2013 COAG / Nikki Kay MP / FSANZ GE Soy 2012

2 April 2013

Hon Nikki Kaye MP

New Zealand Representative on the Council of Australian Governments (COAG)

Parliament Buildings

WELLINGTON

cc John Key, Prime Minister; all MPs; Ministries of Health and for Primary Industries; FSANZ; relevant NGOs

Dear Minister

DOW Transgenic Soy Application A1073 approved by FSANZ in February 2013

PSGR understands the COAG Legislative and Governance Forum on Food Regulation will be confirming the approval of Application A1073 by early May.

As the sole New Zealand representative, we urge you to advocate against the approval of A1073.[i]

When decisions are made on transgenic foods, food ingredients and food crops without essential scientific data on the health impacts of those foods, Food Standards ANZ (FSANZ) and the Forum deny consumers fundamental information about the food they will have no choice in ingesting. This is a denial of the basic right to freedom of choice. Present labelling laws are inadequate to guarantee that choice.

Because of potential adverse effects on ingestion of transgenic soy, FSANZ and the Forum may even be vulnerable to litigation.

Negative health effects on consumers relative to the above are known:

(a) When transgenic soy was introduced into Britain, doctors reported a 50% increase in soy allergies within one year[ii] and a study conducted by the York Laboratory in 1999 confirmed the link to transgenic soy imports to the UK. Doctors in Ireland concurred.[iii]

(b) After a single meal containing transgenic soy was fed to human volunteers transgenes were detected in the gut bacteria of the volunteers.[iv]

See ‘Genetically Engineered Foods May Cause Rising Food Allergies—Genetically Engineered Soybeans’ from the Institute for Responsible Technology.[1]

That official bodies accept the word of developers and that vested interests continue to deny the possibility of adverse effects, does not mean there are no problems. To illustrate this, for example:

(a) A consumer may not know he/she has consumed Botulin toxin - just LD-50 of 0.4 billionth of a gram per kilogram of body weight - until paralysis sets in.

(b) Arsenic exploits pathways in cells, binds to proteins, and creates molecular havoc. Small amounts taken over a long period of time produce weakness, confusion and eventually paralysis.

We know poisons are effective in minuscule amounts that are not always detectable. The human body treats novel proteins as non-self hence a body’s delayed allergic reaction. This particularly applies to the proteins created in transgenic plants.

Transgenes are expressed in the xylem of plants: leaves, fruit, flowers, pollen, nectar, and guttation fluid of plants.[v] A consumer ingesting any part of the plant will consume those herbicide-resistant transgenes. A regime of herbicide applications are applied to transgenic food crops leading to a consumer also ingesting the results of the following:

(a) Residual glyphosate, glufosinate and 2,4-D in the case of Application A1073, or other agri-chemical with other transgenic crops, which remain on the transgenic crop after spraying.

(b) Farmers spray crops before harvesting with broad-spectrum systemic herbicides to kill the crop plants off and give them the appearance of uniform maturity (a practice known as desiccation) leaving significant concentrations of herbicide on the harvested crops.

(c) With protein-rich feed, herbicide is sprayed directly on to the grain several days before it is sold as concentrated feed.

The journal, Ithaka, reported that every urine sample collected from city dwellers around Berlin tested positive for glyphosate. Values ranged from 0.5 to 2 nanograms per millilitre (ng/ml); i.e. five to 20 times the permissible upper limit for glyphosate in German drinking water set at 0.1 ng/ml. A conclusion was that glyphosate entered human populations through daily ingestion in foods, including glyphosate-resistant soy. Glyphosate is the active ingredient in RoundUp herbicide and commonly associated with transgenic crop plants.

A 2009 study ran tests on human cells using formulations of RoundUp that were diluted up to 100,000 times or more. The cells died within 24 hours.[vi] Products containing glyphosate also contain other toxic compounds; e.g. surfactants known as polyoxyethyleneamines (POEA) which can be more toxic than the glyphosate itself. They are irritants of the respiratory tract, eyes and skin and are often contaminated with dioxane, a suspected carcinogen.

MAFF UK states that when used as a desiccant, glufosinate residues are detectable in dried peas, field beans, wheat, barley, rapeseed oil, and linseed. Wheat grain containing residues ground into flour retained 10-100% of the residue; bran residue levels 10-600% of those in the grain.[vii]

The ester forms of 2,4-D (2,4-dichlorophenoxyacetic acid[2]) penetrate foliage. This converts to acid within the plant which accumulates in a plant’s cells through passive diffusion and is ingested in whatever part of the plant is eaten. Studies on human volunteers who drank pure 2,4-D, and on cases of accidental or voluntary acute poisoning with various 2,4-D herbicides, have shown that 2,4-D is rapidly absorbed from the gut and carried in the blood to cells and tissues throughout the body.[viii] [ix]

In human food crops developed to resist 2,4-D, glufosinate ammonium and glyphosate, consumers will be unknowingly ingesting the resistant transgene/s of three herbicides expressed in whatever part of the plant they consume. They will also ingest residues of herbicide applications, including those from the desiccation process.

The reproductive and endocrine disrupting nature of these sprays[x] has raised concerns worldwide. Recently, the American Academy of Environmental Medicine (AAEM) stated: “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. There is more than a casual association between GM foods and adverse health effects. There is causation as defined by Hill's Criteria in the areas of strength of association, consistency, specificity, biological gradient and biological plausibility. The strength of association and consistency between GM foods and disease is confirmed in several animal studies.”[xi]

The AAEM also says:

In reference to gene dysregulation: “Several animal studies indicate serious health risks associated with GM food consumption including infertility, immune dysregulation, accelerated aging, dysregulation of genes associated with cholesterol synthesis, insulin regulation, cell signalling, and protein formation, and changes in the liver, kidney, spleen and gastrointestinal system.”[xii]

In reference to structure and function changes: The studies “show altered structure and function of the liver, including altered lipid and carbohydrate metabolism as well as cellular changes that could lead to accelerated aging and possibly lead to the accumulation of reactive oxygen species (ROS).”[xiii] Changes in the kidney, pancreas and spleen have also been documented.

This is backed by Dona and Arvanitoyannis (2009) who say: “Most studies with GM foods indicate that they may cause hepatic, pancreatic, renal and reproduction effects and may alter haematological (blood), biochemical, and immunologic parameters, the significance of which remains to be solved with chronic toxicity studies.”[xiv] There is support for the specificity of the association of transgenic foods and specific disease processes. Multiple animal studies show significant immune dysregulation, including upregulation of cytokines associated with asthma, allergy, and inflammation.

As we pointed out in our submission to FSANZ, consumers will potentially be ingesting transgenic soy in multiple food products on a daily basis. Transgenic soy represents 77% of global soy production. Soy protein is utilised in a huge range of commonly consumed everyday food products. This fact is well illustrated on http://www.soyconnection.com/soyfoods/index.php. Over three quarters of food helpings containing soy could come from a transgenic soy source.

Estimates suggest up to 80% of US processed food may contain an ingredient from a transgenic crop, such as soy flour or soy lecithin (Hallman et al., 2003). In one calculation, assuming conservatively that 50% of the diet is from transgenic foods and transgenes represent an estimated 0.0005% of the total DNA in food, the consumption figure is 0.5–5 μg/day. While DNA is claimed to be mostly degraded during the industrial process and in the digestive tract, small fragments have been detected in some body tissues such as leukocytes, liver, spleen and gut bacteria (Schubbert et al., 1997). Fragments of orally administered phage M13 and plant DNA have been shown to be taken up by phagocytes as part of their normal function as immune system cells (Schubbert et al., 1998). Fragments could pass into other organs, including the foetus (Beever et al., 2000; Goldstein et al., 2005; Jonas et al., 2001).

Consumption of transgenes would be less in New Zealand than in the US. However, that fact does not excuse irresponsibly adding to the cumulative consumption of transgenes or transgenic material from multiple helpings from multiple transgenic food sources. Such products do enter the market places in Australia and New Zealand, either as ingredients for processed food or in imported foods, or in pharmaceutical or dietary supplement products.

The cumulative effects on humans of ingesting transgenic food crops, even in minute amounts, on a daily basis for unlimited periods have simply not been studied. It took decades to appreciate that trans-fats have caused millions of premature deaths. It is imperative that the regulatory systems of the world learn from that experience and remove transgenic food crops and feed from the food chain.

The cumulative effects of ingesting this novel soy (Application A1073) will stack up, particularly when considering that other transgenic crops already form part of the human diet. For example, FSANZ has already approved A1042 DOW Corn (2011) and A1046 DOW GM Soy (2011), crops that are also heavily sprayed with chemicals. It is currently considering Application A1081, Food derived from Herbicide-tolerant Soybean Event SYHT0H2, resistant to the herbicide glufosinate-ammonium and tolerance to herbicides that inhibit p-hydroxyphenylpyruvate dioxygenase (HPPD). More will follow unless we apply the precautionary principle now.

If vested interests have their way, the public will in time be ingesting food that is near 100% transgenic without there ever having been acknowledged independent safety testing carried out. It is necessary to curb the risks. It is also necessary for the public to be made aware of the risks, so they can exercise true choice before there is no choice.

Transgenic foods are novel and their complex structure means consumers ingest a range of transgenes, transgenic material and new proteins which have generally never previously appeared in nature when these foods are approved for use. These have the potential to cause serious harm and long-term impacts on human health. When toxicity concerns and dangers to health from the medium-term ingestion of transgenic foods have been addressed by independently published studies they have simply been ignored.[xv] [xvi]

The European Food Safety Authority has produced ‘Toxicological data analysis to support grouping of pesticide active substances for cumulative risk assessment of effects on liver, on the nervous system and on reproduction and development.’ It shows that the three chemicals associated with the DOW transgenic products have deleterious effects on developmental and reproductive health.[xvii]

When adequate testing, monitoring and assessment is not carried out ‘No evidence of harm’ does not equate with ‘Evidence of no harm’. As members of PSGR and New Zealand society in general, we hold grave concerns regarding the following:

Ability to correlate reactions

When a definite specific disease state is caused by a single mechanism it is easy to identify the cause and effect connection. An historical example would be Minimata disease - due to mercury contamination of the bay in Minimata, Japan. The effects were rapid and the prevalence was high enough to signal a definite environmental change allowing accurate identification of the cause.

This contrasts, for example, with a Californian study linking Endosulphan with a 6-fold increase in rates of Autism - a connection that can only be made on epidemiological studies as opposed to testing of individual patients blood samples looking for a toxicant. In cases such as the Endosulphan study, the connection will only be made if the study is performed.

It is distinctly possible that transgenes as well as their associated increased dietary herbicide levels will, as demonstrated by research already available, produce mild though debilitating symptoms that make it hard to pinpoint a source, but which lower the standard of health of the population.

They may also cause increased rates of diseases already common such as cancer, heart disease, obesity, diabetes; again making it hard to pinpoint the source.

Time frames

It is distinctly possible that adverse reactions may not be as identifiable in the first generation exposed and there may be a time lag until definite associations are visible. It may be that the next generation suffers from a rush to adopt a technology which, in hindsight, has not been proven to be safe over time.

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 cannot place them with exactitude. Transgenic crops and foods are not subject to the same toxicology testing applied to drugs. Whereas drugs are clearly identified and monitored for adverse health effects, it is often not possible to identify transgenic foods or additives in a diet. Doctors insist patients have a right to know what is in their food and that doctors must know what their patients are eating. Many are now recommending ‘GE-Free’ diets.

Given the above, it is irresponsible of FSANZ to approve this transgenic food, to dismiss the recommendation for allergen testing made by New Zealand’s Ministry for Primary Industries and the risks raised in the many submissions it received, including that from PSGR (attached). It is irresponsible to say they consider there is no scientific justification for including data on endogenous allergens in GM food safety assessments and that they have now completely removed this requirement from their Supporting Document 1(SD1).[xviii]

We would suggest FSANZ has not done its homework. There is increasingly more and more data on the risks of ingesting transgenic foods, as demonstrated even after just one meal as detailed on page 1 of this letter.ⁱⁱⁱ The long-term risks are simply not assessed and/or ignored. A recent study raised serious health issues from ingesting transgenic foods.[xix] It has been ignored.

Assuming ‘substantial equivalence’ of transgenic food crops with conventional varieties endangers the public and the integrity of the food chain. The variables are so great that it effectively makes any degree of safety testing limited to showing a lack of evidence of harm rather than evidence of safety. When a drug is tested for safety researchers are dealing with a pure new single chemical which is being prescribed under controlled conditions in a very specific and controlled dose. When tests are made on a transgenic food, that food may have multiple new chemicals, or multiple missing chemicals, or chemicals in a different balance, any of which may alter the toxicity or allergenicity of the food. The chemical balance could vary widely with circumstances such as where the food is grown or where it is processed, and processing under different conditions. There may also be variability between plants and subsequent productions of that transgenic plant. Novel chemicals may be barely detectable in a tested product yet present strongly in the product which enters the food supply.

It is significant that the human ingestion of transgenic foods would vary widely in terms of frequency, food type, and ‘dose’.

Some commonly used drugs have presented unforeseen results outside of the post-market-release surveillance period: e.g. the anti-inflammatory drug diclofenac (a common brand is Voltaren) showed a significantly increased risk of heart attack discovered decades after its market release. Appropriate testing can reduce the risks of a new drug or chemical to be released onto the market, but a large number of all significant side effects are not found until after the drug/chemical has been released onto the market. There is no guarantee that new post-release side effects will not be serious or even life threatening.

The claim that genetically engineered organisms are substantially equivalent to non-genetically engineered organisms is a regulatory convention contrived to convenience industry. The scientific reality is that genetically engineered organisms and the food produced from them are not risk equivalent to their natural counterparts as they are not biologically identical. They contain some unequivocally different molecules resulting from the engineering process and these different molecules carry inherent risk in the same way that a new pharmaceutical molecule (a drug) does.

The chemically modified group of hormones called progestins have been found (as a part of HRT or hormone replacement therapy) to be responsible for a very significant increased risk of breast cancer in women. Progestins were introduced to the market decades before this side effect was discovered. They are a class of drugs thought to have been substantially equivalent to the natural reproductive hormone progesterone. Even though preapproval testing did show that the modified hormone increased the risk of breast cancers in dogs, it was still approved for use, and was used as if it was fully identical to natural progesterone until this human breast cancer risk finding.

The Food and Drug Administration (FDA), that in the USA not only regulates drugs but also regulates genetically engineered foods, explains the inadequacy of preapproval testing in providing proof of safety for new drug molecules. “Because all possible side effects of a drug can’t be anticipated based on preapproval studies involving only several hundred to several thousand patients, FDA maintains a system of post marketing surveillance and risk assessment programs to identify adverse events that did not appear during the drug approval process.”[xx]

The above comment is supported by another in the British Medical Journal: “When a drug is marketed little is known about its safety in clinical use because only about 1500 patients are likely to have been exposed to it.”[xxi]

In contrast, genetically engineered foods preapproval testing is very limited compared with drug testing. This usually amounts to testing involving a small number of small animals. There is no regulatory requirement for companies to undertake any human testing or the post marketing surveillance studies looking for side effects that the FDA states are necessary to identify adverse effects arising after marketing approval. The following comments indicate that even the effectiveness of these surveillance programmes in picking up drug side effects is limited.

“The increasing challenge to pharmacovigilance is not only to be able to find early signals of drug problems, but to rapidly determine the true benefits and risks. We may not have adequate systems to prevent unnecessary harm from globally marketed drugs”[xxii] and another, “Drugs continue to be withdrawn from the market because of unacceptable safety profiles; over the last 25 years, approximately 10% of new drugs that were approved in the US either had to be withdrawn or were labelled with a ‘Black Box’ warning”.[xxiii] Furthermore, it is pointed out by others that this reporting system only catches a small proportion of the side effects that are identified. “A problem with spontaneous reporting is that less than 10% of all serious and 2-4% of non-serious adverse reactions are reported. The importance of adverse drug reactions is often underestimated. . . . They are common and can be life threatening and unnecessarily expensive. . . . Adverse drug reactions are a major clinical problem, accounting for 2-6% of all hospital admissions. . . . Recent surveys in the United States have indicated that adverse drug events increase the length of hospital stay and costs. . . . The pattern of toxicity is likely to change with the introduction of new biotechnology products.”[xxiv]

From these comments it can be seen that FSANZ, in common with other regulators, does not know the true frequency or nature of side effects of genetically engineered organisms, or their derived food products, as they have inadequate pre-approval testing and they do not require post-approval surveillance of side effects. This constitutes a breach of the Ministry for Primary Industries’ biosecurity protocols referred to in the Auditor General’s recent report.

Even with post marketing surveillance the quotes above indicate that any data on the true incidence of such side effects is very limited with drugs and with a food it is likely to be much more limited. The case of drug testing has repeatedly demonstrated that it requires extensive resources to be applied to specifically look for side effects in order to discover them, except in rare instances and even with such a search some drugs which have side effects causing a greatly increased risks of disease or death may not be detected. In the case of drug side effects the personal cost of such side effects is immeasurable and the societal effect in terms of increased public health costs is also major and these side effects must be balanced by the intended benefits of using the drugs for what are often serious health conditions.

No such countervailing public benefits exist to justify the risk of genetically engineered foods. The appropriate regulation of genetically engineered organisms to avoid side effects must constitute a major safety, public rights and fiscal responsibility.

FRANZ must fulfil its responsibility to protect the safety of the New Zealand food supply for all New Zealanders, including the most vulnerable who share that food supply via their mothers, the unborn child. New Zealand's nuclear free policy has demonstrated that New Zealanders are not prepared to accept the compromise to their public safety that some other countries are. The only appropriate safety protection that FSANZ can offer New Zealanders, in regards to genetically engineered foods, is a precautionary one, which is to exclude genetically engineered foods and their derivatives as completely as possible from the New Zealand public food supply.

Transgenic food crops present multiple risks to public and environmental health when released and there is no ethical justification in allowing them into the open environment or the food supply, or for companies or regulatory authorities to imply that any amount of testing provides an assurance of safety. In fact, any government organisation is obligated by its responsibility for duty of care to the public interest to bar transgenic organisms or foods from the food chain.

New Zealanders are best protected by ensuring that transgenes in any form will not be accepted or approved for release into the New Zealand environment or food chain, including the use of animal feed containing transgenes, in keeping with the precautionary principle.

New Zealanders need to be assured that risks associated with a new technology will not be accepted or approved for New Zealand without following the precautionary principle and public consultation and a public decision making process.

It is critical to recognize that transgenic food and other genetic engineering, is a speculative, commercial project, supported by the ability of companies to own the intellectual property of transgenic life forms through patenting. The companies have the added incentive of selling their patented pesticides in conjunction with their patented transgenic agrichemical resistant crops. The companies involved are in general the most profitable businesses in the world, many of those which produce patented pharmaceuticals. These companies are legally obliged under commercial law to pursue the best financial returns for their shareholders even when doing so brings their actions into direct conflict with the public interest. These companies have economies bigger than most countries and naturally devote huge resources towards influencing national scientific, regulatory and political systems towards their own best interest. Just as companies are legally obliged to serve their corporate interest, government and all of its office holders and employees are legally obliged to uphold the public interest under administrative law. It is therefore a legal obligation upon government to ensure that its scientific research framework, its regulatory framework and its political framework, including the appointment of those who have influence in public policy decision-making, is consistent with protecting the public interest and denying commercial interests when they conflict with the public interest.

However, if there was a strongly recognized public good for a transgenic release into the environment, or into the food chain, a decision on this occurring would require stringent safety testing carried out by independent scientists who have no vested interest in the outcome and an appropriate public consultation and public decision-making process which followed a precautionary approach.

We refer you to ‘Lax GM rules may bite back – scientists’, Paul Gorman, Christchurch Press, 25 March 2013[xxv]: “International researchers - including leading New Zealand geneticist Professor Jack Heinemann of the University of Canterbury - say FSANZ and other regulatory bodies in Australia and Brazil are assuming a new type of GM molecule is safe to eat without requiring proof. The regulators are then approving products containing the GM material, which in New Zealand includes soybeans that may be present in foods such as margarines, mayonnaises, chocolate and miso.” (See full article on page 10 of this letter.)

N.B. Professor Heinemann’s peer-reviewed research with Judy Carman of Adelaide's Flinders University and Sarah Agapito-Tenfen of the Federal University of Santa Catarina, Brazil, was published in Environment International in March 2013 (see http://bit.ly/14i7pyG).^{^[xxvi]}

PSGR asks that, as the Minister representing New Zealand on the Council of Australian Governments COAG Forum, you take the absence of safety data and the dismissal of New Zealand scientific expert recommendation into account when you meet to discuss this most recent application for transgenic food and reject it as unsafe under current known criteria.

Precaution must be mandatory when applications for approval for transgenic foods are received by regulatory bodies. The valid use of scientific evidence is to set precaution, not to perpetuate permissive standards for vested interests.

PSGR maintains that it is crucial to adopt a precautionary approach to transgenic foods. We ask that you bar approval of DOW Transgenic Soy Application A1073.

The Trustees of Physicians and Scientists for Global Responsibility

‘Lax GM rules may bite back – scientists’, Paul Gorman, 25 March 2013; www.stuff.co.nz/the-press/news/8466949/Lax-GM-rules-may-bite-back-scientists

Potentially unsafe genetically modified foods are slipping into our diet because of "systematic neglect" by regulator Food Standards Australia-New Zealand (FSANZ), scientists say.

International researchers - including leading New Zealand geneticist Professor Jack Heinemann of the University of Canterbury - say FSANZ and other regulatory bodies in Australia and Brazil are assuming a new type of GM molecule is safe to eat without requiring proof.

The regulators are then approving products containing the GM material, which in New Zealand includes soybeans that may be present in foods such as margarines, mayonnaises, chocolate and miso.

Heinemann, the director of the university's Centre for Integrated Research in Biosafety (INBI), said there was no evidence such products were unsafe for humans to eat, but neither was there proof they were safe.

New research showed the GM molecule - double-stranded RNA (dsRNA) - could survive cooking and digestion. As a result it could be absorbed into the bodies of people who ate plants containing the molecules, potentially "turning off" human genes.

He said spraying the molecules directly on to crops would contaminate the air and ground within several kilometres. Also, dsRNAs could persist for a long time in the environment.

Potentially they could also be transferred into people inhaling dust from the plants, say by breathing in flour when baking with GM wheat, or through the skin.

"Our current understanding of dsRNA in GM plants is in its infancy and we are still trying to understand how they may work and therefore how they may affect humans, animals and the environment," Heinemann said in a briefing paper.

"We don't want to learn that one or more of these crops or sprays is toxic after millions of people have been exposed to them for years."

Heinemann's peer-reviewed research with Judy Carman of Adelaide's Flinders University and Sarah Agapito-Tenfen of the Federal University of Santa Catarina, Brazil, was published in Environment International on Friday.

FSANZ said it should be able to comment "in the next few weeks". "We need some time to assess the paper," spokeswoman Saffron Urbaniak said.

In the paper, the researchers said FSANZ "regularly dismissed" INBI's recommendations to describe and evaluate the GM molecule in modified foods.

The regulator had argued instead that:

- dsRNA did not transmit to humans through food.

- dsRNA would be unstable in cooking or during digestion.

Techniques that might be used to find dsRNAs were not routinely used in safety studies.

FSANZ had approved at least five GM products with dsRNA molecules for use as human food since 2000, despite "acknowledgment that there was scientific uncertainty" about how the modification worked, the paper said.

Heinemann told The Press the team's findings hardly came as a surprise. "We hope to engage in a constructive way with the regulatory authorities. The point is not to say, ‘we've caught you doing something bad', it's to say, ‘we need some science in the risk assessments'."

For that reason, the researchers had developed a recommended safety testing procedure for all GM plants with the molecules, which was published in their paper, Heinemann said.

Heinemann also said: "It seems amazing that FSANZ needs weeks to read the content of a scientific paper written on a topic on which they are presumably experts."

WHAT IS dsRNA?

GM plants are being designed to make a new RNA (ribonucleic acid) molecule, which is either double-stranded (dsRNA) or has the ability to create one. These dsRNA molecules can silence or activate certain genes in the plant.

Examples include Australian barley and wheat varieties modified to change the type of starch they produce.

Biopesticide plants containing dsRNA silence a gene in the insects that eat them, causing the insect to die.

Footnotes:

[1] http://www.responsibletechnology.org/gmo-dangers/health-risks/articles-about-risks-by-jeffrey-smith/Genetically-Engineered-Foods-May-Cause-Rising-Food-Allergies-Genetically-Engineered-Soybeans-May-2007

[2] An ingredient in Agent Orange

References:

[i] http://www.foodstandards.gov.au/_srcfiles/A1073%20GM%20Soybean%20DAS-4406-6%20AAR%20FINAL.pdf

[ii] www.responsibletechnology.org/gmo-dangers/health-risks/articles-about-risks-by-jeffrey-smith/Genetically-Engineered-Foods-May-Cause-Rising-Food-Allergies-Genetically-Engineered-Soybeans-May-2007; The Risks of Genetically Engineered Foods, Wolfson, Richard, PhD, http://www.consumerhealth.org/articles/display.cfm?ID=19991128220930

[iii] http://www.organicconsumers.org/ge/irish.cfm

[iv] Netherwood T. et al. (2001), Transgenes in genetically modified Soya survive passage through the human small bowel but are completely degraded in the colon, Food Standards Agency Project GO1008.

[v] http://www.ifrc.org/PageFiles/89755/Photos/307000-WDR-2011-FINAL-email-1.pdf.

www.gmo-compass.org/eng/agri_biotechnology/gmo_planting/257.global_gm_planting_2009.html

[vi] Chemical Research in Toxicology 2009 Jan; 22(1):97-105.

[vii] http://www.pan-uk.org/pestnews/Actives/glufosin.htm. Pers. Comm., MAFF, Pesticides Usage Survey Group. York.

Agrow No. 273 January 31st 1997, p. 21; Watkins, 1995. MAFF, Evaluation No. 33 : HOE 399866 (Glufosinate-ammonium), Ministry of Agriculture Fisheries and Food, London, 1990. US EPA, Office of Pesticides and Toxic Substances, Experimental Use permit (6340-EUP-RN) and Temporary Tolerance Petition (4G3156) for HOE 39866. Memo from D.S. Saunders to R. Mountfort, Registration Division, 18th April 1985. MAFF, Health and Safety Executive, 1991. Advisory Committee on Pesticides Annual Report 1991, HMSO, London Fujii et al 1996; Watanabe, 1997; Watanabe and Iwasi, 1996. MAFF, Health and Safety Executive, 1991. Advisory Committee on Pesticides Annual Report 1991, HMSO, London; Pesticides Trust [now PAN UK], Crops Resistant to Glutamine Synthetase Inhibitors.

[viii] Kohli, J D et al, Absorption and Excretion of 2,4-Dichlorophenoxyacetic Acide in Man, Xenobiotical 1974, 4 (2), 97-100.

[ix] 2,4-Dichlorophenoxyacetic Acid, CAS No. 94-75-7,

http://www.cdc.gov/exposurereport/data_tables/2,4-DichlorophenoxyaceticAcid_ChemicalInformation.html;

Reregistration Eligibility Decision (RED) 2,4-D: EPA 738-R-05-002. US Environmental Protection Agency, Office of Prevention, Pesticides and Toxic Substances, Office of Pesticide Programmes, 2005. Munro I C et al, Comprehensive, Integrated Review and Evaluation of the Scientific Evidence Relating to the Safety of the Herbicide 2,4-D. J.Am.Call.Toxical. 1992, 11, (5), 559-664.

http://npic.orst.edu/factsheets/2,4-DTech.pdf.

[x] Annex IV ANSES - http://www.efsa.europa.eu/en/supporting/pub/392e.htm

[xi] http://www.aaemonline.org/gmopost.html

[xii] http://www.aaemonline.org/gmopost.html

[xiii] Finamore A, Roselli M, Britti S, et al. Intestinal and peripheral immune response to MON 810 maize ingestion in weaning and old mice. J Agric. Food Chem. 2008; 56(23):11533-11539. Kroghsbo S, Madsen C, Poulsen M, et al. Immunotoxicological studies of genetically modified rice expression PHA-E lectin or Bt toxin in Wistar rats. Toxicology. 2008; 245:24-34.

[xiv] Dona A, Arvantoyannis I S, Health Risks of genetically modified foods. Crit Rev Food SciNutri. 2009; 49: 164-175.

http://www.somloquesembrem.org/img_editor/file/Dona&Arvanitoyannis2009.pdf

[xv] ‘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 BiolSci 2009; 5(7):706-726. doi:10.7150/ijbs.5.706, 11 February 2013, http://www.biolsci.org/v05p0706.htm. www.biolsci.org

[xvi] ‘Maternal and fetal exposure to pesticides associated to genetically modified foods in Eastern Townships of Quebec, Canada’, Aris A, Leblanc S. Department of Obstetrics and Gynecology, University of Sherbrooke Hospital Centre, Sherbrooke, Quebec, Canada, Reprod Toxicol. 2011 May;31(4):528-33. doi: 10.1016/j.reprotox.2011.02.004. Epub 2011 Feb 18.

[xvii] IV ANSES http://www.efsa.europa.eu/en/supporting/pub/392e.htm

Toxicological details of 2,4-D section 1485-1524 (A1073) Glyphosate 1698 -1713 (A1073) , quizalofop -P 542 - 618 (A1042, A1046)

[xviii] Approval Report -Application A1073 - Food derived from Herbicide-tolerant Soybean DAS-44406-6 (p.15) http://www.foodstandards.gov.au/_srcfiles/A1073_AppR.pdf

[xix] Seralini. G-E., Clair. E., Mesnage. R., Gress. S., Defarge. N., Malatesta. M,.Hennequin. D. and de Vendomois. JS. (2012) Long term toxicity of a Roundup herbicide and a Roundup-tolerant genetically modified maize. Food and Chemical Toxicity.Vol: 50, (11) 4221–4231. http://dx.doi.org/10.1016/j.fct.2012.08.005

[xx] http://www.fda.gov/ForConsumers/ConsumerUpdates/ucm090385.htm

[xxi] BMJ. 1998 April 25; 316(7140): 1295–1298.

[xxii] Journal of the Royal College of Physicians of London [2000, 34(1):48-51]

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