The following response from Dr Doug Gurian-Sherman to the latest report, "Withering on the Vine", from the Center for Science in the Public Interest (CSPI) is note worthy not just for providing a very incisive critique of the fundamental problems with the report.

When Dr Gurian-Sherman takes CSPI to task for having "forgotten basic biology in its new report" and for being "simply wrong on the science", it's worth remembering that he was previously the founding co-director and science director for CSPI's biotechnology project. The same goes when he points out how the new report is at odds with CSPI's own previous published positions.

And when he takes CSPI to task over their proposals on regulation, it's worth remembering that he went to CSPI from the U.S. Environmental Protection Agency, where he was responsible for assessing human health and environmental risks from GM plants, and for developing EPA biotechnology policy. And that he also currently serves on FDA's new advisory Food Biotechnology Subcommittee.
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Response to CSPI's "Withering on the Vine"
- By Doug Gurian-Sherman, Ph.D., Senior Scientist, Center for Food Safety, Washington, DC

CSPI seems to have forgotten basic biology in its new report, complaining that APHIS and FDA are taking too long reviewing petitions to deregulate genetically engineered (GE) crops that contain genes previously reviewed in other crops. Contrary to the implied message of the report, genes do not exist in a vacuum, but their effects on people or the environment depends on which crop they are in. This means that each new gene and crop combination needs to be carefully reviewed, even if the gene was previously inserted into a different crop. This interdependence between genes, organisms, and environment is fundamental biology, and it is surprising that an organization that proposes to represent a scientific perspective would not recognize this.

For example, the evaluation of glyphosate herbicide resistance (a gene CSPI complains about taking too long to review) in creeping bentgrass has taken longer to review. That is clearly due, in large part, to criticism from the public sector and other scientists’ about the potential serious risks from these engineered weeds (CSPI mentions but did not include USDA review of creeping bentgrass in its report, perhaps because the APHIS review is not complete). The glyphosate resistance gene has been inserted into a number of other crops, but its insertion into weedy, perennial bentgrass, with many wild relatives that can acquire the gene, raises significant new issues. Should this review be curtailed?

CSPI also fails to understand that new crops containing genes similar to those already commercialized can have additive risks. For example, glyphosate herbicide resistant crops are now giving rise to weeds resistant to the herbicide, which leads to the use of more harmful herbicides and more glyphosate, increasing risks to people and the environment. Additional glyphosate-resistant crops, as is well known by biologists, will likely exacerbate this problem. Resistant weeds have only been emerging as a problem for the last several years. So even though some of the crops CSPI complains about contain the glyphosate resistance gene, the new weed problems require new and more careful risk assessment.

Furthermore, CSPI is simply wrong on the science when it comments that previously engineered genes in new crops, or similar situations, raise "
no apparent novel considerations that might justify longer reviews." Virtually every major scientific report reviewing GE crops, including several National Academy of Sciences reports, comment that GE causes unintended effects, where even the same gene inserted into the same crop as previously done can cause new unexpected, possibly harmful, changes in the plant. "Old" genes in different crops have a greater potential for causing these changes, which must be evaluated carefully for each GE crop, regardless of previous crop/gene combinations.

CSPI also seems to want it both ways. They complain that regulations for biotech crops are lax, and then criticize the agencies when they spend more time reviewing their safety, perhaps in response to public and scientific criticism. It should be remembered that the National Academy of Sciences, for example, sharply criticized USDA for a lack of rigor in its report released in 2002. One of the almost inevitable consequences of a more careful review is the additional time it will take unless substantial additional human resources are committed, which is highly unlikely in our regulatory agencies. Even then, some things that accompany more careful review, like dialog between the agency and reviewer and requests for more data, will add time even with additional personnel.

CSPI itself published a report early in 2003 criticizing FDA for its cursory and faulty reviews. In other words, perhaps the review process should take longer than it previously did, rather than rushing through the agencies. It has apparently not occurred to CSPI that more careful analysis and improved transparency are likely to take longer than shoddy and perfunctory evaluations. It is, as CSPI points out, unclear why evaluations are taking longer (and if they are due to merely administrative delays, those delays should be addressed). But CSPI’s assumption that these crops should take less time is inconsistent with its own positions and clearly misunderstands the science involved.
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The CSPI report in full is at:
http://cspinet.org/new/pdf/withering_on_the_vine.pdf

Their press release:
http://www.lobbywatch.org/archive2.asp?arcid=4862