GENTECH archive


Re: GE Debate v0.2


Substantial Equivalence (SE) is not a scientific term, it is a legal term.
If it were scientific then SE would apply globally, it does not. What is
regarded as SE in the USA might not be regarded as SE in its neighbour Canada.

All that SE signifies is that a particular product has passed the
legislative requirements to be used in a particular country.

There is not and cannot be a scientific definition of Substantial
Equivalence, at least not in the sense that it is commonly being used. To
say that two things are SE you need to know what factors would constitute a
significant difference. If you observe that products 'A' and 'B' have
different effects then you know they have significant differences. If you
don't observe that products 'A' and 'B' have different effects all you can
say is that the specific observations you have made do not show differing
effects, that does not mean that they are not significantly different. If
you measure the density of two things and they are the same does that mean
they are SE, of course not.

It is impossible to say that something is truly, scientifically, SE even
for one species - since we don't know what factors are significant.

The term SE gives the appearance of being scientific, but it is just a
means of giving approval for the use of a product within a particular legal



At 19:35 29/11/1999, you wrote:
>Thank you for taking the time and trouble to critique the document.
>I'll go through your points one at a time, over the next few days.
>> everything is ok. This leads to the conclusion that 'substantial
>> equivalence' can't be ASSUMED but must be 'PROVEN' in feeding tests.
>> (This should also be done with new varieties created by conventional
>> breeding or new food products, eg kiwi, which caused many allergic
>Should substantial equivalence (SE) be established on a species by
>species basis? For instance, we know Bt corn is not SE to conventional
>corn as far as butterflies, lace wings, and ladybird beetles are
>concerned. How do we show it for other insects, soil microflora, etc.?
>When you say SE must be PROVEN in feeding tests, this is precisely what
>did NOT happen. SE was used to avoid feeding tests with human volunteers.
>Roberto Verzola
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