond to signals from other genes and from the environment which tell it when and where to switch on, by how much and for how long. A CaMV promoter is used for a number of reasons: because it is a very powerful promoter, because it is active in all plants-monocots, dicots, algae-and inE. coli and because it is not greatly influenced by environmental conditions or tissue types. CaMV has two promoter, 19S and 35S, but the 35S is the one most frequently used because it is the most powerful. The powerful nature of the CaMV 35S promoter means that it is not readily controlled by the host genes that surround it and often yields a high expression level of the transgene next to it.

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Date: 23 Oct 2000 20:31:08 +0100
From: "jcummins"

Bacillus thuringiensis and its Toxins as Biopesticides

Prof. Joe Cummins, October 23, 2000

Biopesticides are microbes or natural chemicals produced by organisms that are used to control disease cauing organisms (pests) such as insects or bacteria. In the United States the Environmental Protection Agency (EPA) regulates plant pesticides used directly or as a part of genetically modified (GM) crops. Bacillus thuringiensis (Bt) and its toxins are far and away the most significant biopesticides. Bacillus thuringeinsis is a common spore forming bacterium. Certain of its varieties produce toxins that are effective in controlling specific insect pests ,as well each variety may produce a number of toxins of varying toxicity and specificity.

Normally GM crops are modified with a single toxin gene from among a number available to deal with a particular insect pest, frequently the toxin genes are synthetic copies of the bacterial gene. The toxin proteins bind to the cell membrane at particular target site and create pores that enhance water uptake into the cell, ultimately causing that cell to burst. The toxins used with GM crops are selected so that insect cell are attacked while mammalian cell membranes are not. In bacterial biopesticides some toxins do bind to mammalian cells but overt toxicity to mammals is prevented by the acid environment of the gut (the insect gut is normally alkaline).

Bacillus thuringiensis spores are normally applied to crops as a biopesticide, such spores are known to cause allergy in farm workers (Bernstein,I,Bernstein,J,Miller,M,Tiewzieva,S,Bernstein,D,Lummus,Z, Selgrade,M,Doerfler,D and Seligy,V "Immune responses in farm workers after exposure to Bacillus thuringiensis pesticides" 1999 Environ Health Perspect 107,575-82). The spores are normally washed off crops prior to marketing so do not pose a threat to consumers. The toxins in GM crops are a part of the cells of the crop and cannot be washed out to the crop.

Psuedomonas flourescens genetically modified with toxin gene from Bt toxins are marketed as encapsulated Bt toxin. Such products have been marketed to organic producers without acknowledging that the products are genetically modified.

The EPA listing and reviews of Bt pesticides and toxins are listed on the EPA website:

  1. Bacillus thuringiensis Berliner (006400)
  2. Bacillus thuringiensis Cry1IA© & Cry I© delta-endotoxin in killed Pseudomonas fluorescens (006457)
  3. Bacillus thuringiensis Cry1A(b) delta-endotoxin and the genetic material necessary for its production in corn (006430)
  4. Bacillus thuringiensis Cry1A(b) in corn from PV CIB4431 (006458)
  5. Bacillus thuringiensis Cry1A© delta-endotoxin and the genetic material necessary for its production in cotton (006445)
  6. Bacillus thuringiensis Cry1F protein and the genetic material necessary for its production (plasmid insert PHI8999) in corn plants (pending)
  7. Bacillus thuringiensis Cry3A delta-endotoxin and the genetic material necessary for its production in potato (006432)
  8. Bacillus thuringiensis Cry3Bb protein and the genetic material necessary for its production (Vector ZMIR14L) in corn plants (pending)
  9. Bacillus thuringiensis K Cry1A(b) delta-endotoxin and the genetic material necessary for its production in corn produced by HD-1 gene from PV pZ01502 (006444)
  10. Bacillus thuringiensis K Cry1A© delta-endotoxin and the genetic material necessary for its production in corn (006463) 4/00
  11. Bacillus thuringiensis K Cry1C in killed Pseudomonas fluorescens (006462)
  12. Bacillus thuringiensis subsp. aizawai (006403)
  13. Bacillus thuringiensis subsp. aizawai GC-91 (006426)
  14. Bacillus thuringiensis subsp. israelensis (006401)
  15. Bacillus thuringiensis subsp. israelensis EG2215 (006476)
  16. Bacillus thuringiensis subsp. kurstaki (006402)
  17. Bacillus thuringiensis subsp. kurstaki BMP123 (006407)
  18. Bacillus thuringiensis subsp. kurstaki delta-endotoxin in killed Pseudomonas fluorescens (006409)
  19. Bacillus thuringiensis subsp. kurstaki EG2348 (006424)
  20. Bacillus thuringiensis subsp. kurstaki EG2371 (006423)
  21. Bacillus thuringiensis subsp. kurstaki EG2424 (006422)
  22. Bacillus thuringiensis subsp. kurstaki EG7673 Coleoptera Toxin (006447)
  23. Bacillus thuringiensis subsp. kurstaki EG7673 Lepidoptera Toxin (006448)
  24. Bacillus thuringiensis subsp. kurstaki EG7826 (006459)
  25. Bacillus thuringiensis subsp. kurstaki EG7841 (006453)
  26. Bacillus thuringiensis subsp. kurstaki M200 (006452)
  27. Bacillus thuringiensis subsp San Diego delta-endotoxin in killed Pseudomonas fluorescens (006410)
  28. Bacillus thuringiensis subsp. tenebrionis (006405)
  29. Bacillus thuringiensis subsp tolworthi Cry9C delta-endotoxin and the genetic material necessary for its production in corn fm PV pRVA9909 (006466)

In general the EPA reviews of the Bt and toxins biopesticides roundly ignored the finding that Bt was allergenic to farm workers. The EPA review of the Bt toxin Cry 9 is found at:

"The results of intraperitoneal injection of corn powder extracts into BN rats indicate that both the control and transgenic corn powders are able to induce IgE or reagininc antibody responses by the PCA assay. The use of corn powder immunogen decreases the rate of the immune response to the Cry9C protein compared to the bacterial preparation. However, the lowest responding dose for Cry9C was similar for the two preparations (between 0.1 and 0.4 ug Cry9C).

The control challenge test with the heterologous antigen of control corn powder or transgenic corn powder in the day 42 sera samples indicated that there was significant reactivity from the corn portion of the extracts themselves in the PCA assay. It is unclear, given this background reactivity, how conclusions can be made about the reactivity of the Cry9C protein alone. The PCA results from oral sensitization with ovalbumin II, control corn extract, bacterial Cry9C and transgenic corn (apparently supplemented with bacterial Cry9C) indicated that an IgE or reagin antibody response was elicited in naive Sprague-Dawley rats.

Ovalbumin sensitized serum produced a low frequency of responders and a weak dose response between the 5.0 and 50.0 mg/kg dose levels on days 28 through 42. The control corn also produced a positive oral sensitization response but this was only examined at the 50 mg/kg dose. Oral dosing with bacterial Cry9C gave a positive PCA response as did the Cry9C amended transgenic corn extract. The frequency of response to bacterial Cry9C began to diminish in day 42 sera. The Cry9C amended transgenic corn had a higher frequency of responders and the frequency remained high on day 42 PCA response. Western blot analysis indicated that Cry9C protein bands could be recognized in the rat sera from both exposure routes."

These results are an allergic (IgE) response was associated with Cry9 in corn powder. Considering that the Cry 9 containing corn was fed millions of farm animals and probably as many humans eating corn products contaminated with corn designated only for human use any evidence of IgE response to Cry 9 corn should not be allowed to be buried by bureaucrats protecting the interests of multinational corporations.

Finally a list of biopesticides approved by EPA for human consumption follows:
Plant-Pesticide Protein Approved Dietary Use 40 CFR Citation
Watermelon Mosaic Virus-2 Coat Protein All Food Commodities 180.1184
Zucchini Yellow Mosaic Virus Coat Protein All Food Commodities 180.1184
Potato Virus Y Coat Protein All Food Commodities 180.1182
Papaya Ringspot Virus Coat Protein All Food Commodities 180.1185
Cucumber Mosaic Virus Coat Protein All Food Commodities 180.1186
Potato Leaf Roll Virus Replicase Gene All Food Commodities 180.1183
Bacillus thuringiensis Cry3A Protein Potatoes 180.1147
Bacillus thuringiensis Cry1Ac Protein All Plant Raw Agricultural Commodities 180.1155
Bacillus thuringiensis Cry1Ab Protein All Plant Raw Agricultural Commodities 180.1173
Bacillus thuringiensis Cry9C Protein See: FR Notice Corn Used for Feed; As Well As Meat, Poultry, Milk, or Eggs Resulting From Animals Fed Such Feed 180.1192

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Date: 24 Oct 2000 04:56:53 +0100

Stray genes highlight superweed danger

BY Debora MacKenzie (Brussels) , New Scientist
October 21, 2000 , SECTION: This Week, Pg. 6

SUGAR beets genetically modified to resist one herbicide have accidentally acquired the genes to resist another. The accident provides yet more evidence that the widespread use of herbicide-resistant crops could lead to the creation of superweeds.

European regulations forbid the creation of plants resistant to several herbicides because they might become uncontrollable. However, in September, when trial plots of beets designed to resist the herbicide glufosinate were sprayed with glyphosate to kill them off, not all the plants died. In nine plots in Britain, France and the Netherlands, 0.5 per cent of the crop survived. "That adds up to a lot of plants," says Brian Johnson of the government conservation agency English Nature.

The errant resistance gene crept into the beets in the greenhouses of a German seed company, says Wolfgang Faust of Aventis in Frankfurt, the company that created the beets. A few of the beets were pollinated by another variety engineered to resist glyphosate, making their offspring doubly resistant. "If they can't prevent it there, there is little chance they will avoid it in the field," says Johnson.

Faust says that such "stacking" of resistance genes is unlikely in beets, because they flower in their second year and most are harvested in the first. "But some plants always bolt and bloom in their first year," responds Johnson. Their weedy offspring have to be killed with broad-spectrum herbicides. If these beets acquire additional resistance genes, they can be killed only by more noxious herbicides.

While only one similar incident of gene stacking has been reported, in rapeseed in Canada (NewScientist, 19 February, p 21), Johnson says there are "informal" reports from the US.

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Date: 24 Oct 2000 07:34:31 +0100

Dutch RaboBank Code of Conduct re: transgenic technologies

Rabobank obviously haven't fully looked into the dangers of GMOs on health and the environment. Their "yes, provided" principle will be seen by many as misguided. Those concerned about GMOs might like to consider boycotting Rabobank.


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Date: 25 Oct 2000 08:38:59 +0100

Belgium to Boost Organic Farming by 60% a year

Reuters News Service, Belgium: October 25, 2000

BRUSSELS – Belgium said yesterday that it wanted to increase the number of organic farms by 60 percent annually over the next four years.

Prime Minister Guy Verhofstadt and State Secretary for Energy Olivier Deleuze announced the goal as part of Belgium's four-year plan for sustainable development required by the 1992 United Nations Conference on Environment and Development (UNCED) held in Rio de Janeiro.

"Belgium is the first country to have put forward such a global strategy to match the agreements struck at the Rio Conference," Deleuze told a news conference.

Deleuze is a member of the Green party Ecolo, part of the coalition government led by Verhofstadt's centre-right Liberal party.

He said Belgium wanted at least four percent of the country's 1,386,000 acres (560,900 hectares) of farmed land to be organically farmed by 2004. To reach this target, the number of organic farms would have to increase by 60 percent a year, he said.

Intensive production of milk and pork is common in Belgium, a small-sized country of 10 million people.

The food and agriculture sector were hit hard last year when it was discovered that animal feed contaminated with the carcinogenic chemical dioxin entered the food chain. Products affected were pulled from domestic supermarket shelves while countries around the world stopped importing Belgian food products and livestock.

Under the UNCED plan, sustainable development is designed to address current economic needs, while taking environmental impact into account without jeopardising the needs of future generations.

An increase in organic farming would help address the environmental impact of agriculture. Nitrates and phosphates drain off farmland, leading to acidification of soils and water and contributing to acid rain, the development plan unveiled yesterday said.

It also proposed that by 2010 energy consumption levels are cut to 10 percent lower than 1990 levels and that greenhouse gas emissions are cut by 7.5 percent.

According to the plan, Belgium also seeks to increase the amount of energy generated by renewable resources to two percent of domestic consumption by 2010 and to phase out nuclear power.

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Date: 25 Oct 2000 10:09:55 +0100
Originated from:

Norfolk Genetic Information Network (ngin)

Looking at the issue of GMOs and bees in general and more specifically a possible connection between the US, Canada, on the one hand, and Argentina, on the other, involving (a) the widespread and recent cultivation of GM crops containing tetracycline resistant genes and (b) the sudden simultaneous emergence of tetracycline resistance in bees in these two geographically isolated areas, resulting in disease devastation of bee colonies that had previously been easily treatable against the world's mosty dangerous bee disease.

1. Bee disease – GM crop connection possible
2. Testimony with more detail on GMO and bees

GM crop – Bee Disease link etc.

"Letter to the editors of bee journals"
By Joe Rowland, Commercial Beekeeper
Secretary/Treasurer of the Empire State (New York) Honey Producers Association
October 2000

American foulbrood (AFB) – GM crop connection possible

Dear Editor,

The New York State Legislature has been considering enactment of a moratorium on the cultivation of genetically modified (GM) crops, and/or requiring labeling of products containing GM ingredients.

State legislative committees held public hearings on this subject during October 2000. I was invited to testify at these hearings. Although I am no authority on the topic, I decided to review publicly available information pertaining to the possible impact of GM crops on honeybees, and present this material at the hearing. I identified three main areas of concern.

  1. There is an alarming lack of publicly available information evaluating the effects of GM crops on bees. Biotechnology corporations fund research on GM crops in their efforts to gain regulatory approval for the marketing of GM varieties of corn, soybeans, canola, cotton, and other crops. This research supposedly proves beyond a reasonable doubt that these novel genetic combinations are safe to introduce into the environment.

    Canadian researcher, Mark Winston, recently attempted to gain access to the results of research that assessed the effects of GM crops on honeybees. Canadian government authorities acknowledged that such research had been conducted, but refused to provide any details. Their refusal was attributed to the fact that such research is confidential and owned by the undisclosed biotechnology corporations who funded the studies in question. I believe FDA/EPA policy is similar in this regard. This lack of openness raises serious credibility issues regarding corporate claims about the safety of GM crops. If their research is solid, then why is it kept secret?

  2. Laboratory studies carried out by the French government research institute INRA indicate that pollen from some GM crops shortens the lifespan of adult bees. Also, it seems to cause some learning dysfunctions that could result in the disorientation of foraging bees. Disoriented bees may become lost or unable to locate nectar sources.

  3. Possibly the most important public disclosure came out in June, 2000, when German researchers at Jena University showed that genetic material from GM canola crossed the species barrier, and was positively identified in bacteria that reside in the guts of honeybees. I believe this is the first publicly documented case of horizontal gene transfer from GM crops to bacteria. This discovery may have major implications for the future of GM crops.

    One main objection to GM crops has focused on the fact that during genetic manipulations required to create GMOs, antibiotic-resistant "marker" genes are combined with the so-called genes of interest. These combined genes are inserted into the target plant. Within the plant, the antibiotic resistant gene has no expression and is harmless. However, if this gene were able to transfer from the GM plant and enter another bacterium, that bacterium would become antibiotic-resistant. This might render commonly used antibiotics useless against diseases attacking humans and livestock, including honeybees.

Bees in the US are increasingly afflicted with a strain of antibiotic resistant American foulbrood (AFB). Before the advent of antibiotics, this bacterial infection was the most serious bee disease in the world. Tetracycline had been used effectively against AFB for 40 years until 1996. In that year, tetracycline resistance was confirmed in both Argentina and the upper Midwestern states of Wisconsin and Minnesota. Since then, it has spread to at least 17 states in the US, including New York, and to parts of Canada. During the 1990s, millions of acres of Round-up Ready crops were planted in the US, Canada, and Argentina. According to my information, the antibiotic resistant gene used in the creation of Round-up Ready crops was resistant to tetracycline. After 40 years of effective usage against an infective bacterium found in the guts of honeybees, suddenly two geographically isolated countries develop tetracycline resistance simultaneously. A common thread between the US, Canada and Argentina is the widespread and recent cultivation of GM crops containing tetracycline resistant genes.

I spoke about this with Dr. Hachiro Shimanuki, who until recently was the research leader of the USDA/ARS bee research lab in Beltsville, MD. He is not aware of any attempt to analyze the resistant foulbrood for genetic pollution from GM crops. I think that the technology exists to be able to determine whether these AFB bacteria have the Round-up Ready gene. That gene should have tagged along with the tetracycline resistant gene if in fact this antibiotic resistant AFB was due to horizontal gene transfer between GM crops and foulbrood bacteria.

I want to stress the speculative nature of this possible GMO/antibiotic resistant AFB connection. However, if it is true, the public health implications are enormous. A documented antibiotic resistant gene transfer into a disease organism would strongly indicate that the FDA should re-assess the potential human risks associated with GM crops, and possibly revoke federal approval for the sale and consumption of some of these modified plants.

As an industry, I think we should immediately request, through our local, state, and national associations, that the FDA analyze samples of antibiotic resistant AFB in order to determine whether or not a genetic transfer has occurred from GM crops.

If we act together, the FDA will find our combined resolutions to be a powerful stimulus to investigate this matter in a timely fashion.

Biotech corporations have maintained that we should trust their research findings that secretly prove to Federal regulators that GM crops are safe. I would suggest that it would be wise to maintain a healthy skepticism on this matter. Often there is a fundamental conflict between the corporate interest in short-term profit, and the public interest in the health and safety of the people. In fact, we have recently seen examples of this conflict exposed in the courts concerning other corporations.

I believe that we all are now participating in a vast GMO experiment without our informed consent. Many European beekeepers are fiercely opposed to the cultivation of GM crops in the vicinity of their apiaries. It is well within the realm of possibility that we should be too.

Joe Rowland
2495, Montrose Turnpike, Owego,NY 13827

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Date: 25 Oct 2000 10:09:55 +0100
Originated from:

GMO on Bees: testimony by Joe Rowland to the N.Y. Assembly

October 3, 2000

Submitted by Joe Rowland to the N.Y. Assembly standing committees on agriculture, consumer affairs and the assembly task force on food, farm, and nutrition policy

Thank-you for inviting me to testify on the subject of genetically modified organisms. I'm a commercial beekeeper, and the secretary/treasurer of the Empire State Honey Producers Association. I also sit on the executive committee of U.S. Beekeepers, a national trade association.

Honeybees are an important component of our agricultural economy. Many crops are dependent on honeybee pollination for cost effective production. A recently published Cornell study set the honeybee's value to U.S. agriculture at 14.6 billion dollars. An additional value accrues to home gardeners and wildlife who forage on wild seeds and fruit set as a result of bee pollination. Over ? of the 3 million colonies kept in the U.S. are now trucked around the country for the purpose of pollinating our crops. Thousands of colonies are moved into N.Y. every year and provide a valuable service to N.Y. farmers and consumers.

Sadly, bees and beekeepers have had a rough time recently. We must contend with 3 exotic pests introduced over the past 15 years. The wholesale price of honey in inflation-adjusted dollars is lower than at any time since World War II. There also has been a resurgence of American Foulbrood, which had been successfully controlled by antibiotics in the past.

Are GMO's a real or potential threat to honeybees? I've tried to answer this question by searching for publicly available research on the subject and by drawing on my own knowledge of honeybee biology.

Honeybees collect and consume nectar and pollen. Nectar is a complex sugar solution which provides carbohydrates. There is very little protein from forage plants in nectar. Since GM plants generally express their special characteristics in the form of biologically active proteins, there is probably not much danger to bees from nectar.

Pollen is their protein source, and when collected from GM crops, contains the modified gene structure of the GMO. It may also contain novel proteins produced by the modified plant. Pollen is the male fertilizing component of flowering plants and so is a concentrated source of genetic material. Damaging effects to bees from GMO's are most likely to result from pollen.

A colony of honeybees will collect and consume approximately 75 lbs of pollen in a year. Corn, canola, soybeans, and cotton yield pollen that is collected by bees within foraging range of these crops. All of these crops have GM varieties which are extensively cultivated in the U.S. Field tests in England have shown that bee colonies 4.5 km from GM canola fields collect GM pollen. Bees forage in all directions, and pollen grains are transferred between bees within the colony through bodily contact. It is theoretically possible that small quantities of GM pollen can be transported up to 9 km from GM crops.

The recommended isolation distance between GM crops and non-GM crops in England is 200 meters for corn, and 50 meters for canola. It seems to me that these distances are arbitrary and based more on convenience than on actual isolation of GM crops.

Professor Mark Winston, a Canadian bee research specialist, has attempted to review scientific studies pertaining to bees and GMO's. As you might expect, most GM research has been conducted by the biotechnology companies who create GMO's. What I did not expect is that this research is considered proprietary information, and not subject to public scrutiny. Prof. Winston contacted the Canadian Food Inspection Agency and encountered a brick wall.

Their response was that, yes, honeybee larvae or adults had been examined in tests with GM pollen. They would not reveal what GM crops were tested, who did the testing, what the experimental protocol was, or the results of the tests. Information which is absolutely essential for the independent validation of Biotech company claims regarding the safety of GMO's is unavailable to the GMO consuming public. It is my understanding that FDA policy is similar to the Canadian Food Inspection Agency. This veil of secrecy does not serve the public interest and should be lifted as a precondition for EPA approval of GMO's. Proprietary research on presently approved GMO's should also be publicly accessible.

There are a few publicly reported studies regarding the effect of GM pollen on honeybees. Minh-Ha Pham Deleque has done some work on this area for the French government research institute, INRA. She has studied the effects of GM pollen from varieties of canola and soybeans on honeybees in a laboratory setting. Her findings indicate that none of the tested pollens kill adult bees outright, but that they may shorten their lifespan and cause some behavioral changes, particularly in a loss of their ability to learn and to smell. This may cause foraging bees to "forget" where flowers or even their own hive is located. Obviously, some issues have been raised by this work which need to be further explored.

The most important research finding in this area has recently come from Jena University in Germany. Researchers there have shown that a gene used in GM canola transferred to bacteria in the guts of bees. I believe this is the first publicly documented case of horizontal gene transfer from GM crops to bacteria within any animal. This discovery may have major implications for the future of GM crops. One main objection to GM crops has focused on the fact that during genetic manipulations required to create GMO's, antibiotic resistant "marker" genes are combined with the so-called genes of interest.

These combined genes are inserted into the target plant together. Within the plant, the antibiotic resistant gene has no expression and is harmless. However, if this gene were able to transfer out of the GM plant and re-enter a bacterium, this bacterium would become antibiotic resistant. This might render commonly used antibiotics useless against diseases attacking humans and livestock, including honeybees.

At the beginning of my testimony, I mentioned the fact that bees in the U.S. are increasingly afflicted with a strain of antibiotic resistant American Foulbrood (AFB). Before the advent of antibiotics, this bacterial infection was the most serious bee disease in the world. Tetracycline had been used effectively against AFB for 40 years until 1996. In that year, tetracycline resistance was confirmed in both Argentina and the upper Midwestern states of Wisconsin and Minnesota.

Since then, it has spread to at least 17 states, including New York. During the 1990's, millions of acres of Round-up Ready crops were planted in the U.S. and Argentina. According to my information, the antibiotic resistant gene used in the creation of Round-up Ready crops was resistant to tetracycline. After 40 years of effective usage against an infective bacterium found in the guts of honeybees, suddenly 2 geographically isolated countries develop tetracycline resistance simultaneously. A common thread between the U.S. and Argentina is the widespread and recent cultivation of GM crops containing tetracycline resistant genes.

I spoke about this with Dr. Haricho Shimanuki who until recently was the research leader of the USDA/ARS bee research lab in Beltsville, M.D. Dr. Shimanuki is not aware of any attempt to analyze the resistant foulbrood for genetic pollution from GM crops. I think that with the proper equipment these bacteria could be inspected for the presence of the Round-up Ready gene. That gene should have tagged along with the tetracycline resistant gene if in fact this unlikely coincidence was due to horizontal gene transfer between GM crops and foulbrood bacteria.

Since the public health implications of this are of major proportions, I would urge you to immediately direct funds to a suitable independent research facility such as Cornell for the purpose of determining whether or not this unwelcome gene transfer has occurred. If so, the state of N.Y. should recommend to the FDA that the approval for GM crops containing antibiotic resistant gene markers be reviewed and possibly revoked immediately.

Biotech corporations have maintained that we should trust their research findings which secretly prove to Federal regulators that GM crops are safe. I would suggest that it would be wise to maintain a healthy skepticism on this matter. Often there is a fundamental conflict between the corporate interest in short term profit, and the public interest in the health and safety of the people. In fact, we have recently seen examples of this conflict exposed in the courts concerning other corporations.

I think there are enough valid uncertainties about GMO's to justify NYS to require labeling of GM foods. The world is now participating in a vast GMO experiment. New Yorkers should have the choice of opting out of this experiment if they so desire. GM food labeling would partially provide this option.

Thank you.

Top PreviousFront Page

Date: 25 Oct 2000 19:06:07 +0100
From: "jcummins"

The article below provides a review of the Mad Cow disaster. Those reviewing GM crops should consider the lessons of Mad Cow. Interestingly, the Canadian review of GM crop safety was arranged by the Royal Society whose president debunked the Mad cow scare in a book he coauthored.

A Lesson for current Reviews on GM crops: "Mad cows cast long shadows"

Mad cows cast long shadows

Nature 407, 929 (2000), 26 October 2000

Scientists may escape the worst of the flak from Britain's BSE inquiry, but they ignore its lessons at their peril.

After 34 long months, the public inquiry into Britain's BSE epidemic is to be released this week. Its 16 volumes will make uncomfortable reading. The report is expected to describe how attempts to protect the interests of the agriculture industry were allowed to override concerns about public health – and how, ultimately, both came to suffer. It seems likely that government ministers from the late 1980s to the mid-1990s, plus a number of senior civil servants then at the Ministry of Agriculture, Fisheries and Food (MAFF), will be sharply criticized for their roles in shaping this course of events.

The inquiry is also expected to address the adequacy of the system of providing, and acting on, scientific advice to government. It will examine how a lack of scientific knowledge about the risks posed to human health by an emerging disease of cattle became transformed in ministers' statements into assurances that there was no cause for concern. It would be harsh if the scientists who advised the politicians are themselves censured. But even if the inquiry judges them to have been blameless, there is much for the scientific community to learn from the BSE affair.

From evidence given to the inquiry, and the experience of Nature's staff in reporting on the epidemic, a sorry tale emerges. It is a story of MAFF concentrating government funding into a few 'trusted' laboratories – not necessarily those with the most appropriate expertise (see page 932). The ministry also held a veto over the publication of results from this research. And this journal has previously criticized a culture of secrecy within MAFF that prevented independent groups from analysing detailed epidemiological data (see Nature 383 , 463; 1996).

MAFF also promulgated the view that BSE was caused by the same agent as a related disease of sheep called scrapie, even though the evidence was equivocal. This was a comforting assumption, as scrapie had been present in British sheep for more than 200 years, with no evidence of any risk to human health. When evidence began to emerge that BSE was distinct from any known strain of scrapie, the official line did not change significantly. Today, experts say that it is impossible to determine whether the BSE agent crossed over from sheep, arose de novo in cows or had been present subclinically in cattle for many years. But it seems clear that it spread through British herds through the practice of feeding cows on meat and bone-meal derived from cattle carcasses.

In their defence, ministers of the day have pointed out that the precautionary measures taken in the late 1980s went further than the scientific advice they were given. But having taken the view that BSE was likely to pose no greater risk than scrapie, it is clear that these measures were not strictly enforced. Epidemiological data reveal that infected tissues continued to find their way into cattle-feed, even though the practice of feeding cows to cows had been banned since July 1988. The extent to which traces of potentially infective bovine central nervous tissue continued to enter the human food chain is unknown.

It is easy, with the benefit of hindsight, to criticize scientists for not making more of a fuss about the control that MAFF exerted over research, and for failing to dispel the continuing 'BSE is scrapie' complacency. But to do so would ignore the political and financial climate of the day. In the late 1980s and early 1990s, British agricultural and veterinary research was being 'restructured' – a euphemism for being cut to the bone. No surprise, then, that many scientists were keeping their heads down, not wishing to be identified as troublemakers.

Given the damage caused by the BSE affair, however, we now know the dangers of keeping silent. Of course, the main victims are those whose lives have been tragically cut short by a horrific disease. But science, too, has suffered. With ministers having consistently claimed that they were following the best scientific advice, even while subtly misrepresenting its message, scientists – particularly those working for government – have come to be seen by the British public as part of the problem. It will take much work to regain public trust.

Nature © Macmillan Publishers Ltd 2000 Registered No. 785998 England.