RCGM Witness Brief J Ruth Lawson

Witness Brief Royal Commission on Genetic Modification

1. Name of Witness Julia Ruth Lawson

2. Name of “Interested Person” (on behalf of whom the witness will appear)

Physicians and Scientists for Responsible Genetics New Zealand - Charitable Trust

3. Witness Brief Summary

1. My name is Ruth Lawson. I gained an Entrance Scholarship to Imperial College, University of London, and was awarded a First Class Honours degree in Zoology in 1971. I then completed a D.Phil from York University, UK, on the biology and epidemiology of the parasite Schistosoma mansoni. Following a three year postdoctoral fellowship funded by the Edna McConnel Clark Foundation studying the biochemistry and physiology of host infection by schistosome parasites, I emigrated to New Zealand in 1979. Here, I worked as a scientist employed by MAF in the Hydatid Research Unit in the Otago Medical School studying the epidemiology, population dynamics and control of hydatid parasites. In 1988 I gave birth to my daughter Kate and was made redundant by MAF. In 1989 I started part time lecturing at the Otago Polytechnic and this job has gradually expanded so I now teach a variety of Biological subjects including Anatomy and Physiology, Animal Nutrition and Parasitology. I also act as a consultant on parasite epidemiology and control and give occasional lectures to third-year Zoology students at the University of Otago. I have published 25 research papers in refereed journals and have written student texts in Anatomy and Physiology, Parasitology and Animal Nutrition. I am currently writing a student textbook on the Anatomy and Physiology of vertebrates. I am a member of the New Zealand Society for Parasitology.

Introduction

1. The rapid expansion of research and scientific papers in molecular biology and biotechnology can blind scientists to the considerable level of ignorance that still exists about the functioning of DNA. Scientists in the field often appear to have become cocooned in the narrow area of their particular research interests with the consequence that they lose sight of the bigger picture and the broader implications of their own work and that of their colleagues.

2. That we know the function of only 2-5% of the DNA and could for many years label and consequently dismiss the remaining 95-98% of the DNA as “junk” illustrates most graphically the extent of our ignorance. It seems highly unlikely that this elegant molecule, replicated so precisely and passed down the generations, could have little or no biological function.

3. Not only does DNA control the functioning within the cell and the organism but also the vast web of interactions between the organism and its environment. Our understanding of the complexity of these interactions at all these levels of organisation is still in its infancy. How therefore can we disrupt and modify the DNA of bacteria, plants and animals in random and unknown ways without affecting the balanced functioning of the organisms themselves and the interactive totality of the ecosystems in which they live?

Lewontin, Professor of Genetics at Harvard University, has said “ We have such a miserably poor understanding of how the organism develops from its DNA that I would be surprised if we don't get one rude shock after another.” (1)

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1. The lure of a technology that enables us to investigate the basis of life is irresistible. To many the lure of the potential money to be made by manipulating and patenting life forms is even more irresistible. It is becoming increasingly evident that the rush to apply our knowledge has lead to GEOs being rushed onto the market and into the environment with inadequate testing. What is even more worrying is that the dubious tactics of the commercial world are being used to market them. We see living organisms becoming “products” owned by multinational corporations and aggressive marketing techniques involving hyperbole and false claims being used to sell both the “products” and the technology to a public that has no need for them.

Conventional breeding and rDNA technology are quite different

2. Part of this deception is the claim that the technology is not new, but just an extension of the selective breeding practices that have been carried out for decades and that the risks are therefore similar. In fact recombinant DNA (rDNA) technology and conventional breeding are worlds apart.

Breeding does not manipulate genes, it involves crossing of selected parents of the same or closely related species. It involves the movement of clusters of functionally linked genes, primarily between homologous chromosomes, and including the relevant promoters, regulatory sequences and associated genes involved in the coordinated expression of the character of interest in the plant. In contrast, rDNA technology artificially recombines genetic material between species that have very little probability of exchanging genes otherwise and while conventional breeding shuffles different alleles of the same genes, rDNA technology inserts completely new genes and gene combinations among or even within the genes of the host organism. To mediate these gene insertions vectors, usually derived from disease causing viruses, plasmids and mobile genetic elements, are used. As we have not identified the associated regulatory genes and are unable to introduce a fully 'functional' gene using rDNA techniques they also involve the simultaneous insertion of viral promoters. Antibiotic resistance genes are used to act as markers. At the very least it is therefore misleading to suggest the two techniques are equivalent and incur similar hazards.

The random insertion of genes

3. Once inside the cells of eucaryotes the vectors insert the genes into the genome of the host cell largely at random. Because genes do not operate in isolation but interact in a complicated way, changing their behaviour in response to influences from other genes, this largely random insertion of genetic material results in the disruption of the genetic material on the chromosome. This can result in random and unpredictable changes in the functioning of the cells. Existing molecules may be manufactured in incorrect quantities, at the wrong times, or new molecules may be produced. Genetically engineered foods and food products may therefore contain unexpected toxins or allergenic molecules that could be harmful in the shorter or longer term. The British Medical Association warns that GM foods could have a cumulative, invisible, irreversible effect on the food chain (2). To underline the imprecise nature of the gene insertion process Roundup Ready soya has just been discovered to contain some unintended and unsuspected gene fragments (3).

Consequences of random gene insertion

4. Many unexpected outcomes of gene insertion have now been documented and these include:

Tobacco plants engineered to produce gamma-linolenic acid which instead produced a toxic product; octadecatetraenic acid, which does not exist in unmodified tobacco plants.(4.)
A 40-fold to 200-fold increase of methylglyoxal (MG), a toxic substance which is known to be mutagenic produced by a yeast modified by duplicating its own genes and then reintroducing them to obtain increased fermentation. (5)
The substitution of epsilon-N-acethllysine for lysine in the Bovine Growth Hormone (BGH) produced by engineered E. coli. (6)
and there is a suggestion that milk from cows treated with BGH contains an increased concentration of IGF-1 which may lead to an enhanced risk of breast cancer.(7-9)

Instability of GEOs

5. Instability of the genes inserted in GE plants seems to be common. Inserted genes are often silenced and part or all of the inserted DNA may be lost in the shorter or longer term. In fact there appears to be no research showing that the transgenes in any of the GE crops lines already commercialised or undergoing field trials are structurally stable in successive generations. Physiological stress due to extremes of temperature or drought may increase this instability and recently infection with naturally occurring cauliflower mosaic virus has been shown to silence the genes generating herbicide resistance in Aventis’ GE canola (10). Transgenic lines containing cauliflower mosaic virus promoters, as most that have been released do, are particularly prone to instability. (11).

Horizontal gene transfer

6. Perhaps the greatest potential hazard from GE organisms is the “horizontal transfer” of transgenic DNA across species barriers between wholly unrelated organisms (12). Movement of transferred genes from GE plants into soil microbes has already been documented in culture (13) and horizontal gene transfer has also been found to occur in the field (14). After GE sugar beet was harvested, the GE genetic material persisted in the soil for at least two years and was taken up by soil bacteria (15).

Transgenic DNA can also survive long enough in the gut to transfer genes into mouth and intestinal microflora and it also crosses the placenta (16-20). Antibiotics are known to enhance horizontal gene transfer between 10 to10 000 fold (21). Recently Prof. Hans-Hinrich Kaatz from the University of Jena, has revealed that bees ingesting pollen from transgenic canola had bacteria with modified genes in their gut (22, 23). This indicates that the new genes and gene-constructs introduced into transgenic crops and other transgenic organisms can spread, not just by ordinary cross-pollination or cross-breeding to closely related species, but by the genes and gene-constructs invading the genomes of completely unrelated species including the microorganisms living in the gut of animals eating transgenic material. There is reason to believe that transgenic DNA is much more likely to spread horizontally than the organisms’ own DNA (24). There is already overwhelming evidence that horizontal gene transfer and recombination have been responsible for spreading antibiotic resistance among pathogens (see paragraphs 7-12). Horizontal gene transfer is also of special concern when considering the environmental safety of GEOs (25, 26) (see paragraphs 13 and 14). (Also see Robert G. Anderson’s witness brief).

Horizontal transfer of antibiotic resistance genes

7. The horizontal transfer of antibiotic resistance genes to pathogenic microorganisms is considered by many scientists and physicians to be one of the greatest threats posed by GE organisms. The UK Joint Food Safety and Standards Group has warned of the risks involved in the use of antibioticresistant marker genes in engineering transgenic plants and seeds (27) and the British Medical Association considers that there should be a ban on the use of antibiotic resistance marker genes in GE food, because the risk of antibiotic resistance being passed on to bacteria affecting human beings through marker genes in the food chain cannot at present be ruled out (28). In September 1997 the Norwegian Government banned the imports of 2 rabies vaccines and 4 transgenic plants containing antibiotic resistance marker genes, in recognition of the hazards arising from horizontal gene transfer and recombination (29).

8. The most common antibiotic resistance genes used as markers are those that confer resistance to ampicillin and the aminoglykoside antibiotics (streptomycin; neomycin; paromomycin; kanamycin and its derivative, amikacin; tobramycin; netilmicin; and spectinomycin). It has been argued that the use of these markers poses no significant risk to public health since DNA is broken down by digestion in the gut and “the chance that the gene could be transferred intact from a transgenic plant to a microbial pathogen, and expressed in that pathogen, is very low. In any case, microbial resistance to kanamycin is already widespread, and the contribution that transgenic plants would make to this existing pool of resistance would be negligible” (30). However, it is now known that pieces of DNA the size of genes are unlikely to be broken down in the mouth or gut (31) that bacteria, especially if stressed and starving, can take up isolated pieces of DNA (32, 33) and that human saliva contains factors that increase the ability of resident bacteria to become transformed by taking up transgenic DNA such as antibiotic resistance marker genes (34, 35). The natural, rapid spread of antibiotic resistance genes between different bacteria has now been documented. In 1982, streptothricin was administered to pigs in eastern Germany. By 1983, plasmids containing steptothricin resistance genes were found in the gut bacteria of the pigs. These had spread to the gut bacteria of farm workers and their family members by 1984, and to the general public and pathological strains of bacteria the following year. Although the antibiotic was withdrawn in 1990 the prevalence of the resistant plasmids remained high when monitored in 1993 (36).

9. It is now acknowledged by some advisory bodies that use of some of the resistance markers may compromise the effectiveness of some important antibiotics. The UK Advisory Committee on Novel Foods and Processes is concerned that the aad gene which confers resistance to the antibiotics streptomycin and spectinomycin, and is present in both Bollgard (insect-protected) and Roundup Ready cottons may render the bacterium responsible for gonorrhoea, Neisseria gonorrhoeae, resistant to these commonly used antibiotics. They suggest it could acquire the aad gene from transgenic plant materials during infection of the mouth and small and large intestine as well as the respiratory tract. N. gonorrhoeae could also acquire the gene indirectly from other bacteria in the internal and external environments of animals and human beings, which can take up the gene from transgenic plant materials. The principle use of streptomycin is as a second-line drug for tuberculosis, but it is also the drug of choice, especially during pregnancy, for treating strains of N. gonorrhoeae already resistant to penicillin and third generation cephalosporins (37). The Advisory Committee also warned that antibiotic resistance genes can mutate and could render ineffective the antibiotics used to treat people with diseases such as bronchitis, septicaemia, gangrene and the lifethreatening infections suffered by people with cystic fibrosis and Aids (34, 38).

10. Novartis Bt corn uses an ampicillin resistance gene which is under the control of a bacterial promoter rather than a plant promoter which would increase the possibility of expression of the

resistance gene if it were taken up by bacteria (35). In 1998, the British Royal Society called for the banning of this marker as it threatens the effectiveness of this vital antibiotic used in treating meningitis. In a letter to the US FDA (4.12.1998), N. Tomlinson of British MAFF's Joint Food Safety and Standards Group warned that “there is a case to be concerned about the problem of gene transfer to environmental organisms”, and that bacteria that have taken up the antibiotic resistance genes "could also act as a gene pool that may interact with human pathogens”, and that “when transgenic crops are planted in large fields ----- arguments about the rarity of possible transfer events will become less significant." Tomlinson goes on to say, “The ampicillin-resistance marker gene (used in transgenic maize) encodes a beta-lactamase which inactivates penicillin and other penicillin-like antibiotics. This gene is highly mutable, and hence capable of extending its spectrum of resistance to many other similar antibiotics”.

11. Transgenic cotton, canola and tomatoes carry genes for kanamycin which is used to treat tuberculosis, a disease that is now already resistant to many antibiotics (30). There is also evidence that the kanamycin gene confers cross-resistance against other clinically important kanamycinrelated antibiotics like tobramycin and amikacin (38, 39).

12. An indiscriminate past use of antibiotics has led to the rapid spread of antibiotic resistance so that at least four dangerous bacteria, including a strain of TB, are now resistant to all known antibiotics. The use of antibiotic resistance markers in rDNA technology threatens to exacerbate the situation, and New Zealand should avoid introducing GMOs containing them into the environment or diet.

Other potential dangers of horizontal gene transfer

13. Horizontal gene transfer may also allow pathogens to exchange virulence genes to produce new virulent strains of bacteria and viruses. This has already been shown to have occurred with Vibrio cholera in India and Streptococcus in many areas of the world (34). Dr Joseph Cummins comments that genetic recombination has been shown in the laboratory to create highly virulent new viruses from modified virus and insect virus genes. He warns particularly of the potential dangers of the cauliflower mosaic virus (CaMV) promotor present in virtually all transgenic plants currently on the market or being field-tested. It has been recently shown to have a recombination ‘hotspot’ and be more prone to horizontal gene transfer and recombination than nontransgenic DNA and may combine with dormant viral DNA, as well as with other viruses in the host cell. It is also a pararetrovirus meaning that it multiplies by making DNA from mRNA and some workers suggest it may recombine with related Hepatitis B or HIV to create a most powerful disease (40).

14. Naked DNA and crippled laboratory strains of bacteria not only persist for days, weeks and even months in the environment especially when adsorbed to solid particles in the soil or in aquatic sediments, but can also be taken up through the skin and intestinal wall (26, 41). This means that transgenic plant secretions, and debris ploughed back into the soil are very likely to release DNA for transforming soil bacteria and other microbes. Synthesised DNA and gene constructs could also be a major hazard to laboratory and farm workers etc. who handle GM organisms and create a dangerous form of pollution (31, 32). There is an urgent need to establish effective regulatory oversight, in the first instance, to prevent the escape and release of these dangerous constructs into the environment, and then to consider whether some of the most dangerous experiments should be allowed to continue at all. Rather than loosening regulations as urged by many of the scientists submitting to the RCI, the current regulations on rDNA technology requires urgent revision and should be strengthened.

Safety testing and regulation of GE foods

15. There have been numerous claims that GE food products are based on "sound science", and the New Zealand Grocery Council Leaflet, among others, asserts: "GM foods are among the most extensively tested foods ever sold in the history of mankind". It is therefore most surprising to discover that extensive searches of the literature uncovered only five papers that have been published in peer-reviewed journals until June 2000 (42) and not one peer reviewed, independent research paper on the long term health effects of these foods (43-45). All the research documented in references in the standard list provided by pro GE scientists when they are asked about safety testing of GE soya, for example, is linked directly or indirectly with Monsanto and none of it is to do with testing the safety of the crop or the food produced from it (46).

16. From the beginning, the bodies regulating GE foods and crops have relied on the data supplied either by the companies producing them or by scientists sponsored directly or indirectly by the companies. The American Food and Drug Administration (FDA) is the main world food regulatory body, and the Australia and New Zealand Food Authority (ANZFA) and environmental Risk Management Authority (ERMA) rely heavily on its recommendations. There is considerable evidence of potentially strong biotechnology industry bias in the FDA (and to some extent ANZFA) as numerous key personnel have switched jobs between the major biotechnology companies and the agency (see paragraph 48). Risk assessment relies on the concept of “substantial equivalence” whereby only those GE products that are considered to differ from conventional products on the basis of known characteristics are tested for safety. In a critique of the 1996 Joint FAO/WHO Biotechnology and Food Safety Report Mae-Wan Ho and Ricarda Steinbrecher (29) commented that the principle of substantial equivalence is “unscientific and arbitrary, encapsulating a dangerously permissive attitude towards producers, and at the same time offers less than minimalist protection for consumers and biodiversity, because it is designed to be as flexible, malleable and open to interpretation as possible”. How unscientific and arbitrary it is is demonstrated by the fact that recent examination of the data on Roundup Ready soybeans reviewed by the FDA in 1994 reveals that RR soybeans were judged to be ‘substantially equivalent’ despite having several components at significantly different levels compared to conventional controls. For example the RR soya had 26.7 % higher trypsin-inhibiter levels, and statistically significant differences in ash, fat, carbohydrate, protein, phenylalanine, cysteine and some fatty acids compared to conventional soya (47, 48). In fact all GE products approved to date by the FDA and ANZFA have been judged to be ‘substantially equivalent’ to their conventional counterparts and on this basis have been exempted from both risk assessment and long-term testing. For example, approval of Monsanto’s Roundup Ready soya by ANZFA is based on data from feeding ordinary soybeans and Roundup Ready soybeans to groups of 10 rats per sex for only 4 weeks, 60 chickens of each sex for about a month, and groups of 5-6 Holstein cattle for an unspecified time (49).

17. The difference between the RR soya beans that have been treated with Roundup and those that have not has not been assessed (49) although the possibility of higher levels of chemical residues in foods and food products made from plants engineered to be resistant to herbicides like glyphosate and glyfusinate ammonium are of considerable concern. The application by Monsanto to the Australian and New Zealand Governments to have the permitted levels of glyphosate residues in soya beans increased by 200 times is acknowledgement that they anticipate such an increase. Apart from being identified as the third most common cause of pesticide poisoning among farm workers (50), a recent study by Hardnell and Eriksson (51) has revealed clear links between glyphosate and non-Hodgkin's lymphoma.

18. Despite official statements to the contrary by the Food and Drug Administration, the predominant but suppressed opinion of their own scientists as expressed in their administrative record is that GE foods are different from conventional foods, that they pose unique health risks and that each one should be established as safe through rigorous testing (52).

Contamination and consumer choice

19. The high-handed actions of the biotechnology companies and food regulatory bodies in refusing to segregate and label GE food ingredients have made it almost impossible for consumers to exercise any choice about whether or not they eat foods containing modified ingredients. It seems that labelling will now fail to solve the problem of consumer choice because it is becoming increasingly difficult to source unmodified foods due to the pervasive contamination of the world’s seed supply with modified genes. For example a report from the John Innes Centre, represents the most convincing research to date that modified and unmodified plants can cross-pollinate (53) and the UK Environment Minister has stated: "It is false to pretend that there is any distance [between modified and unmodified crops] which is going to prevent some contamination [due to cross pollination]”. The policy of not segregating genetically altered seed from conventional seed and the accidental mixing that occurs during storage, shipping, or processing has meant that it has become almost impossible to guarantee any foods (even those certified organic) 100% GE free. For example, Monsanto has admitted to an Australian Senate committee that it accidentally let cottonseed from unapproved varieties out of the gin and into cattle feed (54). The Swiss Department of Agriculture has found that non GE corn seed varieties, Ulla and Benicia, contained novel genes from a variety of corn genetically modified to be resistant to the corn borer (55) and in Holland a shipment of 80.000 bags of organic corn chips were destroyed after "testing positive" for traces of GE corn (56). Recently in the USA taco shells have tested positive for StarLink, a corn variety allowed in animal feed, but not approved for use in human food because of concerns about allergenicity (57). It now seems that it is much more pervasive in the food chain than has been acknowledge hitherto and it may have seriously tainted the safety and integrity of the crops American farmers grow and sell to the world (58).

20. By failing to test or label GE food adequately the biotechnology companies are subjecting the population of the world to a gigantic experiment. However, unlike good experiments, this one has no controls and no ethical approval. It is almost impossible to identify any effects the food might have especially if they are subtle or delayed. For example, will we ever know whether or not the 50% increase in soy allergies that has been identified by the York Nutritional Laboratory (59) is due to the increasing proportion of GE soy that is entering the food supply?

Benefits to the consumer

21. We are continually being told of the benefits of GE foods, but the truth is that few benefit the consumer. No GE food marketed to date has been shown to be more nutritious than non-GE food. Even the much-trumpeted vitamin A enriched so-called “Golden Rice” is years away from commercial production and is unlikely to solve the complex problems that cause blindness due to vitamin A deficiency in Africa and Southeast Asia (60-62). (See PSRG Submission).

Benefits to the producer

22. Most GE crops are primarily designed to benefit the producer and are manufactured to be resistant to specific herbicides, to produce their own insecticides or to have an increased shelf life. However, the claimed benefits for the farmer have not materialised as predicted. It is clear that many of the products were released without adequate research, and many have not performed as designed. For instance, in 1996 crops of Monsanto’s insect resistant cotton suffered a heavy infestation of bollworm, the very insect the genetic modification was designed to protect against (63). In 1997 there was widespread failure of Monsanto’s herbicide resistant cotton in Mississippi (64), and the FlavrSavr tomato was withdrawn from the market after only one year because of low yields and poor disease resistance (65).

23. Virtually all independent (not industry-funded) evidence suggests that yield is lower - not higher - in GE soybeans. A review of 40 soybean varietal trials in the northcentral region of the US by Oplinger and colleagues (66, 67) found an average 4% yield drag in Roundup Ready soybeans and Benbrook (68) reviewed 8200 university-based yield trials for the 1998 season, and reported an average yield loss of 4.6 bu/ac or 6.7% compared to the top conventional varieties (or 3.1 bu/ac or 5.3% relative to all tested varieties).

24. Claims of higher yields in Bt corn do appear to be valid although they vary according to the degree of insect infestation (51, 52). Campbell (69) reports that there has been little impact on canola yields but the UK's National Institute of Agricultural Botany (NIAB) report reductions in yield by up to 7 or 8% for both GE canola and sugar beet, compared to traditional varieties (70).

25. In May 1999 Monsanto claimed, “ In 1998 use of Bt insect-protected corn reduced or eliminated the use of broad spectrum chemical insecticides on some 15 million acres of US farmland”. However, the evidence shows that GE crops often fail to reduce agrichemical use as intended. For example, a detailed analysis of the data by E. Ann Clark from the University of

Guelph (71) concluded that at best Bt-corn could have reduced insecticide usage on 1- 2% of the acreage sown to corn in 1998 in the US - e.g. 0.7 to 1.4 million acres (not the 15 million acres claimed by Monsanto). Duffy and Miller (72) surveyed Iowa corn producers and showed a modest increase (not decrease) in the cost of insecticide per acre, although Bt-corn growers treated only 12% of their acres compared to 18% for non-Bt-corn growers.

26. It is hard to assess the influence of GE crops on the use of herbicides because there are so many factors to take into account such as increased acreage of GE herbicide resistant crops and the switch from other weed management systems. Certainly the British Agrochemical Association (BAA) predicted that 1997 sales of herbicides in the United States would boom from the expanded use of transgenic herbicide resistant crops (73) and Monsanto anticipated that Roundup Ready crops would generate an increase in glyphosate sales and invested in new plant accordingly (74). Figures suggest that the volume of glyphosate used in the USA almost doubled in 1998 to 28.1 million pounds as a result of increased plantings of Roundup Ready soybeans (75). Benbrook (68) found that farmers growing RR soybeans used 2-5 times more herbicide in 1998 compared to other popular weed management systems used with non-GE soya and commented that the inevitable emergence of herbicide tolerance in several key weed species was already leading to an increase in the amount of herbicide needed.

27. In general the claims of higher overall returns for GE crops have not been borne out. For example, Cliff Kinzel (76) reviewed several studies to compare the overall profitability of GE versus non-GE crops and found that:

Use of Bt Cotton in 3 Arkansas counties resulted in a decrease in net income.
In Iowa in 1998, GE crops (soya beans and corn) provided farmers with no significant difference in returns.
An Agriculture Canada study of GE canola suggested that farmers might get a better economic return on their farm by not growing herbicide-tolerant canola.
A study by researchers at the University of Missouri at 15 different sites suggested that Bt hybrids were slightly less profitable than non-Bt corn hybrids and
The Mississippi State University Extension Service found the higher seed cost of the Bt corn would only be justified if significant corn borer infestation were likely.

Campbell and colleagues (69) also surveyed the literature and confirmed the neutral effect of GE on the net returns from GE soya, and also suggested that returns for Bt corn depended on the extent of insect infestation and for canola on the type of soil.

28. The problem of equivalent or lower returns on GE crops is further exacerbated by fact that markets are contracting as many countries shun GE crops and pay higher premiums for non-GE crops. For example, the Japanese have recently bought corn and soybeans grown exclusively from non- GE seeds at premiums roughly 40-50 percent higher than those for mixed GE and non-GE crops (77).

29. It is becoming increasingly difficult to insure against the risks of a disaster caused by GE crops, foods or pharmaceuticals. An article in the UK Farming News (18.6.1999) notes that farmers are increasingly unwilling to grow GEO trials on their farms, specifically because of fears of legal damage claims from neighbours, and the Swiss reinsurance company Rueck states that the potential risks of genetic engineering cannot be covered with classical liability insurance models (78). The Royal Institute of Chartered Surveyors has warned the British government that the growing of GE crops could reduce the value of agricultural land and leave the farmers open to legal action (79), and the Deutsch Bank, the largest bank in Europe, has advised investors to sell GE stocks. This has significantly affected stock prices and encouraged major life science companies to consider divesting themselves of their GE divisions (80).

30. The above evidence suggests that at present it is irresponsible to promote GE crop varieties to farmers in New Zealand as a profitable alternative to conventional varieties.

Environmental issues

31. Sales promotions for the GE crops approved for sale have assured the public that they would

pose no danger to the environment and, if they did spread to weedy relatives, the resulting hybrids would soon die out. Numerous studies have now shown that not only do genes regularly transfer to weed species by means of pollen carried by both wind and bees (81-83) and that pollen can travel at least 4 kms (84-86) and that wild plants containing a gene for herbicide resistance can hold their own in competition with unmodified varieties (87-89) but also that these wild plants may even interbreed with related species more readily than traditionally bred plants (90, 91).

32. In the States there are reports that herbicide resistant “volunteers” have increased dramatically in the last 5 years causing management problems and increasing costs (92). In 1999 researchers noticed that in fields of glyphosate resistant soybeans, where cotton resistant to the same herbicide had been grown the previous year, self-seeded GE cotton plants were not killed by glyphosate (93).

Monsanto has acknowledged the problem of these “superweeds”, but has suggested that they “were not an issue since they could always be sprayed with other weedkillers to which they were not resistant”.

33. In a world where demand for non-GE and organic food crops is growing, this potential for indiscriminate and uncontrollable spread of pollen and seed is a major concern. The implications of this for New Zealand are enormous. It means that once any GE crop is introduced here, not only will it be impossible to guarantee that conventional and organic crops are free of GE contamination, but also that world confidence that New Zealand can supply any GE-free products is jeopardized or lost completely.

34. Despite the fact that GE crops were approved and sold commercially with almost no research on their long term effects on the environment, the biotech companies persisted in reassuring us that they were safe. In fact interactions between organisms in ecosystems are so complicated that there is no way of knowing what the downstream effects of the introduction of gene-altered organisms will be. My own work on the epidemiology and control of parasites has demonstrated graphically how quite small differences in the parameters describing the interaction between two organisms, a parasite and its host, can have profound effects on transmission dynamics and how perturbations in the form of changes in a control programme can have little effect on one parasite population while causing another to move towards extinction (94-98). Our ignorance of the complex interconnections and fine balances between the multitude of different organisms in an ecosystem means it is almost impossible to predict what the effect of a perturbation will be on other organisms in that ecosystem. Peter Wills in his Testimony gives a good example of how a biological event, the introduction of the myxoma virus to the English rabbit population, can lead to the extinction of a species, the large blue butterfly, that on superficial examination would seem to be quite unconnected with it.

35. The majority of applications of genetic engineering are on microorganisms. It is of considerable concern that this is the very group of organisms about which we have least knowledge. An indication of our ignorance is the fact that it has been estimated that we have only recognised and described 5% of the estimated number of viruses known and only 0.1% of the bacteria. Studies on how microorganisms interact with each other and the other organisms in an ecosystem like the soil or the animal gut is rudimentary and yet these organisms are being engineered to be introduced into the environment for a variety of functions. Many scientists are now warning of the dangers inherent in this and the inadequacy of the safety testing procedures. This is amply demonstrated by the case of the GE bacterium Klebsiella planticola. This soil bacterium was modified to convert agricultural wastes to an alternative fuel and worked well in the laboratory passing the routine laboratory tests to assess its safety. The fact that it actually killed plants in the soil by destroying the nutrient bacteria was only discovered fortuitously when a doctoral student decided to test the organism in “living” soils rather than the sterile soils used in the routine safety assessment. It is possible that it was only this initiative that averted a potential disaster (99, 100).

36. Herbicide resistance is at present the most common characteristic engineered into plants. It is now clear that broad-spectrum herbicides that can be used indiscriminately with herbicide resistant varieties of crops erode plant and animal diversity. For example glyphosate, a non-selective weedkiller, is lethal to a wide range of herbaceous plants. The US Fish and Wildlife Service identified 74 endangered plant species potentially threatened by widespread glyphosate use and reported that glyphosate may inhibit the growth of soil mycorhizal fungi (101). GE herbicideresistant beets allow farmers to use more powerful weed sprays, which may lead to a 90% reduction in the weed-producing seeds crucial to the (European) skylark's diet (102).

37. Environmental problems of crops containing the genes that produce the Bt insecticidal toxin are legion. The first specific concerns about the safety of Bt crops were raised from within the scientific community in 1997 when Hilbeck and colleagues (103) showed that lacewings fed on pests which have eaten Bt-maize were two to three times more likely to die. Then followed the famous laboratory study published in Nature (104) showing that Monarch butterfly caterpillars that have eaten Bt corn pollen are more likely to die. In August this year Hansen Jesse and Obrycki (105) published their study on the effect onMonarch butterfly caterpillars of two types of pollen from Bt corn marketed by Novartis Seeds: KnockOut, (which contains a Bt gene named Event 176) and YieldGard (with a Bt gene called Bt 11). The experiments showed that Monarch butterfly caterpillars were more likely to die when they ate milkweed plants carrying pollen from Bt corn, compared to conventional corn, and that caterpillar mortality was significantly greater when the pollen was at the highest densities of both GE varieties of corn pollen.

38. It would seem that only some varieties of GE corn pollen are lethal to swallowtail butterfly larvae. For example, larvae exposed to Novartis Max 454 corn pollen were killed after 2 days exposure in the lab (106), while Monsanto's Bt corn (Mon 810 gene), was not lethal to the caterpillars under field conditions in Illinois (107). This work clearly shows that the environmental impact of each new GEO must be tested on a case-by-case basis.

39. Another problem with Bt crops is the rapid evolution of resistance in insect pests (108) making it necessary to plant at least 20% of non-Bt crop in refuges to provide a pool of non-resistant insects. However, a recent study (109) has demonstrated that boll worm larva fed on GE and non-GE plants develop at different rates and it is highly unlikely that they will interbreed and so dilute or slow down the evolution of resistance. Aberrant gene expression in the field resulting in plant varieties containing low doses of the toxin, which are ineffective in controlling pests, may also encourage resistance to develop.

40. Deepak Saxena and colleagues (110) reported that Bt toxin is released from the roots of Bt corn into the soil around the plant roots, where it accumulates and is protected from biodegradation. The impact on soil health is not known, but there are considerable risks to non-target species both in the soil and in the general environment eg birds. The recent report that a GE gene has transferred from GE pollen to bacteria in the gut of bee larvae (22, 23) underlines the fact that Bt toxin genes, like all other GE genes, will spread out throughout the environment.

41. Bt-corn is now banned in Austria, France and Germany, and Monsanto's Bt-potato division has been closed down by its new parent company, Pharmacia. It is clear that there are still too many unknowns about the safety of transgenic Bt crops to allow these crops to be introduced into New Zealand with its fragile ecology and numerous endangered species.

The association between research and industry

42. The move over the past two decades to rely increasingly on corporate funding has changed the nature of scientific research. In most of the Western world, private industry has taken over much of the funding of research from the state, and emphasis has been diverted away from traditional areas in biology and agriculture to molecular biology and genetic engineering. For instance, in Britain 30 times more government money is spent on research into GE crops (which have a static or decreasing market) than on research into organic farming (for which demand is unmet) (111). A similar ratio is probably true here in New Zealand as in Britain, USA and Australia. There would be few scientists involved in rDNA research who are not directly or indirectly funded by industry or working in an establishment that receives no industry support.

43. The question is: does the association between research and industry affect the validity of the

results and the conclusions that are drawn from them? Nathan Batalion (112) thinks it does (at least in the States) and quotes the following statement from an undated New York Times article ” As scientists become the servants of industrial interest it is becoming clear that …lawmakers, bioethics experts and federal regulators are troubled that so many researchers have a financial stake [via stock options or patent participation] … The fear is that the lure of profit could color scientific integrity, promoting researchers to withhold information about potentially dangerous side-effects."

44. Reports from around the world suggest this is not a groundless fear. For example, a piece of research by Stelfox and colleagues (113) published in1998 in the New England Journal of Medicine showed that the authors of almost all articles published in support of a particular drug had financial ties to the manufacturers of that drug while neutral or critical authors were less like to have such ties. In other words, people whose careers are tied to the development of a technology should not be expected to provide impartial advice. In a survey of scientists working for British Government ‘quangos’ or newly privatised laboratories, by the union representing them, 30% (of 500 respondents) said they had been asked to tailor their research conclusions or resulting advice for their backers, 17 % had been asked to change their conclusions to suit the customer's preferred outcome, 10% said they had been asked to do so to obtain further contracts and 3% claimed they had been asked to make changes to discourage publication (114). Bodenheimer (115) reviewing the relationship between clinical investigators and the pharmaceutical industry, reported that companies may design trials that favour their product, can control clinical trial data, "provide the spin on the data that favors them”, alter the content of publications and delay or fail to publish results that are not favourable to them. He reported cases in which the industry threatened legal action against the investigator to prevent them publishing unfavourable results and others in which investigators that found adversely against the companies product were not employed again. Another commentator observes that "ties between clinical researchers and industry include not only grant support, but also a host of other financial arrangements. Researchers serve as consultants to companies whose products they are studying, join advisory boards and speakers' bureaus, enter into patent and royalty arrangements, agree to be the listed authors of articles ghostwritten by interested companies, promote drugs and devices at company-sponsored symposiums, and allow themselves to be plied with expensive gifts and trips to luxurious settings. Many also have equity interest in the companies."

45. The case of Dr. Arpad Pusztai, a senior research scientist with 276 scientific papers to his name and regarded as a world expert on lectins, is instructive here. Whatever the validity of his preliminary research purporting to show that rats fed potatoes genetically modified to express lectins suffered reduced organ weights and immune damage, the facts are that after speaking about his fears regarding the safety of the modified potatoes on the World In Action TV programme, his employers, the Rowett Research Institute in Scotland, immediately suspended him, confiscated his data, seized the potatoes on which he had been carrying out tests and disbanded his team of 18, which he had spent 30 years building up. The Rowett then prevented him from commenting on criticism for seven months under threat of forfeiting his pension. His crime—not publishing his findings in a peer-reviewed scientific journal (117-119). One has to ask where all the peer reviewed publications showing the safety of GE foods are and whether Pusztai’s treatment would have been the same if he had revealed prematurely that his rats had thrived on GE potatoes? It is hardly surprising that it takes real courage now for scientists to speak up about their reservations about rDNA technology and GE products.

46. The extent to which the biotechnology industry is trying to influence scientists and the debate about genetic engineering is demonstrated by classified internal Monsanto company documents obtained by the Observer (UK) paper (120) and also posted by GeneWatch UK [GeneWatch. UK. http://www.genewatch.org] on their website (121). These show how the company:

was “ instrumental in assuring” that GE supporters got on to influential positions on United Nations and World Health Organisation safety committees, and that this produced reports “very supportive of plant biotechnology”.
“averted attacks on recently emerging biotechnology issues” which included reports warning that alien genes used in the genetic modification of crops could jump the species barrier and mutate with bacteria present in the intestines of bees. Their "rapid responses to avoid overreaction to claims regarding...gene transfer by honey bees” included commissioning articles “on the honeybee issue by notable scientists”.
has started targeting US doctors and trainee doctors in attempts to convince them their products are safe.
“developed rapid responses to avoid over-reaction to claims regarding...the characterization of additional non-functional DNA in Roundup Ready soybeans."

Monsanto also confirms that it has been successful in lobbying the UN committee on food safety to ensure that food labelling in Third World countries can be voluntary, not compulsory.

47. Concern over pressure brought to bear on medical researchers has prompted the British Medical Journal to insist that authors declare their source of funding and whether they have any "competing interests" The New England Journal of Medicine, now requires financial disclosure by authors of original research articles. Some disclosures are so lengthy that the magazine can't print them all, so posts them on its website! (116). The Lancet now warns that, “All policy makers must be vigilant to the possibility of research data being manipulated by corporate bodies and of scientific colleagues being seduced by the material charms of industry. Trust is no defence against an aggressively deceptive corporate sector” (122).

48. Nowhere is commercial pressure more apparent than in the regulation of rDNA research and safety testing of GE foods and products. Many of the bodies charged with this regulation are heavily stacked with self-interested bioscience industry and scientific representatives who ensure that genetically engineered products are fast tracked into the market place and the environment with minimal regulation. The classic case of this are the ‘revolving doors’ between the US government and the biotechnology industry documented by the Edmonds Institute and the Third World Network (123) who list at least 13 influential people that have moved back and forth between industry and government. The American government reassures the public that it supports “an arms-length, objective testing process that is independent from industry” and that the safety of GE products is proven by “test after rigorous scientific test” (124). Yet the philosophy of “substantial equivalence” has exempted all GE foods that have been approved by the FDA from any long term independent safety testing and allowed the FDA to ignore warnings from its own scientists that genetic engineering differs from conventional practices and entails a unique set of risks including the recognised potential to produce unexpected toxins and allergens (125) (See paragraphs 15 -18)

49. A similar disregard for the public has also been shown by the Australian GMAC, (Genetic Manipulation Advisory Committee) and the Australia New Zealand Food Authority (ANZFA) which, for example, dispensed with the normal token public consultation processes to facilitate the importation of Monsanto’s Roundup ready soya beans in 1996 (126,127).

50. The take-over of biotechnology by corporate interests has meant that GE products have been subject to the same aggressive marketing as other commodities. This has included distortion of the facts about the technology itself and exaggerated claims about the attributes and performance of the products. Thus we are reassured that genetic engineering is essentially the same as selective breeding, that it is precise, that the products are extensively safety tested and pose no danger to either human health or the environment and that they will be profitable for the farmer. As has been documented above, none of these claims is supported by examination of the facts.

51. Perhaps the most pervasive but insidious myth is that GE crops are necessary to feed the world’s poor in the future without destroying the environment. Universities and nonprofit research organizations are pressing ahead to genetically engineer hardier crops and more nutritious food for the world's poor. The problem is that people do not go hungry because of an overall world shortage of food. The latest assessment of world population trends by the UN (Report by the Global Perspective Studies Unit, Food and Agriculture Organisation (FAO) (1999) indicates that the rate at which the world’s population is growing has slowed considerably, and that there is enough, or more than enough, food production potential to meet the growth of future demand for the world as a whole. A survey in 1997 showed that 78% of all malnourished children lived in countries with food surpluses (128). The problem is that many people are too poor to buy readily available food because they are deprived of land by a powerful few, trapped in debt, or are miserably paid. The widespread adoption of biotechnology would strengthen the control of private global corporations over food supplies and food production technologies and exacerbate rural inequalities. Between 1985 and 1990 group of scholars with long standing interests in the Third World examined the claims of the biotechnology proponents. Campbell (69) summarised their conclusions by stating that “biotechnologies address few of the underlying problems of Third World hunger”. GE crops are unlikely to produce higher yields or net returns than conventional varieties (see paragraphs 23, 24, 27 and 28), the seeds will inevitably cost more and they will encourage further mechanisation and use of agrichemicals. To be viable, the size of farms will need to increase with the result that more small farmers and farm workers will be forced off the land (129-32). People (as opposed to many governments, scientists and biotechnology companies) in Third World countries targeted for this technology are quite clear they do not want it. They see it as unsafe for both health and the environment and likely to increase the already crippling debt repayments they are forced to pay to the West (133,134).

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