RCGM Submission Neil Macgregor and Max Turner

Publications & Resources

Submission Royal Commission on Genetic Modification

Name and Address of Submitters: Dr. A Neil Macgregor and Dr. Max A. Turner

Soil and Earth Science, Institute of Natural Resources, Massey University, Palmerston North; Courier Address Ditto; Phone 06 356 9099 / ext 7433 (ANM), ext 2200 (MAT); Email This email address is being protected from spambots. You need JavaScript enabled to view it.; This email address is being protected from spambots. You need JavaScript enabled to view it..

Submission Description: Soil Effects of Transgenic Agriculture: Biological Processes and Ecological Consequences.

4. Name of submitters

Dr. Max Turner is a soil scientist in Soil and Earth Science, Institute of Natural Resources, Massey University. He graduated M.Agr.Sci from Massey University and PhD from the University of Minnesota. His area of expertise is in soil fertility, soil-plant relationships, and fertilizer use in agriculture and horticulture. He consults within New Zealand and offshore on aspects of soil husbandry and plant nutrition.

Dr. Neil Macgregor is a soil microbiologist and ecologist in Soil and Earth Science, Institute of Natural Resources, Massey University. He graduated M.Sc from the University of Otago and PhD from Cornell University. His primary teaching and research at universities in the USA and Massey have been soil biology, biochemistry, and microbial ecology.

5. Submission Executive Summary

Executive Summary

Provide an overarching summary of your submission and recommendations made [in respect of items (1) and (2) of the terms of reference]. The Executive Summary should be no more than 3 pages in length

In the light of a growing body of scientific evidence on soil repercussions from transgenic organisms and their products published in major scientific journals, and with the realisation of uncertainties about risk and experimental containment, there should be no further development and field testing of transgenic organisms envisaged for agriculture, horticulture, and forestry in New Zealand until the risk potential has been adequately identified and evaluated.

The growing body of compelling evidence relating to soil includes alteration and changes to soil biological activities, the retention and longterm effects of transgenic products, and the natural ability of soil organisms to participate in gene-transfer mechanisms in the soil environment.

[See section B(b) for submission details and documentation.]

Section B (b)

B (b) the evidence (including the scientific evidence), and the level of uncertainty, about the present and possible future use, in New Zealand, of genetic modification, genetically modified organisms, and products

Section B (b) Summary

Response

Based on current knowledge, we believe there is considerable uncertainty about the value of researching and planning the development of transgenic organisms for future use in New Zealand agriculture. Contrary to declarations from supporters of GE-technology, changes to the integrity of soil processes have been scientifically documented, changes that point to risks to New Zealand soils should transgenic organisms be introduced, knowingly or inadvertently, into mainstream agriculture.

There is no published New Zealand research data on the risks and effects of such practices.

There is, however, published information from overseas studies to suggest that there is reason to be concerned. These findings (see references) in prominent scientific journals are the main component of this submission. They do not appear to have been featured in other submissions to the Commission, nor have they been widely aired in debates on the issues of farming GE-crops and other organisms which ultimately enter soils and become involved in nutrient cycling and transformation processes.

We are concerned about the unevaluated effects of these technologies and the possible long-term residual effects on essential soil biological processes. We believe that the responsible stewardship and maintenance of the productive potential of land is enshrined in the Resource

Management Act 1991. Any decline in the known capacity of soil to function normally, or limit its versatility, would be unlawful in this country.

Evidence from published papers:

· Stotzky, G.J.2000. Persistence and biological activity in soil of insecticidal proteins from Bacillus thuringiensis and of bacterial DNA bound on clays and humic acids. Journal of Environmental Quality 29:691-705.

“ DNA is released into soil and other natural habitats from lysed and by growing bacteria. This extracellular DNA can be taken up by competent bacterial cells and its genetic information incorporated into the genome of the cells. This process of gene transfer, called natural transformation, has been considered relatively unimportant in natural habitats because of the susceptibility of “naked” DNA to microbial degradation. However, DNA binds on clay minerals, humic substances and other surfaces and, thereby, becomes resistant to biodegradation while retaining the ability to [genetically] transform.”

and

“ these results indicate that toxins from B. thuringiensis introduced in transgenic plants and microbes could persist, accumulate, and remain insecticidal in soil as a result of binding on clays and humic substances and therefore pose a hazard to non-target organisms, enhance selection of toxin-resistant target species, or enhance control of insect pests”.

and

“With transgenic animal factories, feces, urine, and subsequently even carcasses containing bioactive compounds will eventually reach soil and other natural habitats (e.g. surface and ground waters).If these bioactive compounds bind on clays and humic substances –and as many of these are proteinaceous, they most likely will – they may persist in natural habitats, and if they retain their bioactivity, they could impact the biology of these habitats.

Consequently, before the use of such plant and animal factories, the persistence of their products and the potential effects of the products on the inhabitants (e.g. soil microbiota) of soil and other habitats must be thoroughly evaluated. Unfortunately, such studies were apparently not conducted, nor requested by the relevant regulatory agencies, before the release of BT-containing and other transgenic plants.”

· Lorenz, M.G. and W. Wackernagel. 1994. Bacterial gene transfer by natural genetic transformation in the environment. Microbiological Reviews 58: 563-602.

“ Experiments …showed that competent B. subtilis took up adsorbed chromosomal DNA directly from the sand particles. The studies revealed that the transformation efficiency was up to 50 times higher at the solid/liquid interface than in the liquid, and up to 3200 times higher when only cells bound on the mineral surfaces were considered”.

and

“ the continual production and release of DNA by bacterial populations and the relatively long persistence of this DNA, particularly when associated with soil surfaces, provide extracellular gene pools in the bacterial habitats despite the ubiquitous presence of DNAases.”

· Nielsen, K.M., A.M. Bones, K. Smalla, and J. D. van Elsas.1998. Horizontal gene transfer from transgenic plants to terrestrial bacteria – a rare event? FEMS Microbiological Reviews 22: 79-103.

“ Transfer frequencies should not be confounded with the likelihood of environmental implications, since the frequency of [horizontal gene transfer] is probably only marginally important compared with the selective force acting on the outcome. Attention should therefore be focussed on enhancing the understanding of selection processes in natural environments. Only an accurate understanding of these selective events will allow the prediction of possible consequences of novel genes following their introduction into open environments”.

· Saxena, D., S. Flores, and G. Stotzky. 1999. Insecticidal toxin in root exudates from Bt corn. Nature 402: 480.

“ We have no indication of how soil communities might be affected by Bt toxin in root exudates in the field. Bt in the rhizosphere might improve the control of insect pests, or it might promote the selection of toxin-resistant target insects. Receptors for the toxin are present in non-target as well as target insects, so there may be a risk that non-target insects and organisms in higher trophic levels could be affected by the toxin. Further investigations will be necessary to shed light on what might happen underground”.

· Altieri, M.A., March 2000. International Workshop on the Ecological Impacts of Transgenic Crops. ( March 2-4, 2000) Berkeley, California . Executive Summary.

“At issue is the potential for transgene insertions to cause expression of not simply the larger trait, but also unintended secondary outcomes that could pose environmental risks.

Risk assessment of transgenic crops focus narrowly on only the intended outcomes, virtually ignoring the possibility of unintended outcomes or side effects.”

and

“Because of the importance of soil biota in mineralization and immobilization of nutrients, physical and biochemical degradation of organic matter, biological control of plant pests, and as food sources for other organisms, it is crucial to evaluate the potential impacts of transgenic plants on soil ecosystems”.

Naseby D.C. and J.M. Lynch. 1998. Impact of wild-type and genetically modified Pseudomonas fluorescens on soil enzyme activities and microbial population structure in the rhizosphere of pea. Molecular Ecology 7 : 617-625.

[Abstract only]

“These results indicate that soil enzymes are sensitive to the impact of inoculation with genetically modified microorganisms”

· Macgregor, A.N. 2000. Footprints of Genetic Engineering in Agriculture.

In Designer Genes, Dark Horse Publishing, Wellington. Pp179-185

(About technology packages)

“First there is the [wheat] plant that has been genetically engineered to tolerate commercial applications of a specific herbicide. It usually affects a key enzyme reaction in an essential metabolic pathway of sensitive plants, and is readily prepared in commercial quantities for the international agricultural market.”

and

· Ahmad, I., and D. Malloch. 1995. Interaction of soil microflora with the bioherbicide phosphinothricin. Agriculture, Ecosystems and Environment. 54: 165-174.

[Note: Phosphinothricin is the active herbicidal component of the commercial herbicide glufosinate (known as Buster in New Zealand)].

“ Given that the degradation of organic matter in a soil ecosystem involves a multiplicity of interacting microbial activities, the marked variation observed in phosphinothricin resistance of saprophytic molds suggests a disruptive influence of phosphinothricin on microbial nutrient cycling”.

INTERPRETATION

Soil implications must be taken seriously in any evaluation of risks to the environment from transgenic agriculture. We are not sure why so little attention has been paid to soil related issues, but are prepared to speculate that it may simply be that they are unacknowledged and therefore absent as research-agenda items in biotechnology research programmes.

Contrary to claims made about involvement of soil in GE-field trials, it is unworthy of scientists to be indifferent to the published facts. We were unable to find references that would confirm safety in terms of soil ecology with the contemporaneous use of transgenic organisms in agriculture.

We have come to the following conclusions, based on available scientific evidence, like that cited above:

that soil materials have large sorptive capacities for biological molecules including DNA and insecticidal bacterial proteins,

that soil can protect such molecules from biological degradation for months,

that claims of rapid degradation of DNA in soil are not necessarily factual,

that the toxic properties and genetic information of such molecules can be retained in soil for surprisingly long periods of time,

that soil is a natural medium for gene transfer between organisms.

that biological nutrient cycling in soil could be impaired,

that the frequency of reports of detectable changes in soil ecology is somewhat unexpected and not fully appreciated, and

that long term implications of these changes in soil remain unexplored.

We therefore recommend, that no further field-testing (even in containment) of transgenic plants and animals be authorised in New Zealand until the soil-related risks are acknowledged and receive adequate evaluation.

· Reference. “End of an era”. Editorial [about BSE], NEW SCIENTIST , 4 November 2000.

“ It is this patronising attitude among those who govern and the infantilisation of the governed that must change. We cannot allow any more, as [Lord]Phillips puts it, for the public to be sedated by the official presentation of risk. People don’t need facile reassurances; they need information and the chance to make up their own minds. They need openness.”

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