In a type of action not available in many countries, an Indian citizen is challenging proposed field-trials of a particularly obnoxious GM-eggplant. Several scientists have deposed statements in support - here's mine.

Statement for the Supreme Court of India
on the Writ Petition of Aruna Rodrigues
L. R. B. Mann
senior lecturer in Biochemistry (rtd)
University of Auckland, New Zealand

Introduction

I have studied the statements to the Court by Professor Schubert, Dr Pusztai and Dr Gurian-Sherman. I find I agree with them, and will not reiterate their points here, but have been invited to augment them. What I wish to do is to make some general points about genetic 'engineering', as well as some particular points about the proposed GM-Brinjal that are not emphasized in their prior statements.

Genetic manipulation (GM) or genetic engineering (GE) mean artificial transfer of genes - pieces of DNA - to produce a transgenic organism, e.g. jellyfish genes into sugarcane or human genes into cows. The methods of artificially joining pieces of DNA from different organisms' genes were invented as recently as the mid-1970s and are collectively called recombinant-DNA technology.

I was a university teacher of biochemistry when these techniques were first developed, and became interested in their effects. Much of what I have to say to the Court is taken from a paper presented more recently as a public lecture to the Royal Society of New Zealand (Auckland branch).

The techniques of GM no more entail a uniform degree of hazard than does nuclear science. As in nuclear technology, so with genetic engineering: the tag 'nuclear' does not necessarily connote any serious degree of hazard, and some versions of GM may well be harmless.

But some versions are not harmless. Therefore a regulatory system must perform sceptical analyses of GM proposals to assess their hazards.

General Doubts

Many scientific and moral leaders have queried GM. The science upon which GM technology is founded is under strenuous criticism from scientific thinkers. Genes are not Lego modules which can be blithely slotted into very different organisms free from unintended effects. Rogue diseases are a genuine concern arising from detailed, sceptical appraisal of some GM projects by highly qualified scientists. But global ecological damage is the gravest threat.

One tawdry old argument we have heard since 1974 and can expect to hear again is the claim that gene transfers occur naturally so GM is only hastening them. This line of talk is a smoke-screen designed to obscure the fact that GM usually performs artificial transfers which are not known to occur in nature. This fact is denied when possible harm is suggested, but is acknowledged, indeed emphasised, for claims of benefit. It is certainly true that no brinjal could arise in nature containing modified versions of a Bt toxin in most or all of its cells.

If we change the rates, or even worse the specificities, with which genes can jump around in infectious manners, we may wreak biological havoc on a global scale. Go back to Ovid's Metamorphoses to glimpse what might go wrong.

The gene-manipulators claim they can foresee the evolutionary results of their artificial transposings of human genes into sheep, bovine genes into tomatoes, altered bacterial genes into eggplant,etc. But such claims are a reflection more of arrogance than of scientific analysis.

The science upon which current GM experiments are based, as stated or assumed by the experimenters, is in many places wrong.

For instance:-

1. It is routinely assumed that there are only 4 letters in the 'alphabet' of DNA (called for short G, C, T, and A). But it has been known for several decades that other 'letters' exist in DNA. The functions of the 'odd' bases - methyl-C, methyl-G, and others - are largely unknown, but that does not mean they're equivalent to 'The Big Four'. They are often ignored by genetic engineers sequencing DNA "copied" by systems that can produce only 'Big 4' polymers. The synthetic genes inserted by GM are, on this basis, all made with just 'The Big Four' bases. This is a glaring fallacy.

2. Synthetic genes are routinely inserted which are deliberately different from actual genes. An example in the present case is the 'Bt' genes that have been inserted into GM-Brinjal; the 'Bt' toxin gene must be different from that for any actual toxin produced in the bacterium Bacillus thuringiensis , in order for the plant to make the novel protein to any useful extent.

3. It is routinely assumed that the effects of genes inserted by radically unnatural methods are predictable, when in fact they are known to be extremely variable (frequently lethal). It is pretended that a cell surviving such genes-insertion processes, and then selected on just one property - resistance to an antibiotic - and then grown into a whole organism, e.g. an eggplant, will have all properties at least as good as those of a normal organism. On the contrary, insertional mutation damages the target genome in unpredictable ways, rendering literally unforeseeable the many properties of any surviving GM-cells. The unforeseeability is compounded by somaclonal variation in the GM-progeny: plants grown from single cells, taking advantage of what is called the 'totipotence' of some plant cells, are known to exhibit much more variability than plants grown from normal seed.

How Much Harm; How Often?

In appraising dangerous technologies, it is best to estimate the hazard - the scale of harm in the event of a major mishap - as a separate question, and then analyse if possible the risk - the probability that the major mishap will occur. Much confusion between these two aspects of danger has been created by language-tampering, even in such formal arenas as the Journal of Risk Analysis.

Biology is so much more complex than technology that we should not pretend we can imagine all the horror scenarios, but it is suspected that some artificial genetic manipulations create the potential to derange the biosphere for longer than any civilisation could survive. If only pro-GM enthusiasts are consulted in the appraisal of GM proposals, such scenarios will not be thought of.

The hazard certainly includes some mortality: a hundred or so people were killed, and a few thousand maimed, in the 1980s by impurities in L-tryptophan (a natural amino acid, sold as a dietary supplement) made by Showa Denko using GM'd bacterial cultures. Showa Denko has paid roughly U$2,000,000,000 in out-of-court settlements of suits resulting from some of the approx. 80 - 120 deaths (possibly more) and thousands continuing maimed. This actual damage by GM (http://www.connectotel.com/gmfood/trypto.html) is one basis of the campaign for labelling as such any GM'd foods which may be permitted.

Having taught on environmental health hazards for many years in science &medical faculties, and having served as an adviser to successive Ministers of Health in the first dozen years of the Toxic Substances Board, I know all too well how overloaded government staff, even when backed by statutory powers, get subverted by not only the specific claims but more importantly the whole value-system of the industries which they are supposed to regulate. It is therefore crucially important that a clearly defined agency conduct scrutiny of GMOs before they are allowed into field-trials. Furthermore, that agency must - to be scientifically reliable - take due account of evidence against a proposed field-trial. In the case of GM-brinjal, the evidence summarised by the experts from whom the Court has already heard on behalf of Mrs Rodrigues is, in my opinion, overwhelming.

One aspect of 'Bt'-Brinjal which deserves more attention is the persistent concern among experts that GM-'Bt' plants such as this will evoke selection & proliferation of mutant insects resistant to Bacillus thuringiensis. The natural bacterium B. t. is very important in advanced organic agriculture, so insects resistant to this pesticide would be a serious threat to many types of agriculture on which a country such as India inevitably & rightly relies.

Conclusion

I regard the 'Bt'-brinjal field-trial proposal as one of the most ill-conceived I have encountered in my three decades of critical appraisal of GM. The risks and hazards, while not exactly known or indeed precisely foreseeable, appear to be so grave that the proposed field-trials should be enjoined pending a thorough assessment such as has yet to be performed. Since the intended GM-brinjal would be unfit for human consumption, the hazards of the field-trial can be prevented by not doing the field-trial.

(signed)

L. R. B. Mann

21-7-2006

+ DOCUMENTS ON BT BRINJAL Here are links to documents forming part of the response sent by the Coalition for a GM-Free India, to India's GM regulatory body - the Genetic Engineering Approval Committee (GEAC) - on the biosafety data and the proposal by Monsanto Mahyco for field trials and seed production of Bt brinjal (eggplant/aubergine).

The Coalition's response was endorsed by more than 250 leading organisations and eminent experts from various fields including farmers' organisations, organic farmers, agricultural scientists, microbiologists, medical professionals, and social scientists.

The Coalition also told the GEAC that it strongly objected to the fact that the GEAC had stated in a press release that it WILL permit the trials, even while it was asking for feedback on the proposal to hold the trials! This, the Coalition said, was not just unacceptable but rendered the entire regulatory process farcical.

The documents are at: http://www.lobbywatch.org/archive2.asp?arcid=6772
http://www.lobbywatch.org/archive2.asp?arcid=6773
http://www.lobbywatch.org/archive2.asp?arcid=6774
http://www.lobbywatch.org/archive2.asp?arcid=6775
http://www.lobbywatch.org/archive2.asp?arcid=6776

For a letter to the prime minister of India from the food and trade policy analyst, Dr Devinder Sharma on the Bt brinjal plans, see:
http://www.lobbywatch.org/archive2.asp?arcid=6778