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Date:

December 6, 2000

Subject:

Greenpeace - Retraction; Why Retailers Panick; Borlaug

 

Dear Gordon,

My name is Jim Thomas. I work for Greenpeace as a campaigner on GE food
issues and it recently was brought to my attention that you had made the
following allegation about Greenpeace: "Several years ago Greenpeace sank
a ship killing a sailor and defended it as it was necessary to stop the
whaling." The allegation was made without any detail on a public list run
by Professor Prakash of Tuskegee University called AgBioview. This
allegation is untrue and I would ask you to retract it.

Although you may differ in your opinions from those of Greenpeace I would
ask you to respect that peacefulness and absolute non-violence is at the
core of everything we do - indeed it in our name. All of our activists
undergo training in non-violence and we certainly do not sink ships or
murder. Your allegation is somewhat more insulting since, by contrast, one
of our ships has been sunk by a bomb (The Rainbow Warrior in Auckland
harbour) and a much loved colleague was killed as a result. In over 28
years Greenpeace campaigners have also been shot at, rammed, hurt and
subject to various kinds of torture and harassment and have always
remained entirely non-violent.

Once again I would ask you to retract your allegation and inform the
agbioview list that this was untrue. Although I am not on the list I would
respectfully also ask the listmaster to publish this email for the list.

Yours sincerely

Jim Thomas - Greenpeace UK.
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From: "Gordon Couger"
Subject: Re: Greenpeace allegations

Dear Jim,

I was mistaken and had the parties reversed. I have apologized in the
past and do so again. It was faulty memory not an intentional lie.
Greenpeace was the victim of a very evil deed and no matter how much I
dislike their stand on issues the killing of a person in that manner is
cowardly.

I agree that it particularly insulting to Greenpeace since they were the
victim an not the ones that did it. At the time I wrote the post I
remembered as I wrote it. My memory of the event was faulty I can offer no
outer excuse except the truth.

I am posting this to you and to AgBioView the list that I posted the
piece in question. I was wrong and I can say no more than that.

I offer this apology.

Gordon
Gordon Couger gcouger@couger.com Stillwater, OK www.couger.com/gcouger
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Subj: Why food retailers panick over food labels?
From: Andura Smetacek

Bob MacGregor notes that surveys show consumers would buy products labeled
as GMO, so why are retailers so panicked by the prospects of such labels?

Food retailers panick over food label issues (be they for biotech products
or other production-oriented, non-nutrition, non-safety mandated
information) not because of what consumers will do, but because of what
other retailers will do.

As we've seen in the UK, unscrupulous retailers will use such labels to
falsely suggest products labeled for these production methods are
inferior. This forces other retailers to then adopt the practices of their
competitors regardless of the cost to them or their customers.

This has been verified by the UK Advertising Standards Board which found
this past year that two supermarkets were guilty of misleading claims
about the benefits of their organic foods and the dangers of biotechnology
foods in order to get shoppers to pay more for their alternative organic
products.

In fact, one only need follow the chronology of labeling along side of
consumer practices and then retailer marketing so see how this played out
in the U.K. When first launched, GMO food labels adorned products for over
three months in the U.K. with no change in consumer purchasing. Then
Iceland foods (one of the supermarkets found guilty of the deceptive
marketing practices) began telling consumers in advertising and other
marketing promotions that their "non-GMO" products were better and that
GMO's were less safe. Both claims are untrue; however, this then forced
others food chains to join Iceland's practice of being "GMO-free" to avoid
losing customers. Now consumers have no choice, surveys show them to be
more confused about food safety and food costs have risen.

Non-ingredient, non-nutritional, non-safety related labels contribute to
consumer abuse by retailers attempting to gain market advantage by using
such labeling standards to infer product inferiority of some kind.
Responsible retailers are then forced to follow suit so they don't lose
their market share.

The Wall Street Journal Europe has reported that the GMO labeling regime
which allows for these "ethical interest" and "environmental concern"
labels (those are phrases used by UK Minister Byrne to describe this
labeling system) have contributed to consumer confusion, less food choice
and increased food costs.

Other government leaders and health-care interest groups, such as the U.K.
Heart Association, have noted these types of labels and the misleading
campaigns associated with them may cause people to make unhealthful food
choices incorrectly infering that foods marketed as "organic" or "natural"
are healthier versus pursuing a more balanced and more affordable well
rounded diet.

Remember, the same people demanding biotech labels also demand labels
showing what types and how much pesticides or fertilizers have been used
to produce foods and how much free space or how humanely an animal was
treated before it became your evening meal. The costs for these ethical,
political or social standards (which do not impact the safety, nutrition
or quality of the foods we eat) are then forced upon all consumers
regardless of their position or interest in these standards.

Food productions standards, such as biotechnology, which do not change the
nutrition, safety, quality or basic composition of the products we consume
should remain a "marketing" issue paid for by those who want those
choices. If biotech production (or any other production) methods change
the food, then they must be labeled. This marketing system works for
organic foods, "free-range" meats, kosher foods and many other categories.
And, this protects the nutrition, health and safety value and integrity of
food labels as a proven consumer protection.

Retailers don't fear consumers, they fear themselves.
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Subj: Re: Why food retailers panic over food labels?
From: "Bob MacGregor"

What Andura says is all very true, but what I was trying to get across is
that a large proportion of consumers have NOT been panicked by all the
scare stories. This implies to me that there is an opportunity for an
innovative retailer to provide the choice of GM foods and reap the
benefits. As long as retailers all act defensively and flock together like
sheep in a panicky stampede for the same corner of the field, then this
opportunity is lost and consumers will not have the choice of less
expensive (and possibly healthier-- I'm thinking of reduced mycotoxin
content and nutritionally-improved GM foods nearing release) GM based
products. BOB
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Subj: Re: AGBIOVIEW: EPA Reports on Starlink
From: Claude.Willemot@aln.ulaval.ca (Claude Willemot)

Such reports (of damage by Starlink to individuals) are most unreliable

Indeed, a few months ago there was a water safety alert in a Montreal
district. A bacterium (E. coli?) had been detected. The public was advised
to boil the water pending confirmation. Immediately, a number (unknown to
me, let's say 32) of symptoms were reported. Two days later, the
verification of the first test proved to be negative: false alarm.

Claude Willemot

>Subject: EPA advisory committee report on StarLink
>and particularly: * Follow-up investigation of incidents reported by
individuals to evaluate whether >StarLink residues may have caused
allergic reactions. .

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From: Craig Sams

A Plea to Set Aside Paranoia

As an organic food manufacturer of thirty years standing and an interested
observer in the AgBioView forum I feel that I must set out my concern at
the paranoia and rage about the 'Organic Food Industry' and its imagined
sneaky plotting in support of Friends of the Earth and Greenpeace to get
them to do our dirty work for us and boost sales of our products. There is
no doubt that environmental organisations have been effective, thanks to
their broad membership base, in slowing down the onslaught of genetically
engineered foods. Hendrik Verfaille, the President of Monsanto, has
acknowledged that Monsanto rushed into the introduction of
genetically-engineered food within sufficient concern for the impact on
consumers, non GM farmers and organic farmers. At a meeting in London last
year he and his team expressed concern at how much alarm and commercial
damage Monsanto's actions had caused. CEO Robert Shapiro misjudged the
market badly and put all his shareholders' eggs in the GM basket. Monsanto
was only saved from collapse by a takeover.

Remember, it is the "Organic Food Industry" that has had to bear the
burden of cost of analysis and testing to ensure that the integrity of its
products could be maintained in the face of cross contamination and cross
contact with GM foods.Nobody has offered any compensation for the massive
disruption to the organic market that GM foods has brought. The market has
been growing at an average 40% per annum for more than a decade, long
before GM foods were introduced. Sure,some new organic consumers have
arisen from the desire to avoid GM foods, but these are typically people
who are also concerned about pesticide residues, artificial colorings,
flavorings, preservatives, hydrogenated fat, aspartame, phosphoric acid,
monosodium glutamate and suchlike, so they were going organicanyway to
avoid these ingredients.

The "Organic Food Industry" nowadays includes Nestle, General Mills,
Heinz, Safeway, major UK retailers own brands (Tesco alone has over 300
private labelorganic lines), Unilever and Mars, to name just a few of the
leading lights of the industry.

These companies have reviewed the arguments, considered the market
research, looked at the demographics of the organic consumer and the way
the wind is blowing and either bought or created organic brands to reach
this market. They have invested heavily to reach premium consumers who are
generally no richer than the average consumer, but weight their purchasing
decisions more heavily towards food and preventive health than towards
cars, clothes, travel or other consumer areas. These companies do not want
to see their investment undermined by careless planting and handling of
genetically engineered crops and, like the average consumer, don't see
what's in it for them. The fact is that many large manufacturers and
retailers are distinctly uncomfortable at the prospect of a handful of
biotech companies having a stranglehold on the basic elements in the food
supply chain and their primary duty is to their own shareholders, not to
Monsanto's or Syngenta's shareholders.

Craig Sams, President Whole Earth Foods Ltd

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Forwarded by : ross@acsh.org (Gilbert Ross)

Following is an editorial written by Norman Borlaug discussing his concern
that anti-biotech groups may, through campaigns that cater to public
fears, put an end to biotechnology and its potential to feed the world.
-------
"We Need Biotech to Feed the World"
By Norman Borlaug
Wall Street Journal 12.06.00

Dr. Borlaug, who was awarded the Nobel Peace Prize in 1970 for his
accomplishments in agriculture, is a professor at Texas A&M University.

Science is under attack in affluent nations, where antibiotech activists
claim consumers are being poisoned by inorganic fertilizers and synthetic
pesticides. They also claim that newer genetic engineering technologies
decrease biodiversity and degrade the environment. Neither claim is true,
but fear-mongering could be disastrous for less-developed nations.

Recently, in India, I confronted a move to outlaw inorganic, synthetic
fertilizers. Government officials had been influenced by a cadre of
international foes of technology. Officials told me that although Indian
agriculture had greatly benefited from the use of such fertilizers in its
Green Revolution -- by which India achieved self-sufficiency in grain in
the 1970s -- they were now concerned that these products might have
long-term negative effects. They wanted to revert to the exclusive use of
so-called organic fertilizers.

They were correct about one thing -- India has been the beneficiary of
modern agricultural techniques. In the mid-1960s, both Pakistan and India
saw widespread famine. I managed to persuade both governments to try the
highly productive dwarf wheat and the improved integrated crop management
practices that my colleagues and I developed at the International Maize
and Wheat Center in Mexico.

The results speak for themselves: In 1965, wheat yields were 4.6 million
tons in Pakistan and 12.3 million in India. By 1970, after the
introduction of our new wheat, Pakistan produced nearly twice its amount,
while India increased its yield to 20 million tons. The trend continues.
This year Pakistan harvested 21 million tons, and India 73.5 million --
all-time records.

This salutary trend will be reversed if misguided bureaucrats have their
way. Such a law as India proposed would have seriously diminished the
country's ability to feed its one billion people. Famine would again rear
its ugly head.

The citizens of affluent nations may be able to pay more for food
produced by "natural" or "organic" methods. The chronically undernourished
people of impoverished nations cannot. They also cannot afford to have the
promise of new agricultural technology nipped in the bud, as many
antibiotechnology activists wish.

The latter have been agitating about the supposed threats to human health
engendered by bioengineered foods. But such foods pose no greater threat
to health than foods produced by conventional methods -- probably even
less. While activists inveigh against introducing a gene from one plant or
one species into another, they fail to note that conventional breeders
have been doing just that for many years.

Today we do it better. In the past, conventional plant breeders were
forced to bring unwanted genes along with desirable ones when
incorporating insect or disease resistance in a new crop variety. The
extra genes often had negative effects, and it took years of crossbreeding
and selection to oust them. Conventional plant breeding is crude in
comparison to the methods being used in genetic engineering, where we move
one or a few genes that we know are useful. We must do a better job of
explaining such complexities to the general public, so people will not be
vulnerable to antibiotech distortions.

Some environmental extremists bewail the use of genetic modification that
allows crops to be herbicide resistant, or others that allow plants to
produce their own insecticide. Among other charges, they suggest that
herbicide resistance might be passed to wild relatives of the crops, and
that insecticide-producing plants will decimate insect life and decrease
biodiversity.

The truth is that resistance genes bred into crops by conventional means
could also be spread to wild relatives by Mother Nature herself. Steps can
be taken to minimize the possibility of that happening. Further, the
suggestion that insecticide-producing plants will wipe out insects like
Monarch butterflies is truly far-fetched. The most likely threat to the
butterflies is a reduction of their winter habitat by encroaching land
development in Mexico.

What the activists don't want people to know is that one very good way to
protect wildlife habitat is to ensure that marginal lands are not pressed
into agricultural service in an attempt to feed burgeoning populations. In
1960 in the U.S., the production of the 17 most important food, feed, and
fiber crops was 252 million tons. By 1999 it had increased to 700 million
tons. It is important to note that the 1999 harvest was produced on 10
million fewer acres than were cultivated in 1960. If we had tried to
produce the harvest of 1999 with the technology of 1960, we would have had
to increase the cultivated area by about 460 million acres of land of the
same quality -- which we didn't have.

It is this type of arithmetic that is so important when considering how
to feed the world's ever-increasing population. In 1914, when I was born,
there were about 1.6 billion people in the world. Now it's about six
billion, and we're adding about 85 million each year. We will not be able
to feed the people of this millennium with the current agricultural
techniques and practices. To insist that we can is a delusion that will
condemn millions to hunger, malnutrition and starvation, as well as to
social, economic and political chaos.

I visited Russia recently and spent some time at the newly renamed N.I.
Vavilov Institute of Genetics and Crop Breeding in St. Petersburg. As I
was leaving the conference room, a professor emeritus pulled me aside and
pointed to the red chair at the head of the conference table, which was
unoccupied during our meeting. "That's where Trofim Lysenko sat for 12
years when he destroyed our agricultural research programs and sent many
of our top scientists to prison camps."

T.D. Lysenko, of course, was the pseudo-geneticist who insisted that
Soviet agriculture must be run along politically correct party lines. Many
who disagreed with Lysenko, including N.I. Vavilov, perished in prison
camps. I fear that, like Lysenko, those ideologically opposed to
technological advances will unduly influence our government and developing
nations, as they have almost succeeded in doing in India. If they do, our
prospects for feeding the world will be dim indeed.

I believe the world will be able to produce the food needed to feed the
projected population of about 8.3 billion in the year 2025. I also believe
that it can be done with little negative impact on the environment. But it
cannot be attained without permitting the use of technologies now
available, or without research to further improve and utilize new
technologies, including biotechnology and recombinant DNA.
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From: Mary Murphy
Subject: Honesty from FoE

Dear AgBioViewers,
This is simply unbelievable! Friends of the Earth is finally telling the
truth about their motives, and they've even developed a sense of humor!!
Simply amazing!!

http://www.earthfiends.org/news/news.html

I especially like the T-shirts and mugs, just in time for X-mas. (see
http://www.earthfiends.org/products/tshirts.html)

MM
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From: Andrew Apel

Folks,
The vandals may have been found guilty, but the trial was poignant. On
November 18, the Newcastle Chronicle & Journal reported on page 26 that
one of the vandals "collapsed in tears" during the trial. Stephen Gordon,
26, "sobbed and at one point collapsed into his seat in tears, as he
explained their defence and justified their actions." "'I am running out
of things to eat and I’m not at all confident GM products will continue to
be labelled sufficiently,” he said.

Gives one a sense of the degree of absolute terror which grips these
zealots--or else the extent of acting talent these Brits are famous for.
> GM ACTIVISTS GUILTY OF CRIMINAL DAMAGE
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Avoiding Frankendrugs

Peter A. Singer & Abdallah S. Daar

Nature Biotechnology. December 2000 Volume 18 Number 12 p 1225

The future looks bright for health biotechnology. However, a decade ago,
the future also looked bright for agricultural biotechnology. Since then,
billions of dollars in profits and share value have been lost, and the
food security of billions of people may have been set back. Deutsche
Bank's 1999 report makes the point directly: "Today, the term GMO has
become a liability. We predict that GMOs, once perceived as the driver of
the bull case for this sector, will now be perceived as a pariah."1 Is
such a reversal of fortune possible in health care biotechnology, and what
might be done to prevent it? Some will dismiss the proposition, arguing
that genetically engineered drugs, like recombinant human insulin, have
been used without controversy, or that, for life-saving drugs at least,
the public clearly perceives that their benefits far outweigh any risks.
However, for many drugs that are principally preventative (as is likely
for many of those developed from genomics), people may eschew statistical
benefits because of perceived risks. This may also be the case for
vaccines: In October, the United Kingdom's chief medical officer described
the BSE-derived risk associated with an oral polio vaccine as
"incalculably small," but the UK government nevertheless felt obliged to
recall it2.

One lesson those in health care biotechnology must learn from agriculture
is that research and development needs to take a global view. "Designer"
tomatoes do not generate the same level of public support as rice enriched
with pro-vitamin A or iron. Similarly, post-genomic wrinkle creams or hair
tonics may sell, but a focus of biotechnology on malaria drugs, for
example, would generate stronger public support. We recognize that
biotechnology companies cannot concentrate on products for which there is
no market (as defined by investors and shareholders). However, there are
constructive ways of taking a global view. As more developing countries
join the World Trade Organization, company thinking should begin to
encompass a market of 6 billion people (albeit with smaller unit profit
margins) rather than of 600 million people in the United States and
Europe. Drug donation programs, such as Merck's gift of Mectizan to treat
"river blindness,"3 address global health needs and improve corporate
public relations into the bargain. The proposed vaccine purchase fund is
designed to assure pharmaceutical firms of a market if they develop
vaccines for tuberculosis, malaria, or AIDS.4 Another major lesson from
genetically modified foods is the need to take public perception of risk
seriously.

As Sagar et al.5 noted, "Recent public protests against GM foods are
indicative of a divide between expert and lay perceptions of risk and
uncertainty. . .Public risk perception is influenced as much by social
relations and feelings of power and powerlessness as by objective
knowledge about the likelihood of large-scale accidents or individual
harm." A dismissive attitude toward risk and risk perception on the part
of the scientific or corporate communities was not effective in
agricultural biotechnology and will not be so in health biotechnology.
Proponents of health biotechnology will need to develop better methods of
public engagement and address seriously even hypothetical public health
risks. The market is the loudest voice the public has, but this comes into
play only after a product has been developed. Referenda on biotechnology,
such as that in Switzerland in 1998, can elicit public opinion early, but
they suffer from lack of nuance and perhaps insufficient public education
and deliberation. The public is not properly engaged unless it can address
issues in a balanced manner, mindful, for instance, that biotechnology has
the potential to benefit people around the world—billions of whom have
virtually no resources devoted to health research on the diseases that
afflict them.

Numerous innovative methods of public engagement stop short of national
referenda: theatrical productions, philosophy cafes, consensus
conferences, citizen's juries, citizen's advisory committees, global
panels of public opinion leaders, and Internet-based real-time public
opinion surveys. The need to engage the public on xenotransplantation6,
for instance, has led to a Web-based World Health Organization (WHO,
Geneva) electronic discussion group7. Health Canada is about to launch a
large-scale public engagement exercise before it decides its
xenotransplant policy8. Many of the remedies for the ills lie in the hands
of industry. The former chief executive of Monsanto (St. Louis, MO), took
a long time to reach the stage of dialogue with Greenpeace, and Monsanto
only agreed to stop exploitation of the "terminator seed" technology after
the reasoned intervention of the president of the Rockefeller Foundation.
More recently, however, Monsanto agreed to offer royalty-free licenses to
its technology for producing "golden rice" enriched with pro-vitamin A.

Pharmaceutical firms will need to recognize that no matter how good their
technology or marketing strategies, attention to social and ethical issues
are crucial to their bottom line. They will also need to make it
practicable to license intellectual property where that is justified both
commercially and ethically. At the same time, academic scientists, social
scientists, and ethicists need to accept industry as a legitimate
stakeholder with which to engage in constructive dialogue. We think that
there is a role for international organizations and foundations to
establish forums, networks, and other platforms where stakeholders can
come together. WHO has begun the process by drafting guiding principles
for the future of medical genetics and biotechnology8. Pharmaceutical
companies and their industry associations, among others, responded to the
call for inputs.

Governments need to be involved, too, in facilitating and rewarding the
stakeholders' efforts by creating a stable regulatory environment for the
health biotechnology industry. A model for such a "global public
dialogue"9 is being developed at the University of Toronto. The results of
sustained deliberations in such forums would inform best practices in
industry, nongovernmental organizations, and international organizations.
We need to mitigate the risk of Frankendrugs fiasco by learning the
lessons of the Frankenfoods experience, and acting on them. Billions of
dollars and the health of billions around the world may depend on it.
---------
Peter Singer is Sun Life Chair at the University of Toronto, Joint Center
for Bioethics, Toronto, ON, Canada M5G-1L4 and a Canadian Institutes of
Health research investigator (e-mail: peter.singer@utoronto.ca). Abdallah
Daar is a member of the Ethics Committee of the Human Genome Organization
and professor of surgery at Sultan Qaboos University, Muscat 123,
Sultanate of Oman.
-----

REFERENCES

1. Deutsche Bank (July 12, 1999).
http://www.biotech-info.net/Deutsche.html. 2. BBC News (2000).
http://news6.thdo.bbc.co.uk/hi/english/health/newsid%5F980000/980968.stm .
3. Reich, M.R. Nat. Med. 6, 617–620 ( 2000). MEDLINE 4. Center for
International Development at Harvard University.
http://www.cid.harvard.edu/malaria/malaria.htm. 5. Sagar, A., Daemmrich,
A. & Ashiya, M. Nat. Biotechnol. 18, 2– 4 (2000). MEDLINE 6. Bach, F.H. et
al. Nat. Med. 4, 141–144 ( 1998). MEDLINE 7. WHO Electronic Discussion
Group on International Xenotransplantation Policy Considerations.
http://www.who.int/emc/diseases/zoo/meetings/xenodg.html . 8. Daar, A. &
Mattei, J-F. (Document WHO/EIP/GPE/00.1). Annex 1 of Report of the
informal consultation on ethical issues in genetics, cloning and
biotechnology: possible future directions for WHO. (December 1999>).
9. Conway, C. & Toenniesseu, G. Nature 402, C55–C58 (1999). MEDLINE

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Italian minister axes GMOs

Anna Meldolesi Nature Biotechnology December 2000 Volume 18 Number 12
p 1229

In his latest effort to undermine agbiotech (Nat. Biotechnol. 18, 919,
2000;MEDLINE), the Italian minister of agriculture Alfonso Pecoraro Scanio
has explicitly told scientists they will no longer receive funding from
the ministry unless they eliminate GMOs entirely from their experiments,
even if it means abandoning research conducted over the past 4 years.
Urging the public and scientific community to oppose Pecoraro Scanio's
unilateral decision, the Nobel Prize winner Renato Dulbecco of the
Institute for Biomedical technologies in Milan, together with leading
geneticists, stem cell researchers, anthropologists, and physicists,
published a petition in the Italian financial newspaper Il Sole 24 Ore
(November 5) defending public research and freedom of scientific thought.
Since then, more than 500 international researchers have signed, including
director of the Center for Plant Biotechnology Research at Tuskegee
University CS Prakash, whose own petition in support of agbiotech
(http://www.agbioworld.org ) has more than 2,900 signatures worldwide.
Those wishing to endorse the Italian petition should email e-mail:
appelloMipaf@hotmail.com.
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Best Practice Recommendations from Mae Wan Ho et al:

ISIS Special Report December 2000: Best Practice in the Design of GM Crops
Comment on Consultation Document from Advisory Committee on Releases to
the Environment (ACRE) of the United Kingdom

Executive Summary (For the full document, see ISIS website www.i-sis.org.
To obtain full document plus supplements please send self-addressed
stamped envelop and UKŁ15 to Institute of Science in Society, The October
Gallery, 24 Old Gloucester St., London WC1N 3AL, UK)

The ACRE Subgroup on Best Practice in GM crop Design has invited ISIS to
comment on a draft "Guidance on Best Practice in the Design of Genetically
Modified Crops" www.environment.detr.gov.uk/acre/bestprac/index.htm One of
the main 'enabling technologies' considered in the document is the
'control of gene expression', dubbed 'terminator technology'by its
critics, that genetic engineers seed or pollen to be sterile. A
consultation exercise is simultaneously taking place in the United States
by the US Department of Agriculture, on 'terminator' patents jointly owned
by the USDA and Delta and Pine Land Company. The USDA is considering
commercial development of the technology
http://www.usda.gov/agencies/biotech/downloads/paper72000.html

GM crops engineered with terminator technology for seed/pollen sterility
are already undergoing UK government-funded 'farm-scale' field trials in
the UK. Why has this ACRE consultation not taken place before the massive
field trials were approved, especially in view of the serious new hazards
introduced by the technology (see below)?

The explicit aim of the UK ACRE Subgroup is to improve the safety of GM
crops. The Draft Guidance admits many areas of ignorance and recommends
rigorous testing of all new genes and technologies to ensure that they are
safe and effective.

However, the Draft Guidance does not consider how the potential needs and
benefits offered by the GM crops can be met by developing non-GM crops, or
by means of alternative, sustainable agricultural practices with hundreds,
if not thousands, of years of safety record behind them. Nor does the
Draft Guidance address the socio-economic impacts of corporate control of
agriculture through patents on seeds.

On the contrary, ACRE recommends using 'genetic protection systems' that
engineer seed sterility to enforce corporate patents as a means of
preventing gene transfer from GM crops. ACRE is either attempting to
re-introduce a technology that even Monsanto corporation has abandoned as
the result of universal rejection and condemnation, or else it is
admitting that the transgenes and marker genes are unsafe, and have to be
prevented from dispersal. The latter is surely a strong case for stopping
GM crop development altogether, particularly, as we have argued, and as
admitted by ACRE, the 'biological containment' offered by the technology
is ineffective, and introduces serious new hazards.

The 'genetic protection systems' are ineffective on account of the
'leakiness' of genetic control, which is far short of 100%. Furthermore,
the technology does nothing to prevent horizontal transfer of the genes.
On the contrary, the increased complication of the constructs and
consequent structural instability will tend to enhance horizontal gene
transfer and recombination. In addition, the technology introduces
significant hazards over and above those shared by all GM crops created
to-date. First, the barnase enzyme encoded by the gene that makes pollen
or ovules sterile is a non-specific RNAse, lethal to all cells, animals
and humans included. Second, the recombinase enzyme required to control
gene expression has the potential to scramble genes and genomes in
unpredictable, harmful ways. Third, the spread of sterility genes (or
anther/ovule-lethal genes) will directly threaten food security and
biodiversity.

We recommend the following as 'best practice' on GM crop design that
ensures safety to health and biodiversity and minimises socioeconomic
impacts on farmers. 1. A detailed case for the need and benefit of any GM
crop should be presented before it is made. 2. No seed/pollen sterility
techniques should be used, and no GM crops engineered with these
techniques should be released into the environment. 3. All genes, gene
products and gene constructs should be thoroughly assessed for safety
before they are introduced. 4. Genes with harmful products, genes and
constructs that may enhance horizontal transfer, or have other untoward
consequences on genomes and organisms should not be used. 5. All
antibiotic resistance marker genes should be eliminated. 6. No crop should
be genetically modified to produce pharmaceuticals or industrial
chemicals. The best practice is to use plant cell culture under strictly
contained conditions. 7. No superfluous sequences, or uncharacterised
sequences, should be included in any GMO destined for release into the
environment. 8. No GM crop should be released into the environment unless
it can be thoroughly identified and characterised, using the
state-of-the-art molecular methods, with respect to unintended effects, as
well as genetic uniformity and stability of the insert(s) for at least 5
successive generations. 9. Transformations should be precisely targeted as
well as stable. 10. All patents on GM seeds should be revoked and banned.
11. Research on the safe design and construction of GM crops should be
carried out by independent scientists, not subjected to any pressure to
commercialise prematurely.

Dr. Mae-Wan Ho, Dr. Joe Cummins, Dr. Jeremy Bartlett