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Affidavit submitted by Mae-Wan Ho, August 12, 1998
(Greenpeace).
Personal qualifications
Mae-Wan Ho, Reader in Biology at the Open University, B.Sc. (First
Class) 1964, and Ph. D. 1967, H K University; more than 30 years in
research and 22 years teaching experience; nearly 200 publications
covering human biochemical genetics, molecular genetics, evolution,
developmental biology, and biophysics. Awards include, Chan Kai Ming Prize
for Biological Sciences (HK) 1964: Fellow of the National Genetics
Foundation (USA) 1971-1974; Vida Sana Award (Spain) 1998; Guest of Honour
in Women of the Year Luncheon & Assembly (UK) 1998. From 1994,
Scientific Advisor to the Third World Network and other public interest
organizations on biotechnology and biosafety. Debated issues in the United
Nations, the World Bank, the European Parliament, in the UK, USA and many
other countries all over the world. Author of many papers and reports for
the public and for policy-makers, frequent broadcaster and public
lecturer. Recent publications relevant to genetic engineering:
Genetic Engineering Dream or Nightmare? Mae-Wan Ho, Gateway Books,
Bath, UK, 1998; (revised, 2nd. edition, 1998).
Gene Ecology and Gene Technology of Infectious Diseases, Mae-Wan Ho et
al, Microbial Ecology in Health and Disease 10, 33-59, 1998.
Genetic Engineering and Infectious Diseases, Mae-Wan Ho et al,
Third World Network, Penang, 1998.
Fatal Flaw in Food Safety Assessment: The FAO/WHO Joint Biotechnology &
Food Safety Report, Mae-Wan Ho and Ricarda A. Steinbrecher, Third
World Network, Penang, 1998.
Fatal Flaw in Food Safety Assessment: The FAO/WHO Joint Biotechnology &
Food Safety Report, Mae-Wan Ho and Ricarda A. Steinbrecher, Environmental
and Nutritional Interactions (in press).
Comments on the action taken by defendant
A. General remarks
Ms Shannon Coggins, is within her rights as a citizen of civil society to
draw attention to information which is already given in the list of
ingredients on the packet. The word "contamination" accurately
describes the admixture of genetically modified with non-genetically
modified soya beans in the "soya protein mince" used. The
contamination arose from the lack of segregation in shipment and
processing of the soya beans. In no way can it be construed to result from
Ms Coggins' action. Ms Coggins was motivated by her concern over the
health hazards of the genetically modified "soya protein mince",
a concern that is fully justified on the basis of existing scientific
evidence. She was, therefore, acting responsibly in drawing attention to
the hazards for the benefit of other consumers.
B. Genetic engineering is a new departure from conventional breeding
and introduces significant differences
1. In conventional breeding, closely related species are
cross-fertilized, and plants with the desired characteristics are selected
from among the progeny for reproducing, and the selection is repeated over
many generations. Genetic engineering bypasses reproduction altogether. It
makes use of infectious agents to transfer genes horizontally from
one individual to another (as opposed to vertically, from parent
to offspring); so that genes can be transferred between distant species
that would never interbreed in nature. For example, human genes are
transferred into pig, sheep, fish and bacteria. Fish genes are transferred
into tomatoes. Completely new, exotic genes, can therefore be introduced
into food crops.
2. Natural infectious agents exist which can transfer genes horizontally
between individuals. These are viruses and other pieces of parasitic
genetic material, called plasmids and transposons, which
are able to get into cells and then make use of the cell's resources to
multiply many copies or to jump into (as well as out of ) the cell's
genome. The natural agents are limited by species barriers, so that for
example, pig viruses will infect pigs, but not human beings, and
cauliflower viruses will not attack tomatoes. Genetic engineers make
artificial vectors by combining parts of the most infectious natural
agents, and design them to overcome species barriers, so the same vector
may now transfer, say, human genes, which are spliced into the vector,
into the cells of all other mammals, or cells of plants. Once inside the
cell, the artificial vector carrying the foreign gene(s) can then insert
into the cell's genome, and give rise to a genetically engineered
organism.
3. Typically, foreign genes are introduced with strong genetic signals -
called promoters or enhancers - to boost the expression of
the genes to well above the normal level that most of the cell's own genes
are expressed. There will also be selectable "marker genes"
introduced along with the gene(s) of interest, so that those cells that
have successfully integrated the foreign genes into their genome can be
selected. The most commonly used marker genes are antibiotic resistant
genes, which enable the cells to be selected with antibiotics. These
marker genes often remain in the genetically engineered crops.
C. Health hazards arising from genetically engineered foods in general
1. There are three main sources of hazard to health arising from
genetically engineered foods in general: those due to the new genes and
gene products introduced; unintended effects in the nature of the
technology and interactions between foreign genes and host genes; those
arising from the horizontal spread of the introduced DNA.
2. New genes and gene products are introduced into our food that we have
never eaten before, and certainly not in the quantities produced in the
genetically engineered crops, where they are equipped with strong
promoters to express at high levels. The long term impacts of these genes
and gene products will be impossible to predict, particularly as the
products are not segregated and there is no post-market monitoring. There
are already signs that some of the gene products can harm non-target
species. For example, many plants are engineered to express a bt-toxin
from the soil bacterium, Bacillus thuringiensis, targetted against
specific insect pests. But they actually harm beneficial insects. Thus,
genetically engineered bt-cotton killed 30% of the bees in the fields when
field-tested in Thailand (see Ho et al, 1998, and references
therein). Harmful effects can even go up the food-chain. Lacewings fed on
pests that have eaten genetically engineered bt-maize took longer to
develop and were two to three times more likely to die (Hilbeck et al,
1997).
3. The technology of genetically engineering organisms is hit or miss,
and not at all precise, contrary to misleading accounts intended for the
public, as it depends on the random insertion of the artificial
vector carrying the foreign genes into the genome. This random insertion
is well-known to have many unexpected and unintended effects including
cancer, in the case of mammalian cells (Walden et al, 1991; Wahl
et al, 1984; see also entries in Kendrew, 1995). Furthermore, the
effects can spread very far into the host genome from the site of
insertion (recently reviewed by Doerfler et al, 1997). This is
attested to by the high failure rates in making transgenic animals, and
high levels of gross deformities among the "successes" (see Ho
et al, 1998 and references therein). Unexpected and unintended
effects will also arise from interactions between foreign genes and genes
of the host organism, as no gene functions in isolation. Among the
unintended effects relevant to food safety are new toxins and allergens,
or changes in concentrations of existing toxins and allergens. In 1989, a
genetically engineered batch of tryptophan killed 37 and made 1500 ill,
some seriously to this day (Mayeno and Gleich, 1994). A Brazil nut
allergen was identified in soya bean genetically engineered with a brazil
nut gene (Nordlee et al, 1996).
4. The same cellular mechanisms that enable the vector carrying the
foreign genes to insert into the genome can also mobilize the vector to
jump out again to reinsert at another site or to infect other cells.
Secondary horizontal tranfer of transgenes and antibiotic resistant marker
genes from genetically engineered crop plants into soil bacteria and fungi
have been documented in the laboratory (Hoffman et al, 1994;
Schlutter et al, 1995; Gebbhard and Smalla, 1998). Plants
engineered with genes from viruses to resist virus attack actually showed
increased propensity to generate new, often super-infectious viruses
(Vaden and Melcher, 1990; Lommel and Xiong, 1991; Green and Allison, 1994;
Wintermantel and Schoelz, 1996). Thus, genetically engineered crops may
spread antibiotic resistant genes to pathogenic bacteria in the
environment as well as to bacteria in the gut of animals including human
beings (see next paragraph). They may also contribute to generating new
viral pathogens. This is particularly relevant in the light of the current
world health crisis in drug and antibiotic resistant infectious diseases,
and evidence indicating that horizontal gene transfer has been responsible
for spreading drug and antibiotic resistance genes as well as creating new
pathogens (see Ho et al, 1998).
5. In addition, there is evidence that DNA is not broken down rapidly in
the gut as previously supposed. DNA from a virus fed to mice has been
found to resist digestion in the gut. Large fragments passed into the
bloodstream and into white blood cells, spleen and liver cells. In some
instances, the viral DNA may integrate into the mouse cell genome
(Schubbert et al, 1994; 1997). Viral DNA is now known to be more
infectious than the intact virus, which has a protein coat wrapped around
the DNA. For example, intact human polyoma virus injected into rabbits had
no effect, whereas, injection of the naked viral DNA gave a full-blown
infection (see Traavik, 1995; Ho et al, 1998; Ho, 1998a, 2nd ed.,
Chapter 10). Many kinds of artificially constructed vectors are found to
infect mammalian cells (see Ho, 1998a Chapter 10, Ho et al, 1998).
Thus, the foreign DNA introduced by artificial vectors into genetically
engineered plants may constitute a serious health hazard by itself. As
mentioned in paragraph C.3, integration of foreign DNA into cells are
well-known to have many adverse effects including cancer. While in the
gut, DNA containing antibiotic resistance genes may also spread to gut
bacteria.
D. Health hazards from the genetically engineered soya
1. Health hazards from the genetically engineered soya have been
considered in detail in a Report by the Ecological Institute of Freiburg
(Oekoinstitut Freiburg, 1997). The Report concludes that the tests carried
out by Monsanto failed to exclude significant health risks from the genes
and gene-products introduced, and from unintended changes in allergenicity
of the soya proteins. In addition, evidence of adverse health impacts of
glyphosate and glyphosate residues and of the effects of glyphosate on
phyto-oestrogen levels of the genetically engineered soya have not been
addressed.
2. The processing involved in producing "soybean protein mince"
from transgenic protein may leave non-protein contaminants including DNA
and metabolites that could cause harm. No tests on the contaminants of the
"soybean protein mince" have been reported.
3. The genetically engineered soya used in the product contains genes
from a virus, a soil bacterium and from petunia, none of which has been in
our food before. The main foreign protein expressed, which makes the plant
resistant to glyphosate, is from a soil bacterium, Agrobacterium
sp. It is engineered into the soya plant in a new form (CP4EPSPS), and its
expression is boosted by a strong promoter from the cauliflower mosaic
virus to a high level of approximately 0.2% of the seed protein. The novel
protein is unlike any other protein that human beings have eaten. And
there is no reliable method for predicting its allergenic potential.
Allergic reactions typically occur only some time after the subject is
sensitized by initial exposure to the allergen.
3. Soya beans are known to have at least 16 proteins that can cause
allergic reactions, which differ for different ethnic groups. The tests
applied by Monsanto were not sufficiently discerning and wide-ranging to
reveal changes in those proteins, or indeed other proteins that may also
be allergenic. In one test, a major allergen, trypsin-inhibitor, was found
to be 26.7% higher in transgenic soya beans (Padgette et al,
1996), despite the authors' claim that the genetically engineered soya
bean is "equivalent" to that of conventional soya bean.
Trypsin-inhibitors also have anti-nutritional effects in reducing growth
rate of rats (Kakade et al, 1973).
4. The feeding studies carried out by Monsanto, which also did not use
transgenic soya beans sprayed with glyphosate, nevertheless revealed
significant increases in milk fat in cows fed transgenic soya beans
compared to controls, and a number of other differences including lower
body weights and cumulative body weight gains in male rats fed the
genetically engineered processed soya (Hammond et al, 1996). These
differences plus the difference in trypsin-inhibitor identified in another
paper (Padgette et al, 1996) contradict the claim that the
genetically modified soya and its products "are equivalent to, and as
safe for human consumption as beans from other conventional soya bean
strains and products derived from them" (UK ACNFP statement, cited in
"Some Important Information About Genetically Modified Soya" by
Corporate Relations Department, Van den Bergh Foods Ltd, ).
5. Monsanto did not submit any data on the level of glyphosate residues
in the transgenic soya bean, nor on products derived from it. The toxicity
of glyphosate has been reviewed by Cox (1995). Acute toxicity of some
glyphosate products include eye and skin irritation, cardiac depression
and vomiting. In California, glyphosate is found to be the third most
commonly-reported cause of pesticide related illness among agricultural
workers. The toxicities are often associated with supposedly inert
solvents and detergents in some formulations which greatly increase the
toxicity of glyphosate. These synergistic interactions between chemical
pollutants in our environment are now well-documented (see Howard, 1998).
Chronic toxicity of glyphosate include testicular cancer and reduced sperm
counts and other negative reproductive impacts in rats (FAO/WHO, 1986;
Ohnesorge, 1994). There are also indications that glyphosate formulations
cause mutations in genes (Kale et al, 1995).
6. The currently acceptable daily intake (ADI) of glyphosate set by the
WHO, is 0.3mg/kg body weight/day, and should not exceed 10mg/kg/day. The
latter is the lowest level at which glyphosate has been shown to adversely
affect reproduction in rats. Glyphosate residues have already been found
in strawberries, lettuce, carrots, barley and fish. These residues
persisted for at least one year after the herbicide was applied (see
Greenpeace Report, 1998 and references therein). Glyphosate residues are
bound to increase in glyphosate resistant crops as herbicide usage
increases. In anticipation of that, the 1996 EU limit for soya beans has
been increased to 20mg/kg/day, while the US limit is increased to
100mg/kg/day. These are well over the threshold at which reproductive and
other health impacts are evident from animal experiments.
E. Wider ecological concerns of the genetically engineered soya beans
1. Glyphosate is a broad-spectrum herbicide which will have major impacts
on biodiversity (see Greenpeace Report, 1998, and references therein). It
kills all plants indiscriminately. This will destroy wild plants as well
as insects, birds, mammals and other animals that depend on the plants for
food and shelter. In addition, Roundup (Monsanto's formulation of
glyphosate) can be highly toxic to fish. Glyphosate also harms earthworms
and many beneficial mycorrhizal fungi and other microorganisms that are
involved in nutrient recycling in the soil. It is so generally toxic that
researchers are even investigating its potential as an antimicrobial
(Roberts et al, 1998).
2. Glyphosate, in being a broad spectrum herbicide as well as harmful to
soil microorganisms that are crucial for natural soil fertility, is
completely incompatible with organic agriculture. And that applies
obviously to genetically engineered glyphosate-resistant plants that are
tied to glyphosate sprays. Many studies within the past 10 to 15 years
have shown that sustainable organic agriculture can improve yields and
regenerate agricultural land degraded by intensive agriculture and hence
offer the real solution to "feeding the world" (see Pretty,
1995; Ho, 1998a,b). Sustainable organic agriculture depends on maintaining
natural soil fertility as well as on mixed cropping and crop rotation;
thus reversing the destructive effects of intensive agriculture that have
led to falling productivity since that 1980s. Glyphosate resistant plants
will set us back from the real solution to food security (see Ho,
1998a,b). Yet it is the major category of genetically engineered crops on
offer.
3. Glyphosate resistance genes can spread to nongenetically engineered
crops as well as wild relatives by cross-pollination. The transgenic
plants themselves as well as the hybrids can become weeds. Genetically
engineered glyphosate resistant soya bean is particularly relevant for
Asia and Australasia where wild relatives of soya beans exist (see
Greenpeace Report, 1998).
4. Another route for glyphosate resistance genes to spread is
horizontally, i.e., via infection, to soil microorganisms (see paragraph
C.4). A possible scenario is that pathogens will acquire the resistance
and out-compete beneficial species as glyphosate is increasingly applied.
All bacteria and other microbes, some of which can cause diseases, are
normally susceptible to glyphosate (Roberts et al, 1998).
5. Finally, the use of glyphosate with genetically engineered resistant
plants will encourage the evolution of glyphosate resistance in weeds and
other species, even without cross-pollination. A ryegrass highly resistant
to glyphosate has already been found in Australia (New Scientist,
6 July, 1996). Resistance evolves extremely rapidly because all cells
have the capability of mutating their genes at high rates to resistance if
they are exposed continuously to sub-lethal levels of toxic substances
including herbicides, pesticides and antibiotics. This is inherent to the
"fluidity" of genes and genomes that has been documented within
the past 15 years (see Ho, 1998a). It will render resistant plants useless
after several generations, as the herbicide is widely applied. At the same
time, resistant weeds and pathogens may become increasingly abundant.
Additional herbicides will then have to be used to control the resistant
weeds.
Addendum (October 23 1998)
A recent report (Bergelson, J., Purrington, C.B. and Wichmann, G. (1998).
Promiscuity in transgenic plants. Nature 395, 25) describes the
results of experiments showing that transgenes may be up to 30 times more
likely to escape than the plants's own genes, probably being transferred
horizontally by insects visiting the plants for pollen and nectar.
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