Genetic Engineering: Too Good to go Wrong?

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Genetic Engineering:

Too Good to go Wrong?

 

http://archive.greenpeace.org/comms/97/geneng/getoogoo.html

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Introduction

 

Genetic

engineering,

business and government

 

Genetic

engineering

and science

 

The

unpredictable

effects of genetic engineering

 

Case

studies: Incidents

where genetic engineering has gone wrong

 

 

1.

Microbes that

don't behave as predicted

2.

Mix-ups of genes

provokes costly seed recall

3.

Gene changes

create unanticipated allergies

4.

Bacteria poison

soil

5.

Animal health

problems from extra growth hormone

6.

Toxic by-products

kill beneficial soil life

7.

Laboratory coats

spread unpredicted contamination

8.

Toxic products

from engineered yeast

9.

Did genetic engineering

produce deadly food supplement?

10.

Weather changes

gene expression.

11.

Transplanting

seedlings changes gene expression

12.

Failed tomato

shows "real world" uncertainties

 

Attitude

of government

 

References

 

 

Genetic Engineering: Too Good to go Wrong?

 

 

 

 

"within 10 years we will have a moderate to large-scale ecological

or economic catastrophe,

because there will be so many products being released"1

Norman Ellstrand, Ecological geneticist at University of

California,

Riverside.

 

Introduction

Government and corporations want genetic engineering to be big

business2.

They

want the public to believe it is safe, reliable and, above all,

predictable.

Officially this is the case. In reality it is not. This report

concludes

that the central assumption of predictability is invalid, and case

studies

demonstrate this.

 

This report documents a dozen incidents in which, far from going

according

to plan and producing better crops, farm animals or improved human

health,

these experiments have produced:

 

� genetically engineered bacteria which have unexpectedly killed

beneficial

soil fungi

 

� genetically engineered bacteria which have become toxic to plants

or survived when they weren't expected to

 

� genetically engineered crops which bring new allergy problems

 

� farm animals with genetically engineered growth hormone which have

lameness, heart disease, ulcers, arrested sexual development, kidney

failure

and other diseases

 

� genetically engineered bacteria which through human error and

unanticipated

pathways have escaped into sewers.

 

So what do these incidents mean? Aren't they the sort of minor

teething

problems that you'd expect from any new industry? Are they really

significant?

 

If genetic engineering (GE) were just another manufacturing

industry,

this prospect of problems and errors might give little cause for

concern.

But it is not. Genetic engineering crosses a fundamental threshold in

the

human manipulation of the planet - changing the nature of life itself.

Because genetic engineering deals with living organisms which can

reproduce,

these "mistakes" cannot be recalled. Agricultural and allied

applications

of genetic engineering are designed to be put into the environment.

Farming

takes place outdoors: GE crops therefore, cannot be "lab experiments".

Once out, these organisms are uncontrollable. Often applications

involve

organisms like bacteria which cannot be swept up or recalled.

 

These incidents reveal genetic engineering to be no less flawed by

routine

error and ignorance than any other human activity. The examples point

to

the fact that things will inevitably go wrong against all the best

predictions.

 

While substantial scientific resources are targeted on genetic

engineering,

and a large number of scientists are involved, "science" cannot make

genetic

engineering "safe". Politicians and businesses are expecting too much

of

"science". It is being asked to do the impossible.

 

What is an acceptable risk is a matter of opinion - a matter of

judgement,

not a technical question. If for no other reason than because we

have no choice, people rely on government to control industry and "make

things safe" by avoiding unnecessary risks altogether, looking for

safer

alternatives where they appear and minimising those necessary risks.

 

Yet the Government are so keen to develop genetic engineering that

they

are prepared to change definitions to "eliminate" risks by semantics

(see

later). But the scientific uncertainties are real. Government cannot

make

them vanish in order to please business or in the hope of new jobs.

 

The public finds it difficult to engage in this debate3,

and

that is not surprising as it is often couched in technical terms. Most

people would rather not have to know, and that too is understandable.

Yet

the potential hazards are colossal and quite likely irreversible and

uncontainable

once released into the environment (Greenpeace does not oppose the

principle

of "contained use" of genetic engineering, as in the majority of the

medical

applications, so long as, of course, these applications are properly

contained).

 

In these circumstances it is only right to ask questions, most

importantly

whether genetic engineering in the environment is really necessary.

Greenpeace

says "no" but whether one agrees with Greenpeace or not, public,

scientists,

politicians and all responsible business people should pause to

question

what risks are being taken in their name.

 

 

 

Genetic engineering, business

and

government

 

The European Commission identified4

genetic engineering and biotechnology5

as

one of their hoped-for growth areas. Numerous developments and small

company

start-ups are taking place on the back of an explosion in knowledge and

techniques at the disposal of molecular biologists. The European

biotechnology

sector in 1995 had a turnover of over a billion ECU, with venture

capital

of about 100 million ECU flowing into the sector in that year. Total

market

value of these companies is, of course, far higher6.

This

stock market enthusiasm was on the basis of a very few actual products

on the market7.

And so the apparent success

is based on promises of goodies to come rather than existing product

sales.

There is, consequently, a pressure to maintain a stream of good news to

keep the stock price high: a securities company recently marked down

advice

on buying shares in a biotechnology company on the basis that they did

not expect there to be any upcoming good news8.

There

is also a level of interdependence of companies because a failure

in one company product rubs off on the share prices of others9.

Keeping

the share price high is important in a sector where take-overs

and mergers happen on an ongoing basis.

 

The commercial need for good news creates strong pressure on the

source

science. Markets need to be re-assured that genetic engineering

techniques

are a predictable science, and that results can always be anticipated

and

controlled.

 

 

 

Genetic engineering and

science

 

The genetic engineering industry and its science base are closely

linked

and getting closer. This trend apparent throughout UK science funding

may

be good for business but fears have been expressed that the close

alliance

between academic science and industry may be compromising the

independence

of scientific investigations10.

Science

funding is becoming more biased towards genetic engineering ahead

of other approaches. In the UK there is now the Biotechnology and

Biological

Sciences Research Council where once we had the Agriculture and Food

Research

Council. Whilst it may be argued that other funding for e.g.

improvement

in knowledge of organic farming, may come from other research councils,

it speaks volumes that an institution has been created in which the

promotion

of genetic engineering is a key part. Given institutional biases it is

unlikely that research into refining and improving low input

agriculture

will get the same support as it once might have.

 

Further, all the research councils now operate out of the Department

of Trade and Industry rather than the Cabinet office or the former

Department

of Education and Science, strengthening the link between science and

commercial

considerations.

 

 

 

The unpredictable effects

of

genetic engineering

 

Genetic engineering is the use of recombinant DNA technology. This

gives

the power to move DNA from one organism to another, to identify the

function

of particular genes and to transfer the DNA coding for the

characteristics

from one species to another.

 

Uncertainties enter the frame at many stages.

 

At the very base of the technique, the insertion of introduced DNA

into

host organism's DNA is a random process; disruption can occur to

existing

genes within the host organism with unknown consequences.

 

The new genes may affect the expressioni of quite separate genes11.

 

The expression of the inserted genes may affect the biochemistry of

the cell in unexpected ways.

 

Gene flowii in the environment may be much more extensive than once

thought12.

 

Organisms transformed using genetic engineering can behave in

unpredictable

ways in the environment.

 

The problem is not simply one of predicting how DNA and cellular

processes

behave. As the example of the Flavr Savr tomato (see below) and the

unexpected

and undesirable results of the Green Revolution demonstrated13,

new

technologies always exist in a social, political and cultural context.

The effects of their introduction are not predictable.

 

What is the justification?

 

Recent controversy over the introduction into the European food chain

of genetically engineered commodity crops has focused attention on why

so many agricultural applications, the so-called "ag-biotech" sector,

are

being produced.

 

Much of the justification advanced for genetically engineered food

products

is the widely aired claim that genetically engineered foods will "feed

the world"14.

Such justification

is na�ve. It supposes that major causes of hunger like poverty, social

inequality, absence of land reform and displacement of peoples by war

and

conflict will be dealt with by higher yielding crop plants. One is

reminded

about similarly naive promises about nuclear energy being "too cheap to

meter". In any case this justification hardly accounts for projects to

create tomatoes that don't go soft or potatoes that don't go brown

after

being peeled.

 

The truth in a capitalist world is all too obvious. These products

are

being created because those who do are hoping to make money out of

them.

The "need" is to improve company bank balances. Whether this benefits

society

more broadly or not is virtually irrelevant to the decision making

process

and is not asked in any coherent way at any stage.

 

Whilst the media, pressure groups and the public question the real

need

for these new products, the regulatory process implicitly assumes that

so long as a product is "safe" then it should be allowed. The absence

of

any coherent justification for the whole ag-biotech project is, no

doubt,

partly responsible for the low level of public support it commands15.

 

 

 

Case studies: Incidents where

genetic

engineering has gone wrong

 

1. Microbes that don't behave as predicted

 

In 1989, Biotechnica International wanted to test out a genetically

engineered micro-organism (Bradyrhizobium japonica) which they hoped

would

show improved nitrogen fixation, thereby improving soil fertility. The

microbe also contained some 'marker' genes. Biotechnica contracted the

Louisiana Agricultural Experiment Station to conduct field tests for a

year by planting soybeans coated with the GE rhizobia. At the end of

the

season the plants and seeds were incinerated, the field ploughed over

and

replanted. Biotechnica ceased to have anything to do with the

experiment.

However, subsequent monitoring revealed that the GE rhyzobia were

out-competing

the indigenous strain, something it was NOT supposed to do. Ploughing

had

also spread the GE version over a four acre area16.

As

a review of genetically engineered microbes put it "One of the major

considerations about this case is that a microbe for which there

existed

an extensive historical database was used in a well-planned and

thoroughly

reviewed experiment, and an unpredictable result was still obtained"17.

 

 

 

2. Mix-ups of genes provokes costly seed recall

 

A large stock of canola seeds (oil seed rape) in Canada had to be

withdrawn

because they contained the wrong genes. Tests early in 1997 on two

varieties

of canola showed that the seeds contained genes that had not received

Government

clearance18.

Monsanto had

produced two lines of Roundup resistant genes (Roundup is a herbicide

sold

by Monsanto), type 73 and type 200. Only type 73 went through the full

animal feed and human food review process. However, the type 200 gene

appeared

instead in two varieties of canola bred and sold by Limagrain, who were

licenced to use Monsanto's genes. Seed that would be enough to plant

600,000

acres (an acreage equivalent to almost 7% of 1996 plantings19

in Western Canada) was recalled. Estimates of the cost of the recall

reach

$12 million20

to farmers and $24 million

in lost sales21.

Reportedly

ten farmers had already planted the canola22

and those fields were ploughed under. How it happened is uncertain but

the problem is likely to have gone undetected for a substantial period

because of the time required to produce enough seed for 600,000 acres.

A researcher at the Plant Breeding Institute in Saskatoon is reported

as

saying "There is a lot of cross-breeding going on in literally hundreds

of lines and monitoring it at all stages would be very costly and time

consuming"23.

Whether it

is as costly as $24 million in lost sales is not stated. Whilst

Monsanto

have downplayed the events and described the recall as "small

quantities"24

and "a very, very minor issue"25

others have

been less sanguine; it has been described as "possibly the largest and

most expensive [seed recall] the industry has seen"26.

And

referring to the regulatory agencies that took action against the

Limagrain

varieties, Mark Winfield, research director of the Canadian Institute

of

Environmental Law and Policy, said "I'm floored by this. These guys

have

been the biggest boosters of this stuff forever so for them to pull the

plug on Monsanto, that's an indication to me that something is pretty

wrong"27.

 

 

 

3. Gene changes create unanticipated allergies

 

A problem foreseen by critics of genetically engineered food is the

transfer of allergenic potential along with the transfer of genes from

one organism to another. In other words, people start getting allergies

to things they never used to have problems with because of the genetic

engineering. Dramatic evidence that this can occur came from a soya

bean

genetically engineered with genes from a brazil nut. Blood serum from

people

known to be allergic to brazil nuts was tested for the appropriate

antibody

response to the gene transferred to the soya bean. Seven out of nine

volunteers

did show such a response to the GE soybean and the researchers

concluded

that the allergenicity had been transferred with the transferred gene28.

 

Pioneer Hi-bred developed this soya bean for use in animal feeds but

from the outside one soya bean looks much the same as another, and

fears

that the product could end up in the human food chain meant that

Pioneer

stopped the commercialisation of the product.

 

The implication of this finding should not be lost. As was pointed

out

by a writer in the medical journal where the results were reported:

"Most

biotechnology companies use micro-organisms rather than food plants as

gene donors, even though the allergenic potential of these newly

introduced

microbial proteins is uncertain, unpredictable, and untestable" and

goes

on to point out that "[in this case] the donor species was known to be

allergenic, serum samples from people allergic to the donor species

were

available for testing,.....The next case could be less ideal, and the

public

less fortunate"29.

 

 

 

4. Bacteria poison soil

 

A genetically engineered bacterium (Klebsiella) was found to produce

dramatic changes in the soil food web and inhibit plant growth. The

bacteria

was engineered to produce ethanol from agricultural waste as a way of

generating

fuel30.

But when added

to soil significant decreases in growth in both roots and shoots of

wheat

were found, as were a decrease in beneficial soil fungi, poisoning of

plants,

increases in parasitic nematodes and bacteria, and significant changes

in the soil food web structure31.

The effectiveness

of survival of the GE Klebsiella to survive depended on soil type and

other

properties. Why the GE bacterium was so much better able to survive

than

expected is unknown but this case illustrates the damage that a single

genetically engineered organism can cause. Inhibiting the spread and

activity

of a bacterium once released is likely to prove problematic.

 

5. Animal health problems from extra growth

hormone

 

There have been numerous attempts to genetically engineer farm animals

to grow faster by engineering genes coding for growth hormones.

However,

many of these have encountered problems because growth is a complex

phenomenon

involving more than just a single hormone and because the function of

growth

hormone may be wider than just promoting growth. In sheep,

experimenters

have had difficulty getting sheep to grow any more than normal - but

they

were more likely to have diabetes and all died early. A GE ram failed

to

mature sexually32.

In pigs,

although they didn't seem to die more quickly the transgenic animals

suffered

in other ways: "long-term elevation of [growth hormone] was generally

detrimental

to health: the pigs had a high incidence of gastric ulcers, arthritis,

cardiomegaly, dermatitis and renal disease"33.

The

same paper noted that the animals also showed lethargy, lameness and

uncoordinated gait. Some suffered severe joint disease, inflammation

and

pneumonia. In general, many transgenic animals displaying excess growth

hormone showed lowered fertility34,

a distinctly

unproductive outcome for research aiming to create a viable line of

farm

animals. Note that all this flowed from just one genetic modification

i.e.

insertion of a single gene for enhanced growth hormone.

 

 

 

6. Toxic by-products kill beneficial soil

life

 

A bacterium was engineered to degrade a persistent herbicide, 2,4-D,

in contaminated soil. And so it did. But one of the by-products of the

degradation, 2,4-DCP, built up in the soil and turned out to be toxic

to

soil fungi even in low concentrations. The soil fungi were completely

wiped

out in 10 days in one instance. This effect was not seen in

non-genetically

engineered varieties, nor in the soils that contained quite high

concentrations

of the original herbicide. Soil fungi are important in sustaining soil

fertility and may protect plants from disease. The build up of the

2,4-DCP

and the effects on the soil fungi were completely unanticipated35.

 

 

 

7. Laboratory coats spread unpredicted

contamination

 

Scientific endeavour is almost epitomised by the white coated

scientist.

Yet those same white coats bring their unexpected problems for

laboratories

dealing with genetically engineered bacteria as they provide a neat

escape

route for the bugs. It had been thought that genetically engineered

bacteria,

if they got splashed onto the lab coat, would die once it dried out.

But

Dutch researchers from the National Institute of Public Health and

Environmental

Protection36

found that

perfectly viable bacteria could be isolated from dried lab coats before

they were sent to the local laundry. The first step of washing these

coats

is a soak at 35 degrees centigrade, just right for releasing the

bacteria,

which are then flushed into the sewerage system. The Dutch team went on

to find that lab coats are regularly infected, that the bacteria can

penetrate

the lab coats and go onto clothing beneath (and then into the sewerage

systems via home washing), and that the genetically engineered bacteria

could survive just as well on lab coats as the wild types37.

 

The researchers point out that "the potential for genetic exchange

is

great" when the bacteria enter the sewage system - in other words the

genetic

modifications could well find their way into the general population.

 

This shows how apparently great precautions in use of genetically

engineered

organisms can be totally undermined by the "oops, we didn't think of

that!"

factor.

 

8. Toxic products from engineered yeast

 

A yeast was engineered to produce high levels of enzymes that are

important

in the breakdown of sugar. The scientists were concerned to look at the

effects of boosting enzyme activity on the different chemical pathways

of the breakdown process. The researchers found that concentrations of

a toxic and mutagenic product, methyl glyoxal (MG) was up to 30 times

higher

in the mixtures with the genetically engineered yeast compared to the

original

strains. The fact that boosting the concentration of an enzyme can

affect

build up of products several metabolic steps further downstream has

serious

repercussions for the credibility of the concept of "substantial

equivalence"38

which underpins the testing and labelling regimes applicable throughout

Europe as a consequence of the Novel Foods Regulation39.

As

the scientists put it in their conclusion

 

"in genetically engineered yeast cells, the metabolism is

significantly

disturbed by the introduced genes or their gene products and the

disturbance

brings about the accumulation of the unwanted toxic compound MG in

cells.

Such accumulation of highly reactive MG may cause damage in DNA, thus

suggesting

that the scientific concept of 'substantially equivalent' for the

safety

assessment of genetically engineered food is not always applied to

genetically

engineered microbes..... the results presented may raise some questions

regarding the safety and acceptability of genetically engineered food,

and give some credence to the many consumers who are not yet prepared

to

accept food produced using gene engineering techniques"40.

 

 

 

9. Did genetic engineering produce deadly food

supplement?

 

Tryptophan is an essential amino acid sold as an over-the-counter food

supplement used for treating insomnia and depression. During 1989 in

the

USA a new disease appeared called EMS, whose main characteristics were

raised numbers of a type of white blood cell and severe muscle pain. In

November that year the US FDA issued a nation-wide warning, advising

consumers

to discontinue use of the tryptophan food supplements41.

By

then so many people had been affected by EMS that it caused over 36

deaths and thousands of disabilities, some estimates placing this as

high

as 10,00042.

The problem was linked to a

contaminated batch of tryptophan coming from the Japanese company Showa

Denko, which had been using a newly modified strain of genetically

engineered

bacteria; the new modification being intended to boost the

concentrations

of an intermediate chemical, and ultimately the output, in tryptophan

synthesis.

It is unclear as to whether the genetic engineering or change to the

post-production

filtration process was responsible for the damaging contaminants

getting

into the marketed tryptophan43.

Although

a causal agent (or agents) for the medical problems has not been

identified, as one review commented: "all the analytical studies

revealed

the contaminants' low concentration in L-tryptophan and this means that

the causal contaminant(s) must be very potent indeed"44.

Because

there was such a low concentration of the contaminant, L-tryptophan

could be said to have remained "substantially equivalent" after the

production

process was modified, yet it clearly was more deadly. The current EU

Novel

Food Regulation45

bases its testing regime

prior to marketing on the concept

 

of "substantial equivalence", and it is doubtful that this legislation

would

 

prevent a reoccurrence of this kind of problem elsewhere.

 

 

 

10. Weather changes gene expression.

 

It is often thought that genes are constant and fixed attributes of

a living thing, impossible to change whatever the weather, for example.

This may not be so in the case of genetically engineered organisms. In

an experiment to change the colouring of petunias, the engineered

flowers

were changed from the original white to an intended salmon pink. As the

growing season went on the majority of the 11,000 plants started

showing

much paler colouring or areas of no colouring at all. The change of

colour

was observed both in the field and in greenhouses. The change in

colour,

indicating the loss of effect of the genetic modification, was put down

to a three week period of high temperatures and high light intensity. A

further important factor seems to have been when seeds were taken from

the parent plants, or whereabouts on the parent plant the seeds were

taken

from, or (alternatively) the age of the parent plant46.

 

 

 

11. Transplanting seedlings changes gene

expression

 

In an experiment on tobacco, a genetically engineered alteration was

found to disappear when the young tobacco plants were transplanted out

into the field from the greenhouse. The gene was put into the tobacco

seeds

in order to give resistance to a common herbicide, chlorsulfuron. In

field

trials up to 59% of plants were found to have lost resistance. Only

when

field sown seeds were trialed did the reason become apparent. Tests

showed

that, strangely, mild trauma on transplantation was more likely to

produce

loss of resistance than severe trauma. Timing of transplantation during

the plants' growth was also important. These results suggest that

problems

with vulnerability may not be picked up before commercialisation

occurs.

As the authors of the paper describing this effect put it "the stable

expression

of transgenic phenotypes is essential for the successful

commercialisation

of transgenic crops, however the expression of transgenes in plants can

be unstable" (emphasis added) but points out elsewhere that in this

case

"[suppression] was triggered by the common agronomic practice of

seedling

transplantation and therefore could not be predicted from studies

performed

in growth rooms or greenhouses"47.

 

 

 

12. Failed tomato shows "real world"

uncertainties

 

The Flavr Savr tomato was developed to have a characteristic of delayed

softening. The idea was that it could ripen on the vine, develop a

fuller

flavour, and still be firm on arrival at the retail outlet. The problem

was that the "inventors", Calgene, appear to have been too busy with

the

finer points of gene manipulation to notice that handling ripe tomatoes

off the vine and in transport was problematic - tomatoes are normally

harvested

green and hard, and allowed to ripen later. When the "Flavr Savr"

tomato

was being taken off the plants it got seriously bashed making the

tomatoes

unusable. Investment of $10 million in speciality equipment originally

developed for peach handling48

hugely increased the costs and delayed the product getting to market49.

This,

together with consumer disinterest due to a combination of a "slightly

mealy" texture and the high price50

- left

Calgene running up huge losses. Further, yields were reportedly

disappointing

and the Flavr Savr had insufficient disease resistance51.

One

analyst said of this venture "this tomato has brought them to their

knees - the question is, can they get back up again?"52.

In

the end Calgene was saved by a take-over and the board substantially

changed53.

Calgene, under new ownership,

continues to modify the Flavr Savr so it will work commercially and

agronomically.

But as it says itself: "there can be no assurance that such efforts

will

be successful or will not be discontinued by Calgene. There can be no

assurance

that Calgene will be successful in developing genetically engineered

tomatoes

with the agronomic characteristics necessary for commercial production"54.

 

 

 

Attitude of government

 

One example serves to illustrate the wilfully blind commitment of

government

to push ahead with genetic engineering. The European Union has chosen,

through its regulatory framework, to solve many of the debates over

minimising

and measuring impacts by defining many environmental changes as not

being

anything to do with the environment, and so apparently beyond their

remit.

 

A good example is the evolution of insect resistance to a natural

toxin

known as Bt.

 

Genes that code for this toxin (or actually a particular part of the

naturally occurring form) have been inserted into a series of plants

that

are on their way to market. One genetically manipulated organism,

Novartis

Bt maize, has been given clearance to be marketed within Europe55

although some member states are vigorously resisting it.

 

Many people would prefer, of course, that their food was not

genetically

engineered at all56.

But within the technocratic

confines of EU decision-making this finds expression in scientific

controversy,

which, amongst other things, has been about how to manage and avoid the

evolution of resistance among insect populations57.

Insect

resistance is a major problem in modern agriculture.

 

Bt is used by farmers, including organic farmers, in its naturally

occurring

forms as a pest control agent. In the US, the Environment Protection

Agency

(EPA) offers only conditional and temporary registration to varieties

producing

Bt because of concern over evolution of resistance58

which would also threaten the viability of naturally occurring Bt. Its

conditions include that the company keeps databases on where the crop

is

grown, provides grower education, carries out research and development

on resistance management, instructs farmers on reporting of unexpected

levels of pest damage, notifies the EPA of such matters, and even stops

selling seed in areas where resistance emerges59.

The

EPA also currently requires 4% "refugia" with Bt cotton i.e. 4% of

planted cotton does not express the Bt toxin but is conventional, and

acts

as a refuge for insects to survive and breed, thereby keeping the

overall

level of resistance in the insect population low.

 

Meanwhile for Bt maize, a major US seed company suggests that

"sacrificial"

refugia should be as large as 30%60

(although

how these crops are supposed to be commercially viable with that level

of sacrificial planting which are "expected to sustain substantial

damage"61

is unclear). At a 4% refugia level a recent paper has suggested that

insect

resistance will evolve in as little as 3-4 years62.

Considerable

technical uncertainties remain over the emergence of resistance

including accurate "real world" data, the level of resistance genes in

the insect population, pest behaviour, and how refuges should be

arranged

spatially and temporally63.

 

The European Union has avoided this difficulty and complexity simply

by redefining the problem as an agricultural one and not an

environmental

one. It states "Potential development of insect resistance to the

Bt-toxin

cannot be considered an adverse environmental effect, as existing

agricultural

means of controlling such resistant species will still be available"64.

Thus

there is, in going through the regulatory process in the EU, no need

to embark on research into resistance management or to look at ways to

delay the emergence of resistance. Even the EU's own scientific

committees

have repeatedly pointed out that resistance management plans should be

constructed65.

 

Imagine what would happen if the EU's 'creative' solution to this

problem

were exploited in other domains to avoid the need to act. Polluting

companies

could continue to pour toxins into rivers on the grounds that other

rivers

would still be available. Such an attitude ought to be as unthinkable

as

it is irresponsible.

 

Conclusion

 

The twelve case studies reported here should be enough to make anyone

think twice about whether society really understands what it is now

playing

with. Some effects of genetic engineering are not merely difficult to

test

for, but, for all practical purposes untestable.

 

How can it be possible to know the impact of the genetic

manipulation

on an organism's cell chemistry when even minute quantities of

contaminants

pose huge risks?

 

How can regulators be sure of impacts and changes in the real world

with its attendant complexity once genetically modified organisms get

outside

the laboratory, where the effects of genetic engineering can change

because

of a few hot days?

 

How is it possible to keep a track of where the genes are ending up

in the environment when there seem to be problems keeping track of them

whilst they are still being produced for seed?

 

What right do Government and industry have to release genetically

engineered

organisms when they can confound the best predictions as to how they

should

behave?

 

Beyond these purely technical questions, and scarcely addressed in

this

report, lie other, deeper questions about how our political

institutions

can respond to value-based doubts amongst the public. During the BSE

crisis,

for example, the UK Government was perceived to have covered up and

allowed

what the public clearly saw as "unnatural practices" in the production

of feed for cattle. Genetic engineering also raises value-based doubts

amongst the public, and by ignoring these values governments reduce

their

credibility. This in turn reduces their ability to handle problems as

they

arise; and with genetic engineering, on current behaviour, problems no

doubt will arise.

 

These questions and others need unambiguous answers from the

proponents

of genetic engineering before irrevocable commitments are made for

society

as a whole. Already the Health and Safety Executive is planning to

allow

'crippled' but still living genetically engineered bacteria to be

flushed

into the environment from laboratories. Above all, the possibility of

"worst

case" scenarios flowing from these possibilities must be addressed. The

case studies show the potential for unforeseen, irreversible ecological

damage or public health problems. After years of after-the-fact

struggles

with issues like nuclear waste and radiation, pesticides and BSE, the

lesson

must be that open-ended risks for society must be avoided rather than

simply

waiting for disasters to occur.

 

The only safe way to avoid such limitless difficulties and risks is

to avoid the release of genetically modified organisms into the

environment

or the food chain altogether.

 

References

 

1 King, J., 1996. Could Transgenic Crops one day Breed

Superweeds, Science, Vol. 274, 11 October 1996. Back

to

the text

 

2 See for example European Commission, 1994.

Biotechnology

and the White Paper on Growth Competitiveness and Employment, Preparing

the Next Stage. Communication from the Commission to the Council, the

European

Parliament and the Economic and Social Committee. Back

to

the text

 

3 See for example, Grove-White, R., McNaughton, P.,

Mayer, S., and Wynne, B., 1997. Uncertain World, Genetically Modified

Organisms,

Food and Public Attitudes in Britain, CSEC, Lancaster University, March

1997. Back

to the text

 

4 European Commission, 1994. op cit. Back

to

the text

 

5 Genetic engineering and biotechnology are not the

same although in some contexts they appear to be used interchangably.

Strictly,

genetic engineering is the use of recombinant DNA technology (see text)

whilst biotechnology is more broad and includes the use of living

organisms

for production processes - it would for example include the use of

yeast

in brewing ordinary wine or beer. However, some people have described

genetic

engineering as ãmodern biotechnologyà - then shortened to

biotechnology, and some companies use both genetic engineering and some

more conventional biotechnology in their process and describe

themselves

as a biotechnology company (see, for example, quote from Nestle ref.

29).

In this report ãgenetic engineeringà will be used. ãBiotechnologyà

will only be used if external sources have used the term. Back

to

the text

 

6 Lucas, P. et al., 1996. European Biotech 96

Volatility

and Value, Ernst and Youngås third annual report in the biotechnology

industry, pp.9, 10. Back

to the text

 

7 Lucas et al. op cit pp.16-21. Back

to

the text

 

8 Reuter report, London, 10 June 1997. NatWest

downgrades

Brit Biotech to ãaddà. Back

to the text

 

9 See, for example, Trial failure sends biotech shares

plummenting, Nature, Vol. 387, p. 446, 29 May, 1997; and Flynn, J.,

1996.

Britainås bedazzling biotech stocks, BusinessWeek, 24 June 1996

Back

to the text

 

10 See, for example, Pavitt, K., 1996. Road to ruin,

New Scientist, 3 August 1996, p.32; Dickson, D., 1997. Little change in

the politics of science - but closer links with industry, Nature, Vol.

386, 27 March 1997, p. 315.; Nigel Titchen quoted in Williams, N.,

1996.

K. Labs: A Year of Uncertainty, Science, Vol. 272, 31 May 1996, p.

1254.

Back

to the text

 

11 Senior, I.J., and Dale, P.J., 1996. Plant

transgene

silencing - gremlin or gift?, Chemistry and Industry, 19 August 1996,

p.

604.

 

12 See, for example, Department of Environment, 1995.

Gene Flow in natural populations of brassica and beta, published by

Department

of Environment; Yin, X., and Stotzky, G., 1997. Gene transfer in

bacteria

in the natural environment, Advances in Applied Microbiology, Vol. 45

to

be published October 1997;Ho, M-W., 1997. Comments on HSE Healthate

Executive Consultation Paper, ãDraft Guidance of Exemption No. 1à,

submitted to UK Health and Safety Executive (HSE), June 1997. Back

to

the text

 

13 See, for example, Shiva, V., 1991. The Green

Revolution

in the Punjab, The Ecologist, vol. 21(2), p. 57, March/April 1991. Back

to

the text

 

14 See, for example, The Independent Education

supplement,

19 June 1997, p. 17; comments by Prof. Derek Burke, chairman of the

Governmentås

Advisory Committee on Novel Foods and Processes, BBC Radio 4 Today

programme,

18 June 1997. Back

to the text

 

15 Biotechnology and the European Public Concerted

Action group, 1997. Europe ambivalent on biotechnology, Nature, Vol.

387,

26 June 1997, p. 845. Back

to the text

 

16 US National Biotechnology Impacts Assessment

Programme

Newsletter, March 1991. The Case of the Competitive Rhizobia. Back

to

the text

 

17 Cairns, J., Jr. and Orvos, D.R., 1992.

Establishing

Environmental Hazards of Genetically Engineered Microorganisms, in

Reviews

of Environmental Contamination and Toxicology, Volume 124, p. 19.

Back

to the text

 

18 Farmers Weekly, May 2 1997. Monsanto recalls GM

seeds in regulation scare. Back

to the text

 

19 Reuter report, Winnipeg, April 17 1997. Monsanto

Canada recalls transgenic canola. Back

to the text

 

20 MacArthur, M., April 24 1997. The Western

Producer,

Canola Seed recalled because of Genetic Contamination. Back

to

the text

 

21 Rance, L., April 24 1997. Manitoba Cooperator,

Mix-up prompts recall. Back

to the text

 

22 Reuter report, Winnipeg, April 17 1997. op cit.

Back

to the text

 

23 Quoted in Tjaders, T., April 24 1997. The Western

Producer, Canola is First Gene Suspension Case for Government. Back

to

the text

 

24 St. Louis Post Dispatch, April 18 1997. Argosy

names Perry new Chief Executive. Back

to the text

 

25 Reuter report, Winnipeg, April 17 1997. op cit

Back

to the text

 

26 Rance, L., April 24 1997, op cit. Back

to

the text

 

27 Quoted in Tjaders, T., op cit. Back

to

the text

 

28 Nordlee, J.D., Taylor, S.L., Townsend, J.A.,

Thomas,

L.A., and Bush R.K., 1996. Identification of a Brazil nut Allergen in

Transgenic

Soybeans, New England Journal of Medicine, Vol. 334(11), p. 688.

Back

to the text

 

29 Nestle, M., 1996. Allergies to transgenic foods

- questions of policy, New England Journal of Medicine, Vol. 334(11),

p.

726. Back

to the text

 

30 Ho, M-W., and Tappeser, B., 1996. Transgenic

transgression

of Species Integrity and Species Boundaries Ñ Implications for

Biosafety.

Paper prepared for Workshop on Transboundary movement of living

modified

organisms resulting from modern biotechnology: issues and opportunities

for policy-makers, Aarhus, Denmark, 19-20 July, 1996. Back

to

the text

 

31 Holmes, Michael T., and Ingram, Elaine R., 1994.

Abstract for 79th Annual Ecological society of America published in

Supplement

to Bull. Ecol. Soc. Am. 75: 2 Back

to the text

 

32 Rexroad, C.E., Mayo, K., Bolt, D.J., Elsasser,

T.H., Miller, K.F., Behringer, R.R., Palmiter, R.D., and Brinster,

R.L.,

1991. Transferrin- and Albumin-Directed expression of Growth-related

Peptides

in Transgenic Sheep, Journal of Animal Science, Vol. 69, p. 2995.

Back

to the text

 

33 Pursel, V.G., Pinkert, C.A., Miller, K.F., Bolt,

D.J., Campbell, R.G., Palmiter, R.D., Brinster, R.L., and Hammer, R.E.,

1989. Genetic Engineering of Livestock, Science, Vol. 244, p. 1281. Back

to

the text

 

34 Pursel et al., op cit. Back

to

the text

 

35 Doyle, J.D., Stotzky, G., McClung, G., and

Hendricks,

C.W., 1995. Effects of Genetically Engineered Microorganisms on

Microbial

Populations and Processes in Natural Habitats, Advances in Applied

Microbiology,

Vol. 40. p.237. Back

to the text

 

36 Cremers, H.C.J.C., and Groot, H.F., 1991. Survival

of E.Coli K12 on laboratory coats made of 100% cotton, RIVM report no.

719102009, November 1991. Back

to the text

 

37 MacKenzie, D., 1992. Clean White Coats spread

Mutant Microbes, New Scientist, 21 March 1992, p. 11. Back

to

the text

 

38 substantial equivalence is described as ãthe

idea that existing organisms used as foods or as food sources, can

serve

as a basis for comparison when assessing the safety of human

consumption

of a food or food component that has been modified or is new. If a food

or food component is found to be substantially equivalent to an

existing

food or food component, it can be treated in the same manner with

respect

to safetyà. From Scientific Committee for Food, 1997, Opinion on

the Assessment of Novel Foods, European Commission III/5915/97, January

1997. Back

to the text

 

39 Regulation (EC) No. 528/97 of the European

Parliament

and of the Council concerning Novel Foods and novel food ingredients.

OJ

No. L43, 14.2.97, p. 1. Back

to the text

 

40 Inose, T., and Murata, K., 1995. Enhanced

accumulation

of toxic compound in yeast cells having high glycolytic activity: a

case

study on the safety of genetically engineered yeast, International

Journal

of Food Science and Technology, Vol. 30, p. 141. Back

to

the text

 

41 Mayeno, A.N., and Gleich, G.J., 1994.

Eosinophilia-myalgia

syndrome and tryptophan production: a cautionary tale, Trends in

Biotechnology,

Vol. 12, p. 346. Back

to the text

 

42 DåArcy, P.F., 1995. L-tryptophan:

eosinophilia-myalgia

syndrome, Adverse drug reactions and Toxicological review, Vol. 14, p.

37. Back

to the text

 

43 Mayeno and Gleich, op cit. 1994. Back

to

the text

 

44 DåArcy, op cit, 1995. Back

to

the text

 

45 Regulation (EC) No. 528/97 of the European

Parliament

and of the Council concerning Novel Foods and novel food ingredients.

OJ

No. L43, 14.2.97, p. 1. Back

to the text

 

46 Meyer, P., Linn, F., Heidemann, I., Meyer, H.,

Neidenhof, I., and Saedler, H., 1992. Endogenous and Environmental

factors

influence 35S promoter methylation of a maize A1 gene construct in

transgenic

petunia and its colour phenotype, Mol. Gen . Genet., Vol. 231, p. 345.

Back

to the text

 

47 Brandle, J.E., McHugh, S.G., James, L., Labbe,

H., and Miki, B.L., 1995. Instability of Transgene expression in Field

Grown Tobacco Carrying the csr-1-1 Gene for Sulphonylurea Herbicide

Resistance.

Back

to the text

 

48 The Splice of Life, April 1996, High-tech Tomato

hits low tech problems Back

to the text

 

49 US National Biotechnology Impacts Assessment

Programme

Newsletter, May 1995, Calgene Battling on Two Fronts. Back

to

the text

 

50 Anon. 1995. Improving on Mother nature?, Consumer

Reports,US Consumers Union, July 1995. Back

to the text

 

51 US National Biotechnology Impacts Assessment

Programme

Newsletter, March 1996, Whither the Flavr Savr? Back

to

the text

 

52 The Splice of Life, op cit Back

to

the text

 

53 Calgene press release, 31 July, 1996. Calgene

announces planned $50 million Equity investment by Monsanto - Roger

Salquist

resigns as CEO; to Continue as Director. Back

to the text

 

54 World Wide Web, http://www.calgene.com/freshpr.htm.

Calgene

Fresh Produce page, off Calgene home page. 13 June 1997. Back

to

the text

 

55 European Commission Press Release, Brussels, 18

December 1996. The European Commission has decided to authorize

genetically

modified maize in the light of scientific advice. Back

to

the text

 

56 Biotechnology and the European Public Concerted

Action group, 1997. op cit. Back

to the text

 

57 See, for example, submissions to the US

Environment

Protection Agency on plant pesticide resistance management, 1997 Back

to

the text

 

58 Letter by Janet Anderson of US EPA to Richard

Lotstein, Director of Regulatory Affairs, Ciba Seeds, 9 August 1995. Back

to

the text

 

59 Letter by Janet Anderson of US EPA, 1995, op cit.

Back

to the text

 

60 World Wide Web, http://www.pioneer.com/customer/products/ecb/ncnp/section8.htm

Back

to the text

 

61 Andow, D.A. and Alstad, D.N., 1995. Letter to

US EPA on Dockett no.OPP-30377 (Ciba Seeds petition for

commercialization

of transgenic corn, May 5, 1995.) Back

to the

text

 

62 Gould, F., Anderson, A., Jones, A., Summerford,

D., Heckel, D.G., Lopez., J., Micinski, S., Leonard, R., and Laster,

M.,

1997. Initial frequency of alleles for resistance to Bacillus

thuringiensis

toxins in field populations of Heliothis virescens, Proc. Nat. Acad.

Sci.,

Vol. 94, p. 3519. Back

to the text

 

63 McGauchey, W.H., 1997. Comments to US EPA on Bt

Resistance management Docket OPP-00470. Back

to the

text

 

64 European Commission Press Release, Brussels, 18

December 1996, op cit. Back

to the text

 

65 Scientific Committee on Pesticides, 1996. Opinion

of the scientific Committee for Pesticides on the genetically Modified

Maize Lines notified by Ciba-Geigy, European Commission Directorate

General

VI, 9 December 1996; Scientific Committee on Pesticides, 1997. Further

report of the Scientific Committee for Pesticides on the use of

genetically

modified maize lines, 12 May 1997. Back

to the text