1.Friends of the Earth's response to BASF's application to trial GM potatoes
2.MINUTES OF THE 111th MEETING OF ACRE
GM WATCH COMMENT: With no market for GM foods in the UK and no GM field trials going on at the moment, it would be easy to see the UK Government's current consultation on "co-existence" as largely academic.
But a glance at the minutes (ITEM 2) from the last meeting of the UK's Advisory Committee on Releases to the Environment (ACRE) shows it's anything but.
The biotech industry's back in the form of the corporate giant BASF and its GM potato trials, and ACRE is displaying all it's usual regulatory complacency.
While ACRE recognises that "long-distance cross-pollination events are possible, especially where pollen beetles are common in the release area," these are dismissed as "rare" and nothing to worry about. So while studies suggest cross-pollination can occur at up to a kilometre, "BASF has proposed a separation distance of 20 metres and ACRE considers that this distance is sufficient to ensure that potatoes containing GM events have an extremely low probability of entering the food chain." (ITEM 2)
This despite the fact that another agenda item notes that, "One of the knowledge gaps highlighted in the [Government's official] GM Science Review and in the programme workshop for the NERC-BBSRC initiative on gene flow was the consequences of gene flow from GM crops..."
http://www.defra.gov.uk/environment/acre/meetings/06/min060928.htm
Note too that ACRE bats off the concerns over pollen flow in relation to the GM potato trial by relying on a single paper co-authored by a former member of ACRE (Phil Dale) notorious for his pro-GM lobbying.
http://www.gmwatch.org/profile1.asp?PrId=34
There's no sense here that the current massive GM fiasco affecting US rice was the result of GM field trials that finished 5 years ago! Or that field trials have even resulted in non-GM crops being contaminated with maize engineered to produce an experimental pig vaccine!!
To comment on "coexistence" go to http://www.stopgmcontamination.org
Details of how to comment on the GM potato trials are in item 1 below.
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1.Friends of the Earth's response to BASF's application to trial GM blight-resistant potatoes in the UK is pasted below.
Don't forget, all responses have to be in by this Thursday!
If you want to respond, full details are at http://www.defra.gov.uk/environment/gm/regulation/applications/06-r42-01.htm
Best wishes,
Liz Wright
Representation from Friends of the Earth on application for a part B consent from BASF Plant Science to release genetically modified potatoes with improved resistance to Phytophthora infestans (Application Reference 06/R42/01)
October 2006
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Friends of the Earth objects to this application from BASF Plant Science to release blight resistant genetically modified potatoes into the environment in experimental trials.
Our grounds for objection are as follows:
GM contamination
Although commercial potatoes are propagated via tubers, true potato seed production can also occur, and while not affecting the current tubers, it can create GM volunteers in future crops. Rates of outcrossing recorded under field conditions for potatoes range from 0 to 20%, with both wind and insect pollination likely to be involved [1]. Some studies have detected pollen up to 20m from the source [2], but one study recorded outcrossing levels of 31% at 1000m, thought to be due to pollen beetles [3].
Of the three varieties BASF will be using in the trials, P835 and P880 produce abundant flowers, while P698 is middling. P880 frequently sets berries, P835 sets few, and P698 rarely does, but no information on the viability or longevity of the seeds is given.
Groundkeeper control will be crucial to prevent contamination. True seed, unharvested tubers and damaged tuber pieces can all sprout in the following year to produce weed plants in subsequent crops, which will in turn produce small tubers which can persist to contaminate crops in future years. Control with herbicides is difficult in following broad leaved crops. BASF say that groundkeepers will be quickly killed by frosts, but as a 2002 European Environment Agency report [4] explains, "in recent years, the combination of reduced herbicide rates throughout the rotation due to declining arable margins, a succession of mild winters and the use of vigorous potato varieties has increased the numbers of volunteer potatoes."
Friends of the Earth therefore objects to this application for growing experimental GM potatoes in the open air on the basis that it will be very difficult to prevent them contaminating other non-GM potato crops. Should Defra give the go ahead for these trials, strict measures must be put in place to ensure that these experimental potatoes cannot contaminate future crops via groundkeepers or volunteers derived from seed production. Nearby potato crops must also be protected from pollen transfer from the GM potatoes.
Safety
No evidence is provided in the application to rule out unexpected effects due to the GM insertion, and no safety data is provided on the potatoes. Yet experimental GM potatoes have resulted in entirely unpredicted outcomes in the past for example a potato modified to have low levels of the NAD-malic enzyme showed increase starch content, which the researchers could not explain [5]. And an attempt to introduce yeast and bacterial genes into potatoes to increase starch content actually reduced starch content and produced unexpected compounds due to disruption of the plant metabolism [6]. Research on GM potatoes modified to produce GNA lectin [7] suggested impacts on the gastrointestinal tract of rats, provoking scientific controversy [8], yet no follow up research has ever been carried out.
Although BASF do not intend for these potatoes to enter the food chain, and crops are intended to be destroyed at the end of the trials, the experience of LL601 rice in the USA, where an experimental GM rice line has contaminated worldwide rice supplies, illustrates that these experiments are not always containable. Rice, like potatoes, has always previously been considered a ‘low risk’ GM crop for contamination, due to the low levels of cross pollination expected. Yet recent events would indicate that even ‘low risk’ crops can be involved in serious GM contamination incidents.
Friends of the Earth does not believe that these open-air GM trials should go ahead, but should permission be granted then publicly available safety data would help to provide reassurance in the event of a contamination incident similar to the US experience.
Lack of need
Genetic modification is not the only way of producing blight resistant potatoes breeding programmes have already produced a range of blight-resistant potatoes that are currently in use in the UK, and there are many more in the pipeline. The Sarvari Research Trust has developed the Sarpo blight-resistant varieties which are performing well in UK trials and taste tests.
Phytophthora infestans is constantly mutating, existing as a large population with much genetic variation. Some blight resistant potatoes may have only short-lived resistance, while some individual varieties can last for several decades the rate at which the pathogen can overcome resistance is impossible to predict. A single genetically modified variety of potato may not therefore offer a long-term solution for late blight. Plant breeders need to stay one step ahead of the pathogen, and given the tight regulations around the deliberate release of genetically modified organisms, and long periods of time required for approval, traditional breeding may in fact offer a speedier option.
Furthermore, it is unclear what level of reduction in fungicide use GM blight-resistant potatoes would actually deliver. Figures on reasons for use of fungicides do not appear to have been collected since 1998, when blight accounted for just 34% of fungicide use for ware potatoes [9]. The genuine level of reduction of fungicide use must be investigated before any approval is given for these trials.
Lack of demand
Consumers have made it clear that they do not want to eat genetically modified food in numerous surveys, debates, and by voting with their feet supermarkets have removed almost all genetically modified foods from their shelves due to consumer demand. The latest Eurobarometer poll reports that "Europeans think that GM food should not be encouraged. GM food is widely seen as not being useful, as morally unacceptable and as a risk for society" [10].
It is unclear who BASF expects to eat these GM potatoes should they eventually make it onto the market. These trials therefore represent an unnecessary risk to the environment and could threaten the integrity of GM-free potato supplies in the UK.
Conditions
Friends of the Earth objects to this application, and urges Defra to reject it. Should the application be accepted, very strict conditions must be included in the consent, including:
- Detailed written instructions and procedures for trial management, which must include:
o Removal of flowers prior to pollination
o A separation distance of 1.5km between the trial and the nearest non-GM potato crop, including allotments or gardens.
o Complete removal of tubers post-harvest with measures to minimise any remaining tubers
o Complete destruction of both GM and non-GM potatoes post-harvest
o Secure storage separate from non-GM potatoes prior to planting and after harvest, with detailed and accurate record-keeping
o Thorough cleaning of all farm machinery and equipment after sowing, field operations and harvesting
o Checking of all vehicles used for transport to ensure no spillage can occur
o Planting of a spring cereal crop after the trial and complete destruction of any sprouting tubers with herbicide
o Trial site must be monitored post-harvest for eight years for any sign of emergence of groundkeepers or true potato seed
o Planting of commercial non-GM potatoes in trial area prohibited for ten years
o Trial site must be secured to prevent wild mammals entering the site
- A validated protocol for identification of the GM potato must be provided, together with positive and negative control samples
- Post release monitoring of impacts on biodiversity, gene flow, and persistence of tubers and true potato seed.
References
[1] Treu R & Emberlin J (2000). Pollen dispersal in the crops maize (Zea mays), oilseed rape (Brassica napus ssp oleifera), potatoes (Solanum tuberosum), sugar beet (Beta vulgaris ssp. Vulgaris) and wheat (Triticum aestivum). Evidence from publications. A report for the Soil Association from the National Pollen Research Unit.
[2] Eastham K & Sweet J (2002). Genetically Modified Organisms (GMOs): The significance of gene flow through pollen transfer. European Environment Agency
[3] Skogsmyr, I. (1994) Gene dispersal from transgenic potatoes to conspecifics: A field trial. Theoretical and Applied Genetics 88: 770 774.
[4] Eastham K & Sweet J (2002). Genetically Modified Organisms (GMOs): The significance of gene flow through pollen transfer. European Environment Agency
[5] BBSRC Business, Jan 1998. "Making crops make more starch" p6-7
[6] Gura, T (2000) Reaping the plant gene harvest. Science 287 412-414
[7] Ewan, S.W.B. & Pusztai, A. (1999) Effect of diets containing genetically modified potatoes expressing Galanthus nivalis lectin on rat small intestine. The Lancet 354: 1353-1354.
[8] The Royal Society (1999) Review of data on possible toxicity of GM potatoes.
[9] Garthwaite DG & Thomas MR (1998). Pesticide Usage Survey Report 159: Arable crops in Great Britain 1998. PUSG/CSL. http://www.csl.gov.uk/science/organ/pvm/puskm/arable1998.pdf
[10] http://www.ec.europa.eu/research/press/2006/pr1906en.cfm
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2.MINUTES OF THE 111th MEETING OF ACRE AT THE INSTITUTE OF GRASSLAND AND ENVIRONMENTAL RESEARCH, ABERYSTWYTH, THURSDAY 28 SEPTEMBER 2006 http://www.defra.gov.uk/environment/acre/meetings/06/min060928.htm
4.1 Application for part B consent from BASF Plant Science to release genetically modified solanum tuberosum to screen events for improved resistance to <em>phytophthora infestans - ref 06/R42/1. ACRE/06/P21
The committee gave its advice on an application from BASF Plant Sciences to conduct an experimental field release of a potato genetically modified for resistance to Phytophthora infestans
BASF proposes to release three potato cultivars containing a range of different GM events in order to monitor their resistance to UK pathotypes of Phytophthora infestans. The company plans to trial the potatoes at two different locations, one in Derbyshire and the other in Cambridgeshire. The committee was also asked to comment on the scientific issues raised in two public representations, one from the Soil Association and one from Cavan Leitrim Environmental Awareness Network Ltd.
The chairman reminded the committee that the controls placed on Part B trials ensured that GM products resulting from the trial did not enter the human and animal food chain. The committee was therefore asked to discuss the application and advise on any conditions that should be imposed on the trial.
Regarding the molecular characterisation of the GMOs to be released in this trial, members were content that any products of the gene conferring resistance to the antibiotic spectinomycin were not present in the GM lines to be released. Members were also content with the risk assessment provided by the applicant with respect to the potential impact of other sequences potentially inserted into the plant. The committee concluded that the molecular characterisation and associated risk assessment provided was adequate with respect to the proposed release.
The conditions proposed by the applicant for the control of GMOs on the release sites were discussed in detail. ACRE discussed issues relating to the survival of the GM potatoes on the trial site and concluded that potato tubers are capable of over-wintering at the proposed trial sites.
BASF has also indicated that some of the cultivars to be planted at the trial sites produce berries and therefore that it may be possible for volunteer potato plants to emerge from true seed.
True potato seed is long-lived but readily germinates under appropriate conditions, however, the volunteer potatoes from true seed are extremely vulnerable to herbicide application.
ACRE concluded that once the GM potatoes had been harvested on each trial site, the ground should be left fallow to encourage the germination of true potato seed. This strategy also enables the identification and early treatment of potato groundkeepers and volunteers by hand-pulling before viable tubers have set or by herbicide treatment with a systemic herbicide. The committee also advised that the land should not be ploughed after the potato trial harvest but that shallow tillage should be used on the release site for the next 2 years.
The company proposes to chop or heat-treat the potato tubers following harvest and removal to an off-site location and ACRE was content with this proposal
The company also plans to leave parts of the potato plants other than tubers on the soil surface at each site to decompose. ACRE was content with this proposal if the fallow cropping and herbicide regime proposed by the committee is followed. The applicant proposed to monitor volunteer potatoes at release sites until none had been found for two years. ACRE was content with this proposal and advised that BASF should provide details of groundkeeper and volunteer presence in annually submitted post-release monitoring reports.
The committee was asked to give their advice on whether it would be necessary to fence the trial site to prevent entry of wild animals as proposed by the applicant. The committee agreed with BASF that potatoes are not generally eaten by wild animals due to the natural presence of toxic chemicals in the plant foliage. ACRE did not believe that a fence was likely to reduce the transfer of tubers away from the trial site by involuntary means and therefore concluded that fencing of the trial site for this purpose should not be required.
The committee discussed the potential for entry into the human food chain through cross-pollination of other potato fields growing close to the trial field. A chain of events would be necessary in order for a potato containing a GM event to enter the food chain.
Firstly, pollen containing a GM event would have to be produced, this occurs to a variable degree in potato plants depending on the potato cultivar. BASF has indicated that some of the cultivars proposed for use in this trial frequently produce flowers and set seed and therefore this can be regarded as likely.
The second stage is the successful transfer of the pollen to a non-GM potato growing in a commercial crop. This relies on pollen being transported by the wind or by insects, pollen dispersal typically tails off with distance from the pollen source.
BASF indicated in their application that pollen could travel 10 metres. In this respect the committee was asked to comment on studies referred to in public representations (Skogsmyr, I. (1994) Theoretical and Applied Genetics 88:770-774) indicating cross-pollination events at distances of up to one kilometre. ACRE commented that the Skogsmyr study had no controls for the PCR on which this conclusion was based and therefore that the information provided was not reliable. A later review of studies relating to gene flow in potatoes indicated that a distance of 20 metres would generally be adequate to prevent cross-pollination with non-GM crops (Conner, A.J. and Dale, P.J. (1996) Reconsideration of pollen dispersal data from field trials of transgenic potatoes. Theoretical and Applied Genetics, 92, 505 508).
ACRE recognises that rare long-distance cross-pollination events are possible, especially where pollen beetles are common in the release area. However cross-pollination frequencies reduce dramatically over distance and pollen competition from within a non-GM crop reduces the likelihood of successful hybridisation further. Thirdly, if GM pollen hybridised successfully and resulted in GM seed, the chances of such seed germinating successfully and surviving until harvest as a tuber in a non-GM potato crop are low because potatoes are usually grown in rotations and the volunteers resulting from true seed are very vulnerable to herbicide applications and to competition from the following crop.
BASF has proposed a separation distance of 20 metres and ACRE considers that this distance is sufficient to ensure that potatoes containing GM events have an extremely low probability of entering the food chain.
The public consultation on this application ends on 19 October. Further advice on any scientific issues raised in public representations will be sought by circulation.
Action: Secretariat to draft advice for agreement by circulation