THE GENETIC ENGINEERING DEBATE (v0.32)
compiled by Roberto Verzola
email: rverzola@phil.gn.apc.org

0.   MAJOR CHANGES

0.1. Arguments that are specific to particular GE traits like
     herbicide-tolerant crops, Bt crops, recombinant hormones,
     promoters, antibiotic-resistance markers, etc. have been marked
     appropriately (e.g., HT, BT, RBGH, CAMV, ARM, and so on).

0.2. Headers have been modified to reflect industry claims, which have
     been put under the following general headings: safety claims,
     scientific claims, economic claims, legal claims, moral claims,
     and quality claims.

1.   ABOUT THIS DOCUMENT

1.1. This document aims to support the campaign against the risks of
     genetic engineering (GE). It will try to summarize all claims
     made by the proponents of GE, and the responses by the critics of
     GE. Supporting data and summaries of scientific studies will be
     included as much as possible.

1.2. I welcome suggestions, corrections, improvements and new
     information to this document. Most important are corrections to
     factual or argumentation errors/weaknesses. Style, syntax and
     grammar corrections are also welcome. My real role is to
     coordinate what will hopefully be a worldwide group effort.

1.3. Contributions we are most interested in are of two types: a)
     facts, together with the source or URL, preferably both; source
     can be an email posting or news item, but scientific publications
     are preferred; peer-reviewed articles are even better; b)
     arguments, whether for or against GE; we also want the strongest
     arguments of the other side, so we can research how they may be
     answered properly.

1.4. IMPORTANT: When sending me a suggested change or addition, please
     do not (repeat: DO NOT) send me back the full edited document.
     Send only the paragraph(s) you want to add/change, the version
     number of the document you have (e.g., v0.2), and the section
     heading of the paragraph (e.g., 1.4).

1.5. Updated versions of this document will be released regularly at
     the GENTECH (gentech@ping.de) and BAN (ban@tao.ca) mailing lists.
     You are welcome to post this document on any other mailing list
     or website, but please post it in its entirety.

1.6. Some conventions: + is an argument in favor; - is against; ++ or
     -- means this item is a new entry or is an edited version of its
     earlier counterpart; * is for useful data which is neither for or
     against GE.

2.   SAFETY CLAIMS: GE-FOODS ARE SAFE

          + We have been doing biotech for thousands of years.

          - We have been doing traditional biotechnology
     (fermentation, conventional breeding, etc.) for a long time; but
     modern biotechnology or genetic engineering is a very recent
     development, and the first commercial products were released only
     in the early 1990s. If we look at our experience at DDT and other
     toxic chemicals (produced by the more or less same firms now
     engaged in GE), it took some 20-30 years to determine they were
     bioaccumulating through the food chain and causing cancers and
     around 50 years to determine that they were mimicking some human
     hormones and disrupting our endocrine systems.

          + GE is just an extension of conventional breeding.

          - GE and conventional breeding are radically different.
     Conventional breeding works only within the same or closely
     related species (e.g., bacteria to bacteria, corn with corn, pigs
     with pigs, etc.) In contrast, GE involves mixing genes from very
     distantly related species that in nature will never breed with
     each other (e.g., bacteria to corn, or pig to human beings).

          - Actually GE is a new, experimental, very dangerous, AND
     radical technology. The process causes unnatural mutation and
     combination of the DNA in our food in a manner which excludes
     nature out of the process. This means we and our children are now
     eating lab-created, mutated and experimental "fake" food. They
     are experimenting, not only with us and with our children, but
     with the entire food chain. (From: pmligotti@earthlink.net)

          - Whoever argues that GE is no different from conventional
     breeding is probably laying the groundwork for the concept of
     "substantial equivalence", that the products of genetic
     engineering are as safe as the products of conventional breeding.
     This dubious concept is often used as excuse to avoid thorough
     and rigorous testing.

          + Horizontal gene tranfer across distant species occurs in
     nature. Natural broad-species vectors exist; some do replicate in
     Gram- bacteria, others only in Gram+. There are also vectors
     which replicate in Gram- and Gram+ bacteria, and some organisms
     transfer DNA to plants (eg Agrobacterium tumefaciens, A.
     rhizogenes)

          - Where horizontal gene transfer occurs in nature, it is
     often in connection with the emergence of more virulent or new
     pathogens. GE is inherently risky because it uses the same
     mechanism to facilitate the insertion of foreign genes through
     bacterial or viral vectors.

          + GE is much more precise than conventional breeding.
 
          - GE is only precise in so far as the foreign genes which
     will be inserted into a target organism are known. But GE has no
     control where into the target organism's genome the foreign genes
     will be inserted. The insertion site is totally random and
     unpredictable. Since genes do not operate in isolation, but
     interact in a complicated way and change their behaviour in
     response to influences from nearby and even distant genes, the
     behaviour of the transformed target organism is also
     unpredictable.

          + There are techniques that ensure a precise integration
     into the genome (eg double recombination using a suicide gene or
     by using chimeraplasty which precisely changes an already
     existing gene)

          - The commercially-available GE-crops did not use these new
     experimental techniques, but random techniques like the "gene
     gun" or bioballistics.

          + Even with random methods, it is possible to determine the
     insertion site(s) afterward and choose clones accordingly.

          - Even after the insertion site has been determined, the
     interaction between the inserted promoter and miscellaneous
     foreign genes on the one hand and the neighboring genes on the
     other hand must still be determined. We know too little today
     about most target genomes to determine these interactions
     precisely.

          - There is no data documenting the stability of any
     transgenic line in gene expression, or in structure and location
     of the insert in the genome. Such data must include the level of
     gene expression, as well as a genetic map and DNA base sequence
     of the insert and its site of insertion in the host genome in
     each successive generation.  No such information has been
     provided by industry, nor requested by regulatory authorities.
     (32) (See: "Will genetically engineered crops mean adulterated
     and toxic food, bodies, and ecosystems?", Michael W. Fox, Senior
     Scholar/ Bioethics, The Humane Society of the United States 2100
     L Street, NW Washington, DC  20037)

          + Crop varieties developed through conventional breeding do
     not undergo feeding tests. Why should GE varieties?

          - GE destabilizes the target genome, so it involves
     inherently higher risks than conventional breeding. Thus we
     should assume that GE varieties are unsafe unless proven
     otherwise through thorough long-term testing. Traditional
     varieties of food crops have evolved with us for thousands of
     years, and can be assumed to be safe unless proven otherwise.
     Modern hybrids may or may not need to be rigorously tested
     depending on the situation.

          + Problems attributed to GE-crops may also occur with
     conventionally-bred hybrids especially when breeding with wild
     relatives.

          - GE-crops are inherently riskier, because the results of
     the random insertions are unpredictable. When we breed a natural
     corn variety that is safe to eat with another natural corn
     variety that is also safe to eat, we can reasonably assume that
     the result would also be safe to eat, unless proven otherwise. No
     foreign genes have been introduced. If we cause mutations through
     GE (or even through high-intensity radiation), we cannot
     reasonably assume that the mutant is safe to eat, without
     thorough testing. If we breed this presumably unsafe mutant with
     a natural corn variety, we cannot assume that the result is safe
     to eat either.

          - By 1992, there were already 7 known instances of
     unexpected results from GE. One can only imagine how many more
     there have been in the interim. (Bereano, Philip and Nachama
     Wilker, "Regulations for Genetically Engineered Foods,"  Science,
     Vol. 258, 4 Dec 1992, p. 1561-2)

          - An example of GE unpredictability: Bill Vencill of the
     Univ of Georgia examined the effects of heat on GE soya beans
     after Georgia farmers alerted him to unexpected crop losses,
     esp. during Georgia's two hottest springs since the beans were
     launched in 1996. "In the years we saw the problems, the soils
     were reaching 40 to 50 C," says Vencill. His team replicated
     these conditions in lab growth chambers, comparing the hardiness
     of the Monsanto plants with conventional strains. In soils that
     reached only 25 C during the day, the GM Monsanto beans grew as
     well as other beans. But in warmer soils, the GM plants appeared
     stunted. In soils reaching 45 C, the differences were marked.
     Vencill described the findings at a British Crop Protection
     Council meeting in Brighton this week. "We saw lower heights,
     yields and weights in the Monsanto beans," says Vencill. Worse,
     stems of nearly all the GE beans split open as the first leaves
     began to emerge compared with 50-70% of the other test plants.
     This had occurred on farms, but had been blamed on fungal
     disease. "Instead, we think the stem splits, and it exposes the
     plant to secondary infection," says Vencill. Vencill suspects the
     changes in plant physiology caused by the addition of GE
     resistance to glyphosate, the herbicide marketed as Roundup by
     Monsanto. These herbicide-resistant plants have been shown to
     produce up to 20 per cent more lignin, the tough, woody form of
     cellulose. "We think it might make the plants more brittle," says
     Vencill. (See: Andy Coghlan, New Scientist, 20 Nov 1999)

2.1. CLAIM: GE-FOODS ARE SAFE FOR HUMAN AND ANIMAL CONSUMPTION

          - Summary: we do not know enough yet; some studies justify
     certain concerns about human and environmental safety; more
     studies need to be done; meanwhile, based on the precautionary
     principle, we must assume that GE foods are not safe and take the
     necessary precautions.

2.1.1. CLAIM: GE- AND CONVENTIONAL FOODS ARE SUBSTANTIALLY EQUIVALENT

          + We have established the substantial equivalence between
     commercial GE foods and their conventional counterparts.
     Therefore, we can assume that GE foods are as safe as their
     conventional counterpart.

          + In September 1996, WHO and the FAO convened an expert
     consultation on GE-food safety in Rome, which adopted the same
     industry line that: 1) safety issues in GE-foods were "basically
     of the same nature" as in foods from conventional breeding; 2)
     the substantial equivalence concept can be used to show GE-food
     safety; and 3) once substantial equivalence is shown, "no further
     safety consideration is needed." (See: "Biotechnology and food
     safety: Report of a joint WHO/FAO consultation", Rome, Italy, 20
     Sep - 4 Oct 1996)

          - The 1996 WHO/FAO report made clear that the participants
     were invited "in their individual capacities and not as
     representative of any organization, affiliation or government."
     So the report describes individual opinions and not official WHO
     or FAO position. (See: "Biotechnology and food safety: Report of
     a joint WHO/FAO consultation", Rome, Italy, 20 Sep - 4 Oct 1996,
     p.1)

          - Biotech firms often refer to this 1996 report to falsely
     claim that the "WHO/FAO have declared that Bt corn [or some other
     GE-product] is as safe as its conventional equivalent for animal
     and human consumption." Yet, the WHO and the FAO themselves have
     no such official position.

          + The U.S. FDA has declared that GE crops are as safe as
     their conventional counterpart.

          + On May 18, 1994, the US FDA announced that a GE tomato
     was as safe as conventional tomato. In a nutshell, the FDA
     position is that labeling isn't required unless a GE product
     "differs significantly from its conventional counterpart" - if
     it contains a new sweetener, for example - or if it introduces
     an allergen. (Aberdeen American News, S.D.; Knight Ridder/Tribune
     Business News)

          - Because the FDA accepted the concept of substantial
     equivalence, it did not require feeding and other rigorous tests
     that pharmaceuticals or food additives normally require. (See
     also "Revolving door" under "Government/Industry collusion")

          - Confidential documents made public in an on-going class
     action lawsuit have revealed that the FDAs own scientists do not
     agree with concept of "substantial equivalence between GE and
     normal seeds.

          - The U.S. Food, Drug and Cosmetic Act prescribes that
     additives like the foreign genes in GE foods can only be
     recognized as safe based on tests that have shown the foods are
     harmless. But no such tests exist for GM foods. So, although the
     GRAS exemption was meant for substances whose safety has already
     been shown through testing, the FDA is using it to avoid testing
     and to approve substances based largely on conjecture - one that
     is dubious in the eyes of its own and many other experts. (Steven
     M. Druker, J.D., executive director of the Alliance for
     Bio-Integrity, coordinator of the lawsuit against the FDA to
     obtain mandatory safety testing and labeling of GE foods)

          + GE foods vary from non-GE foods only in the characteristic
     that has been modified.

          - The random insertion of foreign genes into the genetic
     material may cause unexpected changes in the functioning of other
     genes.  Existing molecules may be manufactured in incorrect
     quantities, at the wrong times, or new molecules may be produced.
     GE foods and food products may therefore contain unexpected
     toxins or allergenic molecules that could harm our health or that
     of our offspring. (See: "13 Myths about Genetic Engineering",
     Consumers for Education about Genetic Engineering, Dunedin
     Polytech, as posted by Deborah E Leech
     <dleech@mail.coin.missouri.edu> on the SANET list)

          - A study published July 1, 1999 in the Journal of
     Medicinal Food presents new information about biologically active
     components in GM soybeans resistant to Monsanto's Roundup
     herbicide. Dr. Marc Lappe, Director of the Center for Ethics and
     Toxics (CETOS) and principal investigator says, "Based on
     corporate representations, the phytoestrogen concentrations of
     Monsanto's Roundup Ready and conventional soybeans were supposed
     to be equivalent. But the initial industry studies were performed
     on unsprayed soybeans. We found significant differences when we
     examined herbicide-sprayed soybeans analogous to those used in
     foods. The study shows an overall reduction in phytoestrogen
     levels of 12-14 percent in the genetically altered soybean
     strains.  Most of this reduction was attributable to reductions
     in genistin and to a lesser extent daidzin levels, which were
     significantly lower in modified compared to conventional soybeans
     in both strains. The apparent differences found may be an
     important discovery because consumers tend to buy soy products
     for their naturally occurring phytoestrogens which are thought to
     protect against breast cancer, heart disease, and osteoporosis.
     As GE strains replace conventional ones, any differences in
     phytoestrogen levels becomes increasingly important." (See:
     "Alterations in Clinically Important Phytoestrogens in
     Genetically Modified, Herbicide-Tolerant Soybeans", Maryanne
     Liebert Publishers, J. of Medicinal Food, Vol. 1 No. 4, 1999) (6
     Jul 1999) <http://www.cetos.org>

          + FDA can demand extensive safety testing if the new gene
     "differs substantially" from those generally found in other food.

          - That's a hollow promise. All 44 crops that so far have
     gained FDA marketing approval have avoided scrutiny because FDA
     has accepted the industry's claims that they are "substantially
     equivalent" to conventional food. (See: Rick Weiss, Washington
     Post, 15 Aug 1999)
     <http://www.washingtonpost.com/wp-srv/health/daily/aug99/gmfood15.htm>

          - Some scientists have questioned substantial equivalence as
     "a commercial and political judgment masquerading as if it were
     scientific... primarily to provide an excuse for not requiring
     biochemical or toxicological tests." (See: Letter to Nature by
     Erik Millstone, Eric Brunner and Sue Mayer, 7 Oct 1999) (http:)

          - The Codex Alimentarius itself, the UN agency which WHO and
     the FAO defer to on food safety issues, has not adopted the
     concept for its food safety assessments. (See: ) (http:)

          - The British Medical Association rejected the notion that
     GM foods should be assumed to be safe when they are said to be
     substantially equivalent to their conventional counterparts,
     which is the basis of U.S. regulation of biotech foods. "This
     concept does not account for gene interaction of unexpected
     kinds, which may take place in GM foods," the BMA asserts. "The
     possibility that certain novel genes inserted into food may cause
     problems to humans is a real possibility, and 'substantial
     equivalence' is a rule which can be used to evade this biological
     fact." (See: "The Impact of Genetic Modification on Agriculture,
     Food and Health", British Medical Association, May 1999)

          - In March 1998 a letter in the UK's Farmers Weekly
     reported that livestock on farms from Nebraska to Iowa were not
     grazing, as in the past, in fields of Bt corn. Unpalatability of
     the Bt stalks was suspected. One farm specialist from Dawson
     County, Nebraska, reportedly said: "At first we thought it was a
     joke, but I have heard it enough now that we are looking into
     what could be going on." (See: Farmers Weekly, UK, Mar 1998)
     <http://www.btinternet.com/~nlpwessex/Documents/gmanimalgrazing.htm>

          - Animals reject "substantial equivalence"? After four
     months of hearing anecdotes from Kansas to Wisconsin, it is time
     to collect stories more thoroughly from farmers: About the hogs
     that wouldn't eat ration when GMO crops were included. About one
     farmer who said "if you want your cattle to go off their feed,
     just switch them out to a GMO silage." About another whose cattle
     broke through an old fence and ate down the non-GMO hybrids but
     wouldn't touch the Roundup Ready corn, though "they had to walk
     through the GMOs to get to the Pioneer 3477 on the other side."
     About the cattle whose weight-gain fell off when switched over to
     GMO sources. About the organic farmer with a terrible deer
     problem on his soybeans, who drives out at night, and sees 40 of
     them mowing down his tofu beans while across the road not one doe
     is eating on the Roundup Readies. About the raccoons romping by
     the dozen in the organic corn, while down the road not one ear
     has been touched in the Bt fields. Even the mice will move on
     down the line if given an alternative to these "crops". (See:
     ACRES USA Special Report, 18 Sep 1999 by Steven Sprinkel,
     Yankton, South Dakota)

          - Rodents reject "substantial equivalence"? Consider the
     Flavr Savr tomato, which was given a gene to delay its ripening.
     When scientists tried to feed rodents the tomatoes, however, the
     animals wouldn't eat them, recalled Roger Salquist, a scientist
     involved in creating the Flavr Savr. "I gotta tell you, you can
     be Chef Boyardee and mice are still not going to like them." They
     went so far as to force-feed the rodents through gastric tubes
     and stomach washes. This made the rodents sick, and revealed
     nothing about the tomato's safety. The tomato ultimately won
     approval from the FDA but failed in the market in part because it
     was so expensive. (See: Rick Weiss, Washington Post, 15 Aug 1999)
     <http://www.washingtonpost.com/wp-srv/health/daily/aug99/gmfood15.htm>

          - Although these novel products are different enough to be
     patented, the biotech industry and U.S. regulatory agencies say
     they are no different from their natural counterparts. For this
     reason, the U.S. FDA requires no pre-market testing on animal or
     human subjects (as would be required of new drugs or food
     additives) nor any labeling. "There isn't any difference between
     a GM product and a natural food in terms of its impact on
     consumer health," says Jim Maryanski, biotech coordinator for
     FDA, which oversees the safety of fruits, vegetables and other GE
     food products. FDA only requires a label if a product contains a
     known allergen or is nutritionally different - for example if a
     GM orange had more or less vitamin C, he says.

2.1.2. CLAIM: GE-FOODS DO NOT CAUSE ALLERGIC REACTIONS

          - One GE product you won't find on the market is a soybean
     to which genes from a Brazil nut had been introduced. A New
     England Journal of Medicine article in early 1996 suggested the
     GM soybean could cause reactions in people allergic to Brazil
     nuts. Pioneer Hi-Bred Intl of Johnson, Iowa - which had developed
     the soybean and later funded that allergy study - said it won't
     market the soybean because of the allergy potential. (Aberdeen
     American News, S.D.; Knight Ridder/Tribune Business News)

          * Pioneer Hi-Bred, the giant seed company, asked University
     of Nebraska scientist Steve Taylor in 1995 to study a new soybean
     they had invented. Pioneer had spliced a Brazil nut gene into
     soybean, to make it more protein-rich. Taylor was to check if the
     GM soybean would affect people allergic to Brazil nuts, a serious
     concern because such people wouldn't think to avoid soy. Just one
     of the nut's thousands of proteins was put into Pioneers' new
     soybean, and the odds of that one causing the nut's allergies
     were incredibly low, Taylor said. But one test, then another, and
     finally a third showed that the GE protein was indeed a major
     cause of Brazil nut allergies. In trying improve the soybean,
     Pioneer had made it potentially more deadly; it quickly halted
     the soybean project. Taylor's study is symbolic of all that is
     both scary and reassuring about GM food. It proved that GM food
     could cause an unexpected and potentially fatal reaction. But the
     problem was detected before the product was marketed. Symbolic
     because it was, and still is, one of the very few studies ever to
     look directly for any harm from a GE food or crop. That dearth of
     studies is the legacy of a U.S. policy that treats GM plants and
     food to be substantially the same as conventional ones. (See:
     Rick Weiss, Washington Post, 15 Aug 1999)
     <http://www.washingtonpost.com/wp-srv/health/daily/aug99/gmfood15.htm>

          + This was a very predictable situation. The soya allergy
     was caused by the same protein that was responsible for allergic
     reactions to Brazil nuts.

          - If the allergy was predictable, why did Pioneer even
     attempt to create that GE-soya?

          + The fact that the soya with the Brazil nut gene was
     recalled and not commercialized shows that the regulatory system
     worked.

          - The system may have worked in that particular case. How
     about all the other cases of commercialized GE-soya?

          - A study by the York Nutritional Laboratory, Europe's
     leading specialists on food sensitivity, found that health
     complaints caused by soya - the ingredient most associated with
     GM foods - have increased by 50% in 1998. Researchers said their
     findings provide real evidence that GE food could have a
     tangible, harmful impact on the human body. It is the first time
     in 17 years of testing that soya has crept into the laboratory's
     top 10 foods to cause an allergic reaction in consumers. John
     Graham, spokesman for the York laboratory, said: "We believe this
     raises serious new questions about the safety of GM foods because
     it is impossible to guarantee that the soya used in the tests was
     GM-free." (See: UK Daily Express, 12 March 1999)

          - FDA scientists warn that GE foods could "produce a new
     protein allergen" or "enhance the synthesis of existing plant
     food allergens." Without labeling, people with certain food
     allergies will not be able to know if they might be harmed by the
     food they're eating. (NYTimes full page ad, 18 Oct 1999)

          - BT: A new study of Ohio crop pickers and handlers finds
     that Bt can provoke immunological changes indicative of a
     developing allergy. With long-term exposure, affected individuals
     might develop asthma or other serious allergic reactions, notes
     study leader I. Leonard Bernstein of the University of Cincinnati
     College of Medicine. (See: Science News Online, Vol 156 No 1, 3
     Jul 1999). This means that people must avoid ingesting even
     "relatively safe" biopesticides like Bt.

          - BT: A health survey evaluated farm workers before the
     spraying of Bt pesticides and 1 and 4 months after the spraying.
     Two groups of low and medium exposure workers were also assessed.
     While there was no evidence of occupationally-related respiratory
     disease, positive skin prick tests were seen in exposed workers,
     with a significant increase in the number of positive tests to
     spores 1 to 4 months after exposure to Bt. The increase was more
     significant in high rather than low exposure workers. The study
     concluded that exposure to Bt may lead to allergic skin
     sensitisation and induction of IgE antibodies or IgG antibodies -
     or both. (Bernstein J L et al. 1999. Immune responses in farm
     workers after exposure to Bacillus thuringiensis pesticides.
     Environmental Health Perspectives. 107 (7): 575-582)

          * BT: The EPA has been asked to approve a new kind of Bt
     corn toxin called cry9C, seen as a test case of the degree of
     risk the EPA is willing to accept. While other versions of Bt
     break down harmlessly in the human digestive tract, cry9C can
     survive digestion and remains stable in the human stomach. Thus,
     its potential to cause allergies is higher. The FDA demands extra
     allergy testing for new food with such stable proteins. AgrEvo,
     the German firm seeking cry9C approval, has conducted some more
     tests, including a comparison of cry9C's molecular structure with
     known allergy-causing proteins. So far, no similarities have been
     found. But as the EPA evaluates the corn for human ingestion, the
     reality is that there is no surefire way of testing new proteins
     like cry9C for their potential to trigger allergies. (See: Rick
     Weiss, Washington Post, 15 Aug 1999)
     <http://www.washingtonpost.com/wp-srv/health/daily/aug99/gmfood15.htm>

2.1.3. CLAIM: GE-FOODS ARE NOT TOXIC

          - A case in which a GE-product might have resulted in toxic
     contaminants: a Japanese firm that makes the food supplement
     L-tryptophan changed its production process and switched to GE
     bacteria, at the same time removing some steps in their
     purification process. The new process resulted in a toxic
     contaminant that could have come from the GE-bacteria used in
     producing the L-tryptophan. Before the product could be recalled,
     it had killed 37 and hospitalized 1,500.
     <http://www.natural-law.ca/genetic/NewsNov-Dec97/GENews12-23Trypt.htm>

          - About 37 people died and some 1,500 became sick after
     Japanese company Showa Denko K.K. produced the amino acid
     tryptophan using GE - and inadvertently introduced a toxin. A Web
     site operated by survivors of the 1989 outbreak agrees with those
     basic facts, although one of the articles posted there lists only
     28 deaths. (Aberdeen American News, S.D.; Knight Ridder/Tribune
     Business News)

          + The L-tryptophan contaminant came not from the GE-bacteria
     but from a non-GE source which was overlooked due to the change
     in the purification process,

          - A non-GE contaminant cannot be ruled out. Unfortunately, A
     mysterious fire destroyed all samples of the GE-bacteria used for
     the production process, making it impossible for investigators to
     conclusively determine the real cause. (See: )

          - According to some FDA scientists, GE food may bring "some
     undesirable effects such as increased levels of known naturally
     occurring toxicants, appearance of new, not previously identified
     toxicants, increased capability of concentrating toxic substances
     from the environment (e.g., pesticides or heavy metals), and
     undesirable alterations in the levels of nutrients." In other
     words, scientists from the FDA itself suspect that GE could make
     foods toxic. (NYTimes full page ad, 18 Oct 1999)

          - Dr. Arpad Pusztai found that a diet of potatoes engineered
     to express the snowdrop lectin weakened rats' immune systems and
     adversely affected the kidney, thymus, spleen, gut and brain of
     the animals. If confirmed, Pusztai's conclusions will reinforce
     concerns that gene insertion itself may create new toxins; it
     will also implicate the toxin commonly used in other GE-crops -
     the Bt toxin which, Pusztai says, is also a lectin.

          + The Royal Society of London reviewed Pusztai's study and
     found it flawed and unworthy of publication.

          - After the Royal Society's review, however, Pusztai
     submitted the results of his study to The Lancet, one of the
     world's most prestigious medical journal, which decided to
     publish the study. (See: The Lancet, Oct 1999)

          * The UK's Royal Society has written to the Natural Law
     Party indicating that it has called for Dr Pusztai's work to be
     repeated because of the outstanding uncertainties it considers
     arise from it. (From: "NLP Wessex" <nlpwessex@bigfoot.com>, 19
     Nov 1999) In a way, this is a recognition by the Royal Society
     that Pusztai's work deserves to be taken seriously, a reversal of
     their earlier condemnation of Pusztai's work.

          - The concern of pediatric neurologist Dr. Martha Herbert of
     the Council for Responsible Genetics is "the immature gut and
     immature body of infants." If introduced too early, even proteins
     that are normally part of our diet can lead to auto-immune and
     allergic reactions later on, she said. "If a substance harms
     adults, it may well harm babies, the sick and the elderly more
     severely, and after smaller exposures," Dr. Herbert warned in her
     June 1999 statement. (See: ) <http://>

          + BT: The Bt formulation has been in use as a biopesticide
     for decades and is not considered harmful to human beings. It is
     one of the few insecticides that organic farmers are allowed to
     use.

          - BT: The Bt biopesticide is relatively safe, compared to
     chemical pesticides, but it is not completely safe. The dried Bt
     spores, for instance, may be harmful to the human immune system.
     French scientists at le Bouchet army research labs found that the
     spores caused lung inflammation, internal bleeding and death in
     lab mice. Last year, French scientists isolated a Bt strain that
     destroyed tissue in the wounds of a French soldier in Bosnia. The
     strain, known as H34, also infected wounds in immuno-suppressed
     mice. Now the same team has found that H34 can kill mice with
     intact immune systems if they inhale the spores. Francoise
     Ramisse of le Bouchet and her colleagues found that healthy mice
     inhaling 108 spores of Bt H34 died within eight hours from
     internal bleeding and tissue damage. (See: New Scientist, 29 May
     1999)

          + BT: Spores from mutants of the Bt H34 strain which did not
     produce the toxin were equally lethal to mice, suggesting that
     the Bt toxin was not to blame. Researchers think the symptoms are
     caused by other toxins. The bacterium's close cousin, Bacillus
     cereus, produces a toxin that ruptures cell membranes. And in
     1991, Japanese researchers showed that B. thuringiensis produces
     the same toxin. (See: New Scientist, 29 May 1999)

          + BT: Since the natural Bt toxin is relatively safe, then
     the GE-toxin in corn is safe too.

          - BT: The Bt corn toxin is not identical to the natural
     toxin. The natural Bt gene which produces the toxin was
     substantially modified before it was transferred to corn. The
     toxin gene in Bt corn is a truncated version (at both 5' and 3'
     ends) of the Bt toxin and is the smallest fragment that still
     possesses toxicity to insects. (See: M. Vaeck et al. Nature 328,
     33-37, 1987, as cited by Heine Deelstra).

          * BT: Why is it a bad thing if they are not identical?

          - BT: This means that, unlike the natural Bt toxin, the Bt
     corn toxin has never existed in nature, until Bt corn started
     synthesizing it. It is risky to put into our gut any substance
     which our gut has never seen before, because we have not evolved
     to handle such a substance. In our experience with synthetic
     chemicals, this has led to various long-term problems like
     cancers.

          + BT: The Bt natural gene produces a large, inactive
     pro-toxin that is about 1200 amino acids in length. This
     pro-toxin releases upon digestion by proteases (in the insects
     gut) an active 68,000 Dalton fragment. So the pro-toxins of
     plants and Bt may differ in length, while the active toxic
     fragment is exactly the same in size and mode of action.
     Truncation of sequences before and after the 'toxic fragment'
     might affect, due to folding differences, (1) the crystallisation
     properties and (2) the susceptibility to proteases of the
     pro-toxin. The occurrence of (1) and/or (2) are not known to me.
     (Heine J. Deelstra <h.j.deelstra@bioledu.rug.nl>, on GENTECH
     list)

          - BT: The Bt corn toxin is up to 100 times more powerful
     than the natural toxin. This is part of the high-dose strategy
     which supposedly delays the development of resistance in corn
     borers. However, such high doses may also be riskier to
     non-target species, including human beings who ingest the toxin
     when they eat Bt corn.

          - BT: The expression of the full-length [Bt] toxin was too
     low to achieve pest resistance in plants other than tobacco
     (against the tobacco hornworm) and tomato plants. Toxin levels
     were so low that protection was not attained against less
     sensitive, but agronomically-important insect pests. Researchers
     then modified part of the Bt toxin coding sequence so that it was
     efficiently expressed (and translated) in plants. This was done
     by using a synthetic toxin gene for amino acids 1-453 (coding for
     the same amino acids as the natural Bt toxin gene but using
     codons preferred by plants) and fusing this with the (natural)
     gene fragment encoding for amino acids 454-615. The rest of the
     bacterial gene (amino acids 616-1178) was not used. Expression of
     this gene in cotton plants showed that Bt toxin levels were
     increased by 100 times and that Bt toxin constituted 0.02% of the
     protein in the plant. (See: Recombinant DNA, 2nd edition by James
     D. Watson et al. and Moleculaire Biologie van Schimmels en
     Planten (in Dutch), 1998 by Prof. J.G.H Wessels, as cited by
     Deelstra)

          - The genetically engineered sweetener Aspartame has caused
     thousands of documented disease cases worldwide. (From:
     pmligotti@earthlink.net)

2.1.4. CLAIM: GE-FOODS DO NOT CAUSE CANCER

          - HT: Since herbicide-resistant GE-crops lead to greater
     herbicide use, cancer risk can also come from exposure to higher
     levels of herbicides like bromoxynil (Rhone-Poulenc's Buctril)
     and glyphosate (Monsanto's Roundup). Authors Marc Lappe and Britt
     Bailey (Against the Grain, 1998) warn that bromoxynil
     bioaccumulates, because it is fat-soluble. Rat and rabbit studies
     have shown birth defects, other developmental disorders in
     fetuses, tumors, and carcinomas at levels ranging from 20 to 300
     parts per million. (See: Lappe, Marc and Britt Bailey; Against
     the Grain, 1998) (http:)

          - HT: Glyphosate exposure, on the other hand, can triple the
     risk of non-Hodgkin's lymphoma, say cancer specialists Dr.
     Lennart Hardell and Dr. Mikael Eriksson of Sweden's Orebro
     Hospital, in a study published in the American Cancer Society
     journal (See: Cancer, 3/15/99) (http:)

          - RBGH: U.S. food campaigner Robert Cohen warns about the
     hormone Insulin-like Growth Factor-1 (IGF-1), identical versions
     of which occur in cows and humans. In 1994, Cohen says, the U.S.
     FDA approved the use of a GE-hormone (rBGH) in cows to stimulate
     milk production. Using rBGH raises IGF-1 levels in cows' milk by
     80%. IGF-1, Cohen warns, is a key factor in prostrate cancer
     (Science, 1/98), breast cancer (The Lancet, 5/98), and lung
     cancer (Journal of the NCI, 1/99). Most recently, Cohen cites a
     report in the Journal of the American Dietetic Association
     (10/99, p.1231), which found IGF-1 levels in the blood of milk
     drinkers 10% higher than in non-drinkers. The implication:
     GE-milk exposes its drinkers to higher cancer risks. (See: )

          - RBGH: On December 15, 1998, the Center for Food Safety, on
     behalf of a broad coalition, filed a legal petition in
     Washington, D.C. against the FDA to have rBGH taken off the
     market. The CFS petition cites mounting evidence that the
     original testing of rBGH was flawed. In 1990 the FDA said BGH was
     "safe for human consumption." Part of its findings were based on
     90-day rat feeding studies in which they reported "no
     toxicologically significant changes..." Based largely on this
     conclusion, FDA did not require human toxicological tests usually
     required for a veterinary drug. However in April 1998,
     researchers from Health Canada, the Canadian equivalent to FDA,
     issued a report contradicting FDA's findings. Canadian
     researchers found studies showing that rats were absorbing rBGH
     after all. In fact, between 20 and 30 percent of the rats were
     developing distinct immunological reactions. Additionally, cysts
     formed in the thyroid of some male rats and infiltrated the
     prostate - both warning signs for potential cancer hazards.

          - RBGH: Milk from cows injected with rBGH, which is not
     analogous to normal BGH (7), has elevated insulin-like growth
     factor that is implicated as a risk factor in human breast cancer
     (8,9). (See: "Will genetically engineered crops mean adulterated
     and toxic food, bodies, and ecosystems?", Michael W. Fox, Senior
     Scholar/ Bioethics, The Humane Society of the United States 2100
     L Street, NW Washington, DC  20037)

          - RBGH: The EU Scientific Committee on Animal Health and
     Animal Welfare on Animal Health Aspects of the Use of Bovine
     Somatotropin, rBST, (adopted March 10th 1999) has recommended
     that, due to foot problems, mastitis and injection site reactions
     in dairy cows, rBST from an animal welfare and health point of
     view, should not be used. This is an important recommendation
     given the upcoming vote on rBST in International Trade.

          - RBGH: At the previous 22nd Codex session, the Codex
     Alimentarius Commission decided to suspend the consideration of
     Maximum Reside Limits for rBGH. The reason for the suspension was
     so that scientific data could be re-evaluated. Since then, there
     has been more evidence that rBGH is not safe. The 23rd Session of
     the Codex Alimentarius Commission was held in Rome, June 28 -
     July 3, 1999. Since the U.S. realized that they were not going to
     win on this issue, they essentially dropped it.

          + These examples are not due to the effect of GE but rather
     the use of the chemicals or hormones.

          - HT:/RBGH: But the higher cancer risks are the consequence
     of GE products (more herbicide residues in food, higher IGF-1
     levels in milk, etc.). People would not have been exposed to
     these risks if HT crops or rBGH had not been developed.

2.1.5. CLAIM: GE-FOODS DO NOT GIVE RISE TO PATHOGENS

          - "The evidence is now overwhelming that horizontal gene
     transfer has been responsible for both the rapid spread of
     antibiotic resistance and for the emergence of virulent strains
     of pathogens in recent years... One main contributing factor to
     the recent increase in the scope and frequency of horizontal gene
     transfers may be the deliberate acts of genetic engineers to
     break down species barriers. They do so by constructing a range
     of chimaeric vectors for cloning, and transferring genes... Thus,
     genetic engineering biotechnology has opened effectively opened
     up highways for horizontal gene transfer and recombination, where
     previously, there was only restricted access through narrow,
     tortuous footpaths." (See: Mae Wan-Ho, Terje Traavik, Orjan
     Olsvik, Tore Midtvedt, Beatrix Tappeser, C. Vyvyan Howard,
     Christine von Weizsaecker, and George C. McGavin; Gene Technology
     in the Etiology of Drug-resistant Diseases, 1998.

          + Their conclusion is unsupported by there data; no recent
     increase of transfer has been observed.

          - In May 1999, the British Medical Association, which
     counts some 80% or nearly 115,000 of Britain's medical doctors,
     issued an official statement in May 1999 expressing concern over
     the safety of GE-foods. The BMA recommended a moratorium on
     planting commercial GE-crops in the UK "until there is scientific
     consensus (or as close agreement as reasonably achievable) about
     the potential long-term environmental effects." The BMA also
     called for 1) segregation at source, "to enable identification
     and traceability" of GE-foods; 2) labelling GE-imports and
     banning unlabelled ones, if the industry refuses to segregate;
     and 3) more robust systems of disease surveillance, to deal with
     "potential emergence of new diseases associated with GM material
     which will be obscure and difficult to diagnose". (See: "The
     Impact of Genetic Modification on Agriculture, Food and Health",
     British Medical Association, May 1999)

          - Mae Wan-Ho and Angela Ryan of the UK Open University
     warned last July 1999 that "no transgenic plant containing the
     CaMV promoter should be released," because the Cauliflower Mosaic
     Virus (CaMV) promoter is "very likely to recombine with other DNA
     in the host genome, including dormant viral DNA, as well as with
     other viruses in the host cell." The problem covers practically
     all GE-plants released so far. These GE-plants, according to
     Ryan, "have the potential to create new viruses or other invasive
     genetic elements." (See: )

          - There is potential for vector recombination to generate
     new virulent strains of viruses, especially in transgenic plants
     engineered for viral resistance with viral genes. In plants
     containing coat protein genes, there is a possibility that such
     genes will be taken up by unrelated viruses infecting the plant.
     In such situations, the foreign gene changes the coat structure
     of the viruses and may confer properties such as changed method
     of transmission between plants. The second potential risk is that
     recombination between RNA virus and a viral RNA inside the
     transgenic crop could produce a new pathogen leading to more
     severe disease problems. Some researchers have shown that
     recombination occurs in transgenic plants and that under certain
     conditions it produces a new viral strain with altered host
     range. (Steinbrecher, R.A. (1996) From Green to Gene Revolution:
     the environmental risks of genetically engineered crops. The
     Ecologist 26, 273-282. As cited in: "Ten reasons why
     biotechnology will not ensure food security, protect the
     environment and reduce poverty in the developing world"; Miguel
     A. Altieri, UC Berkeley and Peter Rosset, Institute for Food and
     Development Policy, Oakland, CA)

          - The Cauliflower Mosaic Virus (CaMV) and HIV have
     interchangeable components, according to five researchers of the
     John Innes Centre and Sainsbury Laboratory (UK). (See John Innes
     Centre Annual Report, 1998/1999) If they meet in nature, they
     could recombine to form chimeric viruses with potentially
     devastating properties. (jcummins@julian.uwo.ca, 6 Nov 1999) This
     can happen, for instance, if pollen from a GE plant is inhaled by
     an HIV-positive or AIDS-stricken person.

          - The 1999 UK John Innes Centre and Sainsbury Laboratory
     Annual report specifically acknowledges that this particular
     viral promoter is prone to 'recombination' events (see
     http://www.btinternet.com/~nlpwessex/Documents/camv.htm for more
     information).

          - One must consider not only the "fate" of GMOs but also the
     genes and viruses or parts thereof, that have been inserted into
     them. Such "naked DNA", in the form of recombinant and modified
     nucleic acids, has been found capable of surviving and remaining
     functional longer after organisms' death than was assumed
     previously.(6,30) Furthermore, xenobiotics, especially dioxins
     and various agrichemicals, can act as mutagens (31), altering the
     structure and sequence of DNA and also increasing the
     permeability of cells and the incorporation of foreign DNA into
     living organisms. (See: "Will genetically engineered crops mean
     adulterated and toxic food, bodies, and ecosystems?", Michael W.
     Fox, Senior Scholar/ Bioethics, The Humane Society of the United
     States 2100 L Street, NW Washington, DC  20037)

          - The use of the Cauliflower Mosaic Viral promoter (CaMV)
     has the potential to reactivate dormant viruses or create new
     viruses in all species to which it is transferred. CaMV is known
     to be found in practically all current transgenic crops released
     commercially or undergoing field trials. This transgenic
     instability increases the possibility of promotion of an
     inappropriate over-expression of genes to the transferred
     species. The development of cancer may be one consequence of such
     inappropriate over-expression of genes. The scientists behind the
     research "strongly recommend that all transgenic crops containing
     CaMV 35S or similar promoters which are recombinogenic should be
     immediately withdrawn from commercial production or open field
     trials. All products derived from such crops containing
     transgenic DNA should also be immediately withdrawn from sale and
     from use for human consumption or animal feed". (See: Mae-Wan Ho,
     Angela Ryan, and Joseph Cummins, "Cauliflower Mosaic Viral
     Promotor - A recipe for Disaster?", Microbial Ecology in Health
     and Disease (Dec 1999).

2.1.6. CLAIM: GE-FOODS DO NOT CAUSE ANTIBIOTIC-RESISTANCE

          - Many GE-foods contain antibiotic-resistance marker (ARM)
     genes. These genes can be acquired by harmful bacteria through
     horizontal gene transfer, making it more difficult to cure
     diseases.

          + There is very low probability that ARM genes in GE-plants
     can transfer to pathogenic bacteria.

          - In May 1999, The British Medical Association called for a
     "ban on the use of antibiotic resistance marker genes in GM food,
     as the risk to human health from antibiotic resistance developing
     in micro-organisms is one of the major public health threats that
     will be faced in the 21st Century." (See: "The Impact of Genetic
     Modification on Agriculture, Food and Health", British Medical
     Association, May 1999) (http:/)

          + Modified DNA quickly breaks down in the gut, so it cannot
     transfer antibiotic resistance

          - Using an "artificial gut", Dutch researchers showed that
     DNA remains intact for several minutes in the large intestine. If
     the GE bacteria were a type normally found in the gut, such as
     Enterococcus, the experiment showed each had a 1 in 10 million
     chance of passing DNA containing ARM genes to an native gut
     bacterium when they came in contact. There are normally around a
     thousand billion gut bacteria, suggesting that many would be
     transformed. If some normal gut bacteria were killed off - as in
     the guts of people or animals in antibiotics - the transfer rate
     from gut-type bacteria increased tenfold. (See: New Scientist, 30
     Jan 1999)

          - Safer New Screen for GM Crops: Rockefeller University and
     University of Singapore researchers can now screen for GM crops
     without having to insert an ARM gene. The new method, described
     in Nature, uses a gene that enhances a plant's use of its own
     growth hormones. (Irish Times, 13 Sep 1999) If ARM genes are
     safe, why are so much research funds being spent looking for
     alternatives to these genes?

          + Because plants with ARM genes won't sell, that's why.

          - They won't sell because medical doctors, like members of
     the British Medical Association, have warned against their
     dangers.

          - Countries which have banned the use of ARM genes: Norway

          - Countries where a ban on the use of ARM genes has been
     proposed: Europe (See:)

2.1.7. CLAIM: GE-FOODS DO NOT AFFECT OUR IMMUNE SYSTEM

          - Twenty two leading scientists recently declared that
     animal test results linking GE foods to immuno-suppression are
     valid. (NYTimes full page ad, 18 Oct 1999)

2.1.10. OTHERS

          -  HT: Lappe and Bailey also noted the "remarkably high
     estrogenic activity of soy isoflavones," elevated levels of which
     have been found in herbicide-treated GE-soya. "If ingested by
     nursing infants, these isoflavones can produce circulating levels
     equivalent to 13,000 to 22,000 times the normal plasma estradiol
     concentrations found in babies, with unknown and potentially
     dangerous secondary effects," they warned. Early exposure to
     estrogens, they wrote, is associated with sex organ dysfunctions
     and higher risks of vaginal adenocarcinoma and other tumors.
     (See: Lappe, Marc and Britt Bailey; Against the Grain, 1998)

          + HT: On the isoflavone statement reread
     http://www.gene.ch/gentech/1999/Jul-Aug/msg00200.html (From: "H J
     Deelstra" <H.J.Deelstra@bioledu.rug.nl>)

          - The Scottish Crop Research Institute and the University of
     Dundee, reported that the snowdrop lectin (the same lectin
     Pusztai used in his GE-potato study) can bind with human white
     blood cells, raising questions about safety of the lectin itself.
     (See: The Lancet, Oct 1999) (http:)

2.2. CLAIM: GE-CROPS DON'T HARM THE ENVIRONMENT

          - Summary: Once released into the environment, live GE
      organisms will be practically impossible to recall and will be a
      permanent source of genetic contamination and pollution. We
      therefore oppose field releases, including field-testing, of
      live GE organisms.

2.2.1. CLAIM: GENETIC CONTAMINATION (ESCAPE AND SPREAD) CAN BE AVOIDED

          + Pollen does not travel very far. Isolation distances of
     50-100 meters will prevent any genetic contamination.

          - Pollen can be carried by wind, bees and other insects,
     birds, and other pollinators. Animals can eat seeds and then
     travel long distances. Their droppings can contain viable seeds.
     People can inadvertently transport seeds hundreds or even
     thousands of kilometers from the source.

          - Studies in Denmark, Scotland and Lower Saxony in Germany
     have shown that GMO rapeseed can pass on its traits to, not only
     non-GMO rapeseed, but also weedy relatives up to 2.5 km away.
     This can lead to superweeds.

          - Research by the Scottish Crop Research Institute reported
     at the Gene Flow in Agriculture: Revelence for Transgeneic Crops
     Conference, Keele University April 1999 (British Crop Protection
     Council Symposium Proceedings No 72) reported oilseed rape pollen
     at 4km from a field of oilseed rape.

          - Scientists from the Scottish Crop Research Institute in
     Dundee have shown that as high as 7% of the natural rape plants
     in a field 400 meters away were pollinated by GM pollen. They
     said that oilseed rape pollen had been found 4 km away from the
     nearest source - further than it had been previously discovered.
     They said "bees may be important pollen vectors over a range of
     distances" and concluded that "the results suggest that
     farm-to-farm spread of OSR [oilseed rape] transgenes will be
     widespread." (See: New Scientist, April 1999)

          - The European Commission has formulated 5-point emergency
     plan if GE plants result in widespread illness or death of
     wildlife. The plan includes: 1) methods and procedures for
     controlling the GMOs in case of unexpected spread; 2) methods for
     decontamination of the areas affected and eradication of the
     GMOs; 3) methods for disposal or sanitation of plants, animals,
     soils, etc. exposed during and after the spread; 4) methods for
     isolating area affected by spread; and 5) plants for protecting
     human health and environment in case undesirable effects occur.
     (See: Independent, London, 4 Apr 1999)

          - Steve Jones (professor of genetics, University College,
     London): Those [transgenic] genes are going to get out into other
     plants. Everybody knows that. And we have no idea what is going
     to happen. (BBC, 12 Apr 1999)

          - Spontaneous hybrids and backcrosses occured between GE
     oilseed rape and its weedy relative, Brassica campestris, under
     field conditions (Jorgensen, R.B. and B. Andersen. 1994.
     Spontaneous hybridization between oilseed rape (Brassica napus)
     and weedy B. campestris (Brassicaceae): a risk of growing
     genetically modified oilseed rate. American Journal of Botany
     81:1620-1626, as cited by Kapuscinski 1999).

          - HT: Transgenic, herbicide-tolerant weed-like plants,
     exhibiting high fertility and the same morphology and chromosome
     numbers as in the weedy relative, were produced in field
     experiments where GE herbicide-tolerant interspecific hybrids
     were grown together with the weedy relative. (Mikkelsen, T.R.,
     Andersen, B. and R.B.Jorgensen. 1996. The risk of crop transgene
     spread. Nature 380:31, as cited by Kapuscinski 1999)

          - HT: Arabidopsis thaliana, weed species often used for GE
     studies, was found to be more prolific and promiscuous when
     genetically modified. This implies that GE can substantially
     increase the probability of transgene escape, heightening the
     risk of producing weedy or pest populations of wild relatives. In
     field studies, herbicide-resistant Arabidopsis thaliana produced
     by gene transfer of a resistance allele outcrossed to wild
     relatives roughly 20 times more often than ordinary mutants
     expressing the same mutant allele as the transgenic plants.
     (Bergelson, J., Purrington, C.B. and G. Wichmann. 1998.
     Promiscuity in transgenic plants. Nature 395: 25, as cited by
     Kapuscinski 1999)

          - "This is only the latest in a long list of field trials
     showing that genetically engineered crops, once released, are
     totally uncontainable. They will become a nightmare for
     conventional farmers to control. For farmers who do not want to
     grow them, such as the organic sector, these crops will be almost
     impossible to avoid." (Dr. Michael Antoniou)

          - John Innes Centre, one of Europe's leading research
     institute on GM crops, carried out research commissioned by the
     UK Ministry of Agriculture, Fisheries and Food. They reported: GE
     crops will "inevitably" contaminate organic crops. Pollen and
     seed pollution by GE crops could not be avoided entirely and
     "acceptable levels" of contamination would have to be set. They
     estimated that 1% of organically-grown plants in any one field
     could become GM hybrids because of pollen spread. They concluded
     that contamination by seed or pollen cannot be entirely
     eliminated. (BBC, 17 Jun 1999)

          - Scientists have found GM pollen in beehives nearly 5km
     from an official trial site, Friends of the Earth said today.
     These are the first published monitoring results of GM pollen
     from a farm-scale trial site and show GM pollen travelling
     further than ever previously detected. It also reveals the scale
     of the threat the trials pose to non-GM and organic farmers,
     beekeepers and the wider environment, said Friends of the Earth.
     The government's rules for farm-scale trials require only a
     50-metre separation between GM crops and other fields. (Amanda
     Brown, AAP, London, 30 Sep 1999)

          - Scientists have found GM oilseed rape pollen four and a
     half kilometres from a trial site. Friends of the Earth had
     contracted the National Pollen Research Unit at University
     College, Worcester to monitor airborne pollen on roads and public
     rights of way around the farm scale trial for spring oilseed rape
     at Model Farm, Pirton, Near Watlington, Oxfordshire in June and
     July 1999. Pollen traps were placed on six bee hives sited in the
     area. Two were 500 metres from the crop, two were 2.75 kilometres
     from the crop and two were 4.5 km. The pollen was collected and
     analysed by a bee and honey consultant, Sarah Brookes, of
     Evesham, Worcestershire. Six samples of airborne pollen and 6 of
     beehive pollen were sent to the laboratory of the Federal
     Environment Agency in Austria for DNA analysis. All six beehive
     samples were found to contain GM oilseed rape pollen from an
     AgrEvo variety and 2 out of 6 airborne samples. The Government's
     rules for the farm scale trials require only a 50 metre
     separation distance between GM crops and other fields. For seed
     crops and organic crops the recommended distance is 200m. The
     trial shows GM pollen at distances further than ever previously
     detected and shows the scale of the threat the trials pose to
     non-GM crops, beekeepers and the wider environment

          - HT: And scientists are finding that some GE crops, such
     as herbicide-resistant canola in Canada, are cross-pollinating
     with wild relatives more widely than had been predicted, creating
     hardy weeds that can survive herbicidal sprays. (See: Rick Weiss,
     Washington Post, 15 Aug 1999)
     <http://www.washingtonpost.com/wp-srv/health/daily/aug99/gmfood15.htm>

          + HT: Gary Barton (Monsanto's director of biotechnology
     communications): "Resistance can develop" but superweeds - hybrid
     plants resistant to herbicide - were not an issue since they
     could always be sprayed with other weedkillers to which they were
     not resistant. (See: Independent, London, 25 Apr 1999)

          - HT: The potential transfer through gene flow of genes
     from herbicide resistant crops to wild or semidomesticated
     relatives can lead to the creation of superweeds. (Lutman, P.J.W.
     (ed.) (1999) Gene flow and agriculture: relevance for transgenic
     crops. British Crop Protection Council Symposium Proceedings No.
     72. Stafordshire, England. As cited in: "Ten reasons why
     biotechnology will not ensure food security, protect the
     environment and reduce poverty in the developing world"; Miguel
     A. Altieri, UC Berkeley and Peter Rosset, Institute for Food and
     Development Policy, Oakland, CA)

          - HT: There is potential for HT varieties to become serious
     weeds in other crops (See: Duke l996, Holt and Le baron l990).
     (Duke, S.O. (1996) Herbicide resistant crops: agricultural,
     environmental, economic, regulatory, and technical aspects, p.
     420. Lewis Publishers, Boca Raton; See also: Holt, J.S. and H.M.
     Le Baron (1990) Significance and distribution of herbicide
     resistance. Weed Technol. 4, 141-149. As cited in: "Ten reasons
     why biotechnology will not ensure food security, protect the
     environment and reduce poverty in the developing world"; Miguel
     A. Altieri, UC Berkeley and Peter Rosset, Institute for Food and
     Development Policy, Oakland, CA)

          - A scientific report, carried out for the British
     government in 1997 but not published until now, concluded that GE
     oilseed rape could breed with ordinary farmers' crops and make
     them inedible. The study, conducted by the prestigious Scottish
     Crops Institute for the Ministry of Environment, says that
     contamination of farmers' ordinary fields is "inevitable" under
     current farming practices. (UK Sunday Independent, 21 Feb 1999)

          - Genetic contamination and pollution can occur through live
     DNA fragments.

          - There is evidence that foreign DNA can enter the body via
     the gastrointestinal tract and cross the placenta (1,2). (See:
     "Will genetically engineered crops mean adulterated and toxic
     food, bodies, and ecosystems?", Michael W. Fox, Senior Scholar/
     Bioethics, The Humane Society of the United States 2100 L Street,
     NW Washington, DC 20037)

          - STRAINS of farm-bred fish developed to grow fat quickly
     are threatening to drive Britain's majestic wild salmon into
     extinction. Millions of GM fish have escaped into the Atlantic
     from offshore farms in Europe and America. And the new strains
     are mating with wild salmon, polluting their gene pool and
     producing hybrids that can't survive in the open ocean. (Mail, 19
     Sep 1999)

          - Although the ecological risks issue has received some
     discussion in government, international, and scientific circles,
     discussions have often been pursued from a narrow perspective
     that has downplayed the seriousness of the risks.  (See: Kendall,
     H.W., R. Beachy, T. Eismer, F. Gould, R.  Herdt, P.H. Ravon, J
     Schell and M.S. Swaminathan (1997) Bioengineering of crops.
     Report of the World Bank Panel on Transgenic Crops, World Bank,
     Washington, D.C. p. 30; See also: Royal Society (1998)
     Genetically modified plants for food use. Statement 2/98, p. 16.
     London. As cited in: "Ten reasons why biotechnology will not
     ensure food security, protect the environment and reduce poverty
     in the developing world"; Miguel A. Altieri, UC Berkeley and
     Peter Rosset, Institute for Food and Development Policy, Oakland,
     CA)

          -- Dr. Norman Ellstrand (Professor of Genetics, University
     of California, one of the world's leading authorities in genetic
     engineering) on the economic implications for farmers of gene
     exchange between crops and weedy relatives: "We see this as a
     multi-million dollar problem. In Europe, there is already a big
     problem with gene flow between wild beet and cultivated beet.
     Oil-seed rape also has close relatives and is going to cause
     problems in the future. One would expect that the kind of genes
     that are now being engineered are going to be the ones that have
     a higher potentiality for causing trouble." (From: Protect
     Organic! Campaign jasonab@mediaone.net (617) 661-5609)

2.2.2. CLAIM: GE-CROPS REDUCE CHEMICAL USE

          + GE crops will reduce the use of herbicides, insecticides
     and other chemicals.

          + BT: Prakash of Tuskegee University points out that before
     Bt corn was introduced, farmers controlled the corn borer with
     conventional insecticide sprays that are toxic not only monarch
     butterfly larvae but also other desirable, non-target species
     like lady bugs. By cutting down on using these insecticides, Bt
     corn is a boon to beneficial species and the environment.
     "Ultimately the biggest benefit of biotech will be cultivating
     crops that use no herbicides, insecticides and fertilizers at all
     - and that even have nutrients and vaccines added, possibly at
     lower costs to consumers down the line," says Prakash.

          - BT: Corn farmers very seldom spray field corn for corn
     borers. Doing so will simply be a waste of money, because the
     borers are inside the corn stem, and can't be reached by the
     spray. Thus, using Bt corn does not really reduce chemical use.

          - HT: Crops engineered to be resistant to specific
     herbicides may encourage more liberal use of those herbicides.
     This has been anticipated by one manufacturer, who has applied to
     ANZFA (Australia-New Zealand Food Authority) to have the
     allowable residue of the herbicide glyphosate (Roundup) in foods
     sold in New Zealand increased by 200 times. In areas of the USA
     where GE-crops that produce their own insecticide are grown,
     pesticide use has not decreased. (See: "13 Myths about Genetic
     Engineering", Consumers for Education about Genetic Engineering,
     Dunedin Polytech, as posted by Deborah E Leech
     <dleech@mail.coin.missouri.edu> on the SANET list)

          - The British Medical Association urged that: the risk that
     GM crops may increase the use of herbicides and pesticides in the
     environment needs to be comprehensively assessed to determine
     their full environmental impact. (See: "The Impact of Genetic
     Modification on Agriculture, Food and Health", British Medical
     Association, May 1999)

          - Patent applications by Novartis of Basle, Switzerland
     imply the need for more pesticides to get the best out of GM
     plants. The applications (WO 99/35910 and WO 99/35913) were filed
     after Novartis scientists realised that a wide spectrum of insect
     pests was attacking Bt maize, its major GM crop. So they tried on
     the Bt maize different combinations of their pesticides. Their
     patent applications identify pesticide combinations that could
     raise maize yields by 20 per cent. The same pesticides appear to
     increase the yields of other GM plants, including herbicide-
     tolerant ones. So Novartis extended its patent applications to
     cover use of the pesticides on a long list of GM crops including
     maize, cereals, soya beans, potatoes, rice, cotton and mustard.
     Novartis' patent applications belie claims that GE crops will
     reduce pesticide use. (See: Andy Coghlan and Barry Fox, New
     Scientist, 18 December 1999)

          -- Section 1.5: "All materials and/or the products produced
     from genetically engineered/modified organisms (GEO/GMO) are not
     compatible with the principles of organic production (either the
     growing, manufacturing, or processing) and therefore are not
     accepted under these guidelines." (See: Codex Guidelines for the
     Production, Processing, Labelling and Marketing of Organically
     Produced Foods)
     <http://www.fao.org/WAICENT/FAOINFO/ECONOMIC/ESN/codex/default.htm>

2.2.3. CLAIM: GE-CROPS DO NOT HARM DIVERSITY

          - HT: The use of HT crops undermine the possibilities of
     crop diversification thus reducing agrobiodiversity in time and
     space. (Altieri, M.A. (1994) Biodiversity and Pest Management in
     Agroecosystems. Haworth Press, New York. As cited in: "Ten
     reasons why biotechnology will not ensure food security, protect
     the environment and reduce poverty in the developing world";
     Miguel A. Altieri, UC Berkeley and Peter Rosset, Institute for
     Food and Development Policy, Oakland, CA)

          - Ecological theory predicts that the large-scale landscape
     homogenization with transgenic crops will exacerbate the
     ecological problems already associated with monoculture
     agriculture. Unquestioned expansion of this technology into
     developing countries may not be wise or desirable. There is
     strength in the agricultural diversity of many of these
     countries, and it should not be inhibited or reduced by extensive
     monoculture, especially when consequences of doing so results in
     serious social and environmental problems. (Altieri, M.A. (1996)
     Agroecology: the science of sustainable agriculture. Westview
     Press, Boulder. As cited in: "Ten reasons why biotechnology will
     not ensure food security, protect the environment and reduce
     poverty in the developing world"; Miguel A. Altieri, UC Berkeley
     and Peter Rosset, Institute for Food and Development Policy,
     Oakland, CA)

          - The trend to create broad international markets for single
     products, is simplifying cropping systems and creating genetic
     uniformity in rural landscapes. History has shown that a huge
     area planted to a single crop variety is very vulnerable to new
     matching strains of pathogens or insect pests. Furthermore, the
     widespread use of homogeneous transgenic varieties will
     unavoidably lead to "genetic erosion," as the local varieties
     used by thousands of farmers in the developing world are replaced
     by the new seeds. (Robinson, R.A. (1996) Return to
     Resistance:breeding crops to reduce pesticide resistance.
     AgAccess, Davis. As cited in: "Ten reasons why biotechnology will
     not ensure food security, protect the environment and reduce
     poverty in the developing world"; Miguel A. Altieri, UC Berkeley
     and Peter Rosset, Institute for Food and Development Policy,
     Oakland, CA)

          - A single GM fish released into the wild could wipe out
     local populations of the original species, biologists warn in the
     New Scientist (4 Dec 1999). William Muir and Richard Howard of
     Purdue University, Indiana, studied fish carrying the human
     growth hormone gene (hGH), which increases growth rate and final
     size. US and British biologists are doing similar experiments
     with GE salmon. Muir and Howard put hGH in embryos of Japanese
     medaka, a common aquarium fish, which then matured faster and
     produced more eggs than normal fish, rapidly spreading the new
     gene. But only 2/3 of the GE medaka survived to reproductive age,
     which led the population to dwindle. In a computer model, 60 GE
     fish in a wild population of 60,000 fish, caused extinction
     within 40 generations. Even a single GE animal could lead to
     extinction, they found, but it would take longer. "You have the
     very strange situation where the least fit individual in the
     population is getting all the matings - this is the reverse of
     Darwin's model," says Muir. The researchers say this is the first
     evidence that GMOs could have catastrophic consequences on their
     own species. (See: Environmental News Service, 2 Dec 1999)

          - An aquarium fish, Japanese medaka (Oryzias latipes),
     modified with a growth gene hGH were more succesful in attracting
     mates. Thus the hGH gene spread rapidly through the population.
     However only 2/3 of the GE medaka survived to reproductive age
     compared with wild medakas. Thus the spread of the hGH gene could
     make populations dwindle and eventually become extinct. A
     computer model showed that releasing 60 GE fish into a wild
     population of 60,000 resulted in extinction in just 40
     generations. Even a single modified fish could also result in
     extinction, though over a longer period. The work may also apply
     to salmon who have similar mating preferences. (See: Proceedings
     of the National Academy of Sciences, vol 96, p 13 853)

2.2.4. CLAIM: THE DEVELOPMENT OF BT RESISTANCE CAN BE CONTROLLED

          + BT: Resistance will be controlled by using a high-dose
     strategy to kill all corn borers, and requiring farmers to plant
     20-40% of their fields with non-Bt corn, to provide susceptible
     pests who will mate with resistant pests

          - BT: Farmers find it ridiculous to be required to reserve
     20-40% of their crops as feed for pests they want to eliminate in
     the first place.

          - BT: In the earliest days of the debate, the suggested
     refugia size was 5%. Later, it rose to 10%. Now, it is 20-40%. If
     the trend continues, they will be suggesting a 100% non-Bt field
     soon, which is what we've been arguing for in the first place.

          - BT: The high-dose/refugia strategy can only work
     resistance is recessive and: i) dose should be very toxic so that
     all heterozygotes for resistance are killed; ii) resistance
     alleles are very rare; and iii) susceptible insects are within
     mating distance of resistant insects. ECB have been found to
     exhibit resistance to Bt toxin in a dominant way, which will
     hasten instead of retard the spread of resistance. (See: Science
     284: 965-967, 1999)

          - BT: F.Huang, L.L.Buschman (both with the Dept. of
     Entomology, Kansas State U) and W.H.McGaughey (USDA, Agric.
     Research Center Service, Grain Mktg & Prod. Research Center): ECB
     resistance to a Bt spray formulation (Dipel) appears to be
     inherited as an incompletely dominant autosomal gene. This
     contrasts with the resistance of other insects, which has been
     characterized as recessive. If it is not recessive, the
     usefulness of the high-dose/refugia strategy may be diminished.

          - BT: Dominant mutants conferring resistance to Bt toxin can
     be recovered from Corn Borers exposed to the toxin. Such mutants
     would spread like wildfire through corn fields with refuge plots
     because over half the off-springs of mating between  mutant and
     wild type insects would be resistant to Bt toxin. The refuge
     would provide a rich breeding ground for spread of the dominant
     mutants. (See: "Inheritance of resistance to Bacillus
     thuringiensis toxin (Dipel ES) in the European Corn Borer";
     Haung,F., Buschman,L., Higgins,R. and McGaugen,W., Science, 7 May
     1999:965-967, as cited by Joseph Cummins)

          - BT: Bt resistance has emerged among pink bollworms, a
     major cotton pest, in Arizona cotton fields. (See: California
     Farmer Magazine, mid-January 1999)

          - BT: When Monsanto and other companies took the naturally
     occurring insecticide bacterium Bt and spliced its operating
     mechanism into crops, organic farmers were concerned that insects
     would quickly become resistant to Bt, removing a crucial tool of
     environmentally sound farming only to serve corporate interests.
     These concerns are being borne out in last year's cropping
     trials. (See: "Wake-up call for biotech foods", Wisconsin State
     Journal, 22 Apr 1999)

          - BT: At the same time, recent studies have pointed to a
     variety of other problems that seem to be emerging from Bt corn.
     One report, for example, suggests that the EPA's primary strategy
     for preventing the emergence of Bt-resistant insects-a plan that
     calls for planting "refuges" of conventional corn in nearby
     fields-may be doomed to fail because Bt resistance genes in
     insects behave differently than scientists had thought. (See:
     Rick Weiss, Washington Post, 15 Aug 1999)
     <http://www.washingtonpost.com/wp-srv/health/daily/aug99/gmfood15.htm>

          - BT: Another study showed that Bt can alter the time it
     takes an insect to reach adulthood. That could dash the EPA's
     hopes that Bt-resistant insects will mate with Bt-susceptible
     ones and give birth to offspring still vulnerable to the
     chemical. (See: Rick Weiss, Washington Post, 15 Aug 1999)
     <http://www.washingtonpost.com/wp-srv/health/daily/aug99/gmfood15.htm>

          - BT: GM plants which produce their own insecticides
     closely follow the pesticide paradigm, which is itself rapidly
     failing due to pest resistance to pesticides. Instead of the
     failed "one pest-one chemical" model, GE emphasizes a "one
     pest-one gene" approach, shown over and over again in laboratory
     trials to fail, as pest species rapidly adapt and develop
     resistance to the pesticide present in the plant. (Alstad, D.N.
     and D.A. Andow (1995) Managing the Evolution of Insect Resistance
     to Transgenic Plants. Science 268, 1894-1896. As cited in: "Ten
     reasons why biotechnology will not ensure food security, protect
     the environment and reduce poverty in the developing world";
     Miguel A. Altieri, University of California, Berkeley and Peter
     Rosset, Institute for Food and Development Policy, Oakland, CA)

          - BT: Not only will the new GM varieties fail over the
     short-to-medium term, despite so-called voluntary resistance
     management schemes (Mallet, J. and P. Porter (1992) Preventing
     insect adaptations to insect resistant crops: are seed mixtures
     or refugia the best strategy? Proc. R. Soc. London Ser. B. Biol.
     Sci. 250. 165-169 As cited in: "Ten reasons why biotechnology
     will not ensure food security, protect the environment and reduce
     poverty in the developing world"; Miguel A. Altieri, UC Berkeley
     and Peter Rosset, Institute for Food and Development Policy,
     Oakland, CA), but in the process may render useless the natural
     pesticide "Bt," which is relied upon by organic farmers and
     others desiring to reduce chemical dependence.  Bt crops violate
     the basic and widely accepted principle of "integrated pest
     management" (IPM), which is that reliance on any single pest
     management technology tends to trigger shifts in pest species or
     the evolution of resistance through one or more mechanisms (NRC
     l996). (National Research Council (1996) Ecologically Based Pest
     Management. National Academy of Sciences, Washington DC. As cited
     in: "Ten reasons why biotechnology will not ensure food security,
     protect the environment and reduce poverty in the developing
     world"; Miguel A. Altieri, UC Berkeley and Peter Rosset,
     Institute for Food and Development Policy, Oakland, CA)

          - BT: When the product is engineered into the plant itself,
     pest exposure leaps from minimal and occasional to massive and
     continuous exposure, dramatically accelerating resistance.
     (Gould, F. (1994) Potential and Problems with High- Dose
     Strategies for Pesticidal Engineered Crops. Biocontrol Science
     and Technology 4, 451-461. As cited in: "Ten reasons why
     biotechnology will not ensure food security, protect the
     environment and reduce poverty in the developing world"; Miguel
     A. Altieri, UC Berkeley and Peter Rosset, Institute for Food and
     Development Policy, Oakland, CA)

          - BT: Bt will rapidly become useless, both as a feature of
     the new seeds and as an old standby sprayed when needed by
     farmers that want out of the pesticide treadmill. (Pimentel, D.,
     M.S. Hunter, J.A. LaGro, R.A. Efroymson, J.C. Landers, F.T.
     Mervis, C.A. McCarthy and A.E. Boyd (1989) Benefits and Risks of
     genetic Engineering in Agriculture.BioScience 39, 606-614. As
     cited in: "Ten reasons why biotechnology will not ensure food
     security, protect the environment and reduce poverty in the
     developing world"; Miguel A. Altieri, UC Berkeley and Peter
     Rosset, Institute for Food and Development Policy, Oakland, CA)

          + BT: Resistance has already been observed in Hawaii where
     dusts containing Bt spores were repeatedly applied onto the same
     field (up to 15X in one year). So, resistance development is not
     unique to GE.

          - BT: Expressing the Bt toxin in the plant is the fastest
     way to develop resistance, because it releases the toxin 24 hours
     a day, in all parts of the plant, whether there is infestation or
     not. This is like spraying daily whether there is a pest or not,
     or taking antibiotics daily, whether you are sick or not. If
     true, the Hawaii case stresses the need to use insect control
     measures sparingly, only when they are really needed.

2.2.5. CLAIM: BT IS NOT HARMFUL TO NON-TARGET SPECIES

          + BT: The Bt toxin will not harm non-target species.

          - BT: Iowa researchers have found Bt corn pollen deadly to
     monarch butterflies. First, the Iowa study determined the amount
     of corn pollen deposited on A. syriaca leaves within and adjacent
     to a Bt corn field at 0 m, 1m, and 3m. The highest levels of
     pollen deposition was found on plants within the corn field, and
     lowest levels found at three meters from the edge of the corn
     field. Leaf samples taken from within and at the edge of the corn
     field were used to assess mortality of first instar monarch, D.
     plexippus exposed Bt and non-Bt corn pollen. Within 48 hours,
     there was 19% mortality in the Bt corn pollen treatment compared
     to 0% on non-Bt corn pollen exposed plants and 3% in the no
     pollen controls. (See: "Non-target effects of Bt corn pollen on
     the Monarch butterfly (Lepidoptera: Danaidae)" by L. Hansen, Iowa
     State University, Ames , IA 50011 and J. Obrycki, Iowa State
     University, Ames, IA 50011. (Contact e-mail:
     lrahnsen@iastate.edu)

          - BT: Cornell University researchers, in a letter to the
     journal Nature, May 20 issue, reported that pollen from Bt corn
     harmed monarch butterfly larvae in laboratory tests. In the
     Cornell study, one group of monarch (Danaus plexippus)
     caterpillars fed on milkweed (Asclepias curassavica) leaves
     dusted with pollen from Bt corn, another group fed on milkweed
     leaves dusted with pollen from non-GE corn, and a third group fed
     on leaves without added pollen. The researchers found that the
     caterpillars that ate leaves with pollen from the Bt corn ate
     less, grew more slowly and died sooner. Results were similar to
     those reported earlier by Hansen and Obrycki
     (http://www.ent.iastate.edu/entsoc/ncb99/prog/abs/d81.html) who
     used leaves collected in corn fields. The Cornell researchers
     (Losey, Rayor and Carter, who can be contacted at
     jel27@cornell.edu) collected pollen and applied it to lab-raised
     milkweed leaves. (See: Losey, J.J.E., L.S. Rayor and M.E. Carter
     (1999) Transgenic pollen harms monarch larvae. Nature 399: 214)

          - BT: Concerns over impact on birds that feed on insects
     targetted by Bt crops like the skylark, linnet and corn bunting
     in the UK.

          - BT: Bt crops have a negative effect on Chrysoperla carnea,
     a beneficial insect, based on three studies by A. Hilbeck, M.
     Baumgartner, et. al. of the Swiss Federal Research Station for
     Agroecology and Agriculture. The green lacewings suffered
     reproductive problems and reduced longevity. (See: Hilbeck, A.,
     Baumbartner, M., Fried, P.M. and F. Bigler, 1998. Effects of
     transgenic Bt corn-fed prey on mortality and development time of
     immature Chrysoperla carnea (Neuroptera: Chrysopidae).
     Environmental Entomology 27:480-487, as cited by Kapuscinski
     1999))

          - BT: Still other studies suggest that Bt corn may be
     inadvertently killing beneficial insects such as ladybugs and
     lacewings, which eat insect pests. If true, then the insecticidal
     crops may be giving reprieves to as many insect pests as they are
     killing. (See: Rick Weiss, Washington Post, 15 Aug 1999)
     <http://www.washingtonpost.com/wp-srv/health/daily/aug99/gmfood15.htm>

          - BT: Beneficial insects that feed on insect prey reared on
     transgenic insect-resistant crops exhibited increased mortality
     and reduced developmental time (See: Birch, A N.E., Geoghegan,
     I.E., Majerus, M.E.N., Hackett, C., and J. Allen. 1996/7,
     Interactions between plant resistance genes, pest aphid
     populations and beneficial aphid predators. Scottish Crop
     Research Institute Annual Report, 1996/7: 68-72, as cited by
     Kapuscinski 1999) Researchers led by Dr. Nicholas Birch of the
     Scottish Crop Research Institute, Dundee, fed GE GNA potato to
     aphids, which were in turn fed to ladybird beetles. The
     ladybirds' lives were shortened by up to half the expected
     life-span, and their fertility and egg-laying was significantly
     reduced. Females were apparently affected more seriously than
     males and a change of diet to aphids not exposed to GE plants
     seemed to reverse the process. Potato aphids were fed to adult
     two-spot ladybirds for 12 days, before switching back to non-GE
     diet. Female ladybirds fed with GE-affected aphids died on the
     average after 36 days, compared with the 74 days of those in a
     control group fed on aphids not exposed to a GE diet. The study
     was published in the scientific journal Molecular Breeding. (See:
     Guardian, London, 4 Mar 1999)

          * Butterfly populations are at an almost 30-year low in the
     Sacramento Valley, adjacent foothills and the Sacramento-San
     Joaquin River Delta, researchers say. Entomologists find the data
     particularly worrisome because the decline is so widespread and
     there is no clear reason for it. Some species that typically are
     very common - including orange sulphur butterflies - have been
     almost absent in the region this year. A few varieties were up in
     numbers, but the overall trend was way, way down. ``In all
     candor, I don't understand this,'' said Arthur Shapiro, an
     entomologist at the University of California at Davis. ``Many
     more species are down than up. If this were the stock market,
     investors would be worried.'' Monarchs, large orange-and-black
     migratory butterflies that are among the most easily identified
     of insects, also declined. At Natural Bridges State Beach in
     Aptos (Santa Cruz County), where Northern California monarchs
     winter, 14,000 butterflies were counted, down from an average of
     about 60,000. Shapiro said there is no evidence linking
     California monarch declines with GM crops. Shapiro said there is
     no apparent reason for the decline. ``Pesticide use patterns
     haven't really changed and recent habitat loss hasn't been
     sufficient to account for this,'' he said. ``Nothing has really
     changed that can explain these oddities, unless something subtle
     is going on that has finally reached a threshold level.'' (Glen
     Martin, San Francisco Chronicle, 22 December 1999)
     <http://www.commondreams.org/>

          - Shapiro's response in the above case of crashing
     butterfly populations shows how some scientists can totally miss
     the obvious. Bt toxin kills lepidopterans, butterflies are
     lepidopterans. Since 1997, millions of acres of field have been
     planted with Bt corn. How can Shapiro say that "there is no
     evidence" linking these declines to GM crops, or that "nothing
     has really changed that can explain these oddities"? At least,
     he should point out the Bt crops are one possible cause, and this
     should be explored further.

2.2.6. CLAIM: GE-CROPS HAVE NO HARMFUL EFFECT ON SOIL ECOLOGY

          + BT: Bt toxin from GE-plants is very short-lived in soil
     (Eric Sachs of Monsanto, in response to a question re impacts of
     Bt corn on soil microbial community, 18 Jun 1999 EPA-USDA Bt corn
     workshop, as cited by Charles Benbrook)

          - BT: GE crops are building up Bt toxins in the soil,
     damaging the soil food web and harming beneficial insects. (Gene
     Exchange, Union of Concerned Scientsts, Fall/Winter 1998)

          - BT: New York University researchers found out that unlike
     natural Bt toxin, the active toxin produced by Bt crops do not
     disappear when added to soil, but become rapidly bound to soil
     particles, and are not broken down by soil microbes. The
     researchers contend that these GE Bt toxins can build up in the
     soil, killing Bt-sensitive soil organisms and increasing
     selection pressure for resistance to develop. In addition, a
     broader range of organisms is likely to be susceptible to the
     active, GE toxins. (See: Seedling, Mar 1999, Vol 16 No 1)

          - BT: "Bound humic acid-toxin complexes were toxic to larvae
     of the tobacco hornwork (Manduca sexta). The lethal concentration
     necessary to kill 50% of the larvae (LC50) of the bound toxin was
     comparable with that of the free toxin, indicating that the
     binding of the toxin to humic acids did not affect insecticidal
     activity... The result of these studies indicate that the toxins
     from B. thuringiensis introduced in transgenic plants and
     microbes could persist, accumulate, and remain insecticidal in
     soil as a result of binding to humic acids, as well as on clays,
     as previously described. This persistence could pose a hazard to
     non-target organisms and enhance the selection of toxin-resistant
     target species." (See: C.Crecchio and G.Stotzky 1998.
     Insecticidal activity and biodegradation of the toxin from
     Bacillus thuringiensis subsp. Kurstaki bound to humic acids from
     soil. Soil Biol. Biochem. 30: 463-470). See also: J. Koskella and
     G. Stotzky, "Microbial Utilization of Free and Clay-Bound
     Insecticidal Activity after Incubation with Microbes," Applied
     and Env. Microbiology, Sep 1997: 3561-3568. See further: H. Tapp
     and G. Stotzky, "Persistence of the Insecticidal Toxin from Bt
     subsp. Kurstaki in Soil," Soil Biology and Biochemistry, Vol 30
     No 4 1998: 471-476.)

          - BT: Bt toxin present in crop foliage plowed under after
     harvest can adhere to soil colloids for up to 3 months,
     negatively affecting the soil invertebrate populations that break
     down organic matter and play other ecological roles. (See:
     Donnegan, K.K., C.J. Palm, V.J. Fieland, L.A. Porteous, L.M.
     Ganis, D.L. Scheller and R.J. Seidler (1995) Changes in levels,
     species, and DNA fingerpr