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18 May 2005 13:21:04 -0000

 

Bt10 Detection Method Unacceptable

press-release

 

 

The Institute of Science in Society Science Society

Sustainability http://www.i-sis.org.uk

 

General Enquiries sam Website/Mailing List

press-release ISIS Director m.w.ho

========================================================

 

 

ISIS Press Release 18/05/05

 

Bt10 Detection Method Unacceptable

*****************************

 

The detection method for Syngenta's illegal GM maize is

flawed; there must now be a full disclosure of information

and access to reference material for retrospective risk

assessment and risk management. Dr. Mae-Wan Ho and Prof. Joe

Cummins

 

Concerted move to reassure the European public

 

Swiss biotech firm Syngenta had accidentally sold illegal GM

maize Bt10 in the US for the past four years, resulting in

about 133 million kilograms of the maize making its way into

food and feed.

 

The news broke on 22 March 2005 in the science journal

Nature ( " Syngenta's GM maize scandals " ,

SiS 26 http://www.i-sis.org.uk/isisnews/sis26.php),

although Syngenta had entered into talks with the US

government since December 2004.

 

Under pressure from public protests across the world, the US

government fined Syngenta a derisory US$375 000 (euro 270

000) for the mishap. And on 18 April, the European

Commission imposed an emergency measure to ban certain GM

maize imports from the US unless they are accompanied by an

original analytical report issued by an accredited

laboratory demonstrating that the product does not contain

Bt10 ( " Europe acts swiftly to keep out unapproved GM maize " ,

SiS26 http://www.i-sis.org.uk/isisnews/sis26.php).

 

Scarcely a week later, the EU authorities announced that

Syngenta had presented a detection test for Bt10, which was

already validated by the EU authorities.

 

The validation report [2] from the Joint Research Centre,

also Europe's Community Reference Laboratory (CRL) for GM

Food and Feed, said it carried out an in-house validation of

the event-specific detection method " proposed by GeneScan on

Bt10 maize developed by Syngenta Crop Protection AG. "

 

Syngenta provided the DNA samples (genomic DNA extracted

from the Bt10 maize line and from a control maize line), and

GeneScan provided the event-specific detection method based

on a qualitative polymerase chain reaction (PCR) assay.

 

Monopoly on detection method declared

 

So who, or what is GeneScan? GeneScan advertises itself on

its website as " the world market leader in the field of

molecular biological testing for Genetically Modified

Organisms (GMOs) in food, feed and agricultural raw

materials. "

 

The GeneScan website has a link to a page on Syngenta's

website, which advertises the " European Union Bt10 Detection

Method " [3] as a " validated detection methodology that has

been thoroughly tested for accuracy, reliability and

sensitivity " using authentic samples to ensure actual

targeted material is detected reliably when present. The

method is designed, it says, to exclude " false positives " in

the hands of " highly qualified scientific personnel with

specific experience with the protocol " , working under

" exemplary laboratory practice and standard operation

procedures (SOPS) from an …accredited lab " , with " provisions

for retesting false positives " .

 

The same Syngenta page advises us that GeneScan is " the only

private service laboratory that fulfils the elements listed

above for Bt10 testing " , and the fact that the EU Joint

Research Centre has certified the GeneScan method on April

22, 2005 as " the only EU official method for Bt10

detection. " Following that, yet again, the admonition to

guard against " false positives " is repeated.

 

In contrast, there's not a word said about false negatives,

which as every molecular geneticist knows, is also a problem

with the PCR detection method, particularly if the GM insert

is unstable, and prone to deletions and rearrangements, as

revealed in recent analyses by European government

laboratories ( " Transgenic lines proven unstable " , SiS20

http://www.i-sis.org.uk/isisnews/sis20.php; " Unstable

transgenic lines illegal " ,

SiS21 http://www.i-sis.org.uk/isisnews/sis21.php).

 

This three-way mutual reinforcement between Europe's Joint

Research Centre (the European Commission's official

laboratory), Syngenta and GeneScan seems just a bit too cosy

to be reassuring. What's more, they have jointly declared a

monopoly on the detection method, ruling out all others that

could give " false positives " . It is a case of the poacher

turned gamekeeper with the help of the governor. The

validation report issued by the Joint Research Centre (JRC)

goes on to state [2], " The results of the JRC validation

demonstrated that the method reliably detects an

amplification product specific for Bt10 maize, and therefore

allows discriminating event Bt10 from other GM-events in

maize lines. The sensitivity of the method is below 0.1%….

 

" The method is therefore considered by the CRL as fit for

the purpose of Bt10 detection and it is the only accepted to

certify the presence of Bt10 in maize commodities in

accordance with the Commission Decision 1005/317/EC).

(emphasis added)

 

When is a positive false?

 

In fact, the method amplifies and detects a small 130base

pair fragment of Bt10 DNA, said to be specific for Bt10. It

is not stated which gene fragment from Bt10 is being

amplified. A strict protocol is laid out in detail. The Bt10

and wild type DNA supplied by Syngenta were analysed along

with other reference and non-reference material contained in

the JRC's Community Reference Laboratory.

 

The 130 bp band was indeed specifically amplified only in

Bt10. But unfortunately, bigger bands were amplified and

detected in other GM maize lines, and even in the wild-type

maize DNA supplied by Syngenta. Strangely enough, these

higher molecular weight bands were absent from the Bt10 DNA

from Syngenta.

 

The origins of the " unspecific amplicons " (amplified DNA)

were not investigated further, but effectively dismissed

with the remark, " This suggests that the method can be

further optimised. " Consequently, only the 130bp amplicon is

regarded as a definite positive.

 

The conclusion of the validation report states that the

method is " fit for its intended purpose " , with the

qualification [3], " However, at this stage of testing, the

method produces a higher molecular-weight multi-band pattern

in GM and non-GM maize which requires additional efforts in

its optimisation. "

 

Still further qualifications are contained in a later report

[4] on the detection method: " The analyst shall be aware

that other validation experiments indicated that the method

might perform less reliably at annealing temperatures higher

than specified in the protocol. Moreover, in some incidents

unspecific amplification was observed with PCR profiles that

used high numbers of cycles than specified in the protocol.

Time constraints did not permit to rectify these concerns… "

 

As mentioned earlier, fragmentation or rearrangements of the

GM insert can change the size of the amplicon, or otherwise

fail to give the specific amplicon. Consequently, unless

fragmentation or rearrangement of the Bt10 GM insert can be

ruled out, it is not legitimate to conclude that amplicons

of other sizes are " false positives " .

 

Further data, further confusion

 

Syngenta's reports sent to the US Environment Protection

Agency earlier this year have been leaked to ISIS.

 

The first report dated 28 January 2005 [5] is intended to

present the DNA sequence of Bt10 compared with Bt11, the GM

maize line that Bt10 had contaminated by accident. The Bt10

insert was mapped to chromosome 1 of the maize genome, while

Bt11 insert had been mapped to chromosome 8. This alone will

indicate that Bt10 is completely different from Bt11. In

addition, there were three nucleotide changes in Bt10

compared with Bt11: two in an unspecified sequence contained

within the Bt10 insert (unspecified sequence 1 in Figure 1

below), and one located in the nos terminator associated

with the crylAb gene. No nucleotide changes were identified

in any of the coding sequences and promoters within the Bt10

insert.

 

However, the map of the Bt10 insert presented can only be

partial, as it did not include the ampicillin antibiotic

resistance marker gene, unless that marker gene has inserted

elsewhere in the genome. The map presented also contained at

least three unspecified, unknown sequences (Fig. 1).

 

Unspecified sequence 1 (>1000 bp)-p35S (516pb)-IVS6 maize

adh1S (477bp)-crylAb(syn) (1848bp)-tnos (267bp)-Unspecified

sequence 2 (~400bp)-p35S(422bp)-IVS2 maize adh1S (180bp)-pat

(522bp)-tnos (259 bp)-unspecified sequence 3 (~160bp)

 

Figure 1. Map of Bt11 from Syngenta's report to US EPA

 

The second report from Syngenta to the EPA is of a study

comparing the transgenic proteins expressed in Bt10 compared

with those in Bt11 [6]. The proteins were extracted from

leaves of the plants, and subjected to western blot

analyses, a technique dependent on staining the protein

bands with specific antibodies after separating them by

migration in an electric field through a gel matrix.

 

This report claims that the analyses " revealed similar

dominant immunoreactive bands " in both Bt11 and Bt10

corresponding to the predicted Cry1Ab protein (for insect

resistance) and phosphinothricin acetyltransferase (PAT)

(for tolerance to the herbicide glufosinate ammonium) of

about 69 000 and 22 000 daltons respectively.

 

However, the photographs of the western blots contained in

the report tell a different story. Bt11 showed a series of

bands at 46 000, 63 000 and 52 000 daltons (in order of

strength of staining) besides the dominant 63 000 daltons

band, whereas Bt 10 only had the 63 000 daltons fragment

besides the main predicted band. The PAT protein bands in

Bt10 and Bt 11 were also different from each other and from

the purified standard, with many high molecular weight bands

reacting to the antibody.

 

Neither report contains information on the breeding history

of the GM maize lines analysed, such as the number of

generations since the transformation event; nor data from

appropriate reference material. These are sure signs of

sloppy science.

 

Full disclosure of molecular data and access to reference

material required

 

The detection method for Bt10 is flawed by the admission of

the European authorities. The identity of the 130 bp

amplicon, supposed to be specific for Bt10, is not made

explicit. The molecular data supplied to the US EPA are

incomplete. It is impossible to judge if the detection

method is adequate in the absence of full molecular data

including those from reference material proving that Bt10

had remained genetically stable since it was first

unintentionally released.

 

Bt11 had already been exposed to be unstable, and to be

contaminated with another Syngenta maize Bt176, implicated

in the death of dairy cows in Hesse Germany ( " Cows ate GM

maize and died " ,

SiS 21 http://www.i-sis.org.uk/isisnews/sis21.php).

 

Syngenta has admitted that Bt10, as distinct from Bt11,

contains an ampicillin resistance marker gene, which,

according to an Opinion issued by the Scientific Panel on

Genetically Modified Organisms of the European Food Safety

Authority in 2004,

 

" should not be present in GM plants to be placed on the

market " . No official information has been forthcoming

regarding the ampicillin resistance marker gene in Bt10, nor

any attempt to ascertain whether the marker gene has

contaminated other maize varieties, GM or otherwise.

 

As Bt10 has already entered the market and the human food

chain, it must go through retrospectively the risk

assessment process that would have been applied to a GM

product approved for market. This is also essential for

effective post-release risk management.

 

At the very least, Syngenta must be required to provide the

following:

 

Reference plant material from successive generations of the

Bt10 transformation event plus the non-GM maize variety from

which Bt10 was derived Full genetic map and base sequence of

the Bt10 insert(s) including the ampicillin resistance

marker gene and the host genome sequences flanking the

insert(s) Genome location of the Bt10 insert(s) Profiles of

expressed RNAs and proteins in the Bt10 reference material,

compared to those in Bt11 and the non-GM variety or

varieties from which the GM maize lines were derived

Molecular genetic data of at least five generations after

the Bt10 transformation event, to document genetic stability

Any other information available on Bt 10

 

Furthermore, regulatory authorities on both sides of the

Atlantic must make public all information on Bt10 that they

have received from Syngenta or other sources.

 

Please circulate this report widely and send it to your

elected representatives. " EU detection method for Bt10 maize

validated " European Commission Health & Consumer Protectionate-General E-News 25-05-2005

http://europa.eu.int/comm/dgs/health_consumer/dyna/enews/ene

ws.cfm?al_id=18

 

Mazzara M, Maretti M, Foti N, Price S, Paoletti C, Savini C

and Van den Eede G. Joint Research Centre – European

Commission. Report on the in-house validation of a detection

method for event Bt 10 maize using a qualitative PCR assay.

http://gmo-

crl.jrc.it/detectionmethods/Bt10%20validation%20report.pdf

 

European Union Bt10 detection method. Syngenta

http://www.syngenta.com/en/downloads/050427_Bt10_EU_Method.p

df

 

PCR assay for detection of maize transgenic event Bt10.

European Commission. Community Reference Laboratory for GM

food and Feed. http://gmo-

crl.jrc.it/detectionmethods/Bt10%20Detection%20Protocol.pdf

 

Rabe,s,Mumm,R.Shi,L. and Stein,J. Sequencing of the Bt10

insert and comparison with the previously reported Bt11

sequence Syngenta Biotechnology,Inc. Report : SSB-104-05,

January 28,2005.

 

Graser G. Western blot analysis of CrylAb and PAT proteins

expressed in field corn. Report No. SSB-112-05. Syngenta

report to US EPA, 11 February 2005.

 

 

========================================================

This article can be found on the I-SIS website at

http://www.i-sis.org.uk/BT10DMA.php

 

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press-release ISIS Director m.w.ho

 

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