The Products of GE Technology Must be Assessed for Safety on a Case-By-Case Basis

Mark Lynas was at it again in an opinion piece in The New York Times last week, making claims once more about a so-called “worldwide scientific consensus on the safety of genetic engineering,” and calling those 17 countries in Europe that have announced bans on the cultivation of genetically engineered (GE) crops, the “Coalition of the Ignorant.”

But it is Lynas who appears to be ignorant of the fact that, as I explain in my letter to the editor published in today’s Times, genetic engineering is a technology and technologies are only as safe as they are used, each time they are used.

Therefore, suggesting that there is a scientific consensus “on the safety of genetic engineering” generally, or on “the products of crop genetic engineering technology” en masse is not only not scientific, it is illogical.

All of the products of the technology of genetic engineering should be assessed for safety on a case-by-case basis.

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GMOs: All Facts, No Fiction

I participated in two panel discussions on genetic engineering called “GMOs: All Facts, No Fiction” that were sponsored by the University of California’s Global Food Initiative in 2015.

One was held at UC Davis on November 3rd and the other at UC Riverside on November 4th. You can find a recording of the one on November 4th here (scroll down to: Public Lecture Focuses on “GMOs: All Facts, No Fiction”).

For more information, please see the links below.


UCR GMO-Poster-HighQuality

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Genetic Engineering is Very Different Than Traditional Breeding

The United States National Academies of Sciences, Engineering, and Medicine have established a committee to study the “economic, agronomic, health, safety, or other impacts of genetically engineered (GE) crops and food.” The committee’s results may be used to reassess the way GE crops, animals and foods are regulated in the U.S. and, hopefully, to improve that loophole-filled “regulatory” process. (For more information on the committee’s purpose and history, or for submitting comments, please see the committee’s website.)

Now, while this national review is taking place, is a good time to review the differences between genetic engineering and traditional breeding. The following lists serve to contrast the biological processes that underlie these technologies.

Traditional Breeding (i.e. its biological basis: sexual reproduction):

  • Evolved over eons (along with “checkpoint” mechanisms to eliminate mistakes)
  • Occurs between closely related organisms
  • Genetic exchange occurs in reproductive cells,
  • and occurs between related chromosomes,
  • through homologous recombination
  • Amount of DNA and spacing between genes remain the same


(Traditional) Genetic Engineering (particularly of crop plants):

  • Is human-made, recently (and subject to human and other errors)
  • Involves any gene from any organism (alive or dead) or synthesized in a lab
  • Occurs in somatic cells
  • Insertion into chromosomes occurs “randomly”
  • Causes insertional mutation of recipient’s genes at rates of 27-63%
  • Gene spacing and amount of genomic DNA are altered
  • Involves “selectable marker” genes (e.g. kanamycin-resistance gene)

And because genetically engineered cells–in and of themselves–are of no use to agriculture, they must then be coaxed into becoming whole, fertile plants through another biological process called regeneration. And another form of mutation, called somaclonal variation, can occur during the regeneration process.

And, finally–to be of real use to agriculture–a genetically engineered, regenerated, fertile plant must be traditionally bred into a commercially viable crop variety.

To sum, there are multiple biologically relevant differences between the processes of traditional breeding and genetic engineering of crop plants; and the “process” of genetic engineering actually comprises multiple, different processes.

Therefore, genetic engineering is very different than traditional breeding. And, until proven otherwise, it should be assumed that the risks associated with these technologies must be different as well.

As a scientist trained in biology and genetics, I see no way other way to look at it.

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California EPA to List Glyphosate as Known to the State to Cause Cancer

In case you haven’t already heard…

The California Environmental Protection Agency (EPA) Office of Environmental Health Hazard Assessment (OEHHA) has posted notice of its intent to list glyphosate, the active ingredient in Roundup® and other related herbicides, as “known to the state to cause cancer.”

As stated by the OEHHA: “[California] law requires that certain substances identified by the International Agency for Research on Cancer (IARC) be listed as known to cause cancer under Proposition 65 [AKA California’s Safe Drinking Water and Toxic Enforcement Act of 1986]….OEHHA [has determined that] Tetrachlorvinphos, parathion, malathion, and glyphosate each meet the requirements for listing as known to the state to cause cancer for purposes of Proposition 65.”

The use of glyphosate, and the acreage to which it is applied, has increased dramatically since the first crops genetically engineered (GE) to be resistant to this herbicide were first commercialized in 1996. And new glyphosate-resistant crops continue to be commercialized. The U.S. Department of Agriculture (USDA) recently deregulated new GE corn and GE soybean crops that can survive being sprayed with both glyphosate and another pesticide, 2,4-D, pesticides that would kill their non-engineered relatives…and the U.S. Environmental Protection Agency (EPA) approved the herbicide cocktail, Enlist Duo™, comprised of those two pesticides that can be sprayed on those GE crops with impunity. (For more information, see this previous post of mine.)

So a chemical (soon to be) “known to the state [of California] to cause cancer” is being sprayed on vast acreages of farmland, not only in California, but throughout the United States and in many other parts of the world.

Hopefully, U.S. EPA will similarly take the recent IARC publications into account and take another long, hard look at the widespread use of glyphosate in the United States.

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GMOs and Democracy

The start of a comment made in response to my last post—“Maybe it is undemocratic but in this case…”—still bothers me.

It also worries me when I hear plant molecular biologists say: “I would normally be in favor of labeling, but not when it comes to GMOs.”

Why should anyone suspend democracy, and the capitalist principle of letting the consumer/marketplace decide whether a new product will succeed or not, for the sake of food products of genetic engineering?

Are genetically engineered (GE) food crops such a great innovation that the United States should set aside basic American principles to ensure that they end up on American dinner plates?

GE food products and ingredients have now been commercially available—in the U.S. and elsewhere—for more than two decades. What are the results of this social experiment so far?

According to Colin Macilwain, in an opinion piece published in the scientific journal Nature recently:

“Five-sixths of [the world’s] GM acreage is in the Americas. The rest consists mostly of non-food crops (mainly cotton) grown in India and China. Little of the harvest is in nations that need improved yields to feed themselves. Twenty years in, the GM strains currently under cultivation are still best suited to the needs of large-scale industrial farmers who can afford the seeds and inputs that accompany them.”

That is my take as well…although I would add that much of the yellow GE corn grown in places like China and the Philippines is also fed primarily to animals as opposed to humans.

These “results” appear to indicate that the citizens of the United States, as opposed to those in developing countries with food shortages, comprise many (if not most) of the humans on the planet who are actually eating GE foods. And, as opposed to the citizens of the more than 60 other countries in the world that require foods containing GE ingredients to be labeled, citizens of the United States, one of the most democratic nations on Earth (arguably it seems), don’t have that right…despite the fact that in poll after poll 80-90% of American citizens have indicated they want these foods labeled.

There is something terribly wrong with this picture!

As an American consumer myself, just the fact that genetic engineering has been used primarily in support of unsustainable, industrialized agriculture, combined with the fact that its promoters—including academic scientists, corroborated recently by the New York Times—don’t want me to know whether the foods I buy in my grocery store contain GE ingredients…are reasons enough, in my mind, to vote against such foods with my pocketbook. That I was once a genetic engineer involved in bringing a GE food to market makes me that much more disappointed in the non-tranparent, unsustainable trajectory the ag biotech industry has taken since I left the industry in 1995.

In the United States that I grew up in, these types of reasons–or any others consumers conceived of–were among those that buying decisions were based on. If I didn’t like a product, its packaging, or…whatever, I was free to forego purchasing that product. Back in the day, it was up to the sellers to convince consumers to become their buyers.

And now, after having had two decades to demonstrate the great “potential” of this powerful technology, but without having to take consumer demand into account while doing so, the ag biotech industry has relatively little to show for it…except a public that—for lack of: assurance of long-term safety, GE products that consumers could get excited about, and/or transparency—has only become more and more wary of the whole biotech food endeavor.

It may now be time to pay the piper.

According to Macilwain, there are decisions pending in countries like “Scotland, Germany, France, Italy and others to stand up to corporate pressure and keep GM crop technology out of the European country-side.” And even in the U.S., “John Holdren, science adviser to US President Barack Obama, [has, as of July 2, 2015,] directed regulators to revisit the U.S. framework for regulating agricultural biotechnology.”

Two decades in, it’s time to reassess this technology…why and how it is used, and how it is regulated and marketed.

And at this juncture, the truly democratic nations of the Earth would do well to heed Macilwain’s reminder: “good risk management involves early communication with the public and the careful weighing of many factors, not just scientific risk assessment.”

As for the U.S., being transparent (via labeling, etc.), conducting the long-term studies necessary to reassure the public about GE crops (starting with NK603 GE corn) and having regulatory agencies require case-by-case assessment of new GE products will, in my opinion, all be necessary for there to be any chance of turning public concern around.

And unless public concern is turned around, who knows whether the “potential” of genetic engineering evidenced by projects like Golden Rice (which, if all goes well, may be ready for market in 3-5 more years) will ever be realized?

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Tell the US House of Reps: Defeat HR1599 Because It’s Downright UnAmerican!

I just signed a petition asking members of the U.S. House of Representatives to vote down HR 1599, the deceptively named “Safe and Accurate Food Labeling Act,” which would make it illegal for state governments to pass GMO labeling laws or regulate GMOs in other ways.

The vote is scheduled to occur tomorrow, July 23, 2015.

Here’s the comment I made when I signed the petition:

I am a former genetic engineer, but no matter the subject matter, it is outrageous that the federal government of this great nation is even considering a bill that would negate the will of its people, at the grass roots and state levels, and allow any industry to continue to hide its products from American consumers. It’s supposed to be of, for and by the people…remember?

If you agree that Americans should have the right to know what’s in the food they buy in grocery stores, and when the vast majority of Americans (80-90%, depending on the poll) want to know whether GMOs are in their food labeling those foods should be mandatory, and when the citizens of more than 60 other countries already have this information that Americans should have it too…

then I urge you to let your US representatives know how you feel by signing a petition like the one here.

For more information here’s an article in the Boston Globe supporting the idea that HR 1599 should be defeated and Americans should get to decide for themselves about GMOs via labeling, and another in the Huffington Post by Fedele Bauccio, CEO of Bon Appétit Management Company, indicating that labeling GMOs is just good business.

This is not just about GMOs. This is about our democracy.

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Let USDA APHIS Know that GMOs Should be Regulated

USDA’s Animal and Plant Health Inspection Service (APHIS) has been regulating genetically engineered (GE) crops over the last two decades based on whether development of those products involved use of organisms deemed “plant pests.” (Whether that strategy has been science-based is debatable, in my opinion.)

In light of the fact that more and more GE organisms are now being developed without the use of “plant pests,” the agency is seeking input on how APHIS should regulate the products of biotechnology from here on out. The deadline for submitting comments is Monday, June 22, 11:59PM Eastern Time.

I encourage anyone interested in how GMOs are regulated in the United States to submit comments.

I just submitted mine to the agency; here is a copy of them:

I am a molecular geneticist and former crop genetic engineer. Thank you for seeking input on how APHIS should regulate the products of biotechnology. The following are my comments addressing the four question areas that APHIS is seeking input on.

1. APHIS should regulate biotechnology products based on the fact that they were created using biotechnology processes because any individual biotechnology product (as currently produced) may present potential risks that can not be anticipated based on the product’s intended characteristics; these risks relate to unexpected, unintended changes that could result from insertional mutagenesis, unintentional insertion of vector “backbone” sequences, or off-target effects. The criterion used to determine what APHIS regulates should therefore be the fact that the organism was created using a biotechnology process like genetic engineering, which includes processes that utilize the biolistic gun, Agrobacterium tumefaciens and RNAi technologies, as well as the newer CRISPR-related methods. Until scientists know more about genomic processes governing global gene expression and how those processes might be disrupted by the processes of biotechnology, all biotechnology products should undergo some level of APHIS regulation.
2. Yes, APHIS should add noxious weed provisions to its biotechnology regulations. The intended characteristic of herbicide tolerance that has been genetically engineered (GE) into many biotechnology products grown on vast acreages of U.S. farmland over the last two decades, has, predictably, substantially contributed to the significant noxious weed problem facing many American farmers (and many other farmers around the world). APHIS should therefore require any biotechnology product designed to be tolerant to any herbicide to undergo additional regulatory oversight by APHIS. This oversight should include monitoring herbicide-resistant crop systems for their potential to foster herbicide-resistant weed populations and imposing appropriate control measures if monitoring reveals a problem, as well as regulating direct and indirect harms from these systems to the livelihoods of GE, non-GE and organic farmers, to biodiversity generally and to public health. APHIS should consider protection goals that align with making American agriculture more sustainable, more environmentally friendly and less in need of future “solutions” to GE-produced noxious weed problems that involve additional GE crops engineered to be tolerant of more noxious herbicides.

3. My understanding is that the 2008 Farm Bill gives USDA additional authority to regulate biotechnology, especially with regard to issues of contamination and gene flow to food crops from field trials of GE crops that have not yet been “de-regulated” for commercial release, or from GE crops producing industrial chemicals or drugs. Given the history of contamination and gene flow events from field trials, APHIS should utilize its authority to the fullest extent to regulate GE crop production systems and prevent cases of contamination, such as the pig vaccine-producing GE corn that contaminated a soybean field, and cases of inadequate regulation based on the “intended” use of a GE crop, as was the case for the avidin-producing GE corn product.

4. The history of GE crop contamination events that have occurred in the U.S. in spite of APHIS oversight meant to prevent them is testimony for the need of more federal regulation of GE organisms, not less. The biotechnology industry has not proven that it is capable of regulating itself and yet there are now examples of GE crops ready for commercialization that would not come under APHIS’s “plant pest-based” criteria for regulation of GE organisms. There is certainly no evidence supporting the notion that non-regulatory solutions, i.e. those without the force of law, would be in the best interest of American agriculture, farmers or the public and non-regulatory “solutions” should therefore not be considered as a complement to APHIS’s regulatory program. Increasing regulatory oversight of GE organisms at this time would have the added advantage of instilling more confidence in the U.S. public with regard to products of biotechnology.

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