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ISIS Report 18/07/07
GM Safflower with Human Pro-Insulin
Regulators show cavalier disregard for the safety of threatened species
as well as human beings in proposed release of the GM pharm crop. Prof.
This report has been submitted to the USDA on behalf of ISIS. Please
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Proposed release of transgenic safflower shrouded in secrecy
USDA-APHIS conducted an Environmental
Assessment (EA)  in response to an application (06-363-103r), received
from SemBioSys, Inc to field test a transgenic safflower (Carthamus tinctorius) line 4438-5A that produces
human pro-insulin. The transgenic safflower was engineered to express an oleosin-human
pro-insulin protein exclusively in its seed. The field site (<1 acre) is
located on private property in Lincoln County, WA, and will
be surrounded on all sides by a 50 ft fallow strip. The exact location of
the site is withheld from the public; but the application and risk assessment
are open for public comment at http://www.regulations.gov/fdmspublic/component/main
until 23 July 2007.
Pro-insulin is the precursor to insulin, normally made in the beta cell of
the islets of Langerhans of the human pancreas. The protein is synthesized in
the endoplasmic reticulum (membrane stacks within the cell), where it is folded
and two sulphydryl (-SH) groups are oxidized into a disulphide bond (-S-S-).
It is then transported to the Golgi apparatus (a special organelle) where it
is packaged into secretory vesicles, and processed by a series of proteases
into mature insulin. Mature insulin has 39 less amino acids; 4 are removed altogether,
and the remaining 35 amino acids - the C-peptide - are cut out from the middle
of the pro-insulin molecule; the two ends segments - the B chain and A chain
- remain connected by the disulphide bond formed earlier [2, 3].
A patent application
 describes the genetic modifications for high expression of human insulin
in plants, including shortening the C-peptide by four amino acids. The APHIS
report  notes further that the human pro-insulin has two amino acids removed
for stability in plants plus 11 C terminal amino acids added to ensure retention of the protein
in the endoplasmic reticulum of the plant seed cell. The pro-insulin
sequence was fused to the Arabidopsis
oleosin gene, to be exclusively expressed in seeds. Expression of the fused
gene was controlled by the phaseolin promoter and terminator sequences from
common bean. The bean promoter drives seed-specific transcription of the synthetic
pro-insulin. A selectable marker is regulated by the parsley ubquitin promoter
and terminator, and was deemed confidential business information even though
it is said to be the most commonly used selectable marker in plants, and had
been used in many previous field trials . Animal feeding tests evaluating
the toxicity of the neither the synthetic pro-insulin nor the marker gene
and its proteins were included with the EA.
Site of release in area with threatened species
The area selected
for the transgenic safflower field test releases - “sagebrush steppe” - is
dry and dominated by sagebrush. Resident animals include the sage grouse,
sage sparrows, loggerhead shrikes, and even the once ubiquitous black-tailed
hare or “jackrabbit”. According to USAD/APHIS , the threatened species
in the test area also include bald eagle, pygmy rabbits, Columbian white tailed
deer and grey wolf, and the plant species Spalding’s catchfly and Ladies’
tresses. Pygmy rabbits are the most threatened species, the Columbia pygmy rabbit feeds mainly on sagebrush
and its number may be as low as 30 or less. There has been limited success
in breeding the rabbits in captivity [5, 6]. The pygmy rabbit is likely to
feed on the transgenic safflower seeds with potentially detrimental (even
fatal) consequences. The USDA/APHIS report claims there will be no toxicity
from ingesting seeds from the transgenic safflower, from contact or from inhaling dust and debris . Even if that were true - and
there is evidence ignored by APHIS suggesting that the ingested pro-insulin from transgenic safflower
is active (see below) - the disruption of the habitat of the pygmy rabbit
by human activities and transportation is likely to drive the threatened animals
to extinction. APHIS displays a cavalier disregard for the threatened species,
ignoring studies that do not support their conclusions.
Evidence of potential harm to threatened species ignored
There is at least one report
showing that transgenic pro-insulin can effectively reduce blood glucose in
rats. Feeding a bracken fungus, Ganoderma
lucium, modified with a gene for human pro-insulin to diabetic
rats reduced their blood glucose ; presumably the modified fungus cell
wall and endoplasmic reticulum prevent rapid degradation of pro-insulin, allowing
the transgenic organism to deliver insulin to the diabetic animal. Cholera
toxin pro-insulin fusion proteins were
produced in lettuce and tobacco
plants; and when powdered transgenic plant preparations were fed to diabetic
mice, oral tolerance to insulin was produced, preventing the autoimmune degradation
of insulin-producing beta cells in the pancreas . Human insulin produced
in Arabidopsis seeds was activated
by exposure to the common digestive enzyme trypsin . The APHIS report presumes
that human pro-insulin will be degraded too rapidly for it to become activated
when ingested by animals, but the studies cited show that may not the case.
Furthermore, functional argentine peptides were found to enhance intestinal
absorption of insulin such peptides may be encountered commonly
in anti-microbial peptides . Seed debris may produce dust that contains
human pro-insulin, and it is worth noting that inhaled insulin is an available
option for human therapy . The APHIS report dismisses the possibility that inhaled debris
and dust from the transgenic safflower could be active, but provides no experimental
evidence to support that conclusion.
that wild animals would not be affected by human insulin , but rabbits
were among the animals first used in the discovery of insulin, and continue
to be used as experimental animals in current studies on insulin action .
Furthermore, birds  and snakes  also respond to human insulin; and
it is probably safe to say that all of the threatened species, and human beings
are potential victims of the release of food crops modified to produce human insulin. The APHIS report notes
that grain crops surrounding the transgenic safflower plot will provide a
more attractive “free lunch” for birds and mammals than the transgenic safflower;
that is a fallacious and dangerous assumption because the ‘free lunch’ will
attract both foragers and
predators to the test site. Furthermore, the fallow strip around the test
plot is unlikely to discourage browsers such as rabbits that feed at night
to avoid predators.
Safe haven for pharm crops but deadly for humans and wild life
Eastern Washington State is rapidly being
transformed into a haven for transgenic crops modified to produce pharmaceuticals.
Along with previous safflower field test releases, large plantings of humanized
barley are being tested. The exact locations of such tests are not disclosed
and people living near the test sites are unaware of the potential hazards
to their health. The impact of such developments on threatened species is
also ignored and dismissed by APHIS. The APHIS report reads more like a public
relations document for the company rather than an independent critical evaluation
of the company proposal. This is potentially deadly for humans and wildlife,
and the agency should be held to public account.
USDA-APHIS Environmental Assessment In response to permit application (06-363-103r),
received from SemBioSys, Inc. for a field-test to produce human proinsulin
(line 4438-5A) in genetically engineered safflower (Carthamus tinctorius)
seeds U.S. Department of Agriculture Animal and Plant Health Inspection Service
Biotechnology Regulatory Services 06_363103r 06/22/2007 http://www.regulations.gov/fdmspublic/component/main
Davidson, H. Proinsulin processing. Cell Biochemistry and Biophysics
2004 Supplement, 143-57.
Molony M, Boothe J, Keone R, Nykiforuk C and Van Rooijen. Method for production
of insulin in plants, 2005 US Patent 2005/0039235A1
Washington Department of Fish and Wildlife Pygmy Rabbit 1995
Hays D. Washington Department of Fish and Wildlife Washington Pygmy Rabbit
2003 Recovery Plan Update addendum to 1995 above
Ni T, Hu Y, Sun L, Chen X, Zhong J, Ma H and Lin Z. Oral route of mini-proinsulin-expressing
Ganoderma lucidum decreases blood glucose level in streptozocin-induced diabetic
rats. Int J Mol Med. 2007, 20(1), 45-51.
Ruhlman T, Ahangari R, Devine A, Samsam M and Daniell H. Expression
of cholera toxin B-proinsulin fusion protein in lettuce and tobacco chloroplasts--oral
administration protects against development of insulitis in non-obese diabetic
mice. Plant Biotechnol J. 2007, 5(4), 495-510.
Nykiforuk CL, Boothe JG, Murray EW, Keon RG, Goren HJ, Markley NA and Moloney
MM. Transgenic expression and recovery of biologically active recombinant
human insulin from Arabidopsis thaliana seeds. Plant Biotechnol J. 2006,:77-85.
Morishita M, Kamei N, Ehara J, Isowa K and Takayama K. A novel approach
using functional peptides for efficient intestinal absorption of insulin.
J Control Release 2007, 118(2), 177-84.
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glucose and triglyceride levels during stress in a bird. Am J Physiol Regul
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Sidorkiewicz E and Skoczylas R. Effect of insulin on the blood sugar level
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