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Dr. Brian John of GM-Free Cymru and Dr. Mae-Wan Ho, Director of the Institute
of Science in Society, both members of the Independent Science Panel on GM launched
10 May 2003, have written a strongly worded letter to Margaret Beckett to challenge
the approval of Chardon LL GM maize for Britain. The letter is reproduced below.
Please circulate widely.
From the INDEPENDENT SCIENCE PANEL
19 February 2004
The Rt Hon Margaret Beckett, MP
Department of the Environment, Food and Rural Affairs,
Nobel House, 17 Smith Square, London SW1P 3JR
Dear Mrs Beckett,
We are gravely concerned by the leaked Minutes of the Cabinet Office
Ministerial Sub-Committee on Biotechnology, which demonstrate that you are
about to give approval for the National Seed Listing of Chardon LL.
We respectfully remind you that if you do that you will be failing to
exercise the duty of care that you owe to the public, and also failing to
act as required by Article 20 of the Deliberate Release Directive
(2001/18/EC). This article requires competent authorities (ie your
Department) to bring to the attention of the European Commission and other
EU countries any new evidence relating to Chardon LL which might involve a
likelihood of harm arising from its use. This information should be
accompanied by a request for a variation in the conditions attached to the
original consent which comes to an end in October 2006.
In this case the "lead" competent authority responsible for the original
consent is France. We understand that the FSE research results and the ACRE
recommendations have already been submitted to France and the other EU
countries, and to the Commission. This is a start, but we urge you as a
matter of the highest priority to request a variation in the consent
conditions, citing the following crucial scientific evidence:
1. Chardon LL transgenic insert has changed from the structure
reported in
the company's original dossier, indicating it is unstable, and hence illegal
under the current EC directive on the deliberate release of GMOs. Studies
by a French scientist also found that the transgenic insert in Chardon LL is
in a transposon, which would further increase its instability.(1)
2. Its instability is associated with CaMV 35S promoter, mentioned
in the
minutes of the European Food Safety Authority plenary meeting 10 December
2003. The EFSA also raises other safety issues that have not been
addressed by the UK Government. (2)
3. By common consent, the FSE maize trials did not replicate
the likely
commercial growing conditions that would apply if Chardon LL is grown in the
future. The ACRE assessment of the FSE research results was not a simple
"positive assessment." The ACRE opinion was a highly qualified one,
with a
recommendation that Chardon LL should only be grown in the UK if the
herbicide regime is EXACTLY AS IT WAS IN THE FSEs. (3)
4. There was a virtually identical opinion on the FSE research
from the GM
Science Review Panel chaired by Sir David King, ie that plantings of Chardon
LL would be acceptable "IF ALL ELSE REMAINS CONSTANT AND THE CROPS ARE
INTRODUCED AND MANAGED IN THE WAY THEY WERE IN THE TRIALS."
5. There are now major concerns about the toxicity of GA (Liberty)
herbicide (5). We understand that Sweden is currently conducting a review
of the safety of GA on behalf of the other EU countries. In addition, the
Danish authorities have discovered dangerously high levels of the herbicides
used with GM crops in groundwater where it it not supposed to persist (6).
6. There is published and peer-reviewed information from the
USA on the
ineffectiveness of Liberty when used on its own with GM maize crops after 2
- 3 years. The problem manifests itself in the development of herbicide
resistance by common weeds (7). Bayer has recognized this itself, and has
been recommending a Liberty / atrazine mix to US GM-maize farmers since
early 2001. (8) (9)
7. We have seen reports of cattle deaths in Germany associated
with
Syngenta Bt 176 maize (10). This is similar to Chardon LL in that it is
unstable as well as nonuniform, and it shares the CaMV 35S promoter
responsible for instability. We are also mystified as to the fate of the
famous Reading University feeding studies on Chardon LL, years after their
results should have been published. (11)
8. Recent reports on cross-pollination involving blue maize
and purple
maize suggest that there are serious shortcomings in the current DEFRA view
that GM maize is unlikely to out-cross significantly beyond a few tens of
metres. Cross-pollination and hybridization of conventional maize was
identified at a distance of c 5 km from the source crop (12) (13). It is
not known at present whether this contamination was above the 0.9%
threshold.
There are other scientific concerns also, some of which were analysed in
detail during the Chardon LL Hearing. Many of these concerns have not been
adequately addressed by ACRE.
Please confirm receipt of this letter, and confirm that you will immediately
take the actions required by Article 20 of the Directive.
We look forward to hearing from you.
Yours sincerely,
Dr Brian John and Dr Mae-Wan Ho
Independent Science Panel
NOTES
(1) Mae-Wan Ho, Transgenic Lines Proven Unstable,
http://www.i-sis.org.uk/TLPU.php Collonier C. et al., Characterization of
commercial GMO inserts: a source of useful material to study genome
fluidity. www.crii-gen.org)
(2) Mae-Wan Ho, Unstable Transgenic Lines Illegal.
http://www.i-sis.org.uk/
(3) ACRE advice on the implications of the farm-scale evaluations
of
genetically modified herbicide-tolerant crops. January 13, 2004, paras
36-40.
(4) see para 24 of the ACRE advice 13 Jan 2004. Also:
http://www.gmsciencedebate.org.uk/pdf/gmsci-fse-acre.pdf
(5) Prof Malcolm Hooper "Evidence with special emphasis
on the use of GA
herbicide", Chardon LL Hearing, May 2002.
See also: Josef Hoppichler (Austrian Federal Institute for Less-Favored and
Mountainous Areas), "Critical Observations Regarding the Use of Genetic
Engineering in Agriculture and Food"
Voluntary Report - public distribution
Date: 2/2/2004
GAIN Report Number: AU4002
AU4002
Austria
Biotechnology
Austrian Observations on Biotechnology in Food and Agriculture 2004
Approved by: Robert H. Curtis, U.S. Embassy, Vienna
(6) Analyses of the Danish Pesticide Leaching Assessment Programme
found glyphosate and its degradation products in groundwater above the
warning concentration of 0.1Y´µg/l. Denmark has thus restricted
the
application of Roundup. It is reasonable to assume that GA herbicide would
have the same effect.
(7) The spread of glufosinate-resistant weeds is a growing
problem likely to
make the use of Liberty ATZ almost essential in areas where GM maize has
been grown for several years. American researchers have documented the
emergence since 1996 of heritable glufosinate-resistance in
ryegrass,goosegrass, horsetail and waterhemp in areas of high glufosinate
(Liberty) use. See this:
http://www.weeds.iastate.edu/research/2000/ne/ncs1.pdf
(8) The marketing and packaging materials for Liberty ATZ
say that it is
specifically for use on Bayer Cropscience GM maize. The Aventis Liberty ATZ
Data Sheet was printed on 12/03/2001, ie before the commencement of the
British FSE maize programme. Therefore it must be concluded that
Aventis/Bayer knew prior to 2001 that Liberty would be mixed with ATZ for
commercial plantings, but still applied for the use of unmixed Liberty in
the FSE trials.
(9) Transcript of BBC 2 - Newsnight - Tuesday 25th June on
Atrazine use on
GM Maize at:
http://www.btinternet.com/~nlpwessex/Documents/newsnightGMmaizeatrazine.htm
In the Newsnight report, 25th June 2002, agricultural experts revealed
that between 75% and 90% of US GM maize growers were using a product called
Liberty Atz - a mixture of Aventis' weed killer GA and Atrazine, the
traditional herbicide used on maize crops. Atrazine has been a problem
pesticide for decades, and washes readily into rivers and groundwater. It
is an EU Red List pesticide and is on the EU Priority List for hormone
disrupting effects in animals.
(10) The Institute of Science in Society http://www.i-sis.org.uk
Mae-Wan Ho and Sam Burcher, "Cows ate GM Maize & Died". See also
reports in
Science and Society that animals avoid GM feed,if given the choice, and if
force-fed on GM fodder, fail to thrive.
(11) At the ACRE hearing into T25 in Feb 2002
Prof Phipps of Reading University gave evidence on cattle feeding for Bayer.
He said that he and his colleagues had carried out a cattle feeding study
using silage from an FSE maize site. The study was complete and being
written up for publication in a peer reviewed journal. Since then nothing
has been said or appeared, and it is therefore assumed that the results of
the study have been so disastrous that they have been withheld from public
or peer-review scrutiny.
(12) Letter from Scientists for Global Responsibility to The
Rt Hon
Margaret Beckett re "New Evidence of Long-Range Pollination by Maize"
5th February 2004. Letter signed by Dr Eva Novotny.
(13) Corn pollen drifts further than thought, 29 Sep 2003
http://www.agriculture.com/default.sph/AgNews.class?FNC=goDetail__ANewsindex_html___50672___1
(Iowa State University project examining the distance corn pollen travels to
breed neighboring corn surprised researchers).
Cc:
Dr David King
GM Science Review Panel
Room 472, Office of Science and Technology, 1 Victoria Street, London, SW1H
0ET
Prof Christopher Pollock
Advisory Committee on Releases to the Environment
ACRE Secretariat, Zone 3/G9, Ashdown House, 123 Victoria Street, London,
SW1E
6DE
Dr Les Firbank
The Institute of Terrestrial Ecology (Centre for Ecology and Hydrology)
CEH Lancaster, Lancaster Environmental Centre, Library Avenue
Bailrigg, Lancaster, LA1 4AP
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