RSGM Witness Brief Robert Anderson

Witness Brief

Royal Commission on Genetic Modification Form 2

1. Name of Witness

Robert G. Anderson

My name is Robert Anderson. I hold an honours degree in Chemistry and Physics from the University of Birmingham, (Aston, England.) I also hold a Diploma in Education from the

University of Southampton, England. Prior to my degree I worked at the University of Birmingham, England, as a research technician in the Department of Biochemistry, under Dr John Teal from the University of Cambridge, studying fluorescence of proteins in neutral solution. I also worked under Professor B Perry from the University of Cambridge, England, investigating the actin/myosin relationship in muscle protein. After emigrating to New Zealand I taught Chemistry, Physics, and Laboratory Technology and Nuclear Medicine, at tertiary level, in the Waikato. I am now retired and have undertaken, with others in PSRG, the task of travelling to inform the public on various aspects of genetic engineering. I have authored a booklet on GE, contributed to the recent volume, Designer Genes, for the New Zealand public, and have published articles on genetic engineering in both magazines and the news media.

2. Name of “Interested Person” (on behalf of whom the witness will appear)

Physicians and Scientists for Responsible Genetics New Zealand

3. Witness Brief Executive Summary

My brief of evidence concerns the issues of crops and food as addressed in our submission and release of these GE crops and genetically engineered organisms (GEO’s) into the New Zealand environment. PSRG submits that changes are required to the HSNO Act as it applies to genetically engineered organisms (GEOs) imported into or developed and held in laboratory-based containment in New Zealand. (See Dr P Wills Witness Brief.)

Our recommendations are:

importation of a GEO into containment be treated the same as development in containment
that oversight and approval of all GE research be delegated to a non-industrial body
that assessments be both organism- and project-based
that a committee of experts be selected to advise on higher risk applications
that no GE experiment be exempt from requiring approval, and
that laboratories using GEOs be upgraded to a ‘safe’ containment category.

Other than where I am quoting from a source of reference, the term genetic engineering (GE) will be used throughout this brief rather than the PR generated terminology of genetic modification or “GM.”

Section B (j) (i) Human health and safety issues. prefixed H

My Witness Brief will be confined to CROP and FOOD issues. My views on other aspects of biotechnology will be evidenced from my personal submission to the Commission.

It has been truly said that: “A lie would have no sense unless the truth were felt as dangerous.” And there have been fewer issues over which that statement has became a truism than in biotechnology as developed over the last decade.

Release of GE organisms and/or food

H1. In regard to the release of genetically engineered (GE) crops and foods posing potential risks to human and other consumers (including flora and fauna) and to the ecology of New Zealand I feel it both irrational and immoral to allow the release of any GEO’s into the environment. GE organisms affect biodiversity including soil microbes and beneficial insects, as well as weed populations. The extent to which these changes occur beyond the agricultural field or managed forest is completely unknown. I propose considering the following scientifically documented findings supported, where possible, by the work of highly respected international scientists specialising in this, and allied fields:

I recommend the Commissioners reference Professor Samuel Epstein’s book, “The Politics of

Cancer Revisited”, Appendix XII, and “Public Health Hazards of GE Milk and Food”. Also the

Open Letter from World Scientists to All Governments Concerning GMO’s .

H2. Genetically engineered organisms can and have produced unexpected toxins and allergens. (3)(4)(5) As a result of genetic engineering products and organisms that were not previously present in food are now used in food production. Consequently, humankind are confronted with an increasing number of completely new food components. As well as the notorious Tryptophan case

(106 )- skilfully blamed on inadequate filtering - the common dipeptide sweetener, Aspartame,

(originally a product of G D Searle, now Monsanto) and genetically engineered has been available in New Zealand for some time. This questionable product is recommended to NZ diabetic patients even though there has been ample evidence showing its serious damage to health for some years. [See letter to Senator Metzenbaum from Dr Adrian Gross Senior Science Advisor.] A large percentage of NZ diabetic patients use Aspartame, It is also an ingredient in a plethora of products, including children’s vitamin supplements. Its proven safe and available herbal equivalent, Stevita, is never recommended. Several letters from myself to the head of the New Zealand Health Service, Dr Gillian Durham, were to no avail on this matter. Moreover, she was not aware that the product was genetically engineered. [See letter attached from Professor John Fagan.] Nutrasweet (Aspartame) has been scientifically linked to brain tumours, (2) brain cell damage and neurological conditions such as Alzheimer’s and Parkinson’s disease. According to Dr Russell Blaylock, a practising neurosurgeon, we are witnessing enormous damage to the brain and nervous system due to the ever-increasing amount of Aspartame and other excitotoxic substances added to our foods. Dr Blaylock cited well over five hundred scientific studies, showing the dangers of this genetically engineered compound and others. The tests carried out by Searle for Aspartame’s approval were seriously flawed.(6)(7) [see attached documentation]

H3. Growth in food allergies

The increase of variety in the food sector is considered one of the main reasons for the growth of food allergies. (38)

A Swiss study reviewing the allergenic potential of transgenic cultivars came to the conclusion that these increase the probability of unwanted allergenic reactions. While GE uses all organisms as gene-resources, traditional breeding is restricted to cross-hybridising within the same species posing similar allergenic potential. The direct alteration of the expression levels of a species’ own genes is generally only possible by the use of genetic engineering. (38) See also ingesting Bt goods

H6. The ignorance of allergenicity in transgenic foods is clearly vast.

In April 1994, the US Environmental Protection Agency [EPA], the Food and Drug Administration [FDA] and US Department of Agriculture [USDA] hosted a "Conference on Scientific Issues Related to Potential Allergenicity in Transgenic Food Crops." The conference revealed how little is actually known about the topic. Indeed, two conclusions noted by the scientists at the meeting were that there are:

(i) no direct methods to assess potential allergenicity of proteins from sources that are not known

to produce food allergy, and

(ii) although some assurance can be provided to minimise the likelihood that a new protein will

cause an allergic reaction by evaluating its similarity with characteristics of known food allergens - i.e. whether the new protein has a similar protein sequence, is prevalent in food, is resistant to

enzymatic and acid degradation, is heat stable, and is of the appropriate molecular size - no single

factor is predictive. Their lack of regulatory control was also exemplified by the recent StarLink corn contamination crisis. [see Scientists Seek Best Way to Screen Crops and Food ] The UK Ministry of Agriculture and Fisheries, it would seem, also faces similar frustrating difficulties. [see “Scientists Slam GE Research”]

H4. There is evidence that foreign DNA can enter the body via the gastrointestinal tract and

cross the placenta. (1)

In 1991-1992, when FDA developed its policy on GE plants, the conventional wisdom in the

scientific community was that DNA was a very fragile molecule that would be readily broken down and would not survive digestion in the gut. We now know that this assumption is not be valid (29)(32) and, for instance, Monsanto’s claim that “genes used in Soy crops are ‘inactivated’ by the heat process during animal feed manufacture” has proven to be false. [ see “Key DNA fragments can enter the human food chain”] We now know that DNA fragments can enter the human food chain through animal feed stuffs. (63) This knowledge, combined with Dr Kaatz’s findings that transgenic DNA is taken up by the bacteria in the guts of larval bees (29), should give grave cause for concern. In a meek attempt to allay public fears the industry also often asserts that “allergies occur to the protein produced, not the DNA” This attempts to show that DNA fragments are not immunogenic. This is definitely not the case. (107)

H5. It is now well documented that gene transfer occurs between transgenic plants, bacteria

and fungi (25), the ecological consequences of which could be catastrophic. (104)(105)

Although horizontal gene transfer is known to occur naturally (8) there is no valid reason to increase the process by allowing pollution from artificial gene constructs, vectors and free DNA fragments to increase the risk. (80) The Marina gene, isolated from the fruit fly, but also common to many insects and arthropods (74), is known to have jumped to primates, including humans, where it now causes a neurological wasting disease, Charcot-Marie-Tooth syndrome. (83) Bacteria taken from their natural environment, transformed with a plasmid and then released again as GEOs, have a very high chance of re-establishing themselves in their original ecosystem. (39) Biotechnologists have constantly been warned of ‘hotspots’ on the CaMV - the most commonly used vector in transgenic cultivars - and the hazards involved in using it. [See “Viral danger from GM crops confirmed” and “The CaMV promoter thinks it is still a virus” ]

In their work, using “crippled” viruses as vectors, Greene and Allison clearly reveal the inherent

dangers of using such vectors. A review of 125 plant strains produced through such laboratory

manipulation showed that 3 per cent of the time the crippled virus that was used to carry such genes into plant cells could swap genes with other viruses in the plant, producing active, pathogenic – new - viral species. (101)

H6. Since the documented evidence that horizontal gene transfer between species is a natural

phenomenon (8-14), the precautionary principle must be applied in creating transgenic

organisms that could transfer novel genes and viral vectors to other species. (15-17)

The ecological, evolutionary and public health consequences of such transfers will only be known after they have occurred. Horizontal gene transfer is even likely to take place in the digestive systems of protozoa, nematodes, insect larvae and soil micro-organisms.(10) Similarly, the spread of antibiotic resistance (ARM) genes throughout bacterial communities shows that gene transfer is likely to happen not only in artificial settings, but also under natural conditions. (35)(36)(37) [See Appendix, Professor Cummins, GE Safety Considerations for Humans and for the Environment.]

H7 The genetic engineering of fish, insects and molluscs also began to expand rapidly with the

introduction of pantropic retroviral vectors; vectors based on the mouse leukaemia irus.(Moloney

virus.) [See also section B(j)(ii), environmental concerns.]

Pantropic retroviral vectors, manufactured from the Moloney virus, could infect human cells. Surface antigens are added to the ‘disarmed’ virus to specifically allow the virus to enter cells of crustaceans or other invertebrates. The use of the Moloney virus and products of pantropic retrovirus gene modifications should be restricted to a highly secure virus laboratory [communication from Professor J Cummins](65)

H8. Genes, like viruses, can infect the body (18)(19), which should warn of the potential risks of transgenic organisms serving as a reservoir for new diseases and as a medium for the evolution of new pathogens because of their altered physiology and biochemistry.

Viral "promoters" and "enhancers" that boost expression of transgenes could result, for instance, in the production of high levels of Bacillus thuringiensis (Bt) toxin and other chemicals in transgenic crops. I certainly do not agree with Dr Marian Healy’s glib statement that “Bt has a long history of safe use..” when applied to engineering it into the cells of a plant. [ p12 “GM foods and the consumer” ANZFA booklet for the consumer] Whilst a consumer can wash off a vegetable sprayed with Bt they would certainly not remove it from a transgenic variety. [see also Dr John Clearwater’s Witness Brief under Preserving Bt for Organics.]

H9. A further concern of ‘built in’ pesticides is their effect on soils. The danger of exudates from

transgenic crops poisoning the soil is of considerable concern. (75)(76)(77)(78)(81) [See Dr Neil

Macgregor’s Witness Brief]

The exudates from crops expressing the Bt toxin are a particular worry here. The potential for the accumulative effects of GE-Bt in future years should be carefully considered It has been clearly demonstrated (108 ) that Bt crops exude active Bt endotoxin from their roots during growth, which means that active endotoxin is exerting insecticidal effects throughout the growing season - not just after the harvest of these crops.

H10. In its naturally occurring form the expression of the full-length coding sequence for [Bt] toxin was too low to achieve pest resistance in plants (other than tobacco [against the tobacco hornworm] and tomato plants).

Protection against less sensitive, but agronomically-important insect pests was therefore not achieved. Researchers then altered part of the Bt toxin coding sequence so that it was more efficiently expressed in plants. This was done by using a synthetic toxin gene for amino acids

1-453 (coding for the same amino acids as the natural Bt toxin gene, but using codons preferred by plants) and fusing this with the (natural) gene fragment encoding for amino acids 454-615. The rest of the bacterial gene (amino acids 616-1178) was not used.

Expression of this gene in cotton plants displayed a Bt toxin level increased by 100 times, such that the Bt toxin then constituted 0.02% of the protein in the plant! (86) Similarly, the Bt toxin in

engineered corn is up to 100 times more powerful than the natural toxin and supposedly delays the development of resistance in corn borers. However, such high doses are proving toxic to non-target species, as well as pests. They do kill and damage benign and useful insects (such as ladybugs, butterflies and other insects, and about which we have little information (96)(97) including human beings who ingest the toxin when they eat Bt corn. (98) As professor Bernstein of the University of Cincinnati College of Medicine said, this means that people must avoid ingesting even "relatively safe biopesticides like Bt”. (A major reason for refusing the current applications A385 and A386 of Bt-176 and Bt-11 corn by ANZFA.)

H11. I refute Dr Connor’s statement that, “Populations produced by GM .....is more precise.”

[See Brief Dr A Connor.]

Witness the explanation given in the ANZFA booklet for the public, which states categorically, “Newly introduced genetic material is normally inserted into a RANDOM LOCATION in the DNA of the host organism.” Thus unexpected side effects of gene insertion (pleiotropic effects) are not surprising have been well documented, and are increasing. (See Table 1: “Historical Trends in GMO Citations” attached.) Genetic alterations in crops like soybeans, to make them resistant to herbicides, may result in unpredictable, abnormal genetic recombination’s and change the biochemistry and nutritive values. [see “More GMO Than Monsanto Meant”] For example, higher levels of phyto-estrogens are produced in beans grown in the presence of the herbicide glyphosate which may be of particular risk to children. (20) In another example, 36 cows were fed herbicide-resistant soybeans (produced by Monsanto) and others fed non-GE soybeans. (41) Data from the trials showed that the cows that were fed the normal soybeans produced 1.19 kg of milk fat a day, whereas those fed with GE soybeans gave an increase in milk fat of over 8%. (42) This clearly showed that a genetic change, only intended to make a soybean resistant to a herbicide, had side effects not yet explained. We should remember the admission of Monsanto’s CEO (27 October 1998): “We're in a crisis position where we know the weaknesses of the genetic concept, but we don't know how to incorporate it into a more complete understanding. Monsanto knows this. DuPont knows this. Novartis knows this. They all know what I know. But they don't want to look at it because it's too complicated and it's going to cost too much to figure it out." (64) Many of the products in any case have been failures ie Flavr Savr tomato etc. This is equally as applicable today. Even the British Medical Association warned that GM foods could have a cumulative, invisible, irreversible effect on the food chain. (66) The Royal New Zealand College of GP’s has likewise given salutary warnings to our Government which appear to have been ignored. Professor Lacey’s warnings to the UK Government, similarly ignored, gave us the crisis of BSE.

H12. Virtually all commercial transgenic crops combine virus genes, either as promoters or to control pest infections. These virus genes can recombine with other viruses and may result in new diseases and more invasive pathogens. (21-25) With the inclusion of antibiotic-resistance markers [ARM], transgenic crops could therefore increase the probability of new viral and bacterial pathogens, and the spread of antibiotic and drug resistance genes. The recent statement from Novartis, “that they are anxious to get rid of ARM genes”, is a tacit admission that these markers may not be as safe as their proponents claim. DNA released from living and dead cells can persist in the environment and be transferred to other organisms.

H13. An organism may be dead, but the "naked" DNA released from its decaying cells may remain biologically active for potentially many years, especially in certain soils and marine sediments. [See Dr Neil Macgregor’s Witness Brief.] (26,27)

Naked DNA (nucleic acids) ingested by rats, mice and other rodents can be transferred to offspring and be voided and spread in animals' faeces. (103) For example, the Hantavirus - which first came to attention during the Korean War, affecting 2 500 people and killing 121 (30) - is normally carried on field mice and spread from faecal contamination. This horrific virus has even been considered for use as a biological weapon by American biotechnologists at Fort Derrick. [See Dr Peter Wills Testimony.] Such inane human activity beggars belief and certainly does nothing to endure public to the scientific point of view.

Section B (h) (ii) Environmental concerns. prefixed E

Notwithstanding the fact that any ecological pollution and/or damage is not insurable,

[See, “No cover for GM Pollution, farmers told”], there are a number of very serious hazards to bear in mind when considering the environmental damage due to transgenic crops and organisms.

I enumerate several of these as follows:

E1.Transgenic products are often unstable - even after extensive field trials have selected out the most obvious problems. For this reason, I refute Dr Daniel Cohen’s statement that: “Stability

levels of the selected plants are then similar to plants produced by traditional breeding.”

(Witness Brief for Mt Albert Research centre.)

E2. For instance, in Missouri, in the first year of approval, thousands of acres of glyphosate tolerant cotton malfunctioned. In some cases the plants dropped their cotton bolls, in others the tolerance genes were not properly expressed so that the GE plants were killed by the herbicide they were supposed to be resistant to. (34) Monsanto maintained that the malfunctioning was due to ‘extreme climatic conditions’. (Farmers sued Monsanto who ended up paying millions of dollars in out-of court settlements tacitly accepting liability.) In Saskatchewan thousands of acres of “Innovator canola” resistant to Liberty herbicide, did not express the resistance and germination was very patchy. Again farmers had to be compensated. The seed was developed by AgrEvo. (90) The failure of some Indian crops cost the farmers their lives. They committed suicide unable to bear the debt incurred without the “promised” returns.. [See, GM Rape Changes Character – Gene Silencing.]

E3. This instability of many transgenic crops is a major concern. There is, as far as I am aware, no data documenting the stability of any transgenic line in gene expression, or structure and location of the insert in the genome. Such data must include the level of gene expression, as well as a genetic map and DNA base sequence of the insert and its site of insertion in the host genome in each successive generation. Such information is rarely provided by industry and is often not requested by regulatory authorities. (26) I refute Dr Connor’s statement that, “by the time they have reached large scale trials they do not behave any differently from ...traditional plant breeding.” An illustrative example is given in [E2] above, where 20 000 acres of Monsanto’s Bollgard cotton failed in the first year of approval. Such continued pleiotropisms, resulting in crop failures, simply confirm the imprecision of the technology. I also quote from the official explanation given in the ANZFA information booklet [p18]: “Most of the genome is made up of repetitive “junk” DNA sequences - that is, DNA sequences that do not correspond to genes and which do not appear to have any specific function” (sic). They continue in this vein with: “Newly introduced genetic material is therefore most likely to be inserted into the “junk” DNA. In most cases, therefore, the insertion of new genetic material is unlikely to have any measurable impact on other genes... etc.”

I leave the Commission to judge for themselves whether or not this even sounds like a precise science.

E4. The ecological damage from superweeds is also a serious and growing problem.

Dr Wolfgang Faust of Aventis in Frankfurt reported that resistance genes crossed into beets in the

greenhouses of the German seed company. As Brian Johnson of the UK government conservation

agency said: “If they can’t prevent it there, (in the greenhouse) there is little chance they will avoid it in the field.” With continued plantings this effect is developing at a rapid rate. (87)(88)

[see “Herbicide Resistance is Out of Control” AND “Costs of Resistance”]

Professor Chris Pollock, who chairs the UK committee overseeing farm-scale trials, retorted in The (UK) Independent that there was, "no evidence that DNA from GM crops persisted in the soil." His comment was printed under the sub-heading, ‘The Truth’. What Professor Pollock said was very far from the truth. In research published, for example, in the journal FEMS Microbiology Ecology (1999, Vol.28, No.3, pp.261-272), under the title, “Monitoring field releases of genetically modified sugar beets for persistence of transgenic plant DNA and horizontal gene transfer”, Gebhard and Smalla reported the persistence of transgenic (GE) DNA in soil and in bacteria under field conditions, in one instance even after two years.

E5. Consideration of the “fate” of these organisms and their products.

We must consider not only the "fate" of transgenic organisms, but also the genes and viruses or parts thereof that have been inserted into them. Such "naked DNA" in the form of recombinant and modified nucleic acids has been found capable of surviving and remaining functional longer after an organism’s death than was assumed previously. (6)(27). Donegan (111 ) studied the post-harvest effects of proteinase inhibitor I - an insecticidal protein - in buried GE tobacco residues. Compared to unmodified (parent plant) tobacco residues, transgenic residues altered the species composition of the soil biota responsible for organic matter decomposition and nutrient cycling. For a review of GE effects on soil biota, see Donegan and Seidler (112).

E6. In her recent report to the Biosafety Protocol meeting in Montreal (January 2000), Dr Mae-Wan Ho pointed out that: “An increasing variety of naked/free nucleic acids are now being made for use in research, industrial productions and medical applications, all of which are being released into the environment. They range from oligonucleotides to artificial constructs thousands and millions of base pairs in length, often containing heterogeneous arrays of genes from pathogenic bacteria, viruses and other genetic parasites belonging to every kingdom of living organisms. As most of them have never previously existed, or if they have, not in such large amounts, they are by definition, xenobiotics - substances foreign to nature - with the potential to cause harm.”

E7. GE bacteria also pose unique dangers to the environment.

An example is the well known case of Klebsiella. A typical root-zone-inhabiting bacterium,

Klebsiella planticola, was engineered with the root-zone novel ability to produce ethanol, and the

engineered bacterium was added to enclosed soil chambers in which a wheat plant was growing. In one soil type all the plants with the genetically engineered micro-organism (GEM) treatment died, while those in the parent and no-addition treatment remained healthy. Also, in all cases,

mycorrhizal fungi in the root system were reduced by more than half which ruined nutrient uptake and plant growth. This result was unpredicted. Reduction in this vital fungus is known to result in plants being less competitive with weeds and/or being more susceptible to disease. In low organic matter sandy soil the plant died from ethanol produced by the GEM in the root system, while in high organic-matter sandy or clay soil changes in nematode density and species composition resulted in significantly decreased plant growth. The lead researcher, Dr Elaine Ingham, concluded that these results imply that there can be significant and very serious effects resulting from the addition of a GEM to soil. (43)(44)(82) The tests disproved earlier suggestions that no significant ecological effects have been seen when GEMs are added to test systems.

Genetically engineered to break down 2,4-D, Pseudomonas putida, for instance also killed essential soil fungi. (100) Soil fungi is of cardinal importance for both soil fertility and plant protection.

Dr Ingham emphasised the following:

(a) Up to 1995 only 14 genetically engineered organisms (44) had actually been tested for

ecological effects. This is too small a number from which to broadly apply any principle or to state that other engineered organisms (with extremely different genetic modifications) will not have impacts.

(b) The test systems to determine whether addition of these engineered organisms results in

ecologically significant effects have often consisted of sterile soil, and/or soils with no plants or

other organisms present that could be affected or impacted. (44)

often did not reproduce during the course of the test, and did not carry out their engineered

function. The report stressed that the effects on the whole ecosystem must be understood, not just

isolated portions, because biotechnology products will have a range of impacts much greater than

just the engineered organism. It is critical that effects on the whole ecosystem are assessed, before

any release is made. If other organisms in the food-web are affected to the point that nutrient

recycling, plant growth or important plant growth processes are altered then the risk is significant

and clear. (44) [See Dr Peter Will’s Testimony.]

E8. Dangers to the bee keeping industry.

New Zealand Beekeepers have expressed great concern as to the effects on the industry of growing GE crops. Having spoken on this at the National Beekeepers’ Annual Seminar this year, I can confidently assure the Commission that New Zealand beekeepers are very concerned.

Canada has virtually lost its export market to Europe because its honey was contaminated by GE

pollen. Another worrying issue is that any research by the biotech industry concerning the effects of GE pollen on these insects has been kept secret [ personal communication]. Laboratory studies

carried out by the French government research institute, INRA, indicated that pollen from some GM crops shortens the lifespan of adult bees. It also causes learning dysfunctions that result in the disorientation of foraging bees. Disoriented bees may become lost or unable to locate nectar

sources. (84)(85) Furthermore, the effects of Bt toxin -normally not encountered by honey bees – is now present in many Bt engineered plants. I maintain that the glib assumption that Bt has little or no effect on bees is an invalid one. (93)(94)

E9. Genetically engineered trees.

The heavy reliance on Bt in transgenic crops and especially trees poses many far reaching ecological problems. For instance, decomposing leaves from Bt type endotoxins - particularly in a forest Environment - will create very noxious soil conditions, undermining the entire soil food-web and natural composting systems of the soil. The effect of this on rizospheremicroflora, and the nitrogenfixaters, pathogenics and antagonists, is not known. (79)(78) [See Dr John Clearwater Witness Brief under, “Bt a Critical tool in pine forests”] Viral "promoters" and "enhancers" that boost expression of transgenes resulting in the production of high levels of Bacillus thuringiensis (Bt) toxin will produce exudates that will adversely effect many soil microflora. This poisoning of the soil by transgenic crops is of major concern. (75)(76)(77)(81) To knowingly alter the soil in this way is gross dereliction of our legacy to the generations who will follow us. [See “GM crop toxin leaking into the soil” also Witness Brief of Dr Neil Macgregor ]

E10. The concept of “wiping out” insect pests?

Ironically many biologists are becoming concerned that the frequently expressed aim of

biotechnology - of “wiping out pests” by Bt and such “GE innovations” - is deeply immoral as our knowledge of micro-organisms and how they interact in ecosystems is virtually nil. (See table

below.) We risk disastrous consequences by the indiscriminate use of pesticidal chemicals.

In 1990, Cary Fowler and Pat Moony reported in Shattering Food, Politics, and the loss of Genetic diversity “that over 400 pest species had developed resistance to chemicals that once destroyed them.” Six years later, researcher Gary Gardner of Worldwatch Institute reported that the number had risen to 900 species - with 17 crop-eating insects showing at least some resistance to all major classes of pesticides.(95) The use of pesticides has offered no lasting solution - just as GE resistant crops will not. Insects will develop resistance to these crops in just the same way as they have to chemicals, which may turn into an even greater human burden. There are far safer and sustainable methods of pest management. [see Dr J.Clearwater’s Witness Brief]

Some scientists even express the view that: “The millions of viruses, bacteria and fungi that kill or blight plants world-wide should be conserved with the same urgency as other species.” (92)

Total estimated Known number number of species of species

Bacteria..................................3.0 million..............................................4 000 (0.1%)

Fungi......................................1.5 million............................................70 000 (5%)

Viruses...................................0.5 million..............................................5 000 (5%)

E12. Industrial studies have emphasised the short travel distance of most corn pollen, and inferred that impact - if any - on Monarchs or other lepidopteran species will therefore be limited. If we consider, however, the enormous volumes and travel distances of tree pollen, including those of species modified to express "low lignin" in pulp plantation trees or Bt for pest control this poses an entirely different scenario. Approximately 24 trees species, including European and quaking aspen, black and Norway spruce, Monterey pine, and Easter cottonwood, have already been genetically modified and exposed to the environment through US and Canadian field trials (115). The effect of the "low lignin" GE trait on the wind and pest resistance of wild species, or of GE plant pesticides on non-target forest insects is, as yet, completely unknown.

E13. Environmental aspects of genetically engineering marine organisms is a further worry.

Although not a crop issue, the recent widespread genetic engineering of fish and marine organisms as food products is yet another highly dangerous scheme from both a health and environmental perspective. The genetic engineering of fish is a potential hazard to both natural fish species and river ecology. About 50 laboratories around the world, including New Zealand, have been conducting genetic engineering of fish species. (48) Escapes from fish farms are already a serious problem. In some parts of Norway fish that have escaped from farms have bred and now outnumber wild ones by five to one. (49) Genetically engineered Pacific salmon are now being bred to live and breed the in the ocean rather than follow their traditional annual migrations to fresh water. Should this trait pass into wild salmon populations, they would no longer need to return their native streams to spawn. Severe ecological disruptions would occur to river life and to other species such as bears which depend on annual salmon migrations. (50) As already mentioned [H(j)(i)] the use of pantropic retroviral vectors based on the Moloney virus, used in transgenic research such as the fore-mentioned, should be restricted to a highly secure virus

laboratory. (65)

Section B (h) Global developments. Prefixed G

World Trends in GE Crops and Food

G1. The following short resume of the world situation is pertinent to our recommendation that

New Zealand does not follow an industry with:

(i) growing consumer resistance

(ii) risks to health and environment covered above and

(iii) questionable economic benefits to the farmer.

Looking at the major global trends for GE and those likely to effect NZ the following picture seems to be emerging:

G2. Farming of GE crops is starting to decline - this includes even the USA

On 30 June 2000 US Department of Agriculture (USDA) estimates showed a sharp decline in

GE corn plantings of 39% (USDA Website).

Moratoriums and/or bans on GE crops are in place in Europe, Brazil and elsewhere. (52)
The American Corn Growers Association (ACGA) are on record as stating it has cost US corn

growers up to 700 million pounds sterling in lost export markets as European and other import

markets refuse GE corn.

Corn Export figures reflect this:

For the marketing year 1997- 98 .......................... exports were 2 000 000 tons

For the twelve months to August 2000 .......... they had dropped to 17 900 tons

(AMCG Association and the USDA website.)

Similarly, Roundup Ready soy exports have dropped - from 11million tons in 1998 to 6 million

tons in 1999. The smaller drop here is accredited to soy being mostly exported as animal feed.

(AMCG Association and the USDA website.)

Biotech corporations promised farmers high yields and reduced agri-chemical use with GE crops.

The truth, however, is proving to be very different. [See Witness Brief Dr Ruth Lawson.]

(a) Researchers at several Universities in the US and UK have shown GE crop yields are down as

much as 15% on conventional crops. (45)

(b) Researchers have likewise shown - and farmers have acknowledged - that more herbicide has

been required to manage genetically engineered herbicide-resistant crops, not less. (46)(54)

* In the USA horizontal gene transfer of herbicide-resistant traits is spreading, causing management problems and new expenses. Canola varieties resistant to Roundup, Liberty,

Pursuit and Odyessy have been sold in Canada, with reports of cross-pollination and resistant volunteers increasing dramatically in the last two years. The Canadian Government does not deny that there is an emerging problem with the spread of herbicide resistance. (55) Common ragweed resistant to ALS inhibitors (ALS-resistant) has been identified in 58 fields in Ohio and Indiana and has been reported in Michigan. (56) Canola resistant to three (Roundup, Libery and Pursuit) herbicide-tolerant canola systems has been found in Alberta, Canada and confirmed by chemical and DNA tests. (57)

* Insects are rapidly becoming resistant to GE plant pesticides and as they become more resistant, built-in pesticide traits such as Bt corn [resistant to Ostrinia nubilalis] are failing and the crops therefore require more pesticide, not less. A report in Science shows that dominant mutants conferring resistance to Bt toxin can be recovered from Corn Borers exposed to the toxin. Such mutants would spread like wildfire through corn fields with refuge plots because over half the offspring of mating between mutant and wild type insects would be resistant to Bt toxin. The refuge would provide a rich breeding ground for the spread of the dominant mutants. (60) [See, “Back to Back RR Threatens Boll Weevil Control”.and the 77-page report to Greenpeace International by Swiss research team : EcoStrat of Zurich that addresses Bt on non-target organisms.]

* I do not agree with Dr Markwick (HortResearch Brief) that, “transgenic pest-resistant crops should be part of an Integrated Pest Management (IPM) programme.” The risks from these crops to consumers and non target species grossly outweighs the benefits of transgenic pest resistant crops. In a tri-trophic study, Hilbeck (109) demonstrated adverse effects of Bt endotoxin (fed as GE corn) on non-lepidopteran prey and predator species. This study challenges the claim that Bt crops retain the desirable selectivity. Considering the effect over a wide range of organisms and conditions, such findings will show a loss of selectivity for transgenic vs natural Bt applications. Further evidence came from work in Scotland, Birch (114) demonstrated tri-trophic effects of pesticidal GM plants on beneficial insects. They reported that ladybugs (Adalia bipunctata) which fed on peach potato aphids ((Myzus persicae) which had in turn fed on GM potatoes, produced up to 30% fewer progeny and lived only half as long as ladybugs feeding on aphids which had fed on conventional potatoes.

As insect populations continue to develop resistance (67)(68) more finance must be given to further develop GE cultivars to combat the problem. (69)(70)(71) A treadmill not unlike that offered by the ‘chemical revolution’ will be the result. As Dr Markwick (para 16) herself has said, “At the present time there is no single proven resistance management strategy that may be recommended as a general approach to avoid resistance to transgenic Bt plants.” As organic and pheromone technologies offer no consumer risk and have proved successful (72) it would seem eminently sensible to finance further research into these. As Dr Max Suckling said in his brief, “There are many non-GM solutions available against many pets and diseases”. (73) (See Dr John Clearwater’s Witness Brief.) In Texas, a number of farmers had problems with Bt cotton in the first year of planting. In up to 50% of the acreage the Bt cotton failed to provide complete control (a so-called "high dose") to the cotton boll worm (Helicoverpa zea). When P. chrysocephala were fed on GE oilseed rape expressing a cysteine proteinase inhibitor the larvae, far from dying, grew fatter (47).

* New Zealand’s organic industry is growing at an unprecedented rate. OPEG reported a significant increase in organic exports to June 2000. These reached $60 million for the year 1999-2000, an increase of 77% on the previous year’s figure. [See Witness Brief Dr John Clearwater; AND see Appendix Research at The Rodale Institute Challenges Toughest Critics of Organic.]

* A recent UMR survey (run March to May and commissioned by AFFCO NZ) showed over

70% of New Zealand farmers believe the future of agriculture lies in organic production.

[See attached Research at The Rodale Institute Challenges Toughest Critics of Organic.]

* The introduction of Bt crops would destroy the huge and unique potential of NZ to supply the world with organic products. [See Dr J.Clearwater’s Witness Brief under, “Preserving this valuable organic spray; also Dr Hugh Campbell’s latest report.]

G3. Other Markets - organic and guaranteed GE-free.

Australia’s biggest organic wholesaler, Eco Farms, in the year to September 2000, found its turnover soared by 44%. The Company’s Manager, Philip Rougon, has said: “We’ve just cracked the $10 million mark.” This represents just part of Australia’s $250 million organic food industry, estimated to have a growth of 25% per year. (89)

In a recent briefing paper the USDA commented: “the organic food industry in Australia is riding the crest of a wave.” It encouraged US organic producers to export to Australia as “demand ... far exceeds supply”.
In the Asia-Pacific region the GE controversy has intensified to the point where, on July 8th,

China announced that all GE seed must be labelled. These developments have come about because of increasing pressure from the Asia-Pacific region, China’s largest food export market.

On July 14, in Tokyo, a massive consumer co-operative conference took place in which leaders

from Japan, Korea, the Philippines, Malaysia and Australia reaffirmed their commitment to

work internationally to drive GE foods off the market.

On 8 August a Federal Court in Brazil barred the growing of GE soybeans in that country. (52)
Europe has a ‘de facto’ moratorium on many GE crops and imports. (58)
In South Africa a Coalition has called on the government to implement a five year freeze on the import and export of GE crops. Numerous press reports state African opposition to both

biopiracy and Terminator Technology is also growing. Dr Egziabher from Ethiopia, speaking after the US veto of a Biosafety Protocol on GEO’s said African countries were “absolutely united” in resisting US plans to “decide what we eat.” (102)

The introduction of GE crop growing into India last year created so much debt and despair for

rural farmers that thousands committed suicide. [see E2]

Failure of a monocrop - genetically engineered or not - would mean disaster for both the farmer and the consumer. Researchers have long argued that planting a diversity of crops should lead to benefits like greater productivity and the suppression of disease, compared with single variety plantings known as mono-cultures.
In China an international team of scientists and farmers in China's Yunnan Province planted a mixture of different rice varieties. This diversification enabled them to radically restrict the incidence of rice blast, the most important disease of this most important staple in the world.

Within just two years, farmers were able to abandon the chemical fungicides previously widely used to fight the disease. Researchers say the study's implications extend to prairies, rainforests and other natural ecosystems. (51)

In a similar experiment in Kenya recent studies have shown that sustainable multi-crop farms

helped reduce pest problems and sustained good yields. (53)

Almost all major supermarket chains in the UK and Europe have now announced they will make their own-brand products GE-free. Industry estimates suggest a third of Europe’s farm land may be organic by the end of the decade. (89)
The Canadian honey industry has lost virtually all of its European export markets because of GE contamination of exported honey. Traces of GE pollen were found in two honey samples out of nine that came from an area that grew test trials of GE crops in 1999. (59)
While claiming they are not worried about consumer rejection, the USA food giants are looking closely at segregating or removing GE components from their products. Despite attempts by the biotech industry and the USDA to put a favourable spin on this year’s decline in GE crop plantings, the facts speak for themselves.
Several years ago Monsanto confidently predicted RR Soy would constitute 80% of the US crop by the year 2000. In fact, it now represents only 54%. The same can be said for corn plantings which have fallen a dramatic 40%.[See also Dr Ho’s submission B(h)(1.1) summary.]

Conclusions:

C.1. New Zealand is in a unique position. We should learn from the mistakes of other countries.

Quite apart from the irreparable damage to our growing organic industry, [see GE Risks to NZ

Exports] we should take serious heed that contamination of the "life stream" by naked recombinant

DNA, by transgenic viral vectors, and antibiotic resistant genes, is already taking place in many other countries. We should not let this happen in New Zealand. A large volume of the industry’s claims are based on mis-representation and/or deceit. [See Appendix, “Ministry’s internal paper shows poor crop results were replaced by a forgery; also Witness Brief of Jean Anderson.]

Professor Klaus Ammann’s claim that “critics of GE are pushing for a non-scientific approach to decision making” is absurd in the light of biotech’s unwillingness to have its work peer reviewed.

I am unaware of any scientists expressing an opposing point of view ever being allowed access to any of the official bodies such as IBAC or the Ministry of Commerce. [See Dr Peter Wills Testimony.] There is also a myopic economic promotion of biotechnology by government at the expense of more sustainable and far safer organic alternatives. [See “GE Funding Bias”]

C.2. Since a recall is impossible, I recommend that no release of any genetically engineered living entities and/or crop products be released into the New Zealand ecology. [See “Firms Move to Avoid Contamination] Many of the experiments envisaged by biotechnologists are often poorly researched and the hazards not properly taken into account. [ see Dr John Clearwater A “Magic Bullet”, but who is it aimed at? ]

In support of this brief I would submit the following documentation from four world experts in:

(i) Food safety, Professor Richard Lacey [See FDA Court Declaration.]

(ii) Ecology, Professor Philip Regal [See FDA Court Declaration.]

(iii) Genetics, Professor John Fagan [See FDA Court Declaration.] and

(iv) GE Safety Considerations, Professor Joseph Cummins, Emeritus Professor of Genetics.

I support continued research by New Zealand scientists into molecular biology and cell systems which underlie a more extensive knowledge of the “complex language” used by genes in communicating within the genome. This must be completed only under the strictest containment criteria.

C.3. As far as GE food safety regulation is concerned we have a very difficult situation. ANZFA is forced to operate under conflicting objectives. [see Quaker submission] The first and foremost is the protection of public health and safety and the second is promoting the interest of the food industry. It cannot do both. I recommend that the Commission advocates the latter task be placed in the hands of a separate independent authority and that consumer interest and independent scientific opinion be represented.

The concept of “substantial equivalence” is totally unscientific and adopted to ensure the foods reach the consumer with the least interference possible. The undue reliance of ANZFA on the FDA is also completely unwarranted. [see professor Epstein on The Public Health Hazards of

GE Milk and Food also Jean Anderson Brief]

New Zealand has been disenfranchised by the agreement allowing ANZFA to regulate our food.

ANZFA has no real consumer representation and no scientists holding an opposing view are allowed on the Board. [Refer to paragraph 10 of NNFA submission.]

When scientists are in the employ of corporations, government agencies or similar, and the growing reliance by universities and Crown Research Institutes on corporate support, there is a threat to the objectivity and independence of scientific research. This, in turn, corrupts the advice given by scientists to governments. In the UK, for example, The Biological Research Council was headed by the CEO of Zeneca until May 1999 - hardly a disinterested party.

When scientists do express their fears or concerns they are frequently and savagely vilified. I mention just two of many examples, Dr Richard Burroughs the FDA veterinarian, fired in 1989 for opposing Monsanto’s rBGH and speaking out against the warping of regulatory ethics and standards. There was also the prominent case of Dr Pusztai, his career - and in Pusztai’s case also his health - reduced to ruins. This is a very tragic and dangerous state of affairs. (31) These people are vital to a science free of amoral constraints such as those imposed by the biotech industry.

As Dr Sanjour of the EPA said, “one whistleblower can frequently accomplish more than a room full of inspectors or policemen, and cost far less. Whistleblowers know the system, and speak out in a spirit of public service. Whistleblowers are precisely the kinds of people we should have in top management of government and industry. It is not the whistleblower who needs protection so much as it is the public that needs the protection of the whistleblower.” (William Sanjour, US Environmental Protection Agency.)

C.4. This type of “deceit by consent” has became unfortunately all too prevalent where large profits take precedence over consumer health concerns. (See attached report, Liz Lightfoot,

“Scientists asked to fix results for backer”.) The GE debate has always claimed that the public require, “impartial scientific advice” (MP, Simon Upton, addressing an Agricultural Convention) while making sure scientists likely to offer it are not included. [See attached release from Professor Samuel Epstein on the formation of the National Academy of Sciences, ostensibly put together for just such a purpose.]

C.5. The hallmark of science is that it is always provisional and uncertain. Molecular genetics is still a new discipline and our ignorance regarding gene regulation and the ecological impacts of horizontal gene transfer is profound. The social responsibility of science and the proper use of scientific evidence is to set precaution.

C.6. The lack of full detailed food labelling will pose insurmountable difficulties in tracing food poisoning incidents should they occur from novel foods unless they give rise to extra-ordinary conditions such the Tryptophan case of eosinophilia-myalgia syndrome (EMS).

The heavy reliance by ANZFA on the US Food and Drug Administration (FDA) and US industry is very questionable. [See Jean Anderson’s Witness Brief. and Fraud behind GM food safety claims]

While US regulatory agencies boast of having the safest food supply in the world, statistics reported from the US Centre for Disease Control (CDC) show that 76 million Americans suffer food poisoning each year and about 5 000 die from it. The new CDC analysis also estimates that 325 000 people are hospitalised annually for food-related illnesses.

C.7 Particularly startling is that the new CDC numbers on food poisonings are twice as high as the 1994 analysis which put the figure at 33 million. (33) Could this reflect three years’ of genetically engineered food consumption? We just don’t know. Dr Philip Regal, Professor of Ecology, Evolution, and Behaviour at the University of Minnesota and an internationally recognised plant expert, has stated: "Over the last fifteen years, I and other scientists have put the FDA on notice about the potential dangers of genetically engineered foods. Instead of responsible regulation we have seen bureaucratic bungling and obfuscation that have left public health and the environment at risk." New Zealand has a alarming cancer burden already (113) not only would it be exceedingly hard to trace cancer cases to GE food consumption, it would simply increase this appalling hardship.

I draw the Commissions attention to three abstracts containing work on leukemia and soybean

toxins[attached]. The added effects of genetically engineering soy, now in wide production, is completely unknown.

C.8 Federal decisions on vaccines are also made in secret by a small committee of non-accountable experts who have conflicts of interest, such as affiliation with manufacturers who stand to make enormous profits from required use of their product. (61) The Association of American Physicians and Surgeons (AAPS) is calling for an immediate moratorium on mandatory hepatitis B vaccines for schoolchildren pending further research about dangerous side effects.(62) [See Witness Brief of Dr. M Godfrey; AND attached correspondence to FDA.]

I appeal to the Commission in the strongest terms to recommend to Government that New

Zealand have in place an indefinite moratorium on the release of GE crops ( both food crops and non-food crops). And that the precautionary principle should dictate that we declare an immediate moratorium on

(i) the release of any genetically engineered organisms into the environment, and

(ii) the incorporation of GEOs - their parts, processes and products - into the food chain. (63)

And that New Zealand becomes a signatory to the ‘Genetic Bill Of Rights.’ [Attached.]

ADDENDA

In the light of the USA StarLink debacle the following material is now very relevant. The constant claim from ANZFA that these products are tested and internationally acceptable is seen to be clearly not true. The appalling lack of US government regulation and the greed of biotech corporations to rush untested, and in this case, possible dangerous products to market have now become obvious, even in the United States. Polls taken before the StarLink scandal broke showed that the majority (51% in a poll by Angus Reid) of Americans and Canadians (60% in a poll by Unilever) were already opposed to genetically engineered foods, while an overwhelming majority (80-94%) support mandatory labelling, mainly so that they can avoid buying these controversial foods. US farmers, and even a number of large food corporations, have already begun cutting back on their use of GE seeds or food ingredients. (91)

While 33% of US corn acreage was GE last year, it has now fallen to 19.5%. Whether or not the

StarLink debacle represents a mortal blow to the first generation of GE foods and crops remains to be seen. Certainly a review of recent global developments indicates that the crisis of credibility surrounding genetically engineered foods is steadily increasing.

On the international front:

* Leading producers of genetically engineered crops, the US (74% of all GE crops), Canada (15% of all GE crops), and Argentina (10%), face a similar dilemma. If they try to use the hammer of

economic sanctions from the World Trade Organization to force these foods onto the WTO's other 131 nation-state members, they risk provoking a trade war and possibly even a meltdown of the entire global "Free Trade" system. If they do not use the police and enforcement power of the

WTO, however, more and more countries are going to make it harder and harder for untested and

unlabelled GE products to get into their countries. For example:

* Europe, which has not approved a new GE crop since April 1998, told the US on 11 October,

according to the Bureau of National Affairs Journal, "that the only way the European Union's de

facto moratorium on new GM (genetically modified) seeds is likely to be lifted is for US farmers to be required to segregate genetically modified crops from those grown from traditional seeds..."

* Government officials in Taiwan announced on 17 October that they will follow the lead of other Asian and Pacific countries and require mandatory labelling of food with genetically engineered ingredients. According to officials, labelling requirements will come into force in 2001 – with similar measures being implemented in South Korea and Japan. Taiwan is a major importer of US grains, importing over 4.5 million metric tons of corn last year. According to (US) Cropchoice News, "The government's decision is in response to intense pressure and follows publication of a Gallup poll in which 74% of Taiwanese said they expected the government to require labels on GMO food." According to Reuters News Agency, Uni-Food Enterprises, Taiwan's largest food company, reacted to the news by promising to comply with the labelling requirements and move toward using non-genetically engineered ingredients. Uni-Food Enterprises, with $2.6 billion in annual sales, produces animal feeds, dairy products, frozen foods, instant noodles, and soft drinks.

* According to an Associated Press story of 25 October Japanese authorities have warned the United States not to export StarLink corn to Japan. Government officials were embarrassed after a public interest group, the Consumers Union of Japan, announced in Tokyo that it had found traces of StarLink corn in snack foods sold in Japanese stores as well as in imported animal feed. StarLink corn is prohibited in both human and animal feed in Japan. An earlier Associate Press (AP) story on 24 October reported that an entire 55,000 ton shipload of US corn destined for Japan was rejected after testing positive for StarLink, "sending shock waves through importers in Japan as well as other Asian countries such as South Korea and Taiwan." According to the AP, "Japan imports about 60 percent of its food, much of it from the United States. In 1999, Japan imported 15.9 million tons of corn from the United States, including 10.8 million tons for animal feed, the Foreign Ministry said. The remaining 5.1 million tons were for food, mostly for corn starch." Korea imports about eight million tons of corn per year from the US. The Consumers Union of Japan and allied consumer groups in South Korea are calling for a moratorium on the importation of all GE foods into their countries. In a recent poll 82% of Japanese consumers said they were opposed to genetically engineered food - the highest level of resistance in the world.

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RSGM Witness Brief Robert Anderson

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