ANSES says there is "no scientific basis" for Commission's proposal to remove regulatory safeguards from new GMOs. Report: Claire Robinson
The French government's food safety agency ANSES has demolished the European Commission’s proposal for a definition of a class of new GM plants (so-called Category I NGT plants) that would be exempted from risk assessment, traceability and labelling because of their supposed “equivalence… to conventional plants”.
The Commission has specifically proposed as the criterion for this equivalence a threshold of no more than 20 genetic modifications per plant, at the target site and at sites with similar sequences, and a size of 20 nucleotides for insertions and substitutions.
But ANSES says there is no scientific basis for such an assumption of equivalence. It states:
“The Commission's technical document states that ‘similar genetic modifications obtained by different techniques are not assumed to present different risks’, and ‘if certain types and numbers of mutations can be introduced by conventional breeding techniques as well as by NTGs, then the type of traits associated with these mutations will not differ between these techniques’. It concludes that it is sufficient to consider only the type and number of mutations to assess equivalence between these plants, and that it is not necessary to consider the associated effects.
“The Biotechnology WG [ANSES’ working group of experts on biotechnology] considers that there is no scientific basis for equivalence of type of trait or level of risk between two categories of plants on the basis of equivalent content of genetic variations or modifications defined solely by their type, size and number.
“The WG points out that genetic variability or genetic variations observed in nature are the product of thousands of years of evolution, drift or natural selection. Genetic variations or modifications observed in varieties produced by conventional breeding techniques have undergone selection by breeders.
“In both cases, genetic variations or modifications associated with deleterious effects are eliminated, whether in terms of the plant's fitness or its selective value in nature, or in terms of the agronomic and qualitative characteristics sought by man in conventional breeding programmes. The elimination or selection of these variations and modifications is not based on their type, size or number, but on their potential impact on a biological function.
“The Biotechnology WG emphasises that the functional or biological consequences of a given genetic variation or modification are not determined by its type or size.
“Nevertheless, when analysing the proposed equivalence approach, which focuses on the types, sizes and number of genetic modifications, the Biotechnology WG considers that the thresholds of 20 genetic modifications per plant, at the target site and at sites with similar sequences, and a size of 20 nucleotides for insertions and substitutions, are not justified. Nor is the acceptance of any deletion or inversion without conditions, or, to a lesser extent, of targeted cisgenesis without target orthology conditions. Nor is the lack of consideration for potential modifications outside the targeted sites and similar sequences (with the exception of transgenic elements, due to the definition of the NGT plant) justified.”
ANSES adds, “The possibility or probability that a given modification or combination of modifications could be obtained by conventional techniques should be considered.”
This last point is important. While it is theoretically possible for a chimpanzee with a word processor to write this article, the likelihood that this will happen in any realistic timeframe is practically zero. Nowhere has the Commission or its supporters defined the probability of the claim that any given GMO could occur through traditional processes or that such a GMO would have equivalent biological effects to those of a conventional plant.
We agree with ANSES’s analysis. Basing assumptions of equivalence between GMOs and conventional organisms on arguments related to type, number, and size of mutations is not scientifically based and puts public health and the environment at risk. A mutation may be "small" but have large consequences, such as making the plant toxic or allergenic. It is vital that risk assessment, traceability and labelling are retained for ALL GMOs.