NOTE: Jean-Pierre Berlan is an agronomist, an economist, and retired director of research at L'Institut national de la recherche agronomique (INRA), France.

He wrote to us about the controversy over Seralini's study – his comments are reproduced with his permission below.

We think his comments illuminate an issue that's been raised by honest scientists in the wake of the Seralini study. These scientists have taken in good faith the claims by the European Food Safety Authority (EFSA), the German government, and other bodies and individuals, that the design of Seralini's study was flawed and so no conclusions can be drawn from it.

These scientists are working to come up with a study that will be acceptable to all – industry, regulators and consumers – and which will give reliable information about whether GMOs are safe. They are prepared to seek funding for such a study and ensure that it is carried out in a rigorous fashion.

Though we have the greatest respect for these scientists' motives, we would dissuade them from such an undertaking in the current climate, for the following reasons.

No internationally accepted protocols for testing GM foods for safety have ever been set, either by the European Food Safety Authority or by the international body Codex. These bodies have strenuously resisted attempts by scientists and civil society groups to institute such standard protocols.

The research of Arpad Pusztai in the late 1990s was carried out in order to establish just such protocols. After Pusztai found that the GM potatoes he was testing harmed the health of rats, his experiments were shut down, he was fired, and his data were confiscated. The question of establishing proper protocols for safety testing GMOs was never officially revisited.

Why? Let's suppose that an agreed protocol exists, and independent scientists use it to test a GM food and find harm. What then? Well, the regulators have to accept the finding and actually do something about it, such as banning the GMO.

As things stand, the lack of such protocols enables the most outrageous double standards to be applied to judging the quality of industry and independent studies on GMOs. Industry studies are commonly of poor quality: industry makes up the protocol as it chooses and enjoys a broad range of choice in which data it submits. These industry studies invariably conclude that the GMM food is safe and EFSA and regulatory bodies worldwide accept that conclusion.

Independent studies are often of far better quality in terms of sensitivity, endpoints studied, length of study, and appropriate control groups. They are often limited, however, by the fact that independent researchers are denied access to the necessary research materials – the GMO and the non-GM isogenic (genetically the same) variety. These studies often find risk. But EFSA and regulatory bodies invariably claim that something is wrong with the study design or the way it was carried out, and dismiss the findings.

Typically, their criticisms include one or more of the following: that the study used the wrong animal; wrong exposure route; wrong number of animals; or the wrong statistical method.

The most common criticism is that the study was not done in conformance with OECD protocols or Good Laboratory Practice rules. However, it must be remembered that these protocols and rules only apply to industry studies and are in no way a hallmark of good science. OECD protocols are a way of harmonising tests for industry so they only have to do one set of studies to gain approval internationally; and GLP rules were slapped on industry by regulators in the 1970s-1980s as a way to combat industry fraud in safety testing of chemicals!

Regulators' claims that only OECD/GLP studies are reliable or relevant to risk assessment is simply a way of shielding industry's risky products from the inconvenient findings of independent science.

If EFSA and regulatory bodies were genuinely interested in knowing whether GMOs are safe, they would establish rigorous test protocols that must be applied to all GMOs before release. The fact that no such protocols have been set nearly two decades after GMOs were released into our food supply must tell us something. In our view, it comes down to: Don't look, don't find.
–-
–-
Comment by Jean-Pierre Berlan on the Seralini study
Published by GMWatch
12 October 2012

Thank you for your work and the good summary of the controversy raised by Prof Seralini's study. From my knowledge of history of such scientific controversies, I fear it will be impossible to draw an unambiguous conclusion about the toxicity of GMOs from a scientific-toxicological approach.

In the case of asbestos a French doctor in 1906 described the cancer which struck the workers of an asbestos factory in northern France, but it took one hundred years to ban asbestos. The manufacturers, for instance, argued back in the 1960s that the toxicological study had been made on a certain type of asbestos, but that the one they were producing was OK. So that another round of studies had to be made.

Industry and its mercenaries will always find some fault on any study, ask for more evidence, gain time, and hope, in the case of GMOs, that the genetic smog created meantime will make any scientific evidence impossible.

Another approach can provide the evidence that GMOs are a sure recipe for disaster. We have to consider the 'commodity' sold under the expression GMO”¦ What is, then, the commodity sold, the commodity that we eat?

First, GMOs are clones. Seed laws require that plants be homogeneous (all plants must be the same) and stable (the same plant must be offered for sale, year after year). The seed producer makes copies of a selected plant. Of course, he pretends that he is selling "varieties" – the character of being varied, diversity. The term "variety" to designate what an industrial farmer sows and what we eat is so utterly misleading that it is legitimate to extend the sense of clone from vegetatively reproduced plants to any set of "homogeneous and stable" plants.

Second, GMOs are pesticide clones. The goal of the genetic-pesticide [industry] complex is the change the status of pesticides from noxious chemicals that have to be excluded from our food into a constituent of our food. Since you know that 99.6% of GMOs sold are either producing an insecticide or absorbing an herbicide without dying, there is no need to go into more details.

Third, GMOs are patented pesticides clones. Patents make it possible to separate production from reproduction. This is the dream of all breeders and agricultural geneticists ever since breeding became an economic enterprise, some two centuries ago. Plants, animals, living organisms reproduce and multiply 'gratis'. The law of Life runs contrary to the law of Profit. Consequently, Life is wrong. This is what the infamous GMO Terminator technology claimed. But patents are a much more elegant, and cheaper method to reach the same goal. Here, patents grant a monopoly over reproduction to a cartel enough to anger Adam Smith out of his grave.

GMOs are then patented pesticide clones. No scientific expertise is necessary: they are a sure recipe for disaster:
*because they are clones – "Adios, biodiversity";
*because they are pesticides our addiction to the pesticide system (since pests and diseases overcome the poisons of the pesticide industry, farmers have to use increasing doses and finally turn to more powerful chemicals) grows stronger at a time when elegant low-input agroecological methods are popping up everywhere;
*because they are patented and entrust our biological future to producers of pesti-, herbi-, insecti-, bacteri- CIDES, namely to a cartel of manufacturers of Death.

I add that policy recommendation follow immediately: reorganize seed laws so that agricultural scientists can work on other breeding methods than clones; divest the death industry from life; fight our pesticide addiction; get rid of patents; develop low-input and elegant agroecological methods.

Some resistance is not unlikely.