Previously known as Physicians and Scientists for Responsible Genetics PSRGNZ - Charitable Trust
As required under the new 2005 Charities Act, PSGR has reregistered as a charitable trust.

5 March 2013


The Chairman, Board Members,

Members and Management Staff of Federated Farmers

PO Box 715                                                                                  

WELLINGTON 6140                           


cc Rural Women, Young Farmers, NZ Forest Owners Assoc., Tree Crops Assoc., and other relevant organisations


Developments in technologies, the Trans-Pacific Partnership Agreement, and the welfare of New Zealand and its people

Physicians and Scientists for Global Responsibility is a Charitable Trust established to provide independent scientific assessment and advice on matters relating to genetic engineering, nanotechnology, synthetic biology and other scientific matters.

Potential gains from any new technology must be weighed against the facts.  Increasingly, science is being privatised and can no longer be relied on to serve the public interest.  Patents on products and technologies are growing rapidly.  Research funding is being channelled into new technologies to the disadvantage of other scientific issues in need of research for the public good.  Vested interest is too often allowed to override issues of safety.  Frequently, regulation and public consultation and interest are not pursued.


With negotiations for a Trans-Pacific Partnership Agreement (TPPA) in chain, PSGR urges that free trade should not be at the expense of New Zealand or New Zealanders and not infringe on the right to make free and rational choices.

Anecdotal reports of the realities of farming should not be ignored and/or found wanting against inadequate safety and risk testing largely carried out by interested parties.

The Federated Farmers web page[i] ‘About Us’ says Federated Farmers is member driven, that members’ views are canvassed, aiming to add value to the business of farming and encourage sustainability through best practice.

Best practice should include looking at how adopting genetically engineered crop plants would affect New Zealand and New Zealanders.


The terms genetic modification and biotechnology are often used interchangeably with the deliberate process of genetic engineering, which we take as the most accurate description of the recombinant DNA technology.  While biotechnology encompasses many other processes and offers many important non-transgenic applications that have contributed largely to support and improve agriculture, genetic engineering is the main focus of our concern because of the manner in which it impinges on organisms and their ecological relationships.

Bodies representing rural and urban communities and associations have a duty of care to protect from the effects, costs and damage that may arise from the scientific uncertainty surrounding transgenic organisms in situations of commercial open release, notably because the insurance industry does not offer insurance cover against those risks.

The application of genetic engineering technology alters the DNA of a living organism.  It does this in a way that is inevitably disruptive to some degree as a result of the essentially random insertion of transgenic (or cisgenic) DNA into the functional DNA of a host organism.  It may cause noticeable changes in the appearance of the organism and/or differences in the biochemistry and physiology of the organism.  These changes are unpredictable and may result in the production of new proteins, with potential toxic effects, within the transgenic organism.

The introduction of transgenes into plants may cause unintended phenotypic (unforeseen) effects which could have an impact on the plant itself and the environment.  Little is published in the scientific literature about the interrelation of environmental factors and possible unintended effects in transgenic plants.

Many scientists are concerned about releasing genetically engineered organisms into the environment.  Public concern was amply determined in a 2009 Colmar Brunton Poll to be found on  New Zealand companies are concerned.  Fonterra has said there is insufficient support in this country or from overseas customers to warrant local production of food from genetically engineered sources, and food producers Heinz Watties, Goodman Fielder and others have GE free policies, largely resulting from public pressure and/or an awareness of the uncertainty of genetic engineering technology.

We also need to be cognisant of the risks that can arise from imported commodities.  Feed imported for Fonterra was found to contain transgenic material and undermined its food safety credentials.[ii] Tests on fertiliser found intact transgenic DNA which originated in imported poultry feed.[iii] Transgenic elements have been found contaminating pasture after surviving the gut of animals.[iv]

Conventional corn seed imported into New Zealand had to be dug up when transgenic contamination was found, and the paddocks could not be used to grow corn the following year.

In 2011, the European Court of Justice ruled that pollen is an ingredient of honey and that honey containing transgenic pollen must follow “GM regulations”, meaning it cannot be sold without full food authorisation and labelling.  There have been calls for crop patent holders to be held accountable for beekeepers' losses.[v] Such contamination could threaten our honey exports.

Best practice should include looking at how stringent and independent are safety tests carried out on genetically engineered crop plants before release.

In approving transgenic plants or foods, the US Food and Drug Administration (FDA), its Environmental Protection Agency (EPA) and the US Department of Agriculture (USDA) too commonly accept so-called safety test results direct from the developer.  These results are then deemed adequate by our own Food Safety Authority without further critical evaluation.  PSGR has found no evidence to suggest New Zealand regulatory bodies do other than take FDA, EPA and USDA approval as a satisfactory measure of safety.  Independent safety testing rarely takes place.

The US has said the abolition of laws that require transgenic foods to be labelled is a priority for the proposed TPPA.  Acceptance would remove a basic human right to have freedom of choice about what we eat.

Transgenes in any form should not be accepted or approved for release into the New Zealand environment or the human environment without stringent, independent safety testing, and labelling laws should be more stringent than they presently stand.

Acceptance of transgenes in any form must not become a bargaining chip in the TPPA negotiations.

Best practice must include looking at how adopting genetically engineered crop plants would affect New Zealand agriculture and the environment.

Introducing transgenic ryegrass, which is in development, into this country’s pastures would potentially contaminate conventional ryegrasses.[vi] Pasture seeds, primarily ryegrass and clovers, support a vital livestock industry worth billions of dollars in exports and New Zealand-bred cultivars, especially ryegrass, tall fescue and clover species, supply major markets in the US, Australia, Europe, Japan, China and South America, making a significant contribution to exports.[vii]

Perennial ryegrass cross-pollinates freely and is typical of invasive weed species in riparian zones.[viii] When genetically engineered organisms are released into the environment their transgenes can be transferred to other organisms so that the engineered characteristics spread, to the extent that they are definitively encoded in the transgenes, through the eco-system.  These genetic characteristics cannot be recalled.

Proponents of genetic engineering technology for food crop production claim it is safe and can be contained.  After almost two decades “in the field” this has been shown as a myth.  For example, ryegrass is wind-pollinated and the pollen can travel many kilometres.  Another example are maize landraces in Mexico.  Landraces are seed strains highly adapted to specific locales. They are humanity’s basic stock ‘heirloom’ varieties.  These storehouses of genetic diversity can aid in improving yield, quality, and resistance to pest and disease.  Because of potential risks to its landraces, cultivation of transgenic corn was banned in Mexico from 1998.  Regardless, transgenic material has been found in landraces in remote regions, with higher concentrations near major transport arteries.  Under the North American Free Trade Agreement, Mexico has moved from exporting to importing corn, corn that is largely trucked from the US, without being milled, along main highways.  Many blame this for the landrace contamination.[ix] It is likely Mexico will concede to the planting of transgenic corn in 2013.

A major environmental concern associated with herbicide-tolerant crops is their potential to create weeds that are resistant to agrichemicals through over-applications, outcrossing with wild relatives and by becoming feral themselves.[x] US farmers face having to eradicate weed species that have developed herbicide-resistant traits, including resistance to multiple herbicides.  These so-named ‘superweeds’ can grow aggressively and out-compete transgenic crops.  Over-application of herbicides and pesticides to transgenic crops has increased substantially the volume of agrichemicals used and this has aided in the development of weeds resistant to those chemicals.[xi]

In December 2012, the Foundation for Arable Research confirmed New Zealand’s first case of glyphosate-resistant ryegrass in a Marlborough vineyard and blamed frequent applications of that herbicide as the cause.[xii] Four further cases of glyphosate-resistant ryegrass have been identified in Marlborough vineyards and weeds surviving glyphosate treatment have been reported nation-wide.  A concern is that resistance will spread to a plant species easily dispersed by the wind, allowing it to spread quickly around the country.[xiii]

Trevor James of AgResearch is reported as saying:  “There are 61 weeds all around the world resistant to glyphosate; there are six in Australia and it's a major problem with their cropping...”[xiv] Ryegrass (Lolium rigidum) is an acknowledged problematic weed in Australia and the first glyphosate-resistant weed was annual ryegrass which emerged in 1996.[xv]

Glyphosate is the active ingredient in the herbicide marketed as RoundUp.  The first commercial Roundup Ready (glyphosate-resistant) crop to be planted in Australia was cotton in 1996 and it may have contributed to the development of the ryegrass resistance.  Transgenic resistant crops grown elsewhere are seen as culpable in the emergence of herbicide-resistant weed species.

Each year weeds cost Australia over AUD$4 billion in control and lost production.[xvi] Recently, the Australian government committed AUD$15.3 million over four years to establish a comprehensive National Weeds and Productivity Research Programme to reduce the impact of invasive plants.  Wild radish (Raphanus raphanistrum) costs the Australian grain industry AUD$140 million/p.a. for weed control and in lost production.[xvii] In relation to widely grown transgenic oilseed rape/canola, Britain’s advisory committee on releases to the environment (ACRE) identified wild radish, wild turnip, hoary mustard, brown mustard and wild cabbage as species from which hybrids could be formed with the transgenic varieties.  A Swedish study found transgenic canola seed could remain viable in the wild even 10 years after release.[xviii] In one field trial plot, researchers found 46% of seeds in a wild turnip plant contaminated with transgenic DNA.[xix] Wild radish, wild turnip and wild cabbage grow in New Zealand.

Best practice should include looking at the potential effects of the genetically engineered trees being trialled in the New Zealand environment.

Forestry in New Zealand is a substantial employer and a major export earner.  In 2011, the value of exports of forestry and forestry products increased NZ$264 million (6.3%); an overall value of NZ$4,473,224.[xx] Exports of forestry and forestry products to China alone were up NZ$207 million (17%) to $1.4 billion.[xxi]

Ninety percent of its plantation forests are in Pinus radiata[xxii] which generate wilding pines.  These flourish in many soil types from coastal areas to high altitudes.  Pines seed efficiently from pinecones.  Wind-blown seeds are widely distributed and readily take root.  Wilding pines compete with native flora.  Pine needles discourage regeneration of native forest floor species.

Farmers will be aware of the heavy costs incurred to remove wilding pines which are invasive and a threat to biodiversity, farm productivity and landscape values.  Funding for control comes almost exclusively from the public purse and private landowners.[xxiii]

The Environmental Risk Management Authority (now the Environmental Protection Agency; EPA) gave approval for the Forest Research Institute Limited, trading as Scion, to plant Pinus radiata with a number of engineered traits, including herbicide-resistance.  The experimental trees are being trialled over two decades in the open environment in the Rotorua area.  The premise is that the trees will largely be engineered using what is commonly termed ‘terminator’ technology, making the trees sterile, i.e. not able to flower or replicate.  Transgenic traits are likely to be unstable and the variants of terminator technology offer no absolute guarantee of sterility.  The traits can break down and the trees revert to flowering.  Even if totally sterile, terminator trees can spread by asexual means.  Genes can spread horizontally in soil bacteria, fungi and other organisms in the extensive root system of forest trees.  There could be long-term impacts on soil biota and fertility.  Sterile monocultures yield more readily to disease.  Trees that do not flower and fruit cannot provide food for the organisms that feed on pollen, nectar, seed and fruit; thus, essential pollinating insects may not be available, especially for beekeepers and horticulturalists, and for crops and pasture grasses.

One of the proposed engineered traits is herbicide-resistance.  In the US, herbicide-resistant transgenic crops have increased the use of herbicides, rather than cause a reduction in usage.x This has led to the substantial numbers of weed species that have become herbicide-resistant and in turn are causing major difficulties and increased costs for farmers and growers.  Herbicide-resistant pines could lead to transgenic wilding pines.  With conventional Pinus radiata seeds viable “at least up to twenty-four years”[xxiv] it is conceivable that the seeds of transgenic wilding pines could be equally robust.

You may consider Rotorua too far away to worry about contamination or cross-pollination from the genetically engineered trees growing in the area.  In this regard, we refer you to the work of Sing et al (1993) who found that pollen from pine trees had travelled over 600 kms.[xxv] Pollen is in the order of 100 to 10 microns or smaller in size.  Once in the atmosphere, it can travel vast distances.  It would need a failure rate of only a part of a percent for transgenes in pollen to contaminate other trees, potentially at great distances, in ways that could not easily be monitored.

The risks are environmental and economic.  Terminator technology has attracted a voluntary moratorium from many countries because of the risks involved.  The effect on New Zealand’s reputation overseas and export trade could be damaging.  These experiments are not in New Zealand’s best interests.

We refer you to our full submission to the Environmental Risk Management Authority (ERMA) on this Application (now the jurisdiction of the EPA).[1]


Best practice should include looking at how transgenic crops have affected consumers.

Proponents of genetic engineering claim US citizens have been eating transgenic food crops since the mid 1990s and their health is unaffected.  In reality, US physicians are finding transgenes have had deleterious effects on human health but because of the wide range of transgenes ‘out there’ and the lack of record keeping on allergies and other likely effects, it is almost impossible to track potential health impacts with exactitude.  Doctors insist patients have a right to know what is in their food and physicians must know what their patients are eating.

The FDA approved the first transgenic food crops in 1994 and in 2011 the USDA stated about 88% of corn and 94% of soybeans produced in the US were transgenic.  Transgenic soy represents 77% of global soy production.  Soy protein can be found in a multitude of food products.  The list on demonstrates how easily most consumers would ingest multiple helpings of transgenes daily.

What of transgenic corn?  Researchers ran comparative analyses of blood and organ system data from trials with rats fed three main commercialized transgenic maize (NK 603, MON 810, MON 863) which are present in food and feed globally.[xxvi] Their conclusions were that patho-physiological profiles are unique for each transgenic crop or food crop, necessitating a case-by-case evaluation of their safety.  In this study, effects were mostly concentrated in kidney and liver function, the two major diet detoxification organs, and differed in detail with each maize type.  Some effects on heart, adrenal, spleen and blood cells were frequently noted.  The researchers say results cannot be dismissed as biologically insignificant and the data strongly suggested transgenic maize varieties induce a state of hepatorenal toxicity which can be due to the herbicide or insecticide present specifically in each type of transgenic maize.  The transgenic maize varieties contained a distinctly different pesticide residue associated with their particular transgenic event (glyphosate and AMPA in NK 603, modified Cry1Ab in MON 810, modified Cry3Bb1 in MON 863) and the substances have never before been an integral part of the human or animal diet.  Therefore their health consequences for those who consume them, especially over long time periods are currently unknown.

Transgenic crops grown for feed can still contaminate human food crops.  Distance is no barrier to outcrossing.  Keeping transgenes out of conventional crops is impossible if transgenic crops are grown nearby.

Because of the development of weed species resistant to genetically engineered traits and the impossible task of retrieving those genes out of the environment, developers are working on human food crops that will resist even more toxic chemicals such as 2,4-D.  Consumers will be ingesting the resistant transgene/s from whatever part of the plant they consume and also be exposed to ingesting the residue of herbicide applications which are detectable on the plant.[xxvii] Scientists predict the inevitability of weeds developing resistance to the new chemicals as easily as they have to glyphosate.  Scientists in Nebraska have already found waterhemp resistant to 2,4-D[xxviii] and scientists at the University of Illinois have found waterhemp resistant to HPPD-inhibiting herbicides.  Historically, waterhemp is a problematic weed in the US corn belt because it is aggressive, faster growing and out-competes corn for light, water and nutrients.[xxix]

There is an application for approval currently before Food Standards ANZ for transgenic soy resistant to the three agrichemicals mentioned above:  2,4-D (2,4-dichlorophenoxyacetic acid), glufosinate ammonium and glyphosate.  Other transgenic crops are being developed to resist 2,4-D (an ingredient in Agent Orange), dicamba (a herbicide in the 2,4-D family), HPPD-inhibiting herbicides, and glyphosate and AL (GAT).[xxx] Not only are these transgenic crops heavily and regularly sprayed with the herbicides they are engineered to resist, the resistance transgene manifests in the xylem of the plants:  leaves, fruit, flowers, pollen, nectar, and guttation fluid.  Eat any part of the plant and you ingest the transgene and residual spray.  As an example, the Bt-toxin produced in transgenic crop plants is many thousands times more concentrated than natural externally-applied Bt spray and is designed to be more toxic and cannot be washed off the plant.[xxxi]

Other common genetically engineered crops include alfalfa, canola, cotton (for cottonseed oil for human food products), papaya, zucchini, and sugar beets used to make white sugar.

The American Medical Association has called for mandatory pre-market safety testing for all foods derived from transgenic crops.  Currently pre-market testing is voluntary.

In 2009, the American Academy of Environmental Medicine issued a statement ‘Genetically Modified Foods’ that included:  “GM foods pose a serious health risk in the areas of toxicology, allergy and immune function, reproductive health and metabolic, physiologic and genetic health and are without benefit.[xxxii]

Best practice should include listening to the experience of farmers overseas who have grown transgenic crops.

The claim is that transgenic crops benefit farmers.  Hear from US farmers who planted transgenic crops on (24 minutes) and an interview with Nnimmo Bassey, head of Friends of the Earth International speaking of farmers in India, south-east Asia, Africa and Latin America (8.18 minutes),  The Supreme Court of India is currently considering the advice of a scientific expert panel for a ten-year moratorium on field trials of genetically engineered organisms.

The International Assessment of Agricultural Knowledge, Science and Technology for Development (IAASTD), a large, comprehensive United Nations study, does not support the thesis that genetic engineering is a solution to feeding future generations, and transgenic crops could threaten food security:,English.pdf.

PSGR urges New Zealand farmers to apply a precautionary policy on growing genetically engineered crops, to protect farming and the environment.  For a guide, we recommend the comprehensive analysis of the myths and truths relating to genetically engineered organisms and peer-reviewed studies found at the executive summary of which follows this letter.  This document supports PSGR's recommendations.

Best practice should include considering the potential effects of transgenic organisms if approved for growing in New Zealand on your farms and your neighbours’ farms

In April 2001, The Wall Street Journal tested twenty food products labelled "GMO free".  Sixteen contained at least traces of transgenes; five had significant amounts.  Commercial transgenic crops had been grown commercially for just five years.[xxxiii]

The costs associated with keeping organic and conventional crops separate from transgenic crops and seed are high:  buffer zones, cleaning equipment, inspections of crops and processing facilities, frequent testing; sanitizing combines, trucks and elevators.  Experience has shown it is impossible.

Virtually all of the seed corn in the US has at least a trace of transgenic contamination, canola is as bad or worse, and soy is problematic.  Seed companies cannot guarantee conventional seed is free of transgenes.

No amount of monetary compensation can redress the fundamental, irreparable issues of transgenic contamination:  loss of a farmer’s right to sow their seeds of choice and the public’s right to feed their families traditional foods.  Nor can it compensate for the irretrievable genetic invasion of native flora and ecosystems.

Best practice should include being aware of potential difficulties from any developing technology.

Nanotechnology refers to techniques used to engineer structures, materials and systems that operate at a scale of 100 nanometres (nm) or less, the scale of atoms and molecules.  One nanometre measures one-billionth of a metre.

The technology is nascent in the agriculture sector, but developers suggest it can increase efficiency and overcome challenges in the agricultural industry.  It has been employed with nano-clays, cyclodextrans and nano-emulsions.  Nano-polymer formulation for agricultural applications list “advantages of decreased sedimentation rate, increased mobility through the soil column, increased diffusion rate, decreased crystallinity of active ingredients, and increased efficacy.[xxxiv]

While the technology has a role in the agricultural sector, challenges include the possibility of increased volatility (via increased surface area), soil adhesion, stability, cost, technology maturity and industry understanding.  Nano-formulations pose uncertainty with respect to nano-toxicology and environmental impact testing that has not yet reached industry-standard methodology.xxxii

Recent evidence from hydroponic plant studies showed manufactured nano-materials (MNM) can be taken up and processed by plants.  Priester et al (2012)[xxxv] found MNM can impact on microbes and microbial processes related to nutrient cycling, to plant growth and composition if MNMs are transferred from soil to plants, and to plant-microbe interactions that affect soil fertility.  The researchers propose MNM could alter the quality and yield of soil-based food crops.

A further conclusion was that dispersing wastewater biosolids which may contain MNM on paddocks growing food crops could lead to agriculturally associated human and environmental risks from MNM.  It raised concern that there could be toxic effects higher up the food chain that could potentially be a threat to any form of life.

Biosolids that may contain MNM are routinely dispersed on New Zealand paddocks and into water systems.  Treated sewage that may contain MNM is discharged into the sea.[xxxvi]

We do not know what happens when MNM are ground up, incinerated or disposed of in a landfill, or when they are released into the atmosphere, water or soil.  Studies have shown nanoparticles can move in unexpected ways through soil and can potentially carry other substances with them.  Airborne MNM could travel vast distances.  We do not have filters fine enough to trap MNM and we currently have no way of tracking them in soil, air or water.

It is known that varieties of nanoparticles can pass through skin into the bloodstream, enter an individual cell, and pass through the blood-brain barrier and into the placenta.  Relatively few toxicological studies on nanoparticles have been carried out and where they have been performed on animals and fish adverse reactions have been observed, including fatalities.

Items marketed today containing MNM include electronic, cosmetic, automotive and medical products, and packaging.[xxxvii] MNM known to be in use in New Zealand are dental fillings, cleaning materials, protective and non-stick applications on glass, personal care products, veterinarian and pharmaceutical products.  The waste of any of the above products could be found in biosolid waste matter.

The European Union requires labelling of foods containing nanomaterials.  The European Food Safety Authority has published guidance for assessing nanomaterials in food and animal feed.  The US FDA has issued a statement saying it did not have enough data to determine the safety of nanomaterials in food.  The Environmental Protection Agency is evaluating various nanoparticles used in consumer products.[xxxviii] New Zealand has yet to release regulations for nanotechnology, except for a requirement to notify the EPA about any cosmetic product containing nanoparticles.

Precautionary measures and regulations must be established.  One study highlighted the potential risks of using nanotechnology as fertilizers and plant protection products containing nanoparticles because of potential harm to Earth’s bio-systems.[xxxix]


Best practice would seem to require the leadership and office holders of Federated Farmers to publicly declare any conflicts of interest in regards to proposed Federated Farmers’ policy and the public presentation of views in areas critical to the public interest, such as those relating to genetic engineering.


PSGR has noted the actions of Federated Farmers’ leadership in writing to councils requesting the removal of the precautionary principle in regards to genetic engineering / genetic modification in their annual plans.  The implications of such actions affect not only members of Federated Farmers but the greater farming community and the public in general.  The public perception of clarity and integrity is vital if Federated Farmers is to fairly represent its members and by implication farmers and farming in New Zealand.

The organization’s leaders and office holders should declare any expectation of financial gain through commercial interests from said sciences.  It would also seem reasonable that until all conflicts of interest are ruled out Federated Farmers should refrain from promulgating new policy, such as recommending the removal of the precautionary approach to genetic engineering from local government annual plans.

An example of the dilemma we are alluding to is provided by statements of Dr William Rolleston.  Dr Rolleston told the Nelson Mail:  “I’m not pro- or anti-GM, but we need to have access to all the scientific tools available and GM is part of that.”  However, he was Chairman of the Life Sciences Network (LSN), a pro-GE corporate-funded lobby group that spearheaded the campaign to lift a genetic engineering moratorium in New Zealand.[xl] Commentators have raised concerns that the PR campaign LSN led may have had a significant antidemocratic effect upon the 2002 election outcome.[xli] LSN also spent large sums on a public relations campaign to persuade the public to become pro-GE.  Dr Rolleston’s past and present positions for organisations associated with a pro-GE position suggests he is being rewarded for his pro-GE position.  A company he cofounded means he is well-placed to take advantage of any freeing of the genetic engineering landscape.

The current lobbying of local bodies by Federated Farmers’ leadership bears a strong resemblance to the lobbying performed by the LSN.  The question is, whose interest is leadership of Federated Farmers pursuing in its demand that Auckland Council drop the previous precautionary principle in regards to genetic engineering in the local environment?


We look forward to hearing from you.


The Trustees of PSGR



GMO Myths and Truths

An evidence-based examination of the claims made for the safety and efficacy of genetically modified crops, Michael Antoniou, Claire Robinson, John Fagan; June 2012, Earth Open Source

Executive Summary: Genetically modified (GM) crops are promoted on the basis of a range of far-reaching claims from the GM crop industry and its supporters. They say that GM crops:

  • Are an extension of natural breeding and do not pose different risks from naturally bred crops
  • Are safe to eat and can be more nutritious than naturally bred crops
  • Are strictly regulated for safety
  • Increase crop yields
  • Reduce pesticide use
  • Benefit farmers and make their lives easier
  • Bring economic benefits
  • Benefit the environment
  • Can help solve problems caused by climate change
  • Reduce energy use
  • Will help feed the world.

However, a large and growing body of scientific and other authoritative evidence shows that these claims are not true.  On the contrary, evidence presented in this report indicates that GM crops:

  • Are laboratory-made, using technology that is totally different from natural breeding methods, and pose different risks from non-GM crops
  • Can be toxic, allergenic or less nutritious than their natural counterparts
  • Are not adequately regulated to ensure safety
  • Do not increase yield potential
  • Do not reduce pesticide use but increase it
  • Create serious problems for farmers, including herbicide-tolerant “superweeds”, compromised soil quality, and increased disease susceptibility in crops
  • Have mixed economic effects
  • Harm soil quality, disrupt ecosystems, and reduce biodiversity
  • Do not offer effective solutions to climate change
  • Are as energy-hungry as any other chemically-farmed crops
  • Cannot solve the problem of world hunger but distract from its real causes – poverty, lack of access to food and, increasingly, lack of access to land to grow it on.

Based on the evidence presented in this report, there is no need to take risks with GM crops when effective, readily available, and sustainable solutions to the problems that GM technology is claimed to address already exist.  Conventional plant breeding, in some cases helped by safe modern technologies like gene mapping and marker assisted selection, continues to outperform GM in producing high-yield, drought-tolerant, and pest- and disease-resistant crops that can meet our present and future food needs. and go to "download" to the right for the full report.)


See also 1. The Sustainability Council of NZ 2. GM Watch 3. Herbicide-resistant weeds and; 4. PSGR Frequently Asked Questions on Genetic Engineering 5. A Review of the Adequacy of New Zealand’s Regulatory Systems to Manage the Possible Impacts of Manufactured Nanomaterials ( January 2011) ‘Nanotechnology:  safe or not?’ Organic New Zealand September/October 2010 and ‘Nano waste, how do we deal with it?’ Organic New Zealand November/December 2010.  7. The ETC Group on Nanotechnology






[v] ‘GM honey needs a GM label’ 12 February 2013,; ‘EU bans GM-contaminated honey from general sale’ Leigh Phillips, 7 September 2011




[ix] David Quist,‘Vertical Trans(gene) Flow:Implications for Crop Diversity and Wild Relatives’, Third World Network, 2010,


[xi] Dr Charles Benbrook, a research professor at the Centre for Sustaining Agriculture and Natural Resources at Washington State University, US, states:  “the spread of glyphosate-resistant weeds in herbicide-resistant weed management systems has brought about substantial increases in the number and volume of herbicides applied.  If new genetically engineered forms of corn and soybeans tolerant of 2,4-D are approved, the volume of 2,4-D sprayed could drive herbicide usage upward by another approximate 50%.




[xv] Sydney Morning Herald, 8 May 2012.



[xviii] ‘Long-term persistence of GM oilseed rape in the seedbank’, D’Hertefeldt T et al, Biol Lett. 23 June 2008; 4(3): 314–317.


[xx] ‘Global New Zealand, International Trade, Investment, and Travel Profile, Year ended December 2011’,


[xxii] ‘Situation and outlook for New Zealand agriculture and forestry’, NZ Ministry of Agriculture and Forestry, 2007.

[xxiii] ‘Wilding conifers - New Zealand history and research background’, a presentation by Nick Ledgard at the "Managing wilding conifers in New Zealand - present and future" workshop (2003).

[xxiv] ‘The Fire Pines’, Richard Warren and Alfred J Fordham,

[xxv] Singh, G. et. al., “Pollen-Rain from Vegetation of Northwest India.” New Physiologist, 72, 1993, pp. 191-206.

[xxvi] ‘A Comparison of the Effects of Three GM Corn Varieties on Mammalian Health’,

Joël Spiroux de Vendômois et al, International Journal of Biological Sciences, Int J Biol Sci 2009; 5(7):706-726. doi:10.7150/ijbs.5.706, 11 February 2013,



[xxix] ‘Resistance to HPPD-inhibiting herbicides in a population of waterhemp (Amaranthus tuberculatus) from Illinois, United States’, Hausman NE et al, Pest Manag Sci. March 2011;67(3): 258-61, epub Jan 262011,


[xxxi] See for example, Dutton et al, ‘Uptake of Bt-toxin by herbivores feeding on transgenic maize and consequences for the predator Chrysoperia carnea’, Ecological Entomology 27 (2002): 441–7; and Romeis et al ‘Bacillus thuringiensis toxin (Cry1Ab) has no direct effect on larvae of the green lacewing Chrysoperla carnea (Stephens) (Neuroptera: Chrysopidae)’. Journal of Insect Physiology 50, no. 2–3 (2004): 175–183.



[xxxiv] Center of Innovation for Nanobiotechnology (COIN),

[xxxv] ‘Soybean susceptibility to manufactured nanomaterials with evidence for food quality and soil fertility interruption’, 2012, early/2012/08/14/1205431109?utm_source=HEADS-UP+24-30+AUGUST++2012&utm_campaign=SMC+Heads-Up&utm_medium=email (A)

‘UCSB Scientists Demonstrate Biomagnification of Nanomaterials in Food Chain’ 16/indexNL.aspx?sid=1016&gid=1&pgid=252&cid=1417&ecid=1417&ciid=1790&crid=0

[xxxvi] Mangere; Guidelines for the Safe Application of Biosolids to Land in NZ, August 2003; The Cost-Benefits of Applying Biosolid Composts for Begetalbe, Fruit and Maize/Sweetcorn Production Systems in NZ 2004 7_Cameron2004_4web.pdf; Christchurch


[xxxviii] Study Looks at Particles Used in Food, Stephanie Strom, 5 February 2013,

[xxxix] Nanotechnology in Agriculture and Food:  Nanoforum Report, Scientists eye nanotechnologies to boost crop yields -, In the World: Nanotech on the farm - MIT News Office


[xli], A Discourse Perspective for Critical Public Relations Research: Life Sciences Network and the Battle for Truth. Judy Motion and C. Kay Weaver, Department of Management Communication University of Waikato. Journal of Public Relations Research, 17(1), 49–67.