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Date:

January 7, 2001

Subject:

"Response to Pusztai and apology"

 

Dear Dr Morton,

We now seem to be playing silly games with numbers and other unfortunate
deviations from what we really ought to be focusing on. So let's first
call an end to the numbers' game.

There were 56 so-called references in your initial piece, 5 of which
were in fact duplicates or triplicates. So, in the new list there
should have been 51. It took me half an hour to establish how 56 - 5
came to equal 53. It appears that our J. Nutrition paper has been added
to the list and a previously listed paper, which lacked a reference no.
in the original list, has now acquired one. However, otherwise the
references were still the same as in the original list (although
numbered differently), despite my rather commonsense criticisms.

For a moment I thought that our Lancet paper might have now been
included in the new list, as one of these two extras. Alas, it was not
to be because it was deemed to be "irrelevant to the discussion as to
whether the GM food on the market is safe or not". Clearly, even though
this article and a few others in Domingo's list in Science were most
definitely peer-reviewed papers, they obviously did not come up to the
pro-GM scientists' standards, as exemplified by the 41 non peer-reviewed
references in the original and in the amended list.

I am afraid, even now I and, I guess, a lot of other scientists would
regard the contents of these 41 "references" as little more than
opinions. I pick out a few glaring examples at random. How could
articles such as that published in the FDA Consumer magazine (no. 45),
the R&D Magazine (no. 48), or Canadian Newswire Oct 25 (no. 52), etc be
regarded as superior to the peer-reviewed papers in Domingo's references
in Science?

This, I am sure, would require an explanation for most unbiased people.
Even abstracts given at scientific meetings are not much use because
they very seldom contain much hard data and information and are of
limited circulation. In fact, regarding them as peer-reviewed
publications places Dr Morton on very dangerous ground because most of
our GM potato work has also been presented at scientific meetings and
their abstracts were published in the proceedings prior to my talking
about it during the TV interview. Therefore, the original charge
against us, i.e. that I prematurely gave details of our work without
their having been first peer-reviewed, seems to lose its validity.

While reading the Morton "Response" I realised why it is so difficult to
find common ground between the pro-GM believers and those scientists who
take a more sceptical view of the soundness of the GM science and
technology. I would recommend that people should read the original
piece posted on the AGBIOVIEW website at the beginning of December as it
clearly describes a novel idea of refereeing:

"Look at the bibliography above and you will see the vast majority
of the [56] publications mentioned are full peer-reviewed publications
in journals. Some reports submitted to FDA, EPA etc are not
peer-reviewed by journal editors but you can be sure they are
peer-reviewed by the people at FDA and EPA."

Most scientists regard publishing their results in peer-reviewed
journals as a difficult, sometimes painful and laborious job. However,
they still do this because we have not come up yet with a better and
more responsible system for the dissemination of new results, ideas and
concepts, so that other scientists could use them for their own work.
This is the way science has progressed through the ages. True, it is
not foolproof but it is the best we have for the time being.

Personally, I would be extremely grateful if the biotechnology
companies could prevail on their scientists to properly publish their
work instead of using these bits of communications, articles etc, as
typified by 41 references on the list. Currently they are preventing
other scientists from incorporating the data in their own research and
checking it.

It would also be useful because then we would not have to play this
silly numbers game. I am sure, Dr Morton knows perfectly well that I am
right. Let us all hope that science will win out at the end.

Incidentally, it is rather revealing that, in line with what has been
maintained by the GM biotechnology industry, pro-GM scientists
apparently do not expect to find any differences between GM and non-GM
crops under any conditions in their research. Otherwise the following
passage in the Morton piece which states that "publishing the results of
experiments where there is no difference between the treatments is very
difficult - because there is not a Journal of Boring Results", would be
meaningless.

There is a second essential point about the perspective of pro-GM
enthusiasts which needs to be understood. In Dr Morton's list, with the
addition of our J. Nutrition paper there are now 5 peer-reviewed
publications describing animal feeding studies done with diets
containing GM crops. Although one may not agree with some of the
findings described in these papers and even criticise them, these are
now part of the scientific debate on GM foods and I welcome that.
However, it appears that the GM enthusiasts cannot embrace the idea of
reciprocity or that there are usually two sides to any debate. Indeed,
the word "to debate" in the pro-GM scientist's vocabulary apparently
means "to agree" with the pro-GM point of view. Dr Morton's piece has
demonstrated this, if it has demonstarted nothing else, by leaving out
the more sceptical references (including the Lancet paper and some
others) from the list.

Moreover, as I mentioned previously, the direct relevance of the 7
peer-reviewed compositional studies to the safety of GM food is somewhat
debatable and the sooner this is realized by the pro-GM lobby the better
it will be all round. It needs to be understood that establishing
compositional equivalence of macronutrients between GM and conventional
crops, though important, is of rather limited value.

As the present technology of genetic crop transformation cannot deliver
GM crops which are predictably safe and have no unintended effects, some
sceptics, quite rightly in my opinion, regard the use of the word
"technology" as a misnomer. Provision of tonnes of analytical data will
not make up for the uncertainty as to whether the GM product is safe or
not.

A distinguished French scientist and regulator who was invited to give
an official contribution at the OECD Conference in Edinburgh
(incidentally he is not included in the "list" either) gave a brilliant
example of the basic fallacy of "substantial equivalence" in
macronutrient composition. He said that although a BSE cow is
substantially equivalent to a healthy one nobody would be happy to eat
it. Before scientific work had revealed the reason for the difference
between the two animals nobody knew what to look for. Having identified
that, when scientists try to identify which cow is infected with BSE
they do not measure the macronutrient content of the cow but will look
for the appropriate prion proteins (0.0000....% of the cow's weight)
that makes the cow potentially lethal for herself and the humans eating
it.

The message is that you must first establish whether there is a
difference between the GM crop and its conventional counterpart by
short- and long-term laboratory animal testing and then, if there is,
look for what chemical component(s) is/are responsible for this
difference. From there on, just like with the prions, it is relatively
plain sailing: scientists will determine the changes in the content of
this component(s) in the various lines of GM crops and then
physiologists/nutritionists/toxicologists will establish whether
predictions based on the content of these (toxic, antinutritive,
antihormonal, etc) components will be borne out by animal tests. This
is how science has worked in the past and I need to be persuaded by
logical and factual arguments why this should not apply to GM crops.

I am glad to say that at least in one respect Morton's views and mine
are similar. No true scientist can (or will) ever say that a food is
100% safe regardless of whether its a GM or non-GM variety although we
have in the past two years been bombarded by politicians telling us
that, based on the best scientific advice, it is inconceivable that GM
foods are not safe.

Unfortunately, it is the food processing industry's (and the
regulators') cutting corners which is responsible for not properly
testing novel foods and processes before allowing them onto the
market. However, as we know well, two wrongs do not make a right.
Again we come back to BSE. Why were those re-processed animal
remnants not properly tested before feeding them to cows? Or, why
for that matter were the tryptophan supplements not properly tested
before they poisoned and maimed so many people? It is immaterial
whether this effect was due to genetic modification or cutting corners
with the purification of the product or both. A novel production method
was introduced without testing the outcome. Incidentally, the newly
produced tryptophan was also "substantially equivalent" to the non-toxic
tryptophan produced by all other manufacturers (99% or better).

At this point we must also confront this business about how, by demanding
independent verification of GM safety, the "activists" imply that the
industry-financed "laboratories are fraudulently producing results
showing the food is safe when in fact it is unsafe". In such a light Sir
John Krebs' and the OECD Edinburgh Conference's final motto of "openness,
transparency and inclusiveness" can also be regarded as questioning the
GM industry's credibility.

The fact is that when one buys a second hand car one does not
exclusively rely on the seller's assurance but, if one has any sense,
also asks for an independent opinion. Obviously, the industry does test
their products but that also leaves room for independent testing. The
idea that there is a terrible quandry as to who is going to pay for this,
because the public will not, rings rather hollow in the wake of the Cry9
Taco shell disaster because it was testing by a public NGO and not
Aventis' scientists which alerted everyone to the problem of
contamination.

Perhaps the industry ought to set up a fund from which money could be
used to support independent scientific investigations. It would not
only be in the interest of public safety but the GM companies would also
clearly benefit if independent research workers found that their
products presented no unacceptable health or environmental safety risks.
Industry could only gain by such an endorsement, which inevitably leads
one to ponder why there is so much difficulty about achieving such
"openness, transparency and inclusiveness". Are the companies, in
reality, afraid that the independent research scientists might find
something negative about their GM products? Certainly I (and I am told
many others) had a great deal of difficulties in the past when we tried
to obtain bona fide samples of GM and parent line crops from biotech
companies for our testing. And we did not even ask for their money,
just for the samples.

In the Morton "Responses" there was a return to our GM pea paper. It
was quite revealing that, apparently, it was envisaged that there could
be no possible detrimental effects of these peas on the rats. Thus,
there was a plea that the paper's title should have said that the GM
peas had "NO DETRIMENTAL EFFECT" rather than minimal detrimental effect.

First of all, I should point out that the title was coined by T.J.
Higgins and seconded by Maarten Chrispeels, neither of whom are known to
be rabid anti-GM scientists. Of course, they were right because
although Dr Morton may think that the differences found could not be
regarded as potentially detrimental, some more cautious scientists might
regard the changes as potentially harmful. Now there are two
peer-reviewed papers, in addition to the FDA's own FLAVR SAVR tomato
study, in which gut lesions have been found with GM foodstuffs in three
different labs. In this light, even though in the GM pea study there
was no histology, the significant weight and compositional differences
in the caecum (large intestine) and the increased weight (not
significant) of the small intestine should have at least cautioned
anyone against claiming no detrimental effects and suggested doing
further and more relevant (histological, immunological, etc) studies to
investigate whether these differences had any physiological
significance.

This is of particular importance when one takes into account that in
practically all biological testing of GM crops the scientists use SPF
and fully healthy rats or other animals. No tests have ever been
performed with animals which had problems with their digestive system,
despite the fact that a very sizeable proportion of the human population
has diseases of the alimentary tract, such as Crohn's disease,
ulcerative colitis, intestinal and pancreatic tumours of all kinds, H.
pylory and other bacterial infections, and a compromised immune system,
etc. Can anyone from the GM fraternity assure these people that they
will suffer no ill effects when animal studies have already indicated
the possibility of such? I do not want to appear to be pedantic but we
all must be reminded of the fact that once a GM crop is released we lose
all control over it. If the Taco shell disaster proved nothing else, it
showed that neither the industry, nor the EPA or FDA are equipped to
deal with a recall. This places extra responsibility on scientists to
be ultra cautious and not to claim that something has no detrimental
effects just because their experiences are not wide enough to see
possible problems.

In the "Response" document, in addition to an interpretation of the word
"commercialization", there were again references to our potato study. As
I previously dealt with this point, I have nothing further to add apart
from asking a question as to who would have done a "proper safety
assessment including animal feeding studies" (on these GM potatoes) in
the UK. After all, ACNFP, our regulatory authority, have no labs of
their own and only ask for the companies to submit the results of their
own testing. Incidentally, even this level of regulation is more
rigorous than that in the USA where there is self-regulation and the FDA
would not have required any such documentation, just a notification of
the impending release of a new GM food crop.

There was also some query at the end of the "Response" document about
the comments I have reportedly made about the CaMV 35 s promoter.
According to (as it is claimed in the document) some unidentified
activists (who keep popping up), I claimed that the transgenic potatoes
behaved differently to non-transgenic potatoes spiked with the transgene
product because of the 35 s promoter.

I am now going to quote from our Lancet paper: "The possibility that a
plant vector in common use in some GM plants can affect the mucosa of
the gastrointestinal tract and exert powerful biological effects may
also apply to GM plants containing similar constructs, particularly
those containing lectins..." Or as in the Abstract: "Other parts of the
construct or the genetic transformation (or both) could have also
contributed to the overall biological effects...". Perhaps, after all
it may have been useful to include the Lancet paper in the list and
quote its Abstract to prevent any misunderstandings. One thing is,
however, crystal clear that any mentioning of the 35 s promoter was
conspicuosly absent from the paper even though that construct would
have, of course, contained the promoter too. However, a scientist can
only refer to facts revealed by his/her studies and not, as it is often
found nowadays, to his/her opinions.

Finally, as referred to above, I do not necessarily agree with the view
that we found no potentially detrimental effects with our GM peas. We
are back to the old claim by the GM protagonists that as there is no
proof that human health is affected by GM food, it must be safe!
According to this line of argument, the only thing the GM biotech
industry needs to do in future is not do any testing as then the myth of
the safety of GM food will be maintained for eternity. I am sure, to
judge by present standards, that they are well on their way to achieving this.