Comment on Assessment ReportC/GB/02/M3/03 (herbicide tolerant and insect resistant
hybrid maize, NK603xMon810)
No credible evidence that NK603xMon810 is safe for animal and human
The Assessment Report C/GB/02/M3/03 contains no credible evidence that NK603xMon810
is safe for animal and human health.
No independent molecular data were provided to ascertain that the transgene
inserts are stable as claimed by the company
No independent molecular data were provided to ascertain that the transgene
inserts remained stable in the seeds set that will be used for animal feed and
No toxicological studies were carried out
No tests for allergenicity were conducted
No feeding trials were done on cows or pigs
No data accompanied Monsanto's own feeding trial on chickens
Not a single reference was made to peer-reviewed scientific literature
Thus, there is no justification for the advice from ACRE (Advisory Committee
for Releases to the Environment) that this hybrid GM maize "does not pose
a risk to human health or the environment".
ACRE has ignored all evidence to the contrary
On the contrary, ACRE has totally ignored existing evidence suggesting that
NK603xMon810 may not be safe. We consider first the parental lines, Mon810 and
1. Parental lines proven unstable and hence illegal under European legislation
The transgene insert in the parental line Mon810 has proven to be unstable,
i.e., it has rearranged since characterized by the company [1-5]. Likewise,
the transgene insert in the NK603 line was also found to have rearranged ,
which may be part of the reason why its application for import into Europe for
food and processing has failed to gain the required majority vote in the Regulatory
Committee on the release of GMOs into the environment on 18 February 2004.
According to the new European Directive for deliberate release 2001/18/EC,
event specific characterization of the transgenic insert as proof of transgenic
stability is required for approval. Such even-specific characterization is also
necessary to satisfy EC Novel Foods Regulation 258/97 and regulations 1139/98/EG
and 49/2000 for traceability and labeling. Thus, both parental lines should
be considered illegal within current European legislation. This applies all
the more so to the hybrid NK603xMon810 derived from the two parental lines.
2. NK603xMon810 needs to be characterized for stability
Independent re-characterization of the transgenic inserts in NK603xMon810 is
required because of the strong possibility of non-homologous recombinations
(genome scrambling) between the two non-allelic inserts in the parental lines
which nevertheless possess sequence homologies, specifically, in the cauliflower
mosaic virus (CaMV) 35S promoter with enhancer (e35S) and the hsp70 intron used
to drive transgene expression in both events NK603 and Mon810.
3. Transgene instability is above all a safety issue
The stability of the transgene insert in a GMO is above all a safety issue.
The fact that the transgenic lines have undergone genetic rearrangement since
the company carried out safety tests automatically invalidates all those tests.
As everyone knows, the characteristics of a transgenic line depend entirely
on where in the genome and in what form the inserts have integrated; if an insert
has rearranged or moved elsewhere, then the transgenic line, by definition,
has lost its original identity and become a different line.
4. Mon810 insert associated with a mobile genetic element
The insert for Mon810 has been extensively characterized in the published literature.
The host genome flanking the 5' (head) end of the insert shows homology
to the long terminal repeats (LTR) of the maize alpha Zein gene cluster; but
no homology to the maize genome was detected at the 3' site, indicating
that there had been scrambling of the maize genome at the insertion site [1-3].
Long terminal repeats are found in mobile genetic elements and often contain
strong promoters that respond to environmental signals. That not only makes
secondary mobility of the insert (horizontal gene transfer) much more likely,
but also lead to major disturbances in host gene expression.
Transgene inserts in general show a strong preference for mobile genetic elements.
One study  found that the insert in Chardon LL T25, recently approved by
the UK government for commercial growing, is located in a retrotransposon.
5. The CaMV 35S promoter remains a major safety concern
We have raised serious safety concerns over the CaMV 35S promoter, which is
known to have a recombination hotspot and to be active in species across the
living world, including human cells [7-9]. We note that both events NK603 and
Mon810 have transgenes driven by this promoter, as have other GM maize lines
that the UK government has recently approved: Bayer's Chardon LL T25,
and Syngenta's Bt 176. The safety of this promoter has been set as one
of a list of "self tasking activities" recorded in the minutes of
the European Food Safety Authority 5th Plenary Meeting of the Scientific Panel
on Genetically Modified Organisms held on 11 December 2003 . The relevant
paragraph is reproduced below:
"10. TERMS OF REFERENCE FOR SELF TASKING ACTIVITIES
The members of the GMO Panel are invited to provide written comments by the
next plenary meeting on the following proposals for self tasking activities:
- Impact of GMOs on microbial biodiversity and function in the soil environment
- Post market monitoring of crops
- Assessment of allergenicity of genetically modified (GM) foods
- Post market surveillance of genetically modified (GM) foods
- Safety of use of viral promoters and specifically of the cauliflower mosaic
virus (CaMV) promoter. "
The minutes of the subsequent meeting held in January 2004, recorded that this
issue remains unresolved, and is "deferred to a later stage" .
6. Major incidents involving GM maize with Bt toxins
Finally, we draw your attention to two incidents involving GM maize containing
Bt toxins (from soil bacterium Bacillus thuringiensis). Only one case
is under investigation by scientists.
Between 2001 and 2002, 12 dairy cows died on a farm in Woelfersheim in the state
of Hesse in Germany after being fed Syngenta's Bt 176 maize; and other animals
in the same herd had to be slaughtered on account of mysterious illnesses .
The Robert Koch Institute made little attempt to investigate the deaths and
illnesses and the local district council in Giessen issued a statement in August
2003 stating that "the cause of incidents referred to could not be determined."
We pointed out  that Bt 176 suffers from the worst transgenic instability
of all the transgenic lines examined recently by French and Belgian government
scientists, who found that the company may also have misidentified or misreported
the particular Cry1A protein present. Syngenta claims that the transgene in
Bt176 is crylAb, but on analysis, the sequence of the transgene was 94%
similar to a synthetic crylAc gene, and has only 65% homology with the
native cry1Ab gene of Bacillus thuringiensis subsp kurstaki, from which
it was supposed to have been derived.
This incident highlights the regulatory sham surrounding Bt crops [14, 15].
Bt toxins encompass a large superfamily of Cry proteins made by different strains
of B. thuringiensis. The Bt transgenes incorporated into GM crops, however,
are often synthesized in the laboratory, containing truncated (pre-activated)
versions of the natural toxins (as in the case of Mon810) which means that they
can harm non-target insects and other animals, or changes in amino acid sequences,
or hybrid sequences of two or more Cry toxins, such that the toxicities to insect
pests and other animals are totally unknown and untested. Yet, regulators have
routinely accepted toxicity and allergenicity tests based on the natural toxins
isolated from B. thuringiensis.
Last year, scores of villagers in the south of the Philippines living near fields
planted with Dekalb 818 YG - which turns out to be a hybrid between Mon810 and
a locally adapted variety (Dekalb 818) - became ill when the maize started to
flower. Dr. Terje Traavik, director of the Norwegian Institute of Gene Ecology,
found antibodies reacting against the Bt toxin Cry1Ab, which is produced by
Mon810, in the sera of 39 farmers who were affected. He reported this finding,
along with other results of research in progress during a workshop preceding
the Meeting of the Parties of the Cartagena Biosafety Protocol in Kuala Lumpur,
Malaysia on 22 February 2004. He considered those results too important for
public health to wait until the scientific reports appear in print after a lengthy
"peer-review" process, and wanted to issue a timely warning to the
delegates attending the official biosafety meeting
This provoked an immediate reaction from the pro-GM lobby, which has been running
a campaign to discredit Traavik ever since. Traavik has reaffirmed his findings
in answer to his critics :
"We have used direct and inhibitory ELISAs (enzyme-linked immuno-sorbent
assays) to demonstrate IgA, IgG and IgM antibodies specifically binding to Bt-toxin
Cry1Ab in sera from Philippine farmers. A general interpretation would be that
the farmers had been exposed, in an immunologically meaningful way, to Cry1Ab,
or an antigen sharing epitopes with Cry1Ab, during the last 6-9 months before
blood samples were taken. This might indicate coincidence in time between three
observed events: the very first pollination season for Bt-transgenic maize,
an outbreak of respiratory/intestinal disease among individuals living close
to the Bt-maize field, and the production of serum antibodies. I strongly emphasized
that the tests could not establish any cause-effect relationships between the
3 events, neither could the results preclude such relationships, and hence they
might represent an early warning. As I said at the time, even if I had been
able to present the detection of specific anti-Cry1Ab IgE antibodies, my conclusions
would have been the same."
The companies have repeatedly denied that Bt toxins are allergenic, but there
are reports in scientific literature that Cry1Ac is a strong immunogen [17-19],
and hence a potential allergen. Cry1Ac shares many Cry1A epitopes with CrylAb.
Furthermore, as Travvik points out, "Bacillus thuringiensis spraying
has elicited specific Cry1A antibodies in farm workers, within the same classes
we detected, as well as allergy-related IgE antibodies. These findings
were published already in 1999.." .
Recently, researchers in Japan's National Institutes of Animal Health,
Food Research, and Livestock and Grassland Science found that Cry1Ab protein
in GM maize Bt11 survives digestion in the gut of pigs [21, 22]. Its digestibility
was estimated to be 92% by comparison with indigestible chromic oxide. Researchers
from the Center for Genetic Engineering and Biotechnology in Havana Cuba had
earlier identified 6 proteins in the brush border that bind specifically to
Cry1Ac [23, 24], a toxin in the same family as Cry1Ab.
In conclusion, we consider the approval of NK603xMon810 and other GM maize mentioned,
T25 and Bt176, to be a serious abuse of science in face of scientific and other
evidence indicating that these GM crops pose serious health risks.
Dr. Mae-Wan Ho Prof. Joe Cummins
Institute of Science in Society
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