GM Science Review: First report
This
Group’s response is:
Executive
Summary
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The
Executive Summary minimises the extent of uncertainty and lack of research, as
acknowledged in the body of the report (see below).
It is noted
that some scientific evidence which has not been peer-reviewed and published
has also been used (pp 8-9) The problem
we see with this is that GM development is not a scientifically neutral field
of research but is dominated by a small number of powerful commercial
corporations (with political resources and backing). Peer review will normally put knowledge into
the public domain, and in consequence cutting edge knowledge which has a likely
future commercial value may not be subjected to peer review and/or to a full
safety audit.
The
similarity of GM to traditional breeding transformations is over-emphasised
(pp50-52). The latter occurs only within the same family or with viruses.
5.2.3
Compositional equivalence (p 70)
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Two
molecules may be compositionally and structurally identical, the one being the
mirror-image of the other, but have widely differing properties.
5.2.6
Lack of successful litigation (p 73)
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We do
not consider this to be a valid “form of societal evidence”. Impoverished farmers dependent upon bio-tech
companies for seed, pesticide and herbicides cannot fund litigation. It is also often very difficult to link cause
and effect for low-level poor human health.
Is
there a serious error in the phrase “Milder or less widespread or more delayed
adverse effects can be completely ruled out…” – should can be cannot?
5.5.1
GM crop plants with enhanced value as animal feed (p 101)
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We do
not accept the assertion that such crops will reduce pollution. It is over-dense stocking that causes
pollution. Soil microbes naturally recycle faeces, particularly when composted.
6.2.1
Alien species model (p 111)
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We
believe that the emerging evidence is undermining the credibility of the Crop
Model. The alternative hypothesis of the
Alien Species Model that roughly 1% of introduced GM plants would become pests, is not reassuring.
The number of new pests is not the main concern but the extent of the
devastation that a very few or even a single species can cause (numerous
examples from
6.3.3 Anecdotal
evidence (p 132)
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We
detect bias in the characterisation of
6.4.3
Resistance to several herbicides - "gene-stacking" (p 143)
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The
statement that HT gene-stacked volunteers are not an agricultural problem
because of the multiplicity of herbicides available fails to mention that this
may lead to the use of older, more toxic, herbicides. This is a wider problem than the single
example quoted from English Nature.
The
report frequently admits lack of knowledge or lack of research. Examples, but not the only ones, are on
pages:-
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73, 74,
79, 98, 100, 103,104, 107, 113, 116, 118, 119, 124, 127, 132, 135, 147, 148, 152,
153, 174,
178, 188-189, 190, 191, 193, 198, 202, 212, 221, 223, 232, 233.
We also
make these points:-
1.
Commercial GM crops come as part of an operation by a small number of transnational corporations which seek to create and exploit
a monopoly of the food supply of the World.
The operation includes the use of the corporations’ designated
pesticides and/or herbicides. The report
does not examine the possible consequences of this.
An
example is atrazine which was used on GM maize in the
farm trials in this country. Yet this is
one of the pesticides that, on the basis of other scientific evidence, are to
be banned by a European Pesticides Directive.
This undermines the value of the farm trial as a guide to whether GM
commercial planting should be permitted here.
There
is an impact of pesticides on soil and the micro-organisms in it, the amount
and quality of both of which are diminishing across the World. From this First Report it does not appear
that the possible harmful effects of the accumulated use of glyphosate
or glufosinate on this phenomenon are being evaluated
in the Scientific Review. We believe
that they must.
2. As
more GM crop plantings are scientifically examined more adverse environmental
effects are being reported. The concerns
of some scientists that horizontal gene transfer will occur appear increasingly
to be validated. We see no evidence to
support the re-assurance that this transfer is “likely to be reversible”.
3. We believe
that the Scientific Review must take account of:
(i) Dr. Pusztai’s
work on potatoes.
(ii)
“Characterisation of the Roundup Ready Soybean insert”( P. Windels
et al, Eur Food Res Technol 213:107-112, 2001) where it was found that a
segment of a plant’s own DNA had been scrambled and that “The abnormal DNA was
large enough to produce a new protein, a potentially harmful protein”.
(iii)
“Evaluating the risks associated with using GMOs in
human foods” – the July 2002 report of research at
(iv) “GM Science Review deeply flawed” by Dr Mae-Wan Ho
(“Science and Society” No. 19, Summer 2003) and Dr Ho’s
other work on GMOs, particularly the dangers of
horizontal gene transfer.
(v)
“Unravelling the DNA myth” (B. Commoner in Seedling July 2003) which questions
the scientific theory that inheritance is governed only by DNA:-
“Molecular
genetics is now confronted with a growing disjunction between this widely
accepted premise and an array of discordant experimental results that
contradict it. But this disparity
remains largely unacknowledged and experiments with transgenic plants and
animals (many of which are not even recognized to be experiments) continues on
a massive scale.” One of the sources to
which Commoner refers in support of this is:-
(vi)
“Updated molecular characterisation and safety assessment of Roundup Ready
Soybean Event 403-2” Confidential Report [MSL-16712] produced by Monsanto
Product Safety Center, Monsanto Company,
We are
concerned that Commoner, the Monsanto report and Windels
do not figure in your Review, while the
4. Our
members welcome the conclusions in the report that although there have been no
verifiable adverse effects from GM food, this does not mean that they are safe;
and the recommendation that caution continue to be exercised with regard to
allergies.
5. We
welcome the removal of “substantial equivalence” from the discussion.
6. GM
crops will eliminate the possibility of uncontaminated organic seed and thus of
organic crops and food which the population, including our members, is
increasingly demanding.
7.
While we recognize the scope of the Science Review we do not believe it can
disregard the fact that non-GM agricultural techniques already available are
fully capable of satisfactorily feeding the World. GM food is not needed. GM seeds of which the patents are owned by a
few transnational corporations will create monopoly
monocultures, seriously harming health, food security and biodiversity.