London, United Kingdom
September 2, 2008
The
Institute of Food Science & Technology has authorised the
following
Information Statement, dated September 2008, replacing the
Statement of July 2004 and any previous version.
Source:
http://www.ifst.org/uploadedfiles/cms/store/ATTACHMENTS/gm.pdf
SUMMARY
Over the past 11 years, and in many parts of the world,
genetically modified (GM) crops grown by 12 million farmers (of
which 11 million are resource-poor farmers) have already
provided significant improvements in the quantity and quality of
the food supply while reducing economic cost, energy usage,
pesticide usage, fuel usage, soil erosion and carbon emissions,
with no scientifically-documented evidence of harm to human
health.
In addition to the foregoing benefits, the “second generation”
of GM crops and those in the research pipeline have the
potential to deliver crops to provide much needed nutritional
benefits; crops with more effective utilisation of fertiliser;
crops that will grow under drought and other adverse climate
conditions; and crops that will grow on previously inhospitable
land.
Food scientists and technologists can support the responsible
introduction of GM techniques provided that issues of product
safety, environmental concerns, information and ethics are
satisfactorily addressed. IFST considers that they are being
addressed, and need even more intensively to continue to be so
addressed. Only in this way may the benefits that this
technology can confer become available, not least to help feed
the world's escalating population in the coming decades.
INTRODUCTION AND DEFINITIONS
Food biotechnology is the application of biological techniques
to food crops, animals and micro-organisms to improve the
quality, quantity, safety, ease of processing and production
economics of food. It thus includes the traditional food
manufacturing processes used for bread, beer, cheese and various
fermented milk products.
A relatively more recent (i.e. starting about 30 years ago)
application of biotechnology to food is genetic modification
(GM), also known as genetic engineering, genetic manipulation,
gene technology and/or recombinant DNA technology. The
collective term "Genetically Modified Organisms" or GMOs is used
frequently in regulatory documents and in the scientific
literature to describe the deliberate introduction of DNA by
human intervention into plants, animals and micro-organisms.
Random genetic variation occurs naturally in all living things
and is the basis of evolution of new species through natural
selection. Even before its scientific basis was understood,
mankind took advantage of this natural variation by selectively
breeding wild plants and animals and even micro-organisms such
as yoghurt cultures and yeasts, to produce domesticated variants
better suited to the needs of humans. Such selective breeding
involves the transfer of unknown numbers and kinds of genes
between individuals of the same species. Before the advent of GM
technology, however, so-called "traditional" or "conventional"
breeding technology involved far more than the foregoing. Over
the past half-century it also included techniques involving
polyploidisation and mutagenesis via x-rays, which are far more
disruptive of the original plant genes than any GM modification.
For example barley seeds (Golden Promise) were treated with
x-rays in the Winfrith reactor in 1956 to yield the UK's
favourite variety for brewing -- and this variety is also used
in the production of organic beer. Many changes to food
materials brought about by gene technology are no different in
essence from those which can take place in nature or by
selective breeding, except that the gene technologist transfers
a carefully targeted selected few specific genes, thus
drastically reducing both their random nature and the time taken
to produce an improvement.
Thus, within-species GM involves few fundamentally new issues.
However, gene technology also makes it possible to move genes
between different species. When first used, this property made
the technique revolutionary in terms of the potential benefits
that it may bring, but it also caused concern regarding issues
of safety, ethics, environmental impact and consumer choice.
TECHNIQUES OF GENETIC MODIFICATION
How is GM technology carried out? In simple terms, the gene
technologist uses a "cutting-copying-pasting" approach to
transfer genes from one organism to another. For this, bacterial
enzymes are used that recognise, cut and join DNA at specific
locations acting as molecular "scissors-and-tape". However, the
selected gene is copied billions-fold, with the result that the
amount of original genetic material in the modified organism is
immeasurably small. Since DNA does not always readily move from
one organism to another, "vehicles" such as plasmids (small
rings of bacterial DNA) may be used; alternatively, some plant
cells may be transformed by "shooting" small particles coated
with the new DNA into the target cell using a special type of
gun, the "Gene Gun". The modified cell can then be used to
regenerate a new organism.
However, by currently available methods only small numbers of
cells subjected to a genetic modification procedure are
successfully modified. Furthermore, the regeneration of whole
plants or animals from culture cells may take months or years.
Consequently, it is necessary to identify the modified cells in
a culture mix using "marker genes" closely linked to the genetic
material to be transferred. Antibiotic resistance has often been
used to "tag" genes so that they can be detected easily and
rapidly at the cellular level in the laboratory, providing a
basis for selection. The use of antibiotic resistance marker
genes (ARMG) has, however, been a source of concern.
Although the transfer of antibiotic resistance from a marker
gene contained in a GM plant to a microorganism normally present
in the human gut has not been demonstrated
experimentally, it has been suggested that the potential risk,
however small, of spreading resistance to therapeutic
antibiotics could have serious health consequences and therefore
should be avoided. In the absence of reliable data, the UK
Advisory Committee on Novel Foods and Processes (ACNFP) erred on
the side of caution and recommended some years ago against the
use of antibiotic resistance marker genes.
However, on 4 February 2004 a Working Party of the British
Society for Antimicrobial Chemotherapy
http://www.bsac.org.uk/
stated: "There are no objective scientific grounds to believe
that bacterial antibiotic resistance genes will migrate to
bacteria to create new clinical problems." They looked at
various routes "but are unable to identify a credible scenario
whereby new drug-resistant bacteria would be created". However
they point out that the theoretical possibility of transfer by
novel mechanisms cannot be entirely ruled out, and so consider
whether transfer of the three drug resistance genes that have
been used would pose a threat to antibiotic use in medical
treatment. These 3 genes are common in bacteria, and found on
mobile elements that move between DNA molecules and bacterial
cells, and this gene mobility has already compromised clinical
use of the antibiotics.
"The argument that occasional transfer of these particular
resistance genes from GM plants to bacteria would pose an
unacceptable risk to human or animal health has little
substance. We conclude that the risk of transfer of AR genes
from GM plants to bacteria is remote, and that the hazard
arising from any such gene transfer is, at worst, slight."
The Working Party goes on to ask "Can a blanket ban on
cultivation of GM plants carrying bacterial drug resistance
genes be justified, even in part, because of extremely
improbable, unquantifiable concerns?" They argue that a
precautionary principle approach that argued that such a
negligible risk must prevent the use of plants containing such
genes, must be set against a pragmatic approach that takes
account of the size of the risk and hazard and also the
potential benefits of GM plants, such as reduced pesticide use.
While the Working Party believes that the evidence means that
most bacterial AR genes would be safe, they "consider it
extremely undesirable and unnecessary to extend the list of AR
genes approved for GM plant development. In particular, the use
of any AR gene that if disseminated widely among bacteria would
be likely to compromise use of a front-line or currently widely
used antibiotic should be strongly discouraged, if not banned."
They note that plant biotechnologists chose not to use AR genes
in this category. And conclude, "The moratorium should continue,
particularly as alternatives to AR genes are being developed".
On 16 April 2004 the European Food Safety Authority (EFSA)
issued a scientific opinion
http://www.efsa.eu.int/press_room/press_release/386_en.html on
the subject, classifying those evaluated into 3 groups based on
their biological distribution and taking into account the
current importance of the antibiotics concerned to human and
veterinary medicine. The EFSA GMO Panel has proposed the
following classification for ARMGs:
• Group 1 ARMGs contains
antibiotic resistance genes which (a) are widely distributed
among soil and enteric bacteria and (b) confer resistance to
antibiotics which have no or only minor therapeutic
relevance in human medicine and have only restricted use in
defined areas of veterinary medicine. This refers to the
antibiotic resistance genes nptII conferring resistance to
the antibiotics kanamycin and neomycin with a 13-year
history of safe use in food crops and the hph gene, which
encodes for a protein that inactivates hygromycin, an
antibiotic that is not utilised in human clinical medicine.
No restrictions are required with this class of marker genes
either for field experimentation or for placing on the
market.
• Group 2 ARMGs contains antibiotic resistance genes which
(a) are widely distributed in micro-organisms in the
environment and (b) confer resistance to antibiotics which
are used for therapy in defined areas of human and
veterinary medicine. This group includes genes which confer
resistance to chloramphenicol (cmR gene), ampicillin (ampR
gene) and streptomycin and spectinomycyn (aadA gene). The
use of these genes should be restricted to field trial
purposes and not be present in GM plants placed on the
market.
• Group 3 ARMGs contains antibiotic resistance genes, which
confer resistance to antibiotics highly relevant for human
therapy like the nptIII gene conferring resistance to
amikacin and the tetA gene conferring resistance to
tetracyclines. Irrespective of considerations about the
realistic importance of the health threat, these genes
should be avoided in the genome of transgenic plants to
ensure the highest standard of preventive health care.
Therefore these ARMGs should not be present in GM plants
placed on the market or in plants used for experimental
field trials.
However, other methods are
becoming available. In a development, reported in Science in May
1999, researchers at University of Hawaii demonstrated the use
of sperm to transport "foreign" DNA into an egg. It has a
relatively high rate of success, is technically simple to carry
out, has potential for transferring larger pieces of DNA and is
applicable to animals.
ADVANTAGES AND POTENTIAL BENEFITS OF GENETIC MODIFICATION
For the development of improved food materials, GM has the
following advantages over traditional selective breeding:
• Allows a much wider
selection of traits for improvement: e.g. not only pest,
disease and herbicide resistance (as achieved to date in
plants) but also potentially drought resistance, halo
tolerance, improved nutritional content (yield and quality
of macro-nutrients, enhancement of micro-nutrients e.g.
vitamin A, iron, enhancement of valuable phytochemical
components, removal of allergens or toxic components) and
improved sensory properties
• It is faster and lower in cost
• Desired change can be achieved in very few generations
• Allows greater precision in selecting characteristics
• Reduces risk of random occurrence of undesirable traits.
These advantages in turn lead to a number of potential
benefits, especially in the longer-term, for the consumer,
industry, agriculture and the environment:
• Improved agricultural performance (yields) with less
labour and energy input and less cost input
• Benefits to the soil of “no-till” farming practice
• Reduced usage of pesticides and herbicides
• Benefits to the environment in reducing the cost, energy
usage, fuel usage and carbon emissions associated with
tractor diesel fuel usage and pesticide spraying
• More efficient use of land
• Ability to grow crops in previously inhospitable
environments (e.g. via increased ability of plants to grow
in conditions of drought, soil salinity, extremes of
temperature, consequences of global warming, etc.) leading
to improved ability to feed an increasing world population
at a reduced environmental cost
• Improved sensory attributes of food (e.g. flavour,
texture, etc.)
• Removal of allergens or toxic components, such as the
research on a non-allergenic GM peanut (University of
Arkansas and University of Georgia) and a non-allergenic GM
prawn (Tulane University); and in Japan, to produce a GM
non-allergenic rice.
• Development of crop plants that take up and assimilate
nitrogen more efficiently to improve the efficiency of
utilisation, and hence reduce the application, of nitrogen
fertilisers, resulting in lower production costs.
• Improving nitrogen fertilisation by transfer of nodulation
properties from legumes to non-legumes (research at the UK
John Innes Institute).
• Research indicates that there are also improved
nutritional attributes such as:
o increased Vitamin A
content in rice, which will help to prevent blindness
among children in Southeast Asia (Ingo Potrykus's EU
research project jointly funded by the Rockefeller
Foundation);
o the announcement in September 2003 by Edgar Cahoon and
his team at the Donald Danforth Plant Science Center in
Missouri that by inserting a gene extracted from barley
into a common type of field corn, they have created a
strain that grows with six times the usual amount of
vitamin E, a powerful antioxidant.
o The BioCassava Plus Project by an international
multi-centre research team led from Ohio State
University, funded by a $12 million grant from the Bill
and Melinda Gates Foundation, to produce GM cassava with
enough vitamins, minerals and protein to provide the
poor and malnourished with a day's worth of nutrition in
a single meal while reducing the cyanogen content;
successful in greenhouse trials and now extending to
field trials.
o Research by Dow and Monsanto to develop a canola seed
that produces omega-3 fatty acid, DHA (docosahexaenoic
acid), thus minimising reliance on fish as source of
omega-3.
Improved processing characteristics leading to reduced
waste and lower food costs to the consumer.
• Prevention of loss of
species to endemic disease (e.g. the Cavendish dessert
banana which is subject to two fungal diseases that have
struck Africa, South America and Asia, but could be
reprieved by GM development of a disease-resistant version).
• Chinese scientists have developed a genetically modified
(GM) corn that could help improve the nutritional value of
livestock feed and reduce pollution. The research is carried
out by the Chinese Academy of Agricultural Sciences (CAAS).
The corn has now entered pre-production field trials. The GM
corn produces seeds containing high levels of the phytase
enzyme. This enzyme helps livestock to digest phosphorus
which is enclosed in the indigestible form of phytate.
Animals lack phytase in their system. As a result, farmers
add the enzyme to animal feed to help livestock digest
phosphorus. The CAAS scientists isolated the gene that
produces phytase from a species of the fungus Aspergillus,
and inserted it into corn. Preliminary test have shown that
compared to regular varieties, the rate of seed germination,
growth speed and yield of the GM corn were no different. The
scientists said that, under current
industry criteria for feed additives, adding just a few
grams of the GM corn seed per kilogram of animal feed would
be enough to satisfy livestock's nutritional demand for
phosphorus. If the technology is commercialised, Chinese
farmers could save up to $60 million per year in buying
industrial phytase. Phosphorus pollution caused by animal
waste is a serious problem in China, resulting in widespread
algal blooms in the Chinese lakes. Better phosphorous
digestibility could add to improvement of the environment.
China has not yet approved any GM corn for commercial sale.
• Perhaps a small benefit compared to the above-mentioned,
but in January 2008, researchers at New Zealand Crop and
Food Research announced the successful genetic modification
of onion so that it does not make one cry! Normally when
onions are cut or chopped, amino-acid sulphoxides and an
enzyme are released to react and form the tear-causing
volatile. The genetic modification blocks that enzyme action
and redirects the reaction towards formation compounds
responsible for flavour and health-giving properties. GM has
huge potential for mankind in medicine, agriculture and
food. In food, the real benefits provided by the early
instances that have been appearing so far, are surpassed by
its longer-term benefit to the world - and especially the
developing countries - its potential for developing crops of
improved nutritional quality, and crops that will grow under
previously inhospitable conditions (see above), thereby
contributing to alleviating hunger and malnutrition, while
helping to prevent the otherwise inevitable future pressure
to encroach on natural resources. Even today, there are 860
million people (800 million of them in the developing
countries and 200 million of them children) who regularly do
not receive enough food to alleviate hunger, still less
provide adequate nutrition. 24,000 people die of
malnutrition-related causes daily. That situation will be
greatly worsened as a result of the world's escalating
population over the coming decades.
There are those who allege that
“scientists claim that GM will solve the problem of world
hunger”. This is a familiar "straw man". It is frequently argued
by some that there is more than enough food to feed the world
and all that is needed is "fairer distribution" (which so far
mankind has signally failed to achieve) – or a variant of that,
"the real problem is not shortage of food, it is poverty".
Whatever may be done by way of improved yields through
conventional methods, attempted population control and more
effective distribution would, however, be inadequate for the
future. There are probably enough cereals to feed the present
world population (if only they could be distributed to the right
places at the right times and could be afforded). But there will
be substantial shortfalls in cereals in the next two decades,
especially if the present practice of diverting cereals from
human food use to feedstock for ethanol biofuel production
continues. Moreover, "world hunger" is a complex not only of
inadequate quantity where it is needed but of inadequate quality
i.e. for vast numbers of people the lack of foods with the
necessary micronutrients and of clean water, for reasonable
nutrition and health.
However, in decades to come, with the expected substantial
increase in the world population, mostly in the poorest, least
developed countries, the demand for increased agricultural land
and for water will greatly increase. The important point is not
only how to feed the world now but addressing and trying to
solve the problem of "How shall mankind feed the world in a few
decades from now?” Of course the problem that has huge political
and economic dimensions will not be solved by GM alone, or even
by science alone -- but will certainly not be solved without the
contribution of science, including GM.
Food scientists and technologists can support the responsible
introduction of GM techniques provided that issues of product
safety, environmental concerns, ethics and information are
satisfactorily addressed. so that the benefits that this
technology can confer become available both to improve the
quality of the food supply and to help feed the world's
escalating population in the coming decades.
CURRENT GM FOODS AND FOOD INGREDIENTS
The "first generation" of GM food materials were those that were
relatively easy to develop, chosen for their likelihood of rapid
commercial success by providing traits that would commend
themselves to farmers. Consequently, most of the 80+ crops that
have been modified and the 25,000+ field trials that have taken
place world-wide to date have involved crops engineered for
agronomic traits. The first food plants to be grown successfully
on a large commercial scale and put on the market were the GM
maize resistant to the European corn-borer, a serious
agricultural pest, and the soyabean genetically-modified to be
tolerant of the herbicide glyphosate. The latter involves one or
two applications of a less toxic, more rapidly broken down
herbicide than the spraying regime that it replaces, that of
several applications of different herbicides. Contrary to the
widely held misconception, glyphosate is not a relatively new
herbicide developed for GM crops. On the contrary it has been in
use for over 30 years and has been a very popular
broad-spectrum, safer and less soil-persistent herbicide, for
many conventional crops. But it could not be used for soya
because it killed the soya as well as the weeds. So soya farmers
had to continue to use a "cocktail" of different herbicides at
different stages of the growing season. The clever scientific
trick was so to genetically modify soya that it was not killed
by, but resistant to, glyphosate.
However, these GM products did not offer consumers a readily
perceivable benefit “at the point of purchase”; and with
intensified campaigns and media amplification in the early part
of 1999 and thereafter highlighting problems and uncertainties
(some real, some pure speculation, some spin-doctored and some
urban myths), the UK public became turned against GM. Reacting
to their customers' views, major retailers and manufacturers
decided to exclude GM foods and ingredients.
An incidental victim was the canned tomato puree, prominently
labelled "Produced from genetically modified tomatoes", on sale
in stores of two major UK supermarket groups in competition with
non-GM tomato puree. The GM tomato puree was of better flavour
and consistency, cheaper, and consistently outsold the non-GM
puree. It is now no longer available.
Chymosin, produced by GM micro-organisms, was developed to
replace rennet, the milk-clotting enzyme used extensively in
cheese-making, due to the severe shortage of the traditional
source of the enzyme (i.e. calf stomachs). The GM enzyme,
defined as a processing aid rather than a food additive in
regulatory terms, has been in use since the late 1980s in the
USA and in some European countries, including the UK
WHAT ARE THE CONCERNS ABOUT GM?
Increasingly at the heart of the "concerns" debate about GM, is
the fundamental matter of the role of science and society in
relation to "new" science-based developments such as GM.
There are two ways of dealing with new developments with
associated problems and uncertainties. One is to reject or ban
the developments. The other is to address and solve the
problems, and to accept that there are no certainties in any
aspect of life. Fortunately in the long run mankind has
generally adopted the second course, otherwise we would still be
living in the Stone Age. Looking at more recent times, there
would be no electricity; the first passenger flight would not
have taken place, so there would be no air travel; the first
surgical operation would never have been carried out so there
would be no surgery; the first anaesthesia would never have been
used, so there would be no anaesthetics (it is worth recalling
that the medical profession of the day prevented Queen Victoria
from having anaesthesia with the difficult births of her first
seven children ("not natural, not proven safe, not sufficiently
tested, what about the long term effects?") -- the list could be
endlessly extended. Exactly the same arguments were used in the
early decades of the 20th century to try to prevent the
legalisation of milk pasteurisation. Fortunately it was
eventually legalised and over the last eight decades has saved
untold numbers of lives that would otherwise have continued to
be lost to milk-borne tuberculosis -- second only to clean water
as the most important public health measure ever adopted.
Science depends on gaining knowledge, organising it into a
coherent structure, hence improving understanding, and applying
it. It is society's tool and method for doing so. However, we
can never know everything there is to know about a topic. The
one certain thing about life is that nothing in life is certain.
Science cannot prove that anything is "safe" (i.e. absence of
harm) because "absence of evidence" is not "evidence of
absence". So any policy purportedly based on requiring science
to prove safety is unrealistic.
In real life, decision and action by society to meet its needs
has to be based, not on certainty but on using the best
knowledge available at the time, and on skilful selection of
areas for urgently needed research. In the absence of certainty
it has to involve the combination of risk analysis and the
precautionary principle, which are two inseparable sides of the
same coin. These lie at the very crux of any discussion on the
application of GM.
Risk analysis (RA) consists of:
• risk assessment, a task
for scientists who are experts both in the topic and in the
methodology of risk assessment. Risk assessment should take
account of the likelihood of a risk occurring and its
seriousness if it does occur, and should be applied not only
to a potential course of action, but also to failure to take
that action and to alternative courses of action;
• risk communication, a multi-directional interchange of
information between legislators, the scientific community
and the rest of society, which should be an ongoing process;
and
• risk management, for legislators to carry out on behalf of
society in the light of i and ii.
The relationship involving these
three activities is not a linear one but one of dynamic and
ongoing interplay.
A precautionary approach is a concept familiar to, and used by,
food scientists and technologists. Taking precautions in advance
to identify foreseeable hazards and adopting measures to prevent
harm from occurring is at the heart of the Hazard Analysis
Critical Control Point (HACCP) preventive food safety system.
On 2 February 2000, the EU Commission issued a "Communication on
the Precautionary Principle". It is on-line at
http://europa.eu.int/comm/dgs/health_consumer/library/pub/pub07_en.pdf
This includes
“The precautionary principle is not defined in the Treaty, which
prescribes it only once - to protect the environment. But in
practice, its scope is much wider, and specifically where
preliminary objective scientific evaluation, indicates that
there are reasonable grounds for concern that the potentially
dangerous effects on the environment, human, animal or plant
health may be inconsistent with the high level of protection
chosen for the Community.”
and
“The precautionary principle should be considered within a
structured approach to the analysis of risk which comprises
three elements: risk assessment, risk management, risk
communication. The precautionary principle is particularly
relevant to the management of risk.
The precautionary principle, which is essentially used by
decision-makers in the management of risk, should not be
confused with the element of caution that scientists apply in
their assessment of scientific data.
Recourse to 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.
The implementation of an approach based on the precautionary
principle should start with a scientific evaluation, as complete
as possible, and where possible, identifying at each stage the
degree of scientific uncertainty.
Anti-GM activist groups have focused wholly on the phrases
“….where preliminary objective scientific evaluation indicates
that there are reasonable grounds for concern… and “and that
scientific evaluation does not allow the risk to be determined
with sufficient certainty” and have argued that these phrases
justify opposing any and every GM activity.
This fails to recognise that science can never produce
conclusive results and cannot deal in certainty. Moreover,
experience teaches that the situation envisaged is most likely
to arise in areas (such as biotechnology) where there are strong
ideological agendas, in pursuit of which some individuals,
including, unfortunately, some scientists, present
unsubstantiated speculation, assumptions and guesswork as though
they were "preliminary objective scientific evaluation". This
sometimes takes the form of published purported "research
papers" which on scrutiny turn out to be merely the authors'
speculations and opinions, complete with references to similar
papers by like-minded individuals.
If that sort of presentation is considered enough to bring a
development to a halt, and, as we have seen, scientific evidence
is always insufficient and science cannot prove anything to be
safe, it can then be argued in perpetuity both by its
ideological opponents and by scientists who see further research
as a funding opportunity, that the development should not be
implemented "until we know more".
Purported "preliminary objective scientific evaluation" should,
therefore, always be very carefully and rigorously scrutinised
to ensure that there is a broad scientific consensus that it is
based on some hard scientific evidence.
Moreover, what is frequently overlooked ? and always overlooked
by the opponents of a development ? is that PP should be applied
not only to that development but to all alternative courses of
action, including that of doing nothing. On 8 July 2008 the
European Food Safety Authority issued a Question and Answer
Document, titled "EFSA GMO Risk Assessment FAQs" which addresses
the EFSA role in GMO risk assessment. Some of the questions
answered are: How does EFSA carry out GMO risk assessments? Why
does EFSA not carry out its own studies? Can the public access
GMO applications? How does EFSA take account of long-term
effects for human health and the environment and assess
potential impact on biodiversity? What about the issue of
coexistence with conventional crops and uncertainties,
assumptions and the precautionary principle? Why does EFSA keep
getting asked to look again at its risk assessments? Why does
EFSA consider that antibiotic resistance genes in some of the GM
plants are not dangerous?
http://www.efsa.europa.eu/EFSA/efsa_locale-1178620753812_EFSAGMORiskFAQs.htm
It is an oft-repeated environmental truism that we hold the
world in trust for future generations. It would be a betrayal of
that trust and an abdication of responsibility by the present
generation if science were to limit itself to collecting and
providing information about current biotechnology applications,
or if society were to limit itself to arriving at verdicts about
them. We (society and scientists as part of society) must not
behave as disinterested spectators standing on the sidelines and
observing problems that may stand in the way of providing future
generations with the potential benefits that GM can offer. We
have a duty to address and solve such problems. Science is
society’s tool for doing that.
"As for the future, your task is not to foresee it, but to
enable it."
[Antoine de Saint-Exupery, The Wisdom of the Sands (1948)]
Thus, the real questions to be answered are not "Is it safe? Is
it environmentally friendly?" but "What do we have to do to make
it safe? What do we have to do to make it environmentally
friendly? " Recognition of these is the touchstone of sincerity
and objectivity.
A joint report on "Transgenic Plants and World Agriculture" was
published in July 2000 jointly by the Brazilian Academy of
Sciences, the Chinese Academy of Sciences, The Indian National
Science Academy, the Mexican Academy of Sciences, the National
Academy of Sciences of the USA, The Royal Society (UK) and the
Third World Academy of Sciences. It is available in printed
form, published by The Royal Society, and it may be accessed
on-line as a pdf file at
http://royalsociety.org/document.asp?tip=0&id=1448
The US organization, the Center for Science in the Public
Interest (CSPI), which is no friend of corporations or of US
regulatory agencies, issued a report in November 2001, primarily
from a US perspective, entitled "Genetically Engineered Foods:
Are They Safe?" but which also included environmental
considerations. It mainly took the form of Questions and Answers
by the co-directors of the Biotechnology Project at CSPI. The
full text can be accessed on-line at
http://www.cspinet.org/nah/11_01/
However, their "bottom line" conclusions were as follows:
• The genetically
engineered foods that are currently on the market are safe.
By increasing yields and reducing the use of pesticides,
they benefit farmers and the environment.
• To ensure that new genetically engineered plants and
animals are safe for humans and the environment, Congress
should institute a mandatory government approval process
that is open to public participation and review.
• The Environmental Protection Agency (EPA) should monitor
the environmental impact of genetically engineered crops. It
should require more field testing, enforce insect refuges
for Bt crops, and adopt other environmental safeguards.
• The U.S. government should fund more research on genetic
engineering, especially on fruits, vegetables, and other
crops that are not of great commercial interest to the
biotechnology companies.
• To enable developing nations to benefit from
biotechnology, the U.S. government should:
o fund research and the
training of scientists,
o help countries develop regulations to ensure the safe
use of genetic engineering to produce food, and
o press biotech companies to donate technologies and
allow free access to patents that are used to produce
genetically engineered seeds and animals.
On 21 February 2002, the US
National Academy of Science (NAS) issued its report
Environmental Effects of Transgenic Plants. The report, which
was commissioned in January 2000 by USDA’s Animal and Plant
Health Inspection Service (APHIS), reviewed the scope and
adequacy of the APHIS component of the Federal regulatory
framework for biotechnology. As requested, the report evaluates
the evolution of APHIS’ regulatory program, assessed the
effectiveness of changes that APHIS had made to improve the
program over the years, and made recommendations for further
refinements, particularly involving three processes:
notification, permitting and petitioning for non-regulated
status. On 2 August 2002, USDA's Animal and Plant Health
Inspection Service (APHIS) announced the creation of the new
"Biotechnology Regulatory Services" (BRS) Unit within APHIS "to
focus on USDA's key role in regulating and facilitating
biotechnology".
The full news release is at
http://www.aphis.usda.gov/lpa/news/2002/08/bioreorg.html
The World Health Organization has issued "20 Questions on
Genetically Modified (GM) Foods". These questions and answers
have been prepared by WHO in response to questions and concerns
by a number of WHO Member State Governments with regard to the
nature and safety of genetically modified food.
SAFETY CONSIDERATIONS
When introducing any new technology, including gene technology,
into the food chain, there is a need to adopt appropriate
safeguards to protect human health. Most countries in the
Western hemisphere started developing regulatory controls well
before any GM foods reached the market. These controls were put
in place not because safety problems had been identified but
because of a lack of familiarity with GMOs. Although many of the
early concerns regarding the safety of GM foods have not
materialised, the precautionary approach has continued as it
remains important to ensure that no new hazards are created.
When considering safety in relation to GM, generalisations
cannot validly be made. Instances have to be considered and
studied in a case-by-case approach, and each case should be
assessed in relation to the food involved, as ready for
consumption, whether by man or by animals. Regulations in most
countries, including the UK, include the concept of substantial
equivalence. This concept was developed in the late 1980s by
several national regulators and refined and given international
recognition by the Organisation for Economic Co-operation and
Development (OECD) in 1993 and further developed by the FAO/WHO
Consultation in 1996 with particular reference to foods produced
by modern biotechnology (fully detailed on the Web sites of FAO
and the UK Advisory Committee on Novel Foods and Processes
(ACNFP)). The concept is based on the idea that existing
organisms used as food or food sources can serve as a basis for
comparison when assessing the safety for humans of modified
foods or ingredients. If a new food or component is considered
to be substantially equivalent to an existing food or component
the theory is that it can be treated in the same manner with
respect to its safety and nutritional assessments.
Acceptability or non-acceptability is established by determining
whether a novel food is substantially equivalent to an analogous
conventional food in terms of composition, nutritional
properties, toxin and allergen content, the amount consumed, the
type of processing (industrial or domestic) that the food might
undergo and consumption by vulnerable groups of people (e.g.
infants and the elderly). Foods are assigned to three
categories:
• Products that are shown
to be substantially equivalent to existing foods or food
components
• Products that are substantially equivalent to existing
foods or food components except for defined differences
• Products that are not substantially equivalent to existing
foods or food components
Where differences are identified, extensive animal feeding
and toxicological trials are required. The establishment of
substantial equivalence is an analytical exercise which has
to be approached carefully. The comparison may be a simple
task, or very lengthy, depending upon the nature and
experience with the foods or components being compared. It
must also contain a dynamic element to take into account
that the continuing modification of a food will require that
the most recent novel food is compared with an appropriate
former novel food and not necessarily with the original and
traditional counterpart.
An understanding of substantial
equivalence is key to understanding the basis of GM regulatory
controls. This brief outline may be supplemented by studying the
text of the Report of the Joint FAO/WHO Consultation on
Biotechnology and Food Safety
http://www.fao.org/ag/agn/food/pdf/biotechnology.pdf
The question of antibiotic resistance marker genes (ARMGs) has
been addressed above. There are no inherent grounds for assuming
that GM foods are more - or less - allergenic than traditional
foods. However, when developing any novel foods, including GM
foods, care must be taken that allergenicity is not
inadvertently introduced into the diet. This requires assessment
of the allergenicity of a new protein by predictive methods,
experimental testing and a post-marketing surveillance based on
traceability.
The testing of GM products for suspected allergens can be done
by an IgE test with serum from sensitive individuals [e.g.
Herian et al (1990)]. However, there is also a need to test
products where genes have been inserted from sources not known
to be allergenic. Astwood et al (1996) have developed a method.
Stability of a protein or protein fragments to digestion in
simulated gastric fluid (SGF) may be used to assess the
potential allergenicity of a protein.
The British Medical Association (BMA) in its earlier (1999)
"interim statement" on GM had been hostile to GM and called for
an open-ended moratorium on all commercial planting of GM crops
until more was known about their effects on human health. Indeed
that had been one of the factors influencing the visiting party
of Zambian scientists to return to Zambia with recommendations
against GM. "Doubts over the safety of genetically modified
foods voiced by the British Medical Association were the main
reason behind Zambia's decision to reject food aid in 2002, says
a Zambian scientist who visited Europe this week. Famine still
threatens 2.4 million people in Zambia today". New Scientist, 29
January 2003.
http://www.newscientist.com/news/news.jsp?id=ns99993317
However
in March 2004 the BMA issued
a new statement
Announcing it they said "The BMA produced an interim report in
1999 on the health implications of GM food crops. In accordance
with our intention to keep the public informed, we held a round
table meeting of experts in June 2003 and have recently reviewed
the emerging evidence. In producing an update of our 1999
report, the BMA seeks to support balanced debate. As an
organisation of doctors, we are not experts in agricultural
techniques and crop science, but we are concerned with all
issues of public health. The environment in which we live, the
air we breathe, the water we drink and the food we eat, all have
an impact on our health as individuals. It is this context that
the statement has been prepared. The BMA shares the view of the
Royal Society that that there is no robust evidence to prove
that GM foods are unsafe. However, we endorse the call for
further research and surveillance to provide convincing evidence
of safety and benefit."
Numerous perceived concerns regarding the safety of GM foods
have been aired, many of them speculative and without any
scientific evidence, but three substantial concerns which have
been most widely discussed are in fact urban myths. These are
the L-tryptophan story, the brazil nut allergen story and the
events surrounding Arpad Pusztai and his potato experiment.
THE L-TRYPTOPHAN STORY
A frequently repeated account alleges GM as the cause of the
disease that caused 1500 illnesses and 37 deaths in USA in 1989.
The story refers to the so-called Eosinophilia-Myalgia Syndrome
(EMS syndrome) associated with some dietary supplements
containing the amino acid L-tryptophan.
The illnesses and death did occur, but the rest of the story is
untrue. In reality, extensive investigation traced the cause to
an impurity in L-tryptophan made by just one of its several
chemical manufacturers, all in Japan. The culprit was Showa
Denko KK of Tokyo (the fourth largest chemical manufacturer in
Japan, but which had some 80% of the market for L-tryptophan).
There has been successful litigation by three plaintiffs against
SD KK. The GM issue was not raised seriously by the plaintiffs
because there was such overwhelming evidence against it being a
factor.
The manufacture of L-tryptophan is by a fermentation which also
results in the formation of a number of secondary substances. To
produce L-tryptophan of a purity necessary for human ingestion,
the fermentation product mixture has to go through purification
processes to remove the impurities, by-products and cellular
debris, including treatment with activated carbon and reverse
osmosis. Investigation of the records of Showa Denko KK showed
that in the critical period (December 1988 to June 1989) they
made a number of simultaneous changes to the manufacturing
protocols. One of these was the use of the fermentation organism
Bacillus amyloliquefaciens that had been genetically altered to
increase the production of L-tryptophan. But this was
accompanied by the partial bypassing of the reverse osmosis
purification procedure, and a halving of the amount of activated
carbon used (both stupid and irresponsible things to have done),
thus failing to carry out the purification effectively.
Subsequent research showed that in consequence the procedure
left behind some sixty impurities; and also found significant
correlation between the development of EMS and the reduction of
the activated charcoal.
There have been several attempts to explain the precise
mechanism by which the syndrome occurred. One involves a
residual impurity 1,1 '- ethylidenebis-[tryptophan] (EBT), which
then broke down to give
1-methyl-l,2,3,4-tetrahydro-beta-carboline-3-carboxylic acid
(MTCA), a substance that was thought to have been involved in
the EMS syndrome. Another suggests that it was the result of a
reaction between two (or more) impurities. Like so many food
poisoning outbreaks investigated after the event, the exact
mechanism is unlikely now to be conclusively proved, but it was
nothing to do with GM. Thus the "tryptophan" story was not a
consequence of GM, nor of tryptophan itself, but an impurity or
impurities left in as a result of irresponsible short-cutting by
a particular chemical manufacturer.
THE BRAZIL NUT ALLERGEN STORY
With the currently much greater recognition of food allergens as
a food safety issue, the possible introduction of allergenicity
by genetic modification is a concern; and the apocryphal story
of "people made sick by a brazil nut gene transferred into soya"
has become a widely believed urban myth.
In fact, such a product never came on the market, and nobody
ever ate any such product. Soya protein is deficient in
methionine, and a seed company, Pioneer Hi-Bred, wanted to
investigate the possibility of producing a soyabean with
increased methionine content (thereby improving the nutritional
quality of soya protein), by transferring a brazil nut gene to
soya. With any research involving any gene transfer, it is
routine standard procedure to investigate whether any
allergenicity could be thereby transferred. In this instance,
many people are allergic (some very seriously so) to soya
itself; but it was important to investigate whether such a
transfer would make the resulting soya allergenic also to people
who are allergic to brazil nuts. The research was carried out at
the University of Nebraska, the leading centre for allergenicity
research. Perhaps not surprisingly, the researchers found that
brazil nut allergenicity was transferred to the experimental
material. Pioneer Hi-Bred announced that the research project
was discontinued, and the results were published in a
peer-reviewed journal [Nordlee et al, (1995)].
THE PUSZTAI POTATO EXPERIMENT
This has received considerable publicity. It relates to the
purported adverse effects on rats of GM potatoes in which
lectins had been inserted, and the associated TV programme and
media interviews given by Dr Pusztai. Lectins, which are complex
plant proteins, appear to act as pest deterrents in plants and
lectin insertion into a crop plant by GM has been investigated
as a means of enhancing pest resistance.
The story has been greatly confused by contradictory reports as
to exactly what happened, and as to the supposed ill-treatment
of the researcher concerned – mostly culled from the media and
claims by Pusztai himself and activists keen to exploit the
situation. Fortunately there is now a first-hand history
available. In March/April 1999 the House of Commons
Parliamentary Select Committee on Science and Technology
investigated GM, and on Monday 8 March 1999 they held a Hearing
at which Dr Pusztai and his friend Dr Stanley Ewen, and
Professor Philip James, Director and Dr Andrew Chesson, Head of
the Nutritional Chemistry Unit, both of the Rowett Research
Institute (RRI), all appeared and were examined.
The written statement submitted by the RRI, which, incidentally,
is considerably sympathetic to Pusztai, gives a first-hand
historical account (and, incidentally, disposes of the various
myths that have been put around about Pusztai and his
treatment). For a verbatim account of all the evidence submitted
by RRI and by Pusztai himself, and for the Select Committee's
conclusions, see UK House of Commons, Select Committee on
Science and Technology,
http://www.publications.parliament.uk/pa/cm199899/cmselect/cmsctech/286/9030801.htm
and
http://www.publications.parliament.uk/pa/cm199899/cmselect/cmsctech/286/28602.htm
The study which caused the controversy has since been reviewed
twice by the Audit Committee, by the Royal Society; by ACNFP; by
the Committee on Toxicity; and by the Nuffield Council on
Bioethics. All have found the experiment flawed, poorly
designed, and incapable of leading to meaningful conclusions.
There is, however, agreement that adequate in vivo tests need to
be developed before a new GM crop with a lectin insert is
released for either human or animal consumption.
As the RRI Audit Committee stated "The research was preliminary
and not part of the process of testing specifically genetically
modified crops destined for commercial use." "However, the
purpose of the research remains valid. It was part of a larger
programme designed to identify possible candidate genes, and
their implications, for possible future use in the genetic
modification of crops to enhance the crops' resistance to
pests."
Whilst investigations into this case have shown that the
problems were not directly related to the genetic modification
as originally claimed (and still perpetuated by some) they
emphasise that a greater awareness of the possible areas of
concern is needed when assessing the safety of GM foods.
ENVIRONMENTAL CONSIDERATIONS
Early regulatory controls over the release of GM crops had, of
necessity, been developed on an ad hoc basis due to the virtual
absence in the 1980s of quantitative data on the ability of GM
organisms to survive in the environment. However, in recent
years evidence has accumulated so that regulations and
guidelines can now be developed on a more rational basis; but
there is a continuing need for studies on the possible risks of
GM crops to the agricultural environment In the last few years,
the UK Government has responded to this need by funding over 20
projects in this area at a cost of over £6 million. Clearly,
regulations will need continuous revision and updating as new
data become available.
In the EU Member States, any release of GMOs into the
environment was governed by national regulations implementing EU
Directive 90/220/EEC (now superseded by Directive 2001/18/EC)
(implemented in the UK as part of the Environment Protection
Act). In the UK, at present there are no GM crops being
commercially grown. An experimental release, such as a field
trial of a food crop, requires consent from the Government.
Applications for consent must include a considerable volume of
data and a detailed assessment of the risk of harm to human
health and the environment. If a risk is identified or there is
some uncertainty about the level of risk, the applicant may
propose measures to manage or eliminate the risk. The
applications are scrutinised by the Advisory Committee on
Releases into the Environment (ACRE), a group of independent
experts who advise the Government on whether consent should be
given and whether extra conditions should be imposed prior to
giving consent. All releases are advertised locally and details
are made available via a Public Register. Release sites are
subject to inspection by the Health and Safety Inspectorate and
those making the release are required to report any incidents
that may occur during and after the completion of the trials. On
the one hand this openness and transparency is admirable, but on
the other hand the information made available has been seized on
by organised extremists who invade and destroy the trials.
The EU objective has been to protect health and the environment
when:
• carrying out the
deliberate release into the environment of GMOs for any
purposes other than placing on the market within the
European Community
• placing on the market GMOs as, or in, products within the
European Community
Data required other than for higher plants:
• Information relating to the GMO characteristics of donor,
recipient (or where appropriate parental) organisms
characteristics of vector characteristics of modified
organism
• Information relating to the conditions of release and
receiving environment information on the release information
on the environment
• Information relating to the interactions between the GMO
and the environment characteristics affecting survival,
multiplication and dispersal interactions with the
environment
• Information on monitoring, control, waste treatment and
emergency response plans.
Data required for GM higher
plants:
• Information relating to
recipient and / or parental plant
• Information relating to the genetic modification
• Information relating to the GM plant
• Information relating to the site of release
• Information relating to the release
• Information on control, monitoring, post-release and waste
treatment plans
Since 1987, more than 25,000 field
trials of GM plants have been carried out in 45 countries
without adverse environmental consequences. Furthermore, the
rate of field-testing has increased rapidly especially in the
USA where the number of trials has doubled each year since 1987.
In terms of field releases, the European Union lags well behind
North America. More than 70% of field trials were conducted in
the USA and Canada followed in descending order by Europe, Latin
America and Asia, with very few trials conducted in Africa.
These trials represent considerable accumulated evidence in
support of a favourable safety and environmental record for the
new gene technology.
The relevance of environmental data obtained from small field
trials to large-scale sowing on several million acres of land
has been questioned. However, the present situation is reported
in the International Service for the Acquisition of Agri-Biotech
Information (ISAAA) Report issued 13 February 2008,"Biotech
Crops Experience Remarkable Dozen Years of Double-Digit Growth”
from which the following is extracted:
After a dozen years of commercialization, biotech crops are
still gaining ground with another year of double-digit growth
and new countries joining the list of supporters, according to a
report released today by the International Service for the
Acquisition of Agri-biotech Applications (ISAAA). In 2007,
biotech crop area grew 12 percent or 12.3 million hectares to
reach 114.3 million hectares, the second highest area increase
in the past five years.
In addition to planting more biotech hectares, farmers are
quickly adopting varieties with more than one biotech trait.
These “trait hectares” grew at a swift 22 percent, or 26 million
hectares, to reach 143.7 million hectares – more than double the
area increase of 12.3 million hectares. New crops were also
added to the list as China reported 250,000 biotech poplar trees
planted. The insect-resistant trees can contribute to
reforestation efforts.
Further, 2 million more farmers planted biotech crops last year
to total 12 million farmers globally enjoying the advantages
from the improved technology. Notably, 9 out of 10, or 11
million of the benefiting farmers, were resource-poor farmers,
exceeding the 10-million milestone for the first time. In fact,
the number of developing countries (12) planting biotech crops
surpassed the number of industrialized countries (11), and the
growth rate in the developing world was three times that of
industrialized nations (21 percent compared to 6 percent.) “With
increasing food prices globally, the benefits of biotech crops
have never been more important,” said Clive James, chairman and
founder of ISAAA and the report’s author. “Already those farmers
who began adopting biotech crops a few years ago are beginning
to see socio-economic advantages compared to their peers who
haven’t adopted the crops. If we are to achieve the Millennium
Development Goals (MDGs) of cutting hunger and poverty in half
by 2015, biotech crops must play an even bigger role in the next
decade.”
According to the report, biotech crops have delivered
unprecedented benefits that contribute toward the MDGs,
particularly in countries like China, India and South Africa.
The potential in the second decade of biotech crop
commercialization (2006-2015) is enormous.
Studies in India and China show Bt cotton has increased yields
by up to 50 percent and 10 percent, respectively, and reduced
insecticide use in both countries up to 50 percent or more. In
India, growers increased income up to $250 or more per hectare,
increasing farmer income nationally from $840 million to $1.7
billion last year. Chinese farmers saw similar gains with
incomes growing an average of $220 per hectare, or more than
$800 million nationally. Importantly, these studies showed
strong farmer confidence in the crops with 9 out of 10 Indian
farmers replanting biotech cotton year on year, and 100 percent
of Chinese farmers choosing to continue utilizing the
technology.
While these types of economic benefits are well substantiated,
the socio-economic benefits associated with biotech crops are
starting to emerge. A study of 9,300 Bt cotton and non-Bt
cotton-growing households in India indicated that women and
children in Bt cotton households have slightly more access to
social benefits than non-Bt cotton growers. These include slight
increases in pre-natal visits, assistance with at-home births,
higher school enrollment for children and a higher proportion of
children vaccinated.
Rosalie Ellasus, a widowed mother of 3 children, found similar
benefits, choosing farming as a way to support her family. “With
the extra income generated from biotech maize, investing in
farming made sense and allowed me to earn more than the medical
technology field I was trained in,” she said. “The biotech maze
gave me peace of mind and meant less time monitoring for pests.
With stack corn, I also incur savings on cultivation and weeding
costs. With the added income, I have been able to send all my
children to college.”
“It’s these types of benefits that will make crop biotechnology
a vital tool in achieving the U.N. Millennium Development Goals
of cutting hunger and poverty in half and ensuring a more
sustainable agriculture in the future,” James said. “To reach
these goals, a continued broadening and deepening of biotech
crop use is crucial to meeting food, feed, fiber and fuel needs
in the future.”
In 2007, the United States, Argentina, Brazil, Canada, India and
China continued to be the principal adopters of biotech crops
globally. While the United States continues to be the largest
user of the technology, its biotech crop area represents a
declining share of the global area due to a broadening adoption.
“With a dozen years of accumulated knowledge and significant
economic, environmental and socio-economic benefits, biotech
crops are poised for even greater growth in coming years,
particularly in developing countries that have the greatest need
for this technology,” James said. According to the report,
Burkina Faso, Egypt and possibly Vietnam are the next mostly
likely countries to approve biotech crops. Australia is
field-testing drought-tolerant wheat and two states recently
lifted a four-year ban on biotech canola. Finally, countries
like India recognize the importance of using biotechnology to
make the country self-sufficient in food grains, including rice,
wheat and oil seed production with the first biotech food crop,
biotech eggplant, expecting approval in the near-term.
“I predict the number of biotech countries, crops, traits, area
and farmers will all grow substantially in the second decade of
adoption,” James said. “More developing countries are likely to
approve the technology as it’s now possible to design regulatory
systems that are rigorous without being onerous given their
limited resources. The current delay in timely approvals of
biotech crops like golden rice with benefits for millions is a
moral dilemma where the demands of regulatory systems have often
become the end and not the means.”
The report is entirely funded by the Rockefeller Foundation, a
U.S.-based philanthropic organization associated with the Green
Revolution; Ibercaja, one of the largest Spanish banks
headquartered in the maize growing region of Spain; and the
Bussolera-Branca Foundation from Italy, which supports the
open-sharing of knowledge on biotech crops to aid
decision-making by global society.
http://www.isaaa.org/resources/publications/briefs/37/pressrelease/default.html
See also related slides
http://www.isaaa.org/resources/publications/briefs/37/pptslides/Brief37slides.pdf
ISAAA now has an excellent website, updated weekly, with a very
large number of links grouped to cover Global, Africa, Americas,
Asia and Pacific, Europe, Research, Energy Crops for Biofuels
Production and Biofuels Processing. At the time of writing the
current weekly issue is dated 5 June 2008, but there are
previous and future issues can be accessed by changing the date
at the end of the URL (note the US practice mm/dd/yyyy).
http://www.isaaa.org/kc/cropbiotechupdate/online/default.asp?Date=6/05/2008
Past experience with introductions of new species to
environments where they are not naturally present has shown that
potential problems may take several generations to manifest
themselves. Possible cross-pollination from GM crops to non-GM
crops is of
concern to organic farmers, who fear that, if it occurs, their
produce could no longer be said to be "organic", and to those
who wish to have the right to choose non-GM foods.
Three reports of trials in USA, Germany and Spain respectively
have demonstrated effective co-existence.
• Byrne, P. & Fromherz, S. (2003).
"Can GM and Non-GM Crops Coexist? Setting a Precedent in Boulder
County, Colorado, USA."
Journal of Food, Agriculture & Environment, 1, pp 258-261.
http://www.botanischergarten.ch/Coexistence/Byrne-Fromherz-2003.pdf
• Anonymous (2004).
"Insights gained from the 2004 Test Crop Coexistence of
Genetically Modified and Conventional Corn", InnoPlanta, pp 6
Nordharz/Börde.
http://www.botanischergarten.ch/Coexistence/Innoplanta-Coexistence-2004.pdf
• Brookes, G. & Barfood, P. (2004).
"Co-existence of GM and non GM crops: case study of maize grown
in Spain, PG Economics Ltd, pp 13 Dorchester, UK."
http://www.botanischergarten.ch/Coexistence/Brookes-Coexistence-Casestudy-Spain-2004.pdf
In July 2006, Defra carried out a consultation on proposals for
managing the coexistence of GM and non-GM crops in England.
http://www.defra.gov.uk/environment/gm/crops/pdf/gmcoexist-condoc.pdf
IFST responded that it agreed with Defra’s view of the governing
principle of coexistence; to
“balance the interests of all farmers. Farmers have a legitimate
interest in growing their preferred crops (conventional, organic
or GM), and a coexistence regime |
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