2005 Application A548 Food from Corn Rootworm-protected and Glyphosate-tolerant Corn MON 88 9-2-05

9 February 2005

Food Standards Australia New Zealand

Submission on Application A548
Food from Corn Rootworm-protected and Glyphosate-tolerant Corn MON 88017

PSRG urges Food Standards Australia New Zealand to reject the above application. New Zealanders have the right to expect regulatory authorities to adopt a cautious approach to food safety and health considerations.

PSRG has looked at the material supporting this application and conclude that, in the form it currently stands, it does not sustain making the necessary changes to the Food Code to allow this genetically engineered corn into the human food supply. 88017 corn raises human consumption safety issues that have not been satisfactorily resolved.

Considerations
(1) This corn would also add to the agri-chemical content of the human food supply (see (5) and (6) below). Therefore, it would potentially affect every consumer and the animals consuming the Bt/RoundupReady corn feed.

(2) Corn and its products are widely used in the production of processed foods – possibly as high as 70 percent - and would therefore be widely consumed.

(3) The StarLink corn should stand as an example of how a chemical genetically engineered into a food can adversely affect human health on a large scale.
(3a) In research into its effect physicians pointed out that no published consideration was seen to be given to those members of the population who suffer allergenic reactions to certain foods, nor to those with challenged immune systems (e.g. diabetics or cancer patients), nor to babies, young children or the elderly. Potential allergenic reactions would also place an added burden on the health system. It is estimated that up to 20 percent of a population is subject to allergic reactions varying from mild to potentially life threatening to fatal.

(4) Glyphosate has been linked to various health risks. Recent research has shown that mice fed with glyphosate-resistant soy, which were monitored over a 2-8 month period, showed a transient transcriptional decrease (Vecchio et al., 2004). During this time, clusters of perichromatin granules (PG), known to contain pre-mRNA (Fakan, 2004) were found in all cell types examined. The authors concluded that accumulation of PG is likely to result from inadequate processing/export of (pre)-mRNAs from the nucleus. They also concluded that the cause(s) of the observed cellular alterations could be due either to
(a) the effects of the transgenic insertion(s), or
(b) glyphosate residues.
Mice testes cells were examined as the testis is a well-known bio-indicator and has already been utilized, for instance, to monitor pollution by heavy metals.
Glyphosate residues have been detected in food containing Roundup Ready soy (Granby et al, 2003). It has also been shown that glyphosate generates DNA adducts when used in high doses (Peluso et al, 1998) and cell division dysfunction when administered at low doses (Marc et al, 2002).

(5) The safety of the Bt endotoxin both to humans and animals is yet to be established. In Germany recently, twelve cows fed on GE maize engineered with the Bt toxin (Syngenta Bt176), died from unexplained causes. The Robert-Koch Institute which authorised the GE maize for consumption by animals, refused to conduct a full investigation into the cows’ deaths. The Bt protein, which apparently protects maize/corn from insect pests, degraded more slowly than had been anticipated. It was found in the cows' stomachs, intestines and excrement. Experiments on mice show that it may function similarly in other mammals, something which has until now been ruled out.
A study on Bt corn showed that genetic engineering of corn with the Bt gene produced pleiotropic effects in the form of considerably higher lignin levels (Saxena and Stotzky, 2001). High levels of lignin are associated with disease resistance to insect and microbial pests, but animals feeding on grains with a high lignin content are known to utilize the food inefficiently.
(5a) Transgenic crops producing Bt toxin(s) are widely used to control pests, but their benefits are lost when pests evolve resistance to the toxin. Research has shown that the way Bt corn is grown may mean insects become resistant to its lethal effects (Chilcutt and Tabashnik, 2004). The mandatory high-dose/refuge strategy for delaying pest resistance requires planting refuges of toxin-free crops near Bt crops to promote survival of susceptible pests. This study reported considerable gene flow between the Bt and non-Bt corn. The highest Bt toxin concentration in pooled kernels of non-Bt maize plants was 45% of the mean concentration in kernels from adjacent Bt maize plants. The authors concluded that variable Bt toxin production in seeds of refuge plants undermines the high-dose/refuge strategy and could accelerate pest resistance to Bt crops. Such resistance has already become a widespread problem, resulting the use of insecticides on Bt crops, particularly cotton.

(6) There have been no independent, long-term, peer-reviewed studies proving that the ingestion of transgenic foods are safe for humankind. Nor has the US population – being the principle country releasing untested, unlabelled genetically engineered foods over a period of years - been monitored for any results of ingesting multiple transgenic foods on a continuous, daily, long-term basis. There has been no independent scientific study to see if there is a link or not between the two- to ten-fold increase in food-borne illnesses in the US (1994 to 1999) and the commercial release of transgenic crops on home markets from the mid 1990s onwards. In Scandinavia, where genetically engineered foods have not been widely allowed in the food chain, the same statistics have remained virtually unchanged. Nor is the US known to have evaluated rates for cancers or other statistically monitored health problems since its introduction of genetically engineered foods.

(7) By allowing agri-chemicals, whether engineered into a plant or applied externally, or genetically engineered foods banned by other countries, New Zealand could adversely affect its food exports. The relatively recent incident of pizzas exported to Japan is such an event. Corn and its products would potentially appear in a very wide range of products.

(8) The potential for this product to enter animal feed is high. Distribution of genetically engineered corn to US farmers – following the failure of exports markets to Europe – brought reported adverse affects on stock. Markets worldwide are rejecting meat and meat products produced from animals known to have consumed feed with a genetically engineered content.

PSRG supports a zero-tolerance level for genetically engineering organisms in foodstuffs. This is technically achievable.
PSRG supports an Identity Preservation (IP) traceability system being in place on all foodstuffs to ensure that labelling accurately reflects the presence or absence of food or food ingredients produced using genetic engineering technology. An obligation to IP traceability will facilitate quality control, the verification of labelling claims, and the possible necessity of withdrawing products should unforeseen adverse effects to human health or the environment occur. It will also facilitate the monitoring of potential effects that GEOs could have on human and animal health and the New Zealand environment.
PSRG supports mandatory fully detailed, accurate Country of Origin labelling for all packaged and unpackaged meat, fish, dairy produce, fruit and vegetables, be they in a whole form or as part of an ingredient or additive, or used in the production thereof; and full public disclosure of all information gathered by, or required to be gathered by, government on residues in foods whether they be from pesticides, herbicides or insecticides, heavy metals, industrial chemicals or their by-products, veterinary medicines such as antibiotics and any other contaminants. Such information is crucial in allowing New Zealanders to make informed purchasing decisions, and to meet the basic human rights of New Zealanders to know where food purchases originate.

References
1. Veccio, L et al. (2004). Ultrastructural analysis of testes from mice fed on genetically modified soybean. Eur. J. Histochem. 48:449-454.
2. Fakan, S (2004). Ultrastructural cytochemical analyses of nuclear functional architecture. Eur. J. Histochem 48:5-14.
3. Granby, K., et al. (2003). Analysis of glyphosate residues in cereals using liquid chromatography-mass spectrometry CLC-MS/MS. Food Addit. Contam. 20: 692-698
4. Peluso, M., et al. (1998). 32-P postlabelling detection of DNA adducts in mice treated with the herbicide Roundup. Environ. Mol. Mut. 31:55-59.
5. Marc, J., et al. (2002). Pesticide Roundup provokes cell division dysfunction at the level of CDK1/cyclin B inactivation. Chem. Res. Toxicol. 15:326-31.
6. Saxena, D. and Stotzky, G. (2001). Bt corn has a higher lignin content than non Bt corn. Amer. J. Bot. 88:1704-1706)
7.Chilcutt, C.F. and Tabashnik, B.E (2004). Contamination of refuges by Bacillus thuringiensis toxin genes from transgenic maize. Proc. Natl. Acad. Sci 101:7526-9

(This submission has been prepared with the assistance of Dr Elvira Dommisse, BSc(Hons), PhD, a former GE Scientist with DSIR/Crop & Food Research, Lincoln.)

PSRG will not present this submission in person.

Jean Anderson
Secretary
Physicians and Scientists for Responsible Genetics
www.psrg.org.nz.

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