Chardon LL Public Hearing Ocober 26 2000 on behalf of
Dr. Mae-Wan Ho
I obtained my B.Sc. Biology (1964) and Ph. D. Biochemistry (1967) from
Hong Kong University, and was Postdoctoral Fellow in Biochemical Genetics,
University of California San Diego, from 1968 to 1972. An award of a
Fellowship of the US National Genetics Foundation took me to London
University in the United Kingdom, where I became Senior Research Fellow in
Queen Elizabeth College. I then became Lecturer in Genetics (from 1976)
and Reader in Biology (from 1985) in the Open University, and since
retiring in June 2000, Visiting Reader in Biology at the Open University
and Visiting Professor of Biophysics in Catania University, Sicily. My
career so far spanned more than 30 years in research and teaching in
biochemistry, evolution, molecular genetics and biophysics, with over 200
publications including 10 books. Since 1994, I have been scientific
advisor and spokesperson for the Third World Network on biotechnology,
biosafety and related issues, and have produced many reports and papers on
the subject for policy-makers and the general public, as well as articles
for peer-reviewed scientific journals.
In 1999, I co-founded the Institute of Science in Society (ISIS) of
which I am Director. ISIS is a not-for-profit organisation promoting
socially and ecologically accountable science and the integration of
science in society. ISIS also represent a group of scientists around the
world (currently 364 from some 40 countries) who have co-signed a World
Scientists Statement and Open Letter to All Governments, calling for a
moratorium on environmental releases of GMOs on grounds that they are
unsafe, and to revoke and ban patents on life-forms and living processes,
on grounds that they are unethical (1).
I reiterate ISIS written objections to placing Chardon LL on the
National List which have been submitted,
- The initial EU approval for Chardon LL
is unlawful according to the EUs own regulations.
- The data submitted by the company fail in important respects to
satisfy international agreements on safety of GMOs already reached on
the Biosafety Protocol and the Codex Alimentarius Commission of the WHO.
- The transgenic insert contains hazardous DNA.
- The tests conducted by the company fail to address impacts on health
Today, I want to explain why GMOs are different, how they are made, why
they are inherently unreliable and unsafe, and how current regulatory
processes fail to protect health and biodiversity, using Chardon LL as a
One of the major shortcomings of current regulatory systems is their
fragmented state, reflecting the fragmented state of the science. Those
busy exploiting the technology for biomedicine are unaware of what is
happening in agriculture and vice versa. Many applications are not
regulated because they fall between the scopes of different directives and
regulatory bodies (2,3). Regulators pay lip service to the precautionary
principle which is enshrined in the International Biosafety Protocol under
the UN Convention on Biological Diversity negotiated in Montreal in
January 2000, and to which the UK Government is a party. In practice,
however, they have been adopting the anti-precautionary approach,
and confusion abounds over how scientific evidence is to be interpreted
and used (4).
GMOs are a new departure from conventional selective breeding
The creation of genetically modified organisms (GMOs) is a new departure
from conventional selective breeding and introduces new hazards. This view
is shared by many scientists, including those advising the United States
and United Kingdom Governments (1). The techniques and the nature of
artificial constructs (GM constructs) made are the same in all
applications of GMOs, whether in agriculture or in biomedicine, and so are
the hazards involved.
Conventional selective breeding is restricted to crossing varieties
within a species or between closely related species with similar genetic
makeup. That is because genetic barriers prevent reproduction between
unrelated species and limit the exchange of genetic material between them.
GMOs are created in the laboratory by genetic engineering, techniques
that modify the genetic material directly. The genetic material is
deoxyribonucleic acid or DNA. DNA is made up of long strings of four
different units, A, T, C, G repeated apparently at random for millions or
billions of times. The exact sequences matter, as they code for specific
proteins and enzymes that make up intricate structures of the organism and
enable the organism to transform material and energy to grow, develop and
do all the things that constitute being alive. The totality of all the
genetic material of an organism is its genome, which is organized in a
specific way typical of a species, and represented in every cell of the
In making GMOs, genetic material from different sources are cut and
recombined to make artificial GM-constructs that are transferred into the
genomes of organisms. So, genes can be combined from widely disparate
sources, and transferred between species that would never interbreed in
nature. In other words, the GM-constructs are designed to overcome species
barriers and to invade genomes. There is thus no limit to the new genes
and new combinations of genes that can be made in the laboratory, nor to
the GMOs created, all of which may never have existed in billions of years
What genetic materials are used in GM constructs and how are GMOs made?
Most of the genes used in GM constructs originate from a wide variety of
bacteria and viruses that cause diseases and other genetic parasites which
spread drug and antibiotic resistance genes. A gene is never used by
itself. It needs a start and a stop signal, a promoter and a terminator.
The promoter-gene-terminator together form a unit GM-construct known as an
expression cassette which looks like this:
Very often, the three parts of the expression cassette originate from
different sources. The promoter is usually from a virus, which makes the
gene over-express at very high rates continuously, to make lots of the
protein or gene product. This is something that never happens in a healthy
organism, and effectively puts the gene outside the normal metabolic
regulation of the GM organism. The most common promoter used in plants is
from the cauliflower mosaic virus (CaMV), a plant pathogen. The CaMV 35S
promoter is in practically all GM crops already commercialized or
undergoing field trials. The gene pat coding for resistance to the
herbicide glufosinate in Chardon LL is derived from the soil bacterium,
Streptomyces viridochromogenes, joined to the CaMV 35S promoter
Apart from the expression cassette containing the gene of interest, it
is necessary to have at least one other cassette containing an antibiotic
resistance gene with its own promoter and terminator. This enables the
genetic engineer to select for cells that have taken up the GM construct
with the antibiotic, which kills off all other cells. Two or more
expression cassettes are linked or stacked in series in a typical GM
construct. Chardon LL has an expression cassette for AmpR, a gene
coding for resistance to ampicillin, belonging to the gut bacterium, Escherichia
coli, although the gene is not actively expressed in the GM plant.
For ease of handling and bulking up GM constructs, and for transferring
them into genomes, genetic engineers make a large variety of artificial
gene carrier or vectors (5) by combining parts of the most aggressive
natural vectors, viruses, plasmids and transposons.
A virus consists of genetic material wrapped in a protein coat. It sheds
its overcoat on entering a cell and can either hi-jack the cell to make
many more copies of itself, or it can jump directly into the cells
genome. Plasmids are pieces of free, usually circular, genetic
material that can be indefinitely maintained in the cell separately from
the cells genome, and replicates with the cell. Transposons, or jumping
genes, are blocks of genetic material which have the ability to jump
in and out of genomes, with or without multiplying themselves in the
process. Genes hitch-hiking in genetic parasites therefore, have a greater
probability of being successfully transferred into cells and genomes.
Genetic parasites are vectors for gene transfer.
Natural genetic parasites are restricted by species barriers, so for
example, pig viruses will infect pigs, but not human beings, and cabbage
virus will not attack tomatoes. It is the protein coat of the virus that
determines host specificity, which is why naked viral genomes (the genetic
material stripped of the coat) have generally been found to have a wider
host range than the intact virus. Similarly, the signals for propagating
different plasmids (such as the origin of replication) and
transposons are usually specific to a limited range of host species,
although there are exceptions.
Artificial vectors, however, are especially designed to overcome species
barriers and to invade genomes, so a vector can transfer, say, GM
constructs containing human genes spliced into it, to the genomes of all
other mammals, or of plants. Artificial vectors greatly enhance horizontal
gene transfer, or gene transfer across species barriers.
In making GMOs, the GM construct is generally spliced into an artificial
vector and vector sequences often end up in the resultant GMO, even parts
of the vector that are not intended to do so. This gives rise to
uncharacterized, unknown sequences that may not be safe.
Chardon LL was made by splicing the pat gene expression cassette
into the artificial vector pUC18, which already contains the AmpR
gene. The pUC18 vector is derived from a naturally occurring plasmid,
ColE1 of E. coli, joined with a part of a transposon that contains
the AmpR gene. It is maintained in high numbers of copies in the
E. coli cell on account of a very active origin of replication,
and hence offers a convenient way to bulk up the GM construct. Chardon LL
therefore contains almost all of the pUC18 plasmid vector sequence as well
as the pat gene expression cassette.
The genetic engineer cannot control or target where and in what form the
GM construct becomes integrated into the genome. Each GM line is the
result of one or more transformational events in a single
plant cell, in which the GM construct integrates into the cells
genome. An entire plant is grown from that cell, the progeny of which
constitutes the GM line. Because transformation is random, each
transformed cell, and hence the GM line derived from it, will be distinct,
despite the fact that the same GM-construct(s) and plant cells are used.
GM constructs are also structurally unstable, and are frequently
rearranged (scrambled up), deleted or repeated in part or in whole when
they are integrated into the host genome. The resultant GMOs, likewise,
are unstable and do not breed true, as significant genetic and epigenetic
changes may occur in subsequent generations (6-8), multiplying the
unpredictable risks to health and biodiversity.
Thus, unless there are good molecular genetic data documenting the
genetic stability of the GM line, it is impossible to guarantee that it is
stable or uniform to begin with, or that it will not change further in
subsequent generations, especially with regard to properties that affect
Unfortunately, regulators in Europe, Canada and the United States all
appear to be unaware of this. They have not required industry to submit
molecular genetic data in sufficient detail to document genetic stability,
or to allow identification of the GM line unambiguously (9). Instead, they
are effectively granting blanket approval for GMOs from multiple
transformation events plus all progeny arising from them, variously
backcrossed to non GM varieties.
Chardon LL does not satisfy DUS test
Thus, the product approved under the entity, Chardon LL(Aventis - T25),
is stated as "Seeds of maize line HE/80 transformation event 25 and
any progeny derived from crosses of event T25 with traditional corn
varieties." But no molecular genetic data documenting the stability
or homogeneity of the seeds have been provided.
European Commission legislation actually requires that new plant
varieties be tested for Distinctness, Uniformity and Stability (DUS) prior
to being placed on the National List of a Member State, and prior to
marketing. There is no evidence that any GM line, let alone Chardon LL,
has passed this test, which requires the molecular genetic data mentioned
above. Incidentally, this also invalidates patents on transgenic lines and
The GM insert in Chardon LL has almost the entire pUC18 sequence plus
the pat gene cassette, but the AmpR gene had been
disrupted in its promoter region. This is a sign of structural
instability. Most worrying, the GM insert includes the origin of
replication for the pUC18 plasmid used as a vector, which introduces its
own risks (see below).
Special safety concerns arising from GMOs
There are four special safety concerns arising from GMOs (10):
- Effects due to the exotic gene product(s) introduced into the
- Unintended, unexpected effects due to random insertion of GM
constructs; and interaction between GM genes and host genes.
- Effects associated with the nature of the GM-constructs.
- Effects of gene flow, especially horizontal spread of genes and
gene-constructs from the GMOs to unrelated species.
Hazards from the exotic gene product(s) introduced
The exotic genes introduced into GM crops are mainly from bacteria and
non-food species. Furthermore, the expression of these genes is often
greatly amplified by strong viral promoters. In practice, that means all
species interacting with the GM plants - from decomposers and earthworms
in the soil to insects, small mammals, birds and human beings - will be
exposed to large quantities of proteins new to their physiology. Adverse
reactions may occur in all species, including immune or allergic
responses. For example, Bt toxins from the soil bacterium Bacillus
thuringiensis, engineered into GM crops to kill insect pests, are
found to harm beneficial insects such as lacewings, and endangered species
such as monarch butterflies and the black swallowtail (1). One of them,
the Cry9C in Aventis Starlink GM maize intended for animal feed, is
a potential allergen for human beings, and is behind the recent massive
recall of contaminated taco shells in the United States (11).
How safe is the pat gene product in Chardon LL? It originates
from a soil bacterium, Streptomyces viridochromogene, which has
never been part of our food chain, nor animal feed. The Streptomyces
genus includes plant (12) as well as human and animal pathogens (13). One
feeding trial was conducted in rats for 14 days on the extracted protein,
obtained, not from Chardon LL, but from GM oil seed rape. Rats are
monogastrics and have a completely different digestive system from
ruminants, which have four stomachs and keep the plant material longer.
Furthermore, the feeding experiment was never completed, and no
histological data on the state of internal organs were ever presented. As
has been argued by Dr. Arpad Pusztai and others, feeding studies must be
done on young animals, as the young are more susceptible to
adverse effects, and histological examinations are crucial.
Hazards from random gene integration and interaction with host genes
The random, uncontrollable insertion of GM constructs into the host
genome and interaction of exotic genes with host genes is well known to
give many developmental failures and gross abnormalities in animals. In
microorganisms and plants, unexpected toxins and allergens have been
found. The most notorious case involved a genetically engineered batch of
tryptophan that killed 37 and made 1500 seriously ill in 1989 (1).
There were no attempts to characterise Chardon LL for unintended toxins
and allergens, because industry is not required to do so. The
characterisations that were carried out were undiscriminating.
Nevertheless, significant differences were often found between GM and non
GM counterparts, but were explained away by appealing to variations in
other varieties of the species under the principle of substantial
equivalence. In other words, Chardon LL could have the worst
characteristics of all the varieties within a species, and still be
considered substantially equivalent.
No feeding studies were done with GM plant material of Chardon LL, and
hence its safety is unknown and unproven. Ewen and Pusztai carried out
feeding studies with GM potatoes, from which they concluded that
significant effects may be due to the transformation process or the GM
construct, and not just the gene product itself (14). As yet, our
Government have made no attempts to repeat those investigations. In the
case of Chardon LL, they seem to be avoiding the issue altogether by
accepting feeding data on the novel protein alone.
Hazards from the GM construct
Safety concerns have indeed been raised over the 35S promoter from the
cauliflower mosaic virus (CaMV) that is in the GM-constructs of
practically all GM crops already commercialized or undergoing field
trials. In a series of scientific papers (15-18), my colleagues and I
point out that
- CaMV is closely related to human hepatitis B virus, and less closely,
to retroviruses such as the AIDS virus. Related viruses can more readily
exchange genes than non-related ones, and they use similar regulatory
signals such as promoters.
- The CaMV 35S promoter can substitute in part or in whole for
promoters of other viruses to give infectious viruses.
- Although the intact CaMV specifically infects plants of the cabbage
family, its isolated 35S promoter is promiscuous across domains and
kingdoms. It is active in all plants, algae, yeast, and bacteria, and as
we recently discovered in the scientific literature 10 years old, also
in animal and human systems. The conventional wisdom among plant
molecular geneticists is that CaMV 35S promoter is only active in plant
and plant-like species. Why have they not checked the literature before
using it so widely?
- The CaMV 35S promoter has a recombination hotspot where
it is prone to break and join up with other genetic material, hence
increasing the likelihood for horizontal gene transfer and recombination
These findings suggest that CaMV 35S promoter has the potential to
reactivate dormant viruses, which have now been found in all genomes,
plants and animals included, and to recombine with other viruses, dormant
or otherwise, to create new viruses. In addition, the fact that the
promoter is active in animal and human cells means that, if transferred
into their genomes, it may result in over-expression of genes that are
associated with cancer. There is a strong case for recalling all GM crops
containing the CaMV 35S promoter from environmental release on grounds of
Chardon LL does have a CaMV 35S promoter and is hence subject to all the
potential hazards that it brings. In addition, it has an origin of
replication for the pUC plasmid vector, plus further stretches of
uncharacterized, unidenfied sequences of unknown function and safety
belonging to the plasmid, as mentioned in ISIS written objection
(19). The origin of replication, claimed not to be active in plant cells,
will be active in bacteria to which the GM construct is transferred. This
signal enables the GM construct linked to it to be maintained in the
bacteria as an independently replicating plasmid, hence enabling the GM
construct to be multiplied and spread widely by horizontal gene transfer.
Hazards from gene flow, especially horizontal gene transfer
GM constructs can spread by ordinary cross-pollination to non GM plants
of the same species or related species. The most obvious effects of
cross-pollination already identified are in creating herbicide-tolerant
weeds and superweeds (1). Another consequence is the spread of the novel
genes and GM-constructs for over-expression, as well as the antibiotic
resistance marker genes. This will multiply the unpredictable
physiological impacts on the organisms to which the genes and
gene-constructs are transferred, and hence on the ecosystem.
By far, the most serious consequences are from the horizontal transfer
of GM constructs to unrelated species, in principle, to all species
interacting with the released GMO (20) microorganisms, earthworms and
arthropods in the soil, insects, birds, mammals, human beings. This is not
just a theoretical possibility. There is already evidence that GM genes
from GM plant material can transfer to soil bacteria and fungi. Recent
experiments in gene therapy have also amply documented that GM
constructs, of the same form as those used in GM crops can readily invade
cells and genomes of animals and human beings (21). One of the routes of gene
therapy is oral administration, ie, swallowing.
What is the probability of horizontal gene transfer in the gut? An
important factor is whether the GM genetic material is sufficiently broken
down in processed food and animal feed. The UK Governments own
commissioned research has repeatedly shown that most commercial processing
either left the genetic material intact or in large fragments (22, 23).
The scientists advised against using GM material in animal feed (22).
In fact, government scientists have pointed out that the possibility of
horizontal gene transfer starts in the mouth, which contains dangerous
bacteria that can take up antibiotic resistance genes (24) and similar
bacteria are present in the respiratory tract. They warn of dangers to
farm workers and food processors from GM pollen and dust (25). But, of
course, such dangers would apply to the general public as well. Several
months ago, Prof. Hans-Hinrich Kaatz from the University of Jena in
Germany, reported that GM genes have transferred via GM pollen to bacteria
and yeast living in the gut of bee larvae (26). This raises the issue of
the safety of GM honey.
Chardon LLs ampicillin resistance gene is reported to be
non-functional because its promoter is lost. However, this gene is
notorious for its ability to mutate and extend the ability of the enzyme
encoded to break down new generations of b-lactam
antibiotics (penicillin and chemically similar derivatives). It may regain
function through mutation or recombination on being transferred
horizontally, as was also pointed out by the Governments own
scientific advisors (25). There is an entire class of transposons in
bacteria called integrons that can take up an antibiotic resistance gene
and provide it with a ready-made promoters (see ISIS written
objection, ref.19, and reviewed in ref. 27). It should also be noted that
a rearrangement of the GM construct, which brings the CaMV 35S promoter
next to the inactive ampicillin-resistance gene will restore gene
expression. The CaMV 35S promoter is functional in bacteria.
Hazards from horizontal gene transfer
The hazards from horizontal transfer of GM constructs such as that in
Chardon LL are summarised as follows,
New viruses that cause diseases due to recombination between
viral genes and viruses in the environment. Recombinant infectious viruses
have been recovered in many GM plants containing GM viral genes that are
supposed to make the plants resistant to viral infections (reviewed in
New bacteria that cause diseases due to recombination between
bacterial genes and bacteria in the environment. The existence of
uncharacterized sequences from the bacterial plasmid vector in Chardon LL
is particularly relevant here.
Spread of drug and antibiotic resistance genes to bacteria,
making infections much more difficult to treat. The transfer of antibiotic
resistance genes from GM plant material to soil bacteria and fungi has
been found both in the laboratory and in the field (20), and there is no
reason to expect that Chardon LLs ampicillin resistance gene will
not be transferred.
Harmful effects, including cancer, as the result of random
insertion of GM constructs into cells. This possibility is amply
demonstrated in gene therapy experiments where similar
constructs are introduced into cells in tissue culture (21).
Dormant viruses reactivated by the CaMV and other viral
promoters. Recombinant replicating viruses routinely arise when gene
therapy vectors are packaged in cultured cells that contain
dormant viruses (21).
Multiplication of ecological impacts due to all the above.
There is now overwhelming evidence that horizontal gene transfer and
recombination are responsible for the resurgence of drug and antibiotic
resistant infectious diseases worldwide within the past 25 years (27). We
have reviewed the evidence extensively and questioned whether genetic
engineering, in enhancing horizontal gene transfer and recombination, may
have contributed, and will continue to do so if unchecked.
The current regulatory systems do not take horizontal gene transfer into
account (2,3). There is no requirement for industry to monitor and report
on horizontal gene transfer. On the contrary, dangerous vectors, GM
constructs and GM genetic material are either being released directly into
the environment, or are being recycled as food, feed, fertilizer and
landfills (2). We have repeatedly drawn attention to the dangers of
horizontal gene transfer to no avail. Our Government as well as the
biotech companies have been acting in violation of the precautionary
principle as well as sound science (4). Governments as much as the biotech
companies may well be held legally responsible for any harm from GMOs.
The version of the precautionary principle most relevant for GMOs is one
stating that when there is reasonable suspicion of serious irreversible
harm, lack of scientific certainty or consensus must not be used to
postpone preventative action. I hold that the precautionary principle
is part and parcel of sound science because science, as opposed to
fundamentalist religion, is an active knowledge system. Scientific
evidence is always uncertain and incomplete, and the proper role of
scientific evidence, therefore is to set precaution. Dr. Peter Saunders,
Professor of Applied Mathematics and co-Founder of ISIS, shows how the
precautionary principle is just codified common sense that people have
accepted in courts of law as much as statisticians have accepted in
setting the burden of proof (4).
Society accepts with the law that a person is assumed innocent until
proven guilty beyond reasonable doubt, because, so the saying goes: "It
is better that a hundred guilty men should go free than that one innocent
man should be convicted." If we seriously want to protect health and
the environment, then we must acknowledge that there is already reasonable
suspicion that GM technology is hazardous, and that the effects are
uncontrollable and irreversible. The burden of proof, therefore, should be
on industry to establish it is safe beyond reasonable doubt, particularly
as there is no evidence of benefit or need (see below). Unfortunately, our
regulatory systems have operated the other way round. The burden of proof
is on civil society to establish it is harmful before it can be rejected.
Statisticians have actually been practising precaution by setting a 5%
probability as the level of significance. It means that to
justify introducing something new, one should assume a null
hypothesis that there is no difference between the new and the old,
unless the improvement observed is such that there is only a 1 in 20
chance for getting observed difference. The same goes for safety testing.
One starts with the null hypothesis that there is no difference between GM
and non GM. However, the failure to show that GM is significantly harmful
does not mean it proves GM is safe. Many factors can contribute to this
failure, including insufficient number of experiments and experiments
badly designed and executed. Unfortunately, such failures have all too
often been taken as evidence that GM is safe.
We should reject not only Chardon LL but the whole GM approach
The scientific evidence of actual and suspected hazards arising from GM
technology is sufficiently compelling for hundreds of scientists around
the world to call for an immediate moratorium on further environmental
releases in accordance with the precautionary principle as well as sound
science (1). The scientists also demand a ban on patents on life-forms and
living processes, on grounds that they amount to corporate ownership of
life that destroy livelihoods, compromise food security, violate basic
human rights and dignity and are contrary to public good.
Supporters of GM agriculture are still speaking of potential benefits
after more than 20 years, because there has been none so far. Evidence is
emerging that GM crops are agronomically as well as ecologically
unsustainable. Transgene instability due to gene silencing, rearrangement
and loss of GM constructs give rise to inconsistent performance in the
field, yield drag and other failures (1). There is no evidence that
Chardon LL will be different.
Global market for GM crops has collapsed as people all over the world
are rejecting them and opting for organic sustainable agriculture.
Agroecological approaches since the 1980s, which combine local farming
knowledge and techniques with contemporary western scientific knowledge,
have led to improved yields, as well as social, economic, health and
environmental benefits for tens of millions in the developing as well as
the developed world.
We should reject not only Chardon LL but the entire genetic modification
approach based on a discredited, mechanistic paradigm at odds both with
the scientific findings of the new genetics and with our aspiration for a
safe, healthy, just and compassionate world (28).
- See World Scientists Open Letter to All
Governments on GMOs (with many references to scientific and other
- See "Dangerous GM wastes recycled
as food feed and fertilizer" Mae-Wan Ho and Joe Cummins, ISIS
News#6, September, 2000 www.i-sis.org.uk
- "EU Directive on deliberate
release still inadequate" Angela Ryan, ISIS News#6,
September, 2000 www.i-sis.org.uk
- Saunders, P.T. (2000). Use and abuse
of the precautionary principle. Submitted to US Senate on
Biotechnology, July 2000 also ISIS New#6 September 2000 www.i-sis.org.uk
- See Old, R.W. and Primrose, S.B. (1994). Principles of Gene
Manipulation 5th ed., Blackwell Science, Oxford.
- See Bregitzer, P., Halbert, S.E., Lemaux, P.G. (1998). Somaclonal
variation in the progeny of transgenic barley. Theoretical and
Applied Genetics 96, 521-425.
- "More on instability of
transgenic lines" Joe Cummins and Mae-Wan Ho, ISIS NEW#6,
- Ho, M.W. (1998,1999). Genetic Engineering
Dream or Nightmare? Chapter on Perils amid Promises of
Genetically Modified Food, Gateway Gill & Macmillan, Dublin.
- Ho, M.W. (1999). Biosafety Alert.
Submission to Biotechnology Group of the Trans-Atlantic Economic
Partnership on the Molecular Characterisation Required for GMOs. <www.i-sis.org.uk>
- Ho, M.W. (1999). Special Safety Concerns of Transgenic Agriculture
and Related Issues Briefing Paper for Minister of State for the
Environment, The Rt Hon Michael Meacher in Seminario Internacional
sobtre Direcito da Biodiversidade, Revista cej: Centro de estudos
Judiciarios do Conselho da Justica Federal, pp.120-6.
- "Biotech Corn in Various Foods" Marc Kaufman, Washington
Post October 19, 2000.
- Kinkell, L.L., Bowers, J.H., Shimizu, K., Neeno-Edkwall, E.C. and
Schottel, J.L. (1998). Quantitative relationships among thaxtomin A
production, potato scab severity, and fatty acid composition in
Streptomyces. Can J Microbiol 44, 768-76.
- Mossad, S.B., Tomford, J.W., Stewart, R., Ratliff, N.B. and
Hall,G.S. (1995). Case report of Streptomyces endocarditis of a
prosthetic aortic valve. J. Clin. Microbiol. 33, 3335-7.
- Ewen, S., and Pusztai, A. (1999). Effect of diets containing
genetically modified potatoes expressing Galanthus nivalis
lectin on rat small intestine. The Lancet 354: 1353-1354.
- Ho, M.W., Ryan, A. and Cummins, J. (1999). The
cauliflower mosaic viral promoter a recipe for disaster?
Microbial Ecology in Health and Disease 11, 194-197.
- Cummins, J., Ho, M.W. and Ryan, A. (2000). Hazards
of CaMV promoter. Nature Biotechnology 18, 363.
- Ho, M.W., Ryan, A. and Cummins, J. (2000). Hazards of transgenic
plants with the cauliflower mosaic viral promoter. Microbial Ecology
in Health and Disease 12, 6-11.
- Ho, M.W., Ryan, A. and Cummins, J. (2000) CaMV 35S promoter
fragmentation hotspot confirmed, and it is active in animals.
Microbial Ecology in Health and Disease (in press).
- Ho, M.W. and Ryan, A. (2000). Re: The
proposed decision to add Chardon LL (Aventis T25 Maize) to the
- Ho, M.W. (2000). Horizontal gene transfer, and Ho, M.W. (2000).
Techniques and dangers of genetic engineering. Commentaries to appear on
the website of SCOPE - a NSF-funded research project involving Science
Journal and groups at the University of California at Berkeley and the
University of Washington in Seattle; for a slightly different version of
the commentaries see Ho, M.W. (2000). Horizontal gene transfer
hidden hazards of genetic engineering <www.i-sis.org.uk>
- Reviewed in Ho, M.W., Ryan, A., Cummins, J. and Traavik, T. (2000).
Unregulated Hazards: Naked and Free
Nucleic Acids, ISIS and TWN Report www.i-sis.org.uk; also Ho,
M.W., Ryan, A., Cummins, J. and Traavik, T. (2000).Slipping through the
regulatory net: naked and free nucleic acids
- "Health fears over GM cattle feed" Anthony Barnett, The
Observer October 15, 2000.
- Forbes, J.M., Blair, D.E., Chiter, A., and Perks, S. (1998). Effect
of Feed Processing Conditions on DNA Fragmentation Section 5 -
Scientific Report, MAFF; see also Ryan, A. and Ho, M.W. (1999).
Transgenic DNA in animal feed. ISIS Report,
November 1999 <www.i-sis.org.uk>
- Mercer, D.K., Scott, K.P., Bruce-Johnson, W.A. Glover, L.A. and
Flint, H.J. (1999). Fate of free DNA and transformation of the oral
bacterium Streptococcus gordonii DL1 by plasmid DNA in human
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