1.GMO action alert: Less than 48 hours to go
2.EFSA lies and incompetence
a) to Dimas
b) to Hilary Benn MP
c) Petition to the European Parliament
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1.GMO action alert: Less than 48 hours to go
Greenpeace International, 2 December 2008

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TAKE ACTION
Write directly to the UK and German Ministers now
http://links.mailing.greenpeace.org/ctt?kn=5&m=30628676&r=MTExMjgxNzgzMwS2&b=0&j =NDM0NjA5ODYS1&mt=1&rt=0
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Dear friends,

The UK and German Environment Ministers are trying to wreck Thursday's EU meeting on GMOs.

With less than 48 hours to go, we need to focus now on these politicians alone -- to isolate them, and register our protest as directly as possible.

Can you please write them a personal email right now?
http://links.mailing.greenpeace.org/ctt?kn=4&m=30628676&r=MTExMjgxNzgzMwS2&b=0&j =NDM0NjA5ODYS1&mt=1&rt=0

Germany's turn to the pro-GMO side (they were "undecided" before) is particularly shameful. Most Germans -- and most Europeans for that matter -- don't want GMOs. And they don't want their politicians to water-down or wreck effects to improve food safety!

Thank you, and good luck!

Eoin, Myrto, Juliette, and everyone at Greenpeace

PS Remember to take action today please -- the GMO vote is on Thursday.
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2.EFSA lies and incompetence

From Dr. Brian John
Date: Fri, 28 Nov 2008 15:16:53 +0100
To: Stavros Dimas [European Commissioner for the Environment]
C.c: Jill Evans MEP, Kathy Sinnot MEP, Caroline Lucas MEP
Subject: EFSA lies and incompetence

Commissioner Stavros Dimas
European Commission

Dear Mr Dimas

We have now come to the view that EFSA [the European Food Safety Authority] is no longer capable of looking after the best interests of European consumers, following the revelations that several of the GM varieties which were passed as "entirely safe" by the GMO Panel are in fact responsible for organic and health harm to animals fed on these varieties in feeding trials. We have written to our Environment Secretary, Hilary Benn, to ask him not to support any moves for the "streamlining" and "simplification" of the GM approvals procedure in Europe. This letter is copied below. Mr Benn will not pay any attention to us, of course, but we hope that you will support moves for the assessment procedure to be STRENGTHENED and for EFSA to be stripped of its dominant role in the approval of any future GM varieties that come to its attention.

We also ask for a freeze on all GM approvals pending a full research programme designed to examine (and if necessary to replicate or falsify) the shocking results coming into the public domain from recent feeding trials. We are amazed that the EU, with its massive research budget, has not done this already.

Yours sincerely,

Dr Brian John
GM Free Cymru
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2b.Rt Hon Hilary Benn MP
Secretary of State for the Environment
DEFRA
UK

28th November 2008

Dear Mr Benn,

EFSA LIES AND INCOMPETENCE

Please will you bear this letter in mind when determining the position of the UK delegation involved in the EU discussions on the GM approvals procedure on 4th December.

Our petition, copied below, which is highly critical of EFSA, has now been accepted by the European Parliament Petitions Committee and has been forwarded to the EC for investigation and comment. The Commission's response is awaited ......... and obviously the "citizens' rights" angle must come into the frame when the GM assessment procedure is considered on 4th December. We trust that you will agree with us on that point.

With respect to this section:

As an independent risk assessor, EFSA should not base its assessments of GM foods and crops on "advocacy science" submitted by applicants, which is by definition partial, selective and biased. Yet it continues to do so, despite the fact that some such science may also be fraudulent, since the application dossiers from GM corporations and patent owners cannot be examined in full by members of the public and by independent scientists and thus cannot be subjected to a proper process of peer review. Thus when dossiers are assembled, companies can simply omit "inconvenient" findings; they can also "manufacture" favourable results by the aggregation of data with a view to masking effects, by the use of insensitive testing techniques, by statistical manipulation, and by careful experimental design. Such practices are fraudulent, and they place Europeans at risk since GM crops and foods cleared as "safe" on the basis of dossier evidence may in fact be dangerous.

Our concerns are now shown to have been absolutely justified. Recent research papers in the peer-reviewed and government-sponsored literature show that maize NK603xMON810, maize MON810, and Monsanto Roundup-ready soy cause actual harm (directly attributable to the GM "events" concerned) to animals which consume these materials in feeding trials (1)-(5). These harmful effects have occurred in spite of the fact that EFSA has examined all of these GM varieties on more than one occasion, and has declared them to be safe in all respects.

EFSA has also reaffirmed its confidence in the safety on MON863 and NK603, in spite of the recognition of statistically significant physiological changes in animals fed on those varieties, and in spite of the attempts by the owners of these varieties to "mask" these effects in their application dossiers (6)(7). This means that EFSA is incompetent or corrupt, and that it is not effectively protecting the European consumer.

We should also like to draw your attention to the heavy criticism attracted by EFSA, following its refusal to cite, let alone take account of, two papers showing that transgenic sequences have been detected in animal tissues (8) (9) (10). Mazza et al. (2005) detected fragements of the cry1A(b) genes in the blood, liver, spleen, kidney and muscle of pigs fed with GM maize. Sharma et al (2006) detected transgene fragments in the large intestine tissue of sheep and in the cecal tissues of pigs. On 19 July 2007, EFSA lied to the Commission when it stated that : ...."a large number of experimental studies with livestock have shown that recombinant DNA fragments or proteins derived from GM plants have not been detected in tissues, fluids or edible products of farm animalsì and ìto date no recombinant DNA sequences have been found in any organ or tissue sample from animals fed GM plantsî. These words have been very carefully crafted, and were designed to mislead the Commission. That constitutes serious professional misconduct (11).

We therefore call for the disbanding of EFSA's GMO Panel and the fundamental reform of EFSA itself. Since it is obvious that harmful materials have already passed through the EFSA assessment procedure, leading to unreliable and dangerous advice to the Commission, it follows that there must now be a freeze on all future GM approvals and a reassessment of all of the past science relating to approved GM varieties.

The health of the European consumer must be protected at all costs.

Many thanks for your help on these matters. We will appreciate confirmation of receipt of this letter and confirmation that you are personally aware of its contents.

Yours sincerely

Dr Brian John
GM Free Cymru

(1) Velimirov A, Binter C and Zentek J. (2008) Biological effects of transgenic maize NK603xMON810 fed in long term reproduction studies in mice. Report, Forschungsberichte der Sektion IV, Band 3. Institut f¸r Ern”hrung, and Forschungsinttitut f¸r biologischen Landbau, Vienna, Austria, November 2008.

(2) Finamore A, Roselli M, Britti S, Monastra G, Ambra R, Turrini A and Mengheri E. (2008). Intestinal and peripheral immune response to MON810 maize ingestion in weaning and old mice. J Agric Food Chem, http://pubs.ac.org, 16 November 2008

(3) Kilic, A. and M. T. Akay (2008). A three generation study with genetically modified Bt corn in rats: Biochemical and histopathological investigation. Food Chem. Toxicol. 46(3): 1164-1170.

(4) Manuela Malatesta, Federica Boraldi, Giulia Annovi, Beatrice Baldelli, Serafina Battistelli, Marco Biggiogera, Daniela Quaglino. (2008) A long-term study on female mice fed on a genetically modified soybean: effects on liver ageing. Histochem Cell Biol. 2008 Jul 22; : 18648843 (P,S,G,E,B,D)

(5) M Malatesta, F Perdoni, G Santin, S Battistelli, S Muller, M Biggiogera (2008) Hepatoma tissue culture (HTC) cells as a model for investigating the effects of low concentrations of herbicide on cell structure and function. Toxicol In Vitro. 2008 Sep 18; : 18835430 (P,S,G,E,B,D)

(6) Séralini, G-E, Cellier, D. & Spiroux de Vendomois, J. 2007. New analysis of a rat feeding study with a genetically modified maize reveals signs of hepatorenal toxicity. Archives of Environmental Contamination and Toxicology DOI: 10.1007/s00244-006-0149-5.

(7) http://www.gmfreecymru.org/pivotal_papers/monsanto2.htm

(8) http://www.gmfreecymru.org/pivotal_papers/efsa_misleads.htm

(9) Sharma R, Damgaard D, Alexander TW, Dugan ME, Aalhus JL, Stanford K, McAllister TA.2006 Detection of transgenic and endogenous plant DNA in digesta and tissues of sheep and pigs fed Roundup Ready canola meal.J Agric Food Chem. 2006 Mar 8;54(5):1699-709.

(10) Mazza R, Soave M, Morlacchini M, Piva G, Marocco A.(2005) Assessing the transfer of genetically modified DNA from feed to animal tissues. Transgenic Res. 2005 Oct;14(5):775-84.

(11) EFSA 2007a: Letter to Robert Madelin regarding the EFSA statement on the fate of recombinant DNA or proteins in the meat, milk or eggs of animals fed with GM feed. http://efsa.europa.eu/EFSA/ Non_Scientific_Document/
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2c.Petition to the European Parliament

Name: Brian John
Postal Address: Trefelin, Cilgwyn, Newport, Pembrokeshire SA42 0QN, Wales, UK
Nationality: Welsh
Hosting MEP: Kathy Sinnott, MEP Ireland South
Title of Petition: The importance of impartiality within EFSA & the food safety rights of EU citizens

Text of Petition (No. 0813/2008):

The European Food and Safety Agency (EFSA) was designed to improve food safety in the EU, to restore the faith of EU citizens in EU food and guarantee consumer protection. As such, EFSA claims to provide "independent scientific advice [which] underpins the European food safety system"[1]. As citizens who should be served by this remit of EFSA we petition the European Parliament today because we see that the modus operandi of EFSA means it cannot be neutral or independent and thus violates the rights of all EU consumers to clean, safe and healthy food.

It is our assertion that EFSA does not operate according to EU law, namely Regulation (EC) No 178/2002 of the European Parliament and of the Council of 28 January 2002 laying down the general principles and requirements of food law, establishing the European Food Safety Authority and laying down procedures in matters of food safety. In addition principles of European Consumer Law are being disregarded, and priorities laid down in the Sixth Framework Programme (2000-2006): food quality and safety (2002/835/EC).

As an independent risk assessor, EFSA should not base its assessments of GM foods and crops on "advocacy science" submitted by applicants, which is by definition partial, selective and biased. Yet it continues to do so, despite the fact that some such science may also be fraudulent, since the application dossiers from GM corporations and patent owners cannot be examined in full by members of the public and by independent scientists and thus cannot be subjected to a proper process of peer review. Thus when dossiers are assembled, companies can simply omit "inconvenient" findings; they can also "manufacture" favourable results by the aggregation of data with a view to masking effects, by the use of insensitive testing techniques, by statistical manipulation, and by careful experimental design. Such practices are fraudulent, and they place Europeans at risk since GM crops and foods cleared as "safe" on the basis of dossier evidence may in fact be dangerous.

Furthermore, and more importantly, the science which is assessed by EFSA is for the most part non-replicable science which should never be admitted as valid, let alone considered in detail and acted upon. It is a fundamental principle of science that all experiments must be replicable if scientific fraud is to be avoided -- and yet EFSA never asks for replicability. (It has occasionally asked for supplementary evidence, but never for full independent replication of experiments.) Those who apply for approvals for GM crops and foods systematically block research by refusing to supply GM seeds, reference materials and chow for animal feeding experiments by independent scientists or institutions; this means that the dossier experiments cannot be replicated or improved, and that results cannot be verified or questioned. In Hungary, for example, Monsanto refused to supply MON810 seed to Professor Darvas and colleagues as soon as their research started to throw up negative environmental effects.

Another example is in France, where Monsanto refused to supply MON863 materials for experiments designed to replicate or test the results reported in the MON863 dossier. Both examples clearly violate the terms under which EFSA operates namely Article 38 (concerning Transparency) of Regulation 178/2002 Section 4.

These concerns lead us to ask that the Parliament instruct EFSA to enforce the highest standards of scientific ethics in its own GMO Panel and in the dossiers of GM applicants, thereby safeguarding the health of citizens as per its original remit. We ask that EFSA be instructed to insist on full and early release of all scientific data contained in dossiers, and to insist on signed declarations from applicants relating to replicability, so as to enable a full and independent verification (or falsification) of apparent findings.

As EU citizens with rights we are being discriminated against by EFSA who, rather than protecting us, are supporting the commercial ambitions of the GM companies and "enabling" their approvals. We wish to emphasize the fact that there are no benefits to consumers in terms of taste, quality, shelf-life, price, and nutritional value of GM crops and foods -- the only benefits are to farmers wishing to reduce labour costs and spend less by using chemicals, and to the companies that own the seed and sell the herbicides / pesticides. It is valid for certain EU institutions, such as those involved in trade and agriculture, to support these corporate ambitions but EFSA should represent citizens and not business interests. EFSA exists to provide a service to EU citizens and the European institutions, and it must therefore treat consumers as its number one priority. It is our view that the current modus operandi of EFSA fails to do this, implying that EFSA has breached its responsibility to European consumers and to Regulation 178/2002 Section 4: Article 37-40 on Independence, Transparency, Confidentiality and Communication.

Kathy Sinnott MEP will be the hosting MEP for this petition.

[1] http://www.efsa.europa.eu/EFSA/efsa_locale-1178620753812_home.htm