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6-Regulation: Reply by NLP to UK Minister of Environment



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TITLE:  Comment of NLP on BBC interview of UK Environment Minister
SOURCE: Natural Law Party Wessex, UK
        http://www.btinternet.com/~nlpwessex/
DATE:   May 20, 2003

------------------ archive: http://www.gene.ch/genet.html ------------------


On BBC Radio 4's 'Farming Today' 19 May the BBC interviewed UK
Environment Minister Michael Meacher. He indicated that whilst the
government will 'listen' to the public, the public will not have the
final say on whether GMOs will be allowed to be grown in the UK (http://
news.bbc.co.uk/1/hi/sci/tech/3038893.stm).

Mr Meacher stated: "We have to act in accordance with the law, and the
law at the present moment is set down in the EU Directive and the key and
sole criteria for taking action in regard to GM crops is: 'Are they a
harm, a risk to health or the environment?'...."

The debate therefore is likely to focus especially on evidence of such
harm or risk. However, one matter in particular is being swept under the
carpet in this respect. Very rarely is detailed cytogenetic analysis of
GM plants carried out and published. One of our earlier bulletins reports
on this subject as follows:

"Not surprisingly this chaotic situation [inherent in the physical
process of genetic modification] routinely creates plants which are
abnormal in comparison to their conventionally bred counterparts, a fact
which is rarely discussed in public by the scientific community. Clearly
such genetic aberrations are not desirable. Because of their potentially
unwelcome effects, the genetic engineer will then attempt to filter out
those plants which are abnormal. Sometimes the abnormalities are visibly
obvious. For example, the image below shows seedlings of transgenic
tomato plants, where approximately a quarter have a lethal mutation in
the form of bleached cotyledons [see web page for photo]....

Such obvious adverse mutations can be easily 'weeded' out. But what about
the abnormalities that cannot be seen by eye? Very often many of these
will go undetected simply because little or no molecular research has
been done as to their existence, nature and significance. As a recent
paper by scientists at the University of California, Berkeley, (Plant
Science 160 (2001) 763-772) points out '...no detailed cytogenetic
analysis of transgenic oat plants has been reported. Only a few detailed
reports on cytogenetic analysis of transgenic plants [of any kind] have
been done...'

Cytogenetics is the study of the microscopic structure of chromosomes.

The above statement by the scientists at Berkeley represents one of the
franker admissions in the published literature of the non-scientific
nature of genetic engineering.....

The cytogenetic work on the 'particle bombardment' generated transgenic
oats at the University of California ....describes the much higher
frequency of chromosomal abnormalities in transgenic plants compared with
non-transgenic lines...

However, even in this rare published study the authors confirm that their
methodology only permits quantitation of 'gross changes in chromosomal
integrity' and that it is 'also likely that other less visible changes in
chromosomal fidelity occur e.g. mutation, methylation polymorphism'....


Does that really matter?

The Berkeley paper makes it clear that this ....can have important
consequences: 'In transgenic [oat] plants...overall fertility was
dramatically reduced by the transformation [i.e. genetic modification]
process... The phenomenon of reduced fertility or sterility has also been
observed frequently in other transgenic cereals.... sterility and low
fertility in abnormal plants are likely related to chromosomal damage or
instability of chromosome number during abnormal meiosis...'

Plant breeders will claim that such difficulties can be filtered out by
testing in the field. A paper published by scientists from the US
Department of Agriculture and Monsanto in 1999 concerning transgenic
potatoes gives an indication of the process involved in this: '...
transformation often changes cultivar yield and quality characteristics
that are agronomically important....The gene [introduced through genetic
engineering] itself can affect the plant growth and type.... Off-type
plants can often be identified among new transformants in tissue culture
media by their lack of vigor or by conformational aberrations.... More
subtle vigor and growth aberration defects that are not obvious at an
earlier stage are often exhibited after plantlets are transferred from
soil flats to the field...In our experience with potatoes...[although]
growth aberration is usually associated with poor vigor, it does
sometimes occur in vigorous lines......'

So obvious problems are filtered out. Unfortunately, the less obvious are
not. This is already clear from the experience with the world's most
widely planted GM crop, 'Roundup Ready' soya. Only after
commercialisation was it discovered that additional DNA of unknown origin
had been inadvertently incorporated within the genome of the new
organism. More importantly it is now considered that the process of
genetic modification in this case has lead to the disruption of other
aspects of the soya plant's functioning resulting in reduced yields for
farmers compared to conventionally bred sister lines.


Whilst this unwelcome effect may be primarily a problem for soya farmers,
who is to say what the long term consequences of such genetic distortions
may be in the future for human health in this or any other GM food?

Unfortunately, as the Berkeley study indicates, the commercial interests
now responsible for funding much of the development of transgenic
technology do not have a strong inclination to carry out and publish even
the most basic cytogenetic analysis." [Taken from Tearing Down Biotech's
'Berlin Wall' - The Fundamental Scientific Error of Pursuing Transgenics
Before Competency in Genomics - NLPWessex, 4 May 2003 www.btinternet.com/
~nlpwessex/Documents/genomicsparadigm.htm]

Whilst there is very little peer reviewed published research on the
health effects of GM food, already adverse effects on either laboratory
animals or human beings have been demonstrated in relation to at least:

GM soya
GM maize
GM potatoes
GM tomatoes
GM hormone for injection into cows for milk production (where the company
tried to hide the research)

You can read more about this research at: http://www.tv.cbc.ca/
newsinreview/mar99/milk/intro.htm
http://www.actionbioscience.org/biotech/pusztai.html
http://www.guardian.co.uk/gmdebate/Story/0,2763,756666,00.html
http://www.organicconsumers.org/gefood/iliumstudy.cfm

For more on the general lack of such research see:
http://www.mindfully.org/GE/Many-Opinions-Few-Data.htm

According to the BBC "Two weeks ago, the Royal Society said there was no
evidence eating GM foods was any different from eating naturally produced
food".
(http://news.bbc.co.uk/1/hi/sci/tech/3038893.stm ).

As the above papers indicate this statement is simply untrue. This
situation is deeply damaging to the reputation of science which is
increasingly regarded as having become subservient to commercial
interests. As the highly respected journal 'The Lancet' has already made
clear: "Trust is no defence against an aggressively deceptive corporate
sector."
(http://www.btinternet.com/~nlpwessex/Documents/
ironcurtainmodernscience.htm ).

In the case of GM foods there is already evidence that there can be harm.
The issue simply boils down to how important that evidence is, and
whether there might there be more evidence if we made a serious attempt
to find it (particularly by using independent scientists to design and
carry out the testing, rather than relying on the GM companies).

In short its easy to say there are no adverse effects from GM foods if
you ignore 'inconvenient' research or avoid doing it in the first place.

Interestingly in a paper published by researchers in Egypt (Toxins Volume
6, Issue 6, 1998. Pages: 219-233) it was found that GM potatoes
containing the Cry1 Bt gene caused damage to part of the small intestine
in rats. This gene is already contained in GM crops grown across millions
of acres in the US. (Novartis's Bt maize approved 1997 for growing in the
EU contains the CryIA(b) gene)

According to one commentator "The evidence ...that the Bt Cry1 damages
the ileum is very clear and should not have been ignored. ..... The
damaged ileum would cause distress to digestion and is likely diagnosed
as mild food poisoning or flu."

As it happens reported food related illnesses in the US have more than
doubled since the introduction of GM foods, although no epidemiological
studies appear to have been done to establish whether there is any
connection. That would be virtually impossible in a country where there
is no GM food labelling or consumption monitoring.

In an article in Nature 22 April 1999 it is stated that "Ben Miflin,
former director of the Institute of Arable Crops at Rothamsted, near
London, who is a proponent of the potential benefits of genetic
modification of crops.... argues that, under current monitoring
conditions, any unanticipated health impact of such foods would need to
be a 'monumental disaster' to be detectable."

It is important to understand that most GM food testing is carried out by
the GM companies themselves and not by the regulatory authorities. Some
of these companies already have a track record of surpressing damaging
research data in genetic engineering or other bioscience fields.

During the same BBC 'Farming Today' broadcast there was an interview with
Professor Malcolm Hooper of Sunderland University who commented as follows:

"I think [GM research] is not transparent at all. And where
investigations have taken place about drugs or about radiation, when
people have been able to get at the records which have been hidden and
which have been kept under wraps by a company, then it has become
apparent that there have been much bigger problems than were initially
admitted - and certainly admitted to the public. So I think the
transparency of the science is absolutely crucial. We need an open
debate, but we need the information on the table, and we need the
experiments on the table so we can see how well they have been designed
and many experiments are badly designed. Some of them are even
duplicitously designed in order to

get the result the company asks for. And I would think if big companies
are not prepared to engage in this transparent process, then I think they
will have to suffer the consequence of government legislation which will
say 'no' to the products that they're advocating. If they are simply
making sweeping assertions - and sometimes government agencies are
supporting them in this: 'We don't think there's a problem, our people
have looked at it' - and you say, 'well how have you looked at it,
where's your data, where's your experiments, where's your papers, has it
been published?' And the answer is very often [unsatisfactory]."

More information on such matters is available at:
http://www.btinternet.com/~nlpwessex/Documents/genomicsparadigm.htm

There is no question that there is already enough evidence of the harm or
risk to which Mr Meacher refers, sufficient to demonstrate that at the
very least further reseach is required before GM crops and foods can be
legally authorised for commercial use under EU law.

Failure to do so is likely to lead to legal action against those who do
not appropriately apply the precautionary principle (as enshrined in EU
law - ) in such matters.

There is no reason for not applying such precaution at this stage.

According to a recent position statement by the European Commission
(http://www.foodlaw.rdg.ac.uk/eu/doc-17.htm ): "... the precautionary
principle presupposes that potentially dangerous effects deriving from a
phenomenon, product or process have been identified, and that scientific
evaluation does not allow the risk to be determined with sufficient
certainty.... Decision-makers need to be aware of the degree of
uncertainty attached to the results of the evaluation of the available
scientific information. Judging what is an 'acceptable' level of risk for
society is an eminently political responsibility. Risk can rarely be
reduced to zero, but incomplete risk assessments may greatly reduce the
range of options open to risk managers. A total ban may not be a
proportional response to a potential risk in all cases. However, in
certain cases, it is the sole possible response to a given risk Where
action is deemed necessary, measures based on the precautionary principle
should be, inter alia... [e]xamining costs and benefits... This is not
simply an economic cost-benefit analysis: its scope is much broader, and
includes non-economic considerations, such as the efficacy of possible
options and their acceptability to the public. In the conduct of such an
examination, account should be taken of the general principle and the
case law of the Court that the protection of health takes precedence over
economic considerations.... measures based on the precautionary principle
should be maintained so long as scientific information is incomplete or
inconclusive."

The 'benefit' side of the debate is also covered in the 'Farming Today'
discussion.

In particular Dr Denis Murphy, from the University of Glamorgan and an
advisor to the government on GMs, makes some interesting comments.
Although he does not have concerns about the risk to human health of the
GM varieites currently grown in North America he states: "What I am a
little more skeptical about is their value as agricultural varities,
whether they are really going to be profitable or the next big
agricultural revolution".

This statement is supported by analysis published by the US Department of
Agriculture during 2002. Its economic research concludes that "Perhaps
the biggest issue raised by these results is how to explain the rapid
adoption of GE crops when farm financial impacts appear to be mixed or
even negative." (see: 'USDA Report Exposes GM Crop Economics Myth',
NLPWessex 22 August 2002 www.btinternet.com/~nlpwessex/Documents/
usdagmeconomics.htm ).

If the benefits for farmers are more imaginary than real, then the
situation would seem to be even worse for consumers.

Dr Murphy adds: "We have to think in the whole food chain, really is it
benefiting everyone equally? At the moment you see, the customer because
they don't benefit they are free to reject these..... [Customers are not
benefiting, because with] the GM crops at the moment, the food is no
different... it's no cheaper, it doesn't taste better.... For them, I'd
say its a cost free decision to reject GM crops."

So if the evidence of risk is already there, or at the very least that
possible risks need to be looked at more carefully, and if benefits to
farmers and consumers are questionable or non-existent, then what is the
legal and economic justification for proceding with the commercialisation
of GM crops in the EU at this stage?


Or is the public about to 'Iraqed' again?

In order to support its case for the war in Iraq the British government
even submitted forged documents to the UN (http://www.newyorker.com/fact/
content/?030331fa_fact1 ).

If that experience is anything to go by, anyone who wishes to rely on the
British goverment for the reliable assessment of evidence during the
process of public policy debate may have to think again.


NATURAL LAW PARTY WESSEX
nlpwessex@btinternet.com
www.btinternet.com/~nlpwessex

Tearing Down Biotech's 'Berlin Wall'
www.btinternet.com/~nlpwessex/Documents/genomicsparadigm.htm

The Acceptable Face Of Ag-biotech
www.btinternet.com/~nlpwessex/Documents/monsantoMASpossibilities.htm