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 fingerprints of soil micro organisms associated
     with cotton expressing the Bacillus thuringiensis var. Kurstaki
     endotoxin. Applied Soil Ecology 2, 111-124. 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) (See also: Palm, C.J.,
     D.L. Schaller, K.K. Donegan and R.J. Seidler (1996) Persistence
     in Soil of Transgenic Plant Produced Bacillus thuringiensis var.
     Kustaki (-endotoxin. Canadian Journal of Microbiology (in press).
     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: DNA released from living and dead cells can persist in
     the environment and be transferred to other organisms. An
     organism may be dead, but its "naked" DNA released from decaying
     cells may remain biologically active for potentially thousands
     years, especially in certain soils and marine sediments. (30)
     Naked DNA (nucleic acids) ingested by mice can be transferred to
     offspring and be voided and spread in animals' feces.  (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)

          - BT: Studies Note Risks of GM Plants: Dr. Guenther
     Stotzky, soil microbiologist at New York University, has found
     that Bt toxin in the soil, as it might be found after a crop is
     plowed under, can remain active for at least eight months. "We
     were surprised," Dr. Stotzky said. "I'm sure it hangs around
     longer. We just terminated the experiment after eight months."

          - Ethanol-producing GE microbes had adverse effects on wheat
     plants grown on sandy soil (Holmes, M.T., Ingham, E.R. Doyle,
     J.D. and C.W.Hendricks. 1998. Effects of Klebsiella planticola
     SDF20 on soil biota and wheat growth in sandy soil. Applied Soil
     Ecology 326:1-12, as cited by Kapuscinski 1999)

          - BT: The Dec. 2 issue of the scientific journal Nature
     <http://www.nature.com/server-java/Propub/nature/402480A0.pdf>
     describes a study which indicates that Bt toxins from GE crops
     are leaching into the soil through the plants' root systems,
     damaging or killing beneficial soil microorganisms, and
     disrupting the soil food web. The report also documents that Bt
     toxins bind with soil particles for up to 243 days and remain
     toxic to soil insects for long periods of time. This study comes
     in the aftermath of other research indicating a hazardous buildup
     of Bt toxins in the soil after Bt crops are plowed under. The
     Nature study fuels the fire of a growing movement to ban all Bt
     crops because of their documented damage to the environment and
     their threat to organic agriculture. Last February the Center for
     Food Safety, Greenpeace, and the International Federation of
     Organic Agriculture Movements filed a lawsuit in US Federal Court
     to force all Bt crops off the market. See: <http://www.icta.org>
     (Organic View, Vol. 1 No. 18, 8 Dec 1999)

           - BT: Dr. Charles Benbrook (former member of the National
     Academy of Sciences and head of Benbrook Consulting Services):
     "What goes on underground in a field planted with today's Bt-corn
     varieties is largely a mystery. Enhance the toxin levels 100- to
     1,000-fold and it becomes a mystery of some consequence and
     immediacy." (Organic View, Vol. 1 No. 18, 8 Dec 1999)

2.2.10. OTHERS

2.3. CLAIM: GE RISKS CAN BE MANAGED THROUGH USUAL RISK ASSESSMENT

2.3.1 CLAIM: WE HAVE ASSESSED THE RISKS FROM GE-CROPS AS MINIMAL

          - In fact methods for risk assessment of transgenic crops
     are not well developed. (Kjellsson, G and V. Simonsen (1994)
     Methods for risk assessment of transgenic plants, p. 214.
     Birkhauser Verlag, Basil. 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)

          - There is also justifiable concern that current field
     biosafety tests tell little about potential environmental risks
     associated with commercial-scale production of GE crops. (See:
     "Ten reasons why biotechnology will not ensure food security,
     protect the environment and reduce poverty in the developing
     world"; Miguel A. Altieri and Peter Rosset, Oct 1999)

          + The benefits of GE outweigh the risks.

          - Assessing risk means to anticipate the various potentially
     harmful events that can occur, and totaling the probability of
     each event multiplied by the consequence of that event. This
     means an event of low probability can still be very risky if its
     consequences are very serious. For GE organisms, we still lack
     the knowledge to anticipate many of the harmful events, or to
     measure their probability or consequences.

          - Richard Lewontin, Professor of Genetics at Harvard
     University: "We have such a miserably poor understanding of how
     the organism develops from its DNA that I would be surprised if
     we don't get one rude shock after another." (See: "13 Myths about
     Genetic Engineering", Consumers for Education about Genetic
     Engineering, Dunedin Polytech)
 
          - Funds for research on environmental risk assessment are
     very limited. For example, the USDA spends only 1% of the funds
     allocated to biotechnology research on risk assessment, about
     $1-2 million per year. Given the current level of deployment of
     GE plants, such resources are not enough to even discover the
     "tip of the iceberg". (See: "Ten reasons why biotechnology will
     not ensure food security, protect the environment and reduce
     poverty in the developing world"; Miguel A. Altieri and Peter
     Rosset, Oct 1999)

          - Risks increase as the GE organisms that carry them
     multiply. Unlike oil spills, chemical releases or nuclear leaks,
     which eventually dissipate, living GE organisms reproduce and
     multiply, and they cannot be recalled once released.

          - The British Medical Association urged that: the
     precautionary principle should be applied in developing GM crops
     or foodstuffs, as we cannot at present know whether there are any
     serious risks to the environment or to human health involved in
     producing GM crops or consuming food products. (See: "The Impact
     of Genetic Modification on Agriculture, Food and Health", British
     Medical Association, May 1999)

          + There is no such thing as zero risk or 100% safety.
     Everything involves some risk.

          - We are not looking for zero risk or 100% safety. But we
     must first objectively assess the actual risk from a GE product,
     so that the public or whoever will be at risk can decide for
     themselves if they want to be exposed to that risk or not. This
     decision cannot be made the scientists or experts alone. Risk is
     the product of the probability of an event and the cost of its
     consequences, if it occurs. Today, we do not know enough about
     the potentially harmful events that can occur from GE products,
     nor their probability of occuring or the cost of their occurence.
     We simply know very little today. This justifies holding off
     field releases until the public has enough information to decide.

2.3.2. CLAIM: GE IS LIKE ANY OTHER TOOL WHOSE RISKS CAN BE MANAGED

          - GE is not like any other tool. It is a technology of
     incredible power to disrupt the very basis of life on Earth. Most
     risk assessments assume well-intentioned genetic engineers. Very
     little public debate has occurred regarding the risks associated
     with GMOs that may be created by ill- or evil-intentioned
     technologists with access to typical university biotech labs.

          - Joseph Rotblat, the British physicist who won a 1995 Nobel
     Prize: "My worry is that other advances in science may result in
     other means of mass destruction, maybe more readily available
     even than nuclear weapons. Genetic engineering is quite a
     possible area, because of these dreadful developments that are
     taking place there." (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)

2.3.10. OTHERS

2.10. OTHERS

3.   SCIENTIFIC CLAIMS: GE TECHNOLOGIES ARE BASED ON SOUND SCIENCE

3.1. CLAIM: THERE IS SCIENTIFIC CONSENSUS ON THE SAFETY OF GE PRODUCTS

          - There is no scientific consensus at all. In fact, the
     scientific debate on various issues has intensified, with some
     scientists insisting that GE crops are safe, other scientists
     insisting that we do not know for sure at this time because of
     lack of scientific studies, and an increasing number of
     scientists insisting they are not safe.

          - Statement by scientists: We, the undersigned scientists,
     call for the immediate suspension of all environmental releases
     of GM crops and products; for patents on life-forms and living
     processes to be revoked and banned; and for a comprehensive
     public enquiry into the future of agriculture and food security
     for all. ... The hazards of GM crops and products to biodiversity
     and human and animal health are now becoming apparent, and some
     even acknowledged by sources within the UK and US Governments. In
     particular, the horizontal spread of antibiotic resistance marker
     genes from GM crops will compromise the treatment of
     life-threatening infectious diseases which have come back
     worldwide. New findings show that the horizontal spread of
     transgenic DNA can occur, not only by ingestion but via breathing
     in pollen and dust. The cauliflower mosaic viral promoter, widely
     used in GM crops, may enhance horizontal gene transfer and has
     the potential to generate new viruses that cause diseases.
     (Signed: 231 scientists from 31 countries, 14 Dec 1999)
     <http://www.i-sis.dircon.co.uk>

          - Here are some highly respected scientists who have taken a
     position against GE and its risks:

          -- Professor Richard Lacey, microbiologist, medical doctor,
     and Professor of Food Safety at Leeds University has become one
     of the best-known figures of food science since his prediction of
     the BSE (mad cow disease) crisis, made more than seven years ago.
     Recently Professor Lacey has spoken out strongly against the
     introduction of genetically engineered foods, because of the
     essentially unlimited health risks." "The fact is, it is
     virtually impossible to even conceive of a testing procedure to
     assess the health effects of genetically engineered foods when
     introduced into the food chain, nor is there any valid
     nutritional or public interest reason for their introduction."
     (From: Protect Organic! Campaign jasonab@mediaone.net (617)
     661-5609)

          -- Professor Mae-Wan Ho of the UK Open University Department
     of Biology says, "Genetic engineering bypasses conventional
     breeding by using artificially constructed parasitic genetic
     elements, including viruses, as inside cells. These vectors slot
     themselves into the host genome. The insertion of foreign genes
     into the host genome has' long been known to have many harmful
     and fatal effects including cancer of the organism." (From:
     Protect Organic! Campaign jasonab@mediaone.net (617) 661-5609)

          -- Professor Dennis Parke of University of Surrey School of
     Biological Sciences, a former chief advisor on food safety to
     Unilever Corporation and British advisor to the US FDA on safety
     aspects of biotechnology writes: "In l98 hundreds of people in
     Spain died after consuming adulterated rapeseed (canola) oil.
     This adulterated rapeseed oil was not toxic to rats." Dr. Parke
     warns that current testing procedures for genetically altered
     foods including rodent tests- are not proving safety for humans.
     He has suggested a moratorium on the release of genetically
     engineered organisms, foods, and medicines. (From: Protect
     Organic! Campaign jasonab@mediaone.net (617) 661-5609)

          -- Dr. Peter Wills, theoretical biologist at Auckland
     University writes "Genes encode proteins involved in the control
     of virtually all biological processes. By transferring genes
     across species barriers which have existed for eons between
     species like humans and sheep we risk breaching natural
     thresholds against unexpected biological processes. For example,
     an incorrectly folded form of an ordinary cellular protein can,
     under certain circumstances, be replicative and give rise to
     infectious neurological disease."' (From: Protect Organic!
     Campaign jasonab@mediaone.net (617) 661-5609)

          -- Dr. Joseph Cummins, Professor Emeritus of Genetics at the
     University of Western Ontario warns: "Probably the greatest
     threat from genetically altered crops is the insertion of
     modified virus and insect virus genes into crops. It has been
     shown in the laboratory that genetic recombination will create
     highly virulent new viruses -from such constructions'. Certainly
     the widely used cauliflower mosaic virus is a potentially
     dangerous gene. It is a pararetrovirus meaning that it multiplies
     by making DNA from RNA messages. It is very similar to the
     Hepatitis B virus and related to HIV. Modified viruses could
     cause famine by destroying crops or cause human and animal
     diseases of tremendous power." (From: Protect Organic! Campaign
     jasonab@mediaone.net (617) 661-5609)

          -- Dr. John Fagan, an award-winning microbiologist and
     cancer researcher, Professor of Microbiology at Maharishi
     University of Management, has renounced $3 million in US
     government research grants to publicize the dangers of misuse of
     biotechnology. He advocates a science-based precautionary
     approach requiring the labeling of all novel foods. He says
     "without labeling it will be very difficult for scientists to
     trace the source of new illness caused by genetically engineered
     food." (From: Protect Organic! Campaign jasonab@mediaone.net
     (617) 661-5609)

3.2. CLAIM: PRO-GE SCIENTISTS ARE OBJECTIVE AND MOTIVATED BY PURE
SCIENCE

          - Some 90% of GE research is funded by the biotech
     industry. (Data from Terje Traavik, University of Tromso, Norway)

3.3. CLAIM: STUDIES WHICH HIGHLIGHT UNSAFE ASPECTS OF GE ARE FLAWED

          - An increasing number of researches, published in
     peer-reviewed scientific journals, are raising concerns about the
     safety of GE crops. Instead of doing more scientific research to
     confirm these findings, the biotech industry is instead engaging
     in a dishonest media campaign to malign and discredit independent
     scientists.

3.3.1. CLAIM: PUSZTAI'S LECTIN POTATO STUDY IS FLAWED SO IT IS RIGHT
TO SACK HIM

          - Dr. Arpad Pusztai, a world-reknowned expert on lectins,
     had began a #1.6-million study which indicated that a GE-potato
     diet weakened rats' immune systems and adversely affected the
     animals' internal organs. When he shared with the media (with his
     superior's permission) some of his concerns, Pusztai was promptly
     sacked from his research post. His papers were confiscated, he
     was prohibited from talking to the media, and his research team
     was closed down.

          - Some 20 scientists from 13 countries issued a statement
     deploring the harsh treatment by Scotland's Rowett Research
     Institute of world-renowned British researcher and lectin expert
     Dr. Arpad Pusztai and demanding his reinstatement. (See: )

          - In April last year [1998], a scientist, Arpad Pusztai,
     from the Rowett Research Institute in Aberdeen, UK, unwisely
     announced on television that experiments had shown intestinal
     changes in rats caused by eating GE potatoes. He said he would
     not eat such modified foods himself and that it was "very, very
     unfair to use our fellow citizens as guineapigs". A storm of
     publicity overtook Pusztai. He was removed from his job, a
     sacrifice that did not quell public alarm in the UK or in Europe.
     Last week (May 22, p1769 ) we reported that the Royal Society had
     reviewed what it could of Pusztai and colleagues' evidence and
     found it flawed, a gesture of breathtaking impertinence to the
     Rowett Institute scientists who should be judged only on the full
     and final publication of their work. (See: The Lancet, Vol 353 No
     9167, 29 May 1999, "Health risks of genetically modified foods")

          - Monsanto Funded the Rowett Research Institute: The
     Institute that sacked and alienated Arpad Pusztai over his GE
     research received a sum of PST 140 000 before the controversy
     blew up. Monsanto's media adviser claims the money was granted to
     the Institute's Dairy Business Group research. After initially
     supporting the findings disclosed by Pusztai on British
     television last year, the Institute sacked him and accused him of
     scientific inaccuracy and bumbling. (Source: Mail on Sunday,
     13/2/99)

          - Despite the publication of Pusztai's research in the Oct
     1999 issue of the Lancet, pro-biotech advocates continue to
     repeat the industry lie that his research as "flawed".

          - Thanks to the courageous example of Dr. Arpad Pusztai and
     other independent researchers, an increasing number of scientists
     are coming out with their research results, which are not
     necessarily favorable to the biotech industry.

3.3.2. CLAIM: HILBECK'S GREEN LACEWING STUDY IS FLAWED

          - Hilbeck's study was published in a peer-reviewed
     scientific journal. (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)

3.3.3. CLAIM: LOSEY'S MONARCH BUTTERFLY STUDY IS FLAWED

          - Losey's research was published in a peer-reviewed
     scientific journal. Losey warned that their lab findings should
     not be automatically extrapolated to field conditions. This
     simply means that field studies must also be done. Why were these
     studies not done before millions of acres were planted with Bt
     corn? (See: Losey, J.J.E., L.S. Rayor and M.E. Carter (1999)
     Transgenic pollen harms monarch larvae. Nature 399: 214)

3.3.4. CLAIM: STOTZKY'S BT TOXIN SOIL PERSISTENCE STUDY IS FLAWED

          -Stotzky's studies on the soil persistence of both the
     natural Bt toxin and the Bt corn toxin were published in
     peer-reviewed scientific journals. (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.)

3.3.5. CLAIM: MAE WAN HO'S ANTI-GE STAND IS UNSCIENTIFIC

          - Ho's warnings against the use of the Cauliflower Mosaic
     Virus promoter and the danger of horizontal gene transfer have
     recently been published in peer-reviewed scientific journals.
     (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).

          - The biotech industry should stop maligning independent
     researchers simply because their results raise concerns about
     commercial products.

3.3.10. OTHERS

3.4. CLAIM: GE-FOODS HAVE UNDERGONE THOROUGH SCIENTIFIC TESTS

          + GE food is extensively tested and the GE food at present
     on our supermarket shelves is perfectly safe to eat. GE foods
     have been one of the most thoroughly tested foods in history.

          - The US FDA does not require testing, just assurances from
     the GE food manufacturer that the product is safe. Glickman
     acknowledged that none of the agencies responsible for the safety
     of GM foods - USDA, FDA or Environmental Protection Agency - had
     enough staff or resources to conduct such testing. (Marian
     Burros, Reuters News Service, 14 Jul 1999)

          - While Glickman stressed that most studies had indicated
     that there were no known health risks to consumers, he said no
     long-term studies had been conducted - one of the central
     arguments made by Europeans. In the past few years members of the
     EU have refused to import many products that contain GE
     ingredients. (Marian Burros, Reuters News Service, 14 Jul 1999)

          - No GE food testing is done in America.  We rely almost
     entirely on the testing carried out by the GE biotech firms that
     have spent billions of dollars developing the food and intend to
     make a profit selling it to us. There are serious doubts about
     the adequacy of the testing and the validity of the conclusions
     drawn from the results. Independent long-term testing is required
     before we can be sure that GE food is safe to eat. (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)

          + In 1996, only one GE-food feeding test had been published
     - done by Monsanto (no harmful effects observed) (See: )

          + BT: A feeding study on broiler chickens by a Novartis
     researcher was published 1998 (no harmful effects observed)
     Abstract: "A 38-d feeding study evaluated whether standard
     broiler diets prepared with transgenic Event 176-derived "Bt"
     corn (maize) grain had any adverse effects on male or female
     broiler chickens as compared to diets prepared with nontransgenic
     (isogenic) control corn grain. No statistically significant
     differences in survival or BW were observed between birds reared
     on mash or pelleted diets prepared with transgenic corn and
     similar diets prepared using control corn. Broilers raised on
     diets prepared from the transgenic corn exhibited significantly
     better feed conversion rations and improved yield of the
     Pectoralis minor breast muscle. Although it is not clear whether
     this enhanced performance was attributable to the transgenic corn
     per se, or due to possible slight differences in overall
     composition of the formulated diets, it was clear that the
     transgenic corn had no deleterious effects in this study." The
     authors also wrote that "to our knowledge, this is the first
     published large-scale feeding study of transgenic corn." (See:
     J.Brake (NCSU) and D.Vlachos (Novartis), "Evaluation of
     Transgenic Event 176 Bt corn in Broiler Chickens," 1998, Poultry
     Science 77:648-6??)

          + BT: The Bt toxin is safe to mammals, as confirmed by rat
     feeding experiments. Unlike the gut of target insects, the
     mammallian gut has no receptors which the toxin can bind to.

          - Pusztai's rat study on GE potatoes with the GNA lectin
     published October 1999 - the only independent study so far -
     observed some harmful effects (See: The Lancet, Oct 1999) (http:)

          - No feeding studies had been done on swine or cattle (major
     consumers of GE-corn and -soya), primates, or human volunteers

          - No study on the long-term effects of GE-food had been done

          - Studies of their effects in combination with other toxins
     or with conventional chemicals are non-existent (See:) (http:)

          + Millions of Americans are already buying GE food and
     nobody has gotten sick eating them.

          + Dr. Prakash adds that every aisle of the supermarket now
     has GM corn and soybean derived products, from soaps and baby
     foods to Coke, which contains GE high fructose corn syrup. And
     all the products have been widely consumed for about two years,
     with no apparent ill health effects reported. (Dr. C.S. Prakash,
     a geneticist and professor of biotechnology at Tuskegee
     University in Tuskegee, Ala.)

          - The feeding of GE-food to the American population is not
     a scientific experiment but a criminal act of doing uncontrolled
     experiments on human subjects without their knowledge or consent.
     It is not possible to determine from the uncontrolled feeding of
     unlabelled GE-foods to Americans how much foods have contributed
     to the greater incidence of allergies, emergence of new or more
     virulent pathogens, or higher cancer rates.

3.10. OTHERS

4.   ECONOMIC CLAIMS: GE-CROPS ARE ECONOMICALLY COMPETITIVE

          - Summary: Based on the actual experience after the 1999
     harvests of U.S. farmers who planted GE crops, it is now clear
     that the market considers GE crops as undesirable contaminants.
     If mixed with a non-GE batch, that batch will be considered
     contaminated and cannot be sold in some markets or will fetch a
     lower price in other markets. Consumers want GE-free foods, more
     and more firms are going GE-free, and GE-imports are banned in
     some countries. Why plant an undesirable contaminant? Why let a
     neighbor plant an undesirable contaminant which can
     cross-pollinate and contaminate your own crops?

4.1. CLAIM: GE-CROPS WILL INCREASE YIELDS

          - On the whole, GE crops do not lead to higher yields and in
     many occasions, they have in fact produced lower yields.

          - Dr. Charles Benbrook presented evidence that farmers who
     use Monsanto's RoundUp Ready soybeans are getting lower yields
     than farmers using conventional soybeans. (See: Campaign on Food
     Safety News #20, 14 Jul 1999)

          - Some researchers have shown that none of the GE seeds
     significantly increase the yield of crops. Indeed, in more than
     8,200 field trials, the Roundup Ready seeds produced fewer
     bushels of soybeans than similar natural varieties, according to
     a study by Dr. Charles Benbrook, the former director of the Board
     on Agriculture at the National Academy of Sciences. (Peter
     Rosset, "World Hunger: Twelve Myths")

          - Recent experimental trials have shown that GE seeds do
     not increase the yield of crops. A recent study by the USDA
     Economic Research Service shows that in 1998 yields were not
     significantly different in GE versus non-GE crops in 12 of 18
     crop/region combinations. In the six crop/region combinations
     were Bt crops or HRCs fared better, they exhibited increased
     yields between 5-30%. Glyphosphate tolerant cotton showed no
     significant yield increase in either region where it was
     surveyed. This was confirmed in another study examining more than
     8,000 field trials, where it was found that Roundup Ready soybean
     seeds produced fewer bushels of soybeans than similar
     conventionally bred varieties (United States Department of
     Agriculture (1999) Genetically Engineered Crops for Pest
     Management. USDA Economic Research Service, 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)

          - Dr Will McCarty, University of Mississippi Extension
     Service Cotton specialist: "Before you plant transgenic
     varieties, be sure you need the value-added trait. Also evaluate
     the yields of varieties with the transgenic trait you desire, and
     study the risk and benefit ratio, if any. In other words, if you
     feel you need to plant Bt and the variety does not or has not
     yielded well for you or in your area, consider the risk of not
     using it and the potential cost of additional insect control
     versus potential yield loss to planting it. The same can be said
     for a transgenic variety for herbicide tolerance. Before you pay
     extra for the convenience of using a particular herbicide
     over-the-top, be sure the variety fits your farm and will yield
     well. .... Also, transgenic varieties may not perform as well as
     did their parents. Just because you have had good experience with
     a particular variety does not mean you will have the same results
     with a transgenic version." (Agronomy Notes, 5 Oct 1999)

          - Dr Alan Blaine, soya bean specialist, University of
     Mississippi extension service: "The vast majority of the problems
     soybean growers have encountered over the last couple of years
     have been on relatively new varieties. Instead of taking 6 to 8
     generations for a variety to reach the market, we are seeing
     varieties blown up and put on the market in probably 3 to 4
     generations. It is this trend that has caused many of you to
     experience poor performance from many new varieties. Steer away
     from planting a variety just because someone tells you how good
     it is. Prove it to yourself and this should be done with no less
     than 2 years of yield test data. Variations in growing conditions
     cause varietal differences to be expressed, and 1999 really
     exposed some potential weakness in several varieties." (Agronomy
     Notes, 5 Nov 1999)

          -- Studies at the Department of Entomology, Ohio State
     University by Hal Wilson indicate no yield difference between Bt
     and non-Bt lines. At their Northwestern Station, 3 non-Bt maize
     hybrids averaged corn borer injury of 1.08 cavities per plant
     compared to 0.55 the previous week at the Western Station. In
     1997 trials at the Northwestern Station, injury in non-Bt maize
     averaged 1.66 cavities per plant, with no significant difference
     in yields between the Bt and the equivalent non-Bt maize. This is
     their third year of comparison trials. Over this 3-year period,
     corn borer injury per non-Bt plant has averaged 0.54 cavities at
     the Western Station and 0.74 at the Northwestern Station. The
     results accumulated to date raise questions about the economic
     benefits of Bt-maize hybrids if such technology must be purchased
     at premium prices. (AgBiotecNet Oct 99)
     <http://iris.biosci.ohio-state.edu/osuent/>

4.2. CLAIM: GE CROPS WILL REDUCE FARMERS' COSTS AND RAISE THEIR INCOME

          - GE seeds cost 20-30% higher than conventional seeds.

          + BT: Bt corn will result in lower pesticide costs.

          - BT: This is offset by the higher seed costs, by the need
     to maintain 20-40% of the field as sacrificial refugia for
     non-resistant corn borers, and the lower market price of GE corn.

          - Farmers incur higher costs to segregate GE from
     conventional crops.

          - Because of risks associated with GE crops insurance
     companies in the USA and UK are now reluctant to insure them.
     This can raise insurance costs. (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)

          - Surveyors warned yesterday that farmers who plant GM crops
     could see their land values fall, and that tenants of such land
     might face bills to make up the shortfall. The Royal Institute of
     Chartered Surveyors (RICS) called for the creation of a land
     register through which potential buyers, and banks, could find
     out if and when GM crops had been planted or grown on a
     particular holding. However, the RICS report, sent to the
     Government's Office of Science and Technology and other
     departments, warned that growing such crops might lower the value
     of the land. In the case of tenant farmers, a landlord could, in
     effect, sue for any shortfall in land value caused by the tenant
     growing GM crops. (INDEPENDENT, London, 12 Mar 1999)

          - Farmers growing GE crops have to sign binding contracts
     with the biotechnology producers.  These commit them to using
     only the herbicides produced by that company and prohibit them
     from the traditional practice of saving seed for the next season.
     (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)

          - HT: The integration of the seed and chemical industries
     appears destined to accelerate increases in per acre expenditures
     for seeds plus chemicals, delivering significantly lower returns
     to growers. Companies developing herbicide tolerant crops are
     trying to shift as much per acre cost as possible from the
     herbicide onto the seed via seed costs and/or technology charges.
     Increasingly price reductions for herbicides will be limited to
     growers purchasing technology packages. In Illinois, the adoption
     of herbicide resistant crops makes for the most expensive soybean
     seed-plus-weed management system in modern history -between
     $40.00 and $60.00 per acre depending on rates, weed pressure,
     etc. Three years ago, the average seed-plus-weed control costs on
     Illinois farms was $26 per acre, and represented 23% of variable
     costs; today they represent 35-40% (Benbrook l999). (Benbrook, C.
     l999 World food system challenges and opportunities: GMOs,
     biodiversity and lessons from America's heartland (unpub.
     manuscript). 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) Many farmers are willing to pay for the simplicity and
     robustness of the new weed management system, but such advantages
     may be short-lived as ecological problems arise.

          -- The National Family Farm Coalition (NFFC), consisting of
     farm, conservation and rural advocacy groups from 33 U.S. states,
     has launched a 9-point petition titled "Farmers' Declaration on
     Genetic Engineering in Agriculture." It identified the ff impacts
     of GE: increased economic uncertainty among farmers; loss of
     critical markets; loss of farmer independence due to corporate
     control of the seed supply; impure products due to genetic drift;
     social and economic disruption. In their 9-point petition, U.S.
     farmers demanded: a suspension of approval and releases of GE
     seeds and agriculture products until their comprehensive impacts
     are independently assessed; liability by corporate agribusiness
     for damages from GE crops and livestock; that GE firms bear the
     burden of proof of safety as well as bear the cost of an
     independent review. (Email: nffc@nffc.net)

          - Because consumers don't want GE-food, GE crops fetch a
     lower price in the market; some markets will even reject them.
     Non-GE crops now receive a premium and as more countries reject
     GE foods, the opportunities to sell GE produce overseas are
     diminishing.

          -- In summary, GE crops may in some cases increase yields
     slightly. However, in the case of Bt crops, 20-40% of the fields
     have to be sacrificed as refugia. Furthermore, the seeds will
     cost some 20-30% higher, and the harvest may have to be sold at a
     lower price as more and more companies try to keep their products
     GE-free in response to consumer demand. As Deutsche Bank said, GE
     crops are bound to be losers, economics-wise.

4.3. CLAIM: CONSUMERS WANT GE-FOODS

          - Opinion polls consistently show that more than 90% of
     Americans support the labeling of GE foods. A 1999 Time poll
     revealed that close to 60% would avoid such foods if they were
     labeled. (NYTimes full page ad, 18 Oct 1999)

          - "Ag Biotech: Thanks, But No Thanks?" - that was the title
     of a July 1999 report of investment analysts Frank Mitsch and
     Jennifer Mitchell of the Deutsche Banc Alex. Brown, the largest
     investment firm in the world. The two said they were "willing to
     believe that GMO crops are safe," but they warned that the "no
     thanks" attitude "appears to be in the lead in Europe and could
     easily become the thought process in the United States as well."
     Earlier, three analysts from the same company had sent investors
     a report entitled "GMOs Are Dead," advising them to sell their
     Pioneer Hi-Bred stocks.
     <http://www.dmg.com/central/ver40/index.html>
     <http://www.biotech-info.net/Deutsche.html>

          - In Britain, for example, where GE food labeling is
     required, poll results last March [1999] showed that nine out of
     10 shoppers would switch supermarkets and travel considerable
     distances to avoid such food. (See: "Wake-up call for biotech
     foods", Wisconsin State Journal, 22 Apr 1999)

          - Some 86% of consumers questioned in a poll for Here's
     Health magazine said they would switch to a different supermarket
     if it banned all GE products. On top of this, 84% of the same
     sample of 1,030 shoppers said they would be willing to travel
     double the distance it normally takes to visit their supermarket
     if they could be sure of shopping in a GM-free environment. (The
     Press Association, 10 Mar 1999)

          - More than 100 chefs and food writers launched a campaign
     to oppose "freakish" GM food yesterday. Antonio Carluccio, Antony
     Worrall Thompson, Fay Maschler and Annie Bell, food writer for
     The Independent, were among those who pledged to secure a ban on
     the release of all GM organisms into the food chain. In a joint
     statement, they said: "As food professionals we object to the
     introduction of [GM] foods into the food chain. This is imposing
     a genetic experiment on the public, which could have
     unpredictable and irreversible adverse consequences. " In a
     recent Mori poll, 61 per cent of respondents said they would not
     be happy to eat GM food. (INDEPENDENT, London, 27 Jan 1999)

          - Washington, D.C.: Citing major deficiencies in the
     government's regulatory system, a coalition of environmentalists
     and scientists issued a document today calling for the suspension
     of all further releases of GMOs. The Pacific Declaration was
     first drafted at a national meeting on July 26-28, 1999 at the
     Commonweal Conference Center in Bolinas, California. The
     Declaration cites the failure of governmental agencies to review
     the long-term prospects for environmental and human harm stemming
     from GMOs. Among the groups endorsing the Declaration are the
     Sierra Club, Friends of the Earth, the American Corn Growers
     Association,  Rural Advancement Foundation International (RAFI),
     the Institute for Agriculture and Trade Policy, the Council for
     Responsible Genetics, the Edmonds Institute, and the Center for
     Ethics and Toxics (CETOS). (CETOS press statement, 12 Oct 1999)

          - SEOUL, Sept 9 (Reuters) - The Korea Consumer Protection
     Board said last Thursday its survey had found that 94.7 percent
     of the total 526 survey respondents said labelling for GM foods
     was necessary - 71.5 percent said all the time and 23.2 percent
     in some cases. (Reuters, 9 Sep 1999)

          - The ff U.S. organizations have asked for the suspension
     of all further releases of GMOs: Sierra Club, Friends of the
     Earth, the American Corn Growers Association, Rural Advancement
     Foundation International (RAFI), the Institute for Agriculture
     and Trade Policy, the Council for Responsible Genetics, the
     Edmonds Institute, and the Center for Ethics and Toxics (CETOS).
     (CETOS press release, 12 Oct 1999)

          - Australian farmers reject GE: "That the Federation oppose
     the release of 'Genetic Modification' of both livestock and other
     farm produce and that we continue to promote R&D of those
     products by natural means." (Western Australian Farmers
     Federation, Rural Press Report, 15 Sep 1999)

          - California Labeling Initiative: California volunteers are
     gathering signatures to put an initiative on the ballot that
     would require GE foods labeling. The initiative would require
     labeling of "crops and livestock containing genetic material
     transferred from one species to another or other DNA
     modifications not commonly possible under natural conditions,
     such as cell fusion, gene deletion or doubling, and induced
     sequence or encapsulation variations." To qualify for the Nov
     2000 ballot, 413,000 valid California voter signatures are needed
     by February 20. If such initiative passes, implications for the
     rest of the country are huge. Food firms which are not GE-free
     would need to add labels if they wanted to do business in our
     most populated state. Legislation on GE foods is also being
     considered in New York, Vermont and Minnesota in the next year.
     (Organic View, Vol. 1 No. 18, 8 Dec 1999)

          - U.S.: More than 30 farm groups in the U.S., representing
     tens of thousands of farmers, have warned their members they are
     risking their livelihoods if they plant GE crops, because these
     had become so unpopular with consumers. "Export markets in Europe
     and Asia are saying 'no' to foods produced from GM crops and
     farmers know they have to respond to consumer demand if they are
     to survive," Gary Goldberg, head of the American Corn Growers
     Assoc., said. He predicted that 25% fewer GM crops would be
     planted next year in US fields, based on talks with farmers and
     local seed company salesmen. "We believe that farmers in mass
     exodus are moving away from planting GM crops next year," he
     said. The farmers' main concern is that growing consumer demand
     for traditional seed varieties will create a two-tier market in
     which GM products will fall in price. Farmers have said they are
     concerned about paying premium prices for GM seeds and then
     finding they can't sell their crops. Grain dealer Jerry Bertrand
     said: "I can't tell them with certainty that I'll take their GM
     corn and soya next year because I don't know if there'll be a
     market for it." The farm groups also warned that inadequate
     testing of GM seeds could make farmers vulnerable to massive
     lawsuits if the seeds were later found to have negative
     environmental effects. Some European countries have banned
     American maize and soya shipments because US authorities cannot
     guarantee they only contain EU-approved varieties. The US says
     this has cost it approximately $200m in maize sales alone over
     the past two years, and will raise the issue with the WTO. (24
     Nov 1999)

4.4. CLAIM: COMPANIES ARE SHIFTING TO GE-FOODS

          - With more and more major food retailers, restaurants, and
     processors in Germany, Austria, Switzerland, France, Scandinavia,
     the UK, and other nations going "GE-free" a tremendous market now
     exists for certified "non-GE" and organic products.

          - GM-free feed cannot meet rising demand: Not enough non-GM
     soya or derived products are available on the international
     market to met growing demand for GM-free animal feed, according
     to [National Farmers Union]'s Dr Vernon Barber. (See The Farmer's
     Guardian, 15 Oct 1999, UK)

          - AUSTRALIA: Australian trade authorities announced Jan. 8,
     1999, the largest shipment of canola (rapeseed) ever exported
     from Australia. The $16.5 million dollar shipment is bound for
     oilseed crushing plants in Europe. According to Graham Lawrence,
     managing director of the New South Wales Grains Board, "Europe
     has moved to become a major buyer this year because Australia is
     the only country to guarantee non-GM canola."

          - CANADA: The Canada press have noted continuing indecision
     among rapeseed (canola oil) farmers whether to plant GE rapeseed
     in the next growing season. Over one-half of Canada's canola crop
     this year is GE. Canada has lost almost a billion dollars in
     canola sales to Europe since the GE controversy erupted in 1997.
     If Japan (which is likely) and China cut back on canola
     purchases, Canada's rapeseed farmers will be facing economic
     disaster. (Organic View, Vol. 1 No. 18, 8 Dec 1999)

          - Canada has lost $300-400 million in canola sales to
     Europe IN 1998 because authorities have followed the US model of
     co-mingling GE and non-GE grains. This year over 50% of Canada's
     13.4 million acres of canola are GE.

          - U.S.: There have been virtually no corn exports from the
     US to the EU States because the GE corn cannot be separated from
     the rest of the crop, costing American farmers about $200 million
     a year. (Marian Burros, Reuters News Service, 14 Jul 1999)

          - BRAZIL: Almost no US corn (nor Canadian canola oil) has
     being exported to the EU for the past two years because of
     consumer resistance. Meanwhile Brazil, where a GE ban is in
     effect, is exporting record-breaking amounts of soya to the EU;
     while Australia is exporting increasing amounts of non-GE canola
     to Japan. (See: Cummins, Ronnie and Ben Lilliston, Campaign for
     Food Safety News #22, 21 Oct 1999) <http://www.purefood.org;
     http://www.organicconsumers.org>

          - U.S.: The National Corn Growers Association acknowledges
     that U.S. corn sales to Europe plunged from nearly 70 million
     bushels in 1997 to less than 3 million last year because the U.S.
     crop contained a small amount of GE corn. (See: "Wake-up call for
     biotech foods", Wisconsin State Journal, 22 Apr 1999)

          - Last fall, testers in Europe detected traces of GE corn
     in organic corn chips made by elodi Nelson's company, Prima Terra
     Inc. of Hudson, Wis. Some of the corn supplied to Prima Terra
     from a certified organic supplier was contaminated, it turned
     out, with minuscule amounts of GE corn, perhaps because a few
     grains of GE pollen blew into the organic grower's fields from a
     neighboring farm. The positive test forced Prima Terra to recall
     87,000 bags of chips valued at $147,000. (Rick Weiss, Washington
     Post, 15 August 1999)

          - Carlsberg to Avoid GM corn: Carlsberg AS said it will
     henceforth brew its beer only from malt and no longer use corn to
     reassure consumers of a GM-free product. (AFP, 12 Nov 1999)

          - The maker of Gerber baby food is dropping suppliers who
     use GE corn and soybean products, the company's CEO confirmed
     today. The move by Novartis follows a request from Greenpeace for
     information on the company's use of GE products. The company was
     evaluating their use before then, said Al Piergallini, president
     and CEO of its North American consumer health division, based in
     Summit. Novartis plans to drop some of the company's grain
     suppliers this summer in favor of producers who use non-GE corn
     and soybeans. Those ingredients account for less than 2 percent
     of Gerber's products, mainly dry cereal, Piergallini said.
     Novartis said it was turning to other suppliers anyway, and is
     taking its changes a step further by adding a new promise to try
     to use only organic - pesticide- and herbicide-free - ingredients
     in Gerber products. Two other baby-food makers, H.J. Heinz Co. of
     Pittsburgh and Poway, Calif.-based Healthy Time Natural Foods,
     have made similar product changes in response to Greenpeace
     concerns. Gerber is the nation's largest maker of baby food,
     producing 5.5 million jars per day and annual worldwide sales of
     $1 billion. (AP Online, 30 Jul 1999)

          - Dow Jones reported on October 5 that the Japanese futures
     market (where buyers pay in advance for future deliveries) for US
     soybeans which were harvested last year are "declining rapidly"
     because last year's soybeans "are mixed with large amounts of GM
     products." According to Dow Jones, "Japanese [grain] traders are
     rapidly switching to imports of GM-free soybeans." With giant
     importers in the EU, Japan, and other nations now demanding
     GE-free foods, more large transnational grain traders are
     expected to follow the example of Archer Daniels Midland, who
     announced in September they expect US farmers and grain elevators
     to start separating out and segregating GE from non-GE grains.
     Archer Daniels Midland purchases fully 1/3 of all corn, soybeans,
     and wheat produced in the US. (See: Cummins, Ronnie and Ben
     Lilliston, Campaign for Food Safety News #22, 21 Oct 1999)
     <http://www.purefood.org; http://www.organicconsumers.org>

          - Europe's biggest bank has advised the world's largest
     investors to sell their shares in leading GMO makers because
     consumers do not want to buy their products. In a report sent to
     several thousand of the world's large institutional investors,
     including British pension funds, Deutsche Bank says that "growing
     negative sentiment" is creating problems for the leading
     companies, including Monsanto and Novartis. "More broadly
     speaking, it appears the food companies, retailers, grain
     processors, and governments are sending a signal to the seed
     producers that 'we are not ready for GMOs'." Since the report was
     circulated to investors, shares in companies named have fallen
     against a rising trend in stock markets generally and the frenzy
     to takeover seed companies has stopped. In the six months to
     yesterday Monsanto's stocks had fallen 11%, and Delta & Pine, a
     seed company that owns the terminator gene, which Monsanto is
     taking over, has lost 18% of its value. The Deutsche Bank's
     Washington analysts, Frank Mitsch and Jennifer Mitchell, say it
     is nine months since they first voiced their concerns that the
     biotech industry was "going the way of the nuclear industry in
     this country, but we count ourselves surprised at how rapidly
     this forecast appears to be playing out. Deutsche Bank's first
     research report, dated May 21 and entitled GMOs Are Dead, said:
     "We predict that GMOs, once perceived as a bull case for this
     sector, will now be perceived as a pariah. "The message is a
     scary one - increasingly, GMOs are, or in our opinion, becoming a
     liability to farmers," it adds. Non-GMO grains were already
     gaining a premium price which would, if the trend continued, far
     outweigh any economic benefit in growing GMOs. GM grains would
     have to be sold at a discount. "Farmers who planted (Monsanto's)
     Roundup Ready soya could end up regretting it." It could become
     an "earnings nightmare" for Pioneer Hi-Bred (a company due to be
     taken over by the chemicals giant DuPont) and for Monsanto which
     is buying Delta & Pine, a stock, the bank says, not worth holding
     on to. The concerns of European consumers are real, concludes the
     report. "European consumers have recently been through the mad
     cow crisis, the French Aids-tainted blood crisis, the Dutch pig
     plague crisis, the Belgium chicken dioxin crisis, the Belgian
     Coca-Cola crisis, etc. Therefore hearing from unsophisticated
     Americans that their fears are unfounded may not be the best way
     of proceeding." (Paul Brown and John Vidal, GUARDIAN (London), 25
     August 1999)

          - Monsanto, the beleaguered U.S. biotech firm, is coming
     under intense pressure from Wall Street analysts and professional
     investors in New York to dismember itself in the wake of the
     campaign against GM food. New York's financial community is now
     convinced that successful protests from consumers and
     environmental groups in Europe have hurt Monsanto's growth
     prospects and its stock market rating so badly that the only
     option to realise some value for investors would be some kind of
     sell-off. (The Guardian, 22 Oct 1999, London)

          - The following companies are part of the growing list of
     firms which have declared that they will not use GE-ingredients
     or sell GE-foods:

          - AUSTRALIA: Vitasoy International Holdings Ltd., Australia
     (AFX Asia, 2 Nov 1999); Sanitarium Health Food Company,
     Australia; Cadbury-Schweppes, Australia; Master Foods, Australia;
     Mars Confectionery, Australia; Wyeth, Australia; Heinz Watties
     Australasia

          - CANADA: McCain Foods, Canada's French-fries giant (Ottawa
     Citizen, 29 Nov 1999);

          - New Brunswick-based McCain Foods, the largest potato and
     frozen french fry processor in the world, announced they would no
     longer accept Monsanto's Bt potatoes for their brand-name
     products. The McCain decision comes in the wake of a recent
     highly-publicized petition by 200 scientists of Canada's own
     health department to Allan Rock, the Health Minister, saying they
     lacked sufficient staff and resources to examine potential health
     risks of GE foods. (Ottawa Citizen, 29 Nov 1999)

          - FRANCE: Carrefour (France's largest supermarket chain);

          - ITALY: Esselunga;

          - JAPAN: Nissin Food Products; Kirin Brewery; Itochu Corp,
     Japanese trading house; Itochu Feed Mills; Sapporo Breweries;
     Nippon Flour Mills; Fuji Oil Co.; Japan Tofu Association;

          - Major food and beverage companies in Japan have begun
     removing GE soybean and corn ingredients in their products. Kirin
     Brewery, Sapporo Breweries, Itochu Feed Mills, Nippon Flour
     Mills, Nissin, Fuji Oil Co., and the Japan Tofu Association,
     among others have decided to either ban GE ingredients completely
     or put a major marketing effort into sourcing and selling GE-free
     products. A division of Honda Motor Company announced they were
     building a soy-handling plant in Ohio to supply the sharply
     rising demand for non-GE soybeans in Japan. Interpress on Oct. 14
     reported a similar move by Pioneer-Hibred Japan, who announced a
     major business venture to import non-GE soybeans from the US. In
     the same article Interpress called attention to a 1999 poll in
     Tokyo where "90% of those surveyed expressed deep concern over
     the growing trend toward biotechnology." Japan is the largest
     importer of food products and animal feeds in the world. (See:
     Cummins, Ronnie and Ben Lilliston, Campaign for Food Safety News
     #22, 21 Oct 1999) <http://www.purefood.org;
     http://www.organicconsumers.org>

          -- Kibun Food Chemifa Co Ltd, Japan's largest soybean milk
     maker, said yesterday it will stop using GM ingredients in its
     soybean milk products by March 2000. A Kibun official said: The
     company will use rice bran oil instead of corn oil and sugar
     instead of high fructose corn syrup (HFCS), to remove consumer
     safety concerns. For soymilk, Kibun imports non-GM soybean from
     China. "We have decided to eliminate all the GM ingredients from
     soymilk products." Kibun holds 50% of Japan's soymilk market
     worth some 17 billion yen this year. (Reuters, 21 Dec 1999)

          -- Nisshin Flour Milling Co Ltd, Japan's largest flour
     miller, said yesterday it will stop using ingredients from GM
     corn and soybeans in its flour products for home use by the end
     of Feb 2000. A company spokesman said: The company will use wheat
     protein instead of soybean protein due to consumer concerns about
     GE food safety. "We found it difficult to secure a sufficient
     volume of ingredients made from non-GM corn and soybeans."
     Nisshin uses 2,000 tonnes of corn starch, soybean protein and soy
     powders annually in its flour products for home use. It is also
     talking to corporate clients about eliminating GM ingredients
     from its business-use flour products. (Reuters, 21 Dec 1999)

          -- Japanese corn snack maker Tohato Inc, which is now
     completely dependent on U.S. corn, plans to switch to corn grits
     made in France in order to avoid the GM label. A Tohato spokesman
     declined to say how much corn the company uses for corn snack
     production. But one trader at a Japanese trading house estimates
     Tohato needs 200 tonnes of corn a year. (Aya Takada, Reuters, 24
     Aug 1999)

          - MEXICO: Grupo Maseca, Mexico's leading producer of corn
     flour;

          -- SOUTH AFRICA: Retail chain Woolworths said today it had
     decided to remove all known GM foods from its shelves until they
     were proven safe, making it the first South African retailer to
     take that stance. "The current situation with regard to GE food
     in South Africa is unsatisfactory," Woolworths said in a
     statement. "Woolworths have stated their intention to remove GE
     food from their shelves." (Reuters, 21 Dec 1999)

          - SWITZERLAND: Migros;

          - UK: Unilever, the world's largest food manufacturer (See:
     Independent, 28 Apr 1999); Tesco (Britains biggest supermarket
     chain, sales: #18.5bn) (See: Observer, 7 Mar 1999); Asda, a major
     British supermarket chain (See: Independent, 27 Jan 1999);
     Kentucky Fried Chicken UK (See: Daily Mail, 23 Feb 1999);
     Iceland, a British frozen food specialist; Marks and Spencer,
     another British retail chain; Waitrose, UK; McDonald's, UK (See:
     Observer, 7 Mar 1999); Burger King, UK (See: Daily Mail, 23 Feb
     1999); United Biscuits, UK (See: Observer, 7 Mar 1999);
     Sainsbury, UK;

          - U.S.: Gerber Baby Foods; Heinz; Burger King;

          -- U.S.: Whole Foods Market Inc. and Wild Oats Markets Inc.,
     the two largest natural-food store chains in the U.S., plan to
     ban GM ingredients from their hundreds of private-label products.
     They would be the largest U.S. food retailers to ban GM
     ingredients. The Austin-based Whole Foods operates 103 stores in
     22 states and Washington, D.C., and has more than 600 products
     carrying its brand name. Boulder, Colorado-based Wild Oats
     operates 110 stores in 22 states and British Columbia. It has
     about 700 products under its own brand. ``You're seeing more and
     more examples of this,'' said Frank Mitsch, an analyst with
     Deutsche Banc Alex Brown. (From: Brett Chase, Bloomberg/Newsroom,
     30 Dec 1999) <bchase1@bloomberg.net>

          - GM food has been banned from the staff cafeteria at
     Monsanto Co.'s UK headquarters by the company's own caterer,
     Monsanto confirmed Tuesday. Granada Food Services, whose
     customers include Monsanto's High Wycombe office near London,
     recently told clients it would not supply food containing GM soya
     or maize due to customer concerns. Granada said the move was
     designed "to ensure that you, the customer, can feel confident in
     the food we serve."
     http://www.infobeat.com/stories/cgi/story.cgi?id=2562764499-062

          - Caterers at the House of Commons serve food that avoids
     GM ingredients "in response to the general unease about such
     foods expressed by significant numbers of our customers". At the
     Welsh and Scottish Assemblies, caterers also have a policy of
     avoiding GM ingredients, and the European Parliament has banned
     them too. (Alex Kirby, BBC Online, 22 Dec 1999)
     <http://news.bbc.co.uk/hi/english/sci/tech/newsid_574000/574245.stm>

4.5. CLAIM: COUNTRIES ARE RAPIDLY ADOPTING GE-CROPS

          - AUSTRALIA: Australia's $14 billion farm export sector is
     shunning GE crops due to fears of "consumer backlash." Despite
     heavy biotech industry lobbying, the country has not allowed the
     commercialization of many GE products, including sugar cane,
     beer, and canola. The only GE crop grown on a large-scale in
     Australia is cotton. (Reuters, 15 Oct 1999)

          - AUSTRIA: A total ban on Bt corn, including field trials,
     has been imposed

          - BRAZIL: It grows 25% of the world's soybeans. Its Supreme
     Court ruled in June that Monsanto's GE soybeans (RRS) cannot be
     grown until the govt finalizes stringent regulations on biosafety
     and Monsanto completes an environmental impact statement. Farm
     and environment groups have made GE a major national issue.
     Monsanto reps admitted late-September that no RRS soybeans will
     be planted in 1999-2000 and that prospects for 2000-2001 planting
     are also in jeopardy. Analysts believe that if Brazil's ban
     continues for several more years (and sales to the EU of non-GE
     soya continue to grow), GE crops may never gain significance in
     the country. (See: Cummins, Ronnie and Ben Lilliston, Campaign
     for Food Safety News #22, 21 Oct 1999) <http://www.purefood.org;
     http://www.organicconsumers.org>

          - Brazil's state of Rio Grande do Sul will launch what may
     be the world's first program aimed at weeding out GM crops, a
     state official said Tuesday. Treating GM soybeans like drug
     plants, the state will offer farmers a total of 10 million reals
     (US$5.37 million) in special low-interest loans if they rip out
     GM soy - illegal in Brazil - and replant normal varieties. "What
     we are telling them it is better to lose seedlings than lose
     their entire crop," said the state's agriculture secretary, Jose
     Hermeto Hoffmann. (Phil Stewart, Reuters, 7 Dec 1999)

          - EUROPE: Public opposition to GE foods is so strong that
     the European Union requires the labeling of all newly
     manufactured GE products from the U.S. The approval of new GE
     crops in the EU has ground to a halt. No new varieties have been
     approved in the last 15 months. (Marian Burros, Reuters News
     Service, 14 Jul 1999)

          - INDIA: India's Supreme Court ruled on Feb. 23 to halt all
     field trials of Monsanto's Bt Cotton. The court said that no
     field trials can be permitted on a large scale unless the rules
     and guidelines are amended ensuring protection of the
     environment, biodiversity and human health. The court ruling was
     a response to the petition of Dr Vandana Shiva of the Research
     Foundation for Science, Technology and Ecology, which also calls
     for a 3-5 year moratorium on field releases. (See: Environmental
     News Service, February 23, 1999)

          - INDONESIA, PAKISTAN: Officials recently announced plans
     for more stringent safety-testing of GE imports. crops and
     imports. (See: Cummins, Ronnie and Ben Lilliston, Campaign for
     Food Safety News #22, 21 Oct 1999)

          - ITALY: Farm Minister Paolo De Castro on Friday blocked 3
     GM crops - maize, soya and chicory - that had completed testing
     and were ready to proceed to field planting... For the moment, De
     Castro has also halted all new GM testing programs. He said he
     wanted responsibility for the schemes to be shared by regional
     governments before giving the go-ahead. (Xinhua, 5 Nov 1999)

          - ITALY: The govt has temporarily suspended the use of 7 GM
     food products, a Health Ministry statement said Friday.
     "Following opinions from the Italian Health Institute and the
     Health Council, the Health Ministry will take a precautionary
     step, in conformity with EU regulations, to suspend temporarily
     the use of the substances," it said. The Health Council said the
     7 GM products are maize Bt11, maize Mon 810, rapeseed oil Gt73,
     rapeseed oil MS1 RS1, rapeseed oil RF2 MS1, maize Mon 809 and
     maize T25. The ministry statement said the suspension followed
     complaints by environmental groups over allegedly irregular sales
     procedure, but the ministry gave no details and did not say how
     long the suspension could last. The Health Council said it was
     not possible to guarantee that genetic alteration of foods was
     safe. (Reuters World Report, 17 Dec 1999)

          - NORWAY, DENMARK: The governments have banned the
     commercialization of GM organisms and food

          - PARAGUAY: Its Biosafety Commission, supported by many
     NGOs, called on August 4 for GE-free production in Paraguay.
     (See: Cummins, Ronnie and Ben Lilliston, Campaign for Food Safety
     News #22, 21 Oct 1999) <http://www.purefood.org;
     http://www.organicconsumers.org>

          -- PORTUGAL: The Agriculture Ministry suspended on 27 Dec
     1999 all commercial growing of GE-corn in Portugal next season.
     There had been two approvals (Novartis and Monsanto varieties)
     and 15 more were expected. There was a single year of GE corn
     production in Portugal (1999), with a total area of about 1300
     hectares (about 0.5% of all cultivated corn). This U-turn follows
     strong NGO pressure and rising consumer awareness in the last few
     weeks. Cited as reasons were the precautionary principle and the
     present inability to accurately and independently monitor the
     impacts of the releases. Growers had earlier voiced concern about
     the lower market value of GE or mixed corn production. (Margarida
     Silva, Quercus, Portugal, 28 Dec 1999) <msilva@esb.ucp.pt>

          - RUSSIA: The sale to the population of foodstuffs and
     medicinal preparations, obtained from GM sources, without special
     marking on the package will be banned, starting from July 1,
     2000. (TASS, 5 Oct 1999)

          - THAILAND: They will set up GMO-free agricultural zones to
     promote exports, a senior Thai official said. 'Agricultural
     products from GMO-free zones exported to foreign markets will be
     guaranteed by Thai authorities as GMO-free,' said Newin Chidchob,
     deputy agriculture minister... 'We have no policy of allowing
     trading in modified food in Thailand. GMO plants are banned from
     import, except for study and research, and we never produce and
     export such food,' Newin said. In certain areas, the govt will
     control the whole process of production from seed to harvest, he
     said, noting the zone will be expanded until the entire nation is
     GMO-free. (Kyodo, 27 Sep 1999)

          - THAILAND: The govt announced Oct. 18 it will ban imported
     GE seeds "pending clear scientific proof that they are safe."
     Fears reached new levels last week when a shipment of GE wheat
     from the U.S. mysteriously arrived in Thailand. EU warned that
     Thai rice may be rejected if shipments are found contaminated
     with GE rice being grown in Thailand. (AP, 18 Oct 1999)

          - US soybean exports to Europe have declined from $2.1
     billion in 1996 to $1.1 billion in 1999,  and will likely decline
     to zero over the next 12 months as Greenpeace, Friends of the
     Earth, and other anti-biotech campaigners drive GE soy and
     corn-derived animal feeds off the market. As the same thing
     happens in Japan, Korea, Taiwan, and the rest of Asia-not to
     mention the US and Canada-GE grains, for all practical purposes,
     will be dead. Meanwhile exports  of GE-free soybeans from Brazil
     to Europe are booming, with sales rising from 3.1 million tons to
     5.4 million tons over the past year. (Organic View, Vol. 1 No.
     18, 8 Dec 1999)

4.6. CLAIM: SEGREGATING NON-GE CROPS IS IMPOSSIBLE OR VERY EXPENSIVE

          + Complicating the issue, GE DNA or proteins can disappear
     during processing, so products can test negative despite their GE
     origins. At the same time, even a sprinkling of GE cornmeal or
     soy flour from a previous shipment can make an entire grain silo
     or rail car of otherwise non-GE food test falsely positive as GE.
     (Rick Weiss, Washington Post, 15 August 1999)

          ** Traders estimate purchasing costs for U.S. corn by
     Japanese end-users could rise as much as 50 percent if they seek
     non-GM crops. As for U.S. soybeans, purchasing costs by Japanese
     users are expected to rise by about 30 percent. (Aya Takada,
     Reuters, 24 Aug 1999)

          - Multinational grain marketer Archer Daniels Midland
     recently announced that it will separately market non-GE soybeans
     and will reject any GE corn not accepted in Europe. (See:
     "Wake-up call for biotech foods", Wisconsin State Journal, 22 Apr
     1999)

          - The Korean Bean Processing Association and the Korea
     Soybean Food Association said Thursday that they want to
     cultivate non-GM beans through free contracts with farming groups
     in the U.S., Canada and Australia... Meanwhile the Korea Consumer
     Protection Board said Wednesday that a GM bean ingredient has
     been found in 18 tofu (bean curd) products out of 22 examined, or
     81.8 percent, and many famous tofu makers were also found to have
     used GM beans imported from the U.S. (Asia Pulse, 4 Nov 1999)

          - Reuters news service reported on Oct. 29 Canadian Wheat
     Board chief, Greg Arason, saying that the giant Canadian grain
     exporting agency "must mobilize to identify and segregate GM
     wheat and barley from natural grain," to reassure consumers and
     safeguard Canada's multi-billion dollar wheat export market.
     Although GE wheat has not yet been commercialized, Monsanto and
     other companies hope to market GE wheat in a few years. (Organic
     View, Vol. 1 No. 18, 8 Dec 1999)

          - Reuters news service in Paris reported on Dec. 1 that
     Minneapolis-based grain commodities giant Cargill is "studying
     whether to adopt a system that would segregate GM soybeans from
     non-GM organisms for the purpose of supplying European
     consumers." Apparently Archer Daniels Midland and other grain
     traders' booming sales of GE-free soybeans and corn are starting
     to cut in to Cargill's profit margins. Both Cargill, ADM, and the
     rest of the firms that make up the international grain cartel now
     see the writing on the wall. (Organic View, Vol. 1 No. 18, 8 Dec
     1999)

         - US-based Burger King told Farmers Weekly that although it
     has not banned GM foods, no GM ingredients are used in its
     products, including French fries. (Farmers Weekly, 3 Dec 1999)

          + Europe's banning of GE-foods is simply a protectionist
     move. It is a trade issue, not a health issue.

          - Even analysts from Deutsche Bank, the largest investment
     bank in the world, who were themselves willing to concede that
     GE-foods were safe, were telling their investors to sell their
     Pioneer stocks, because the health concerns of Europeans are
     real, not imagined. (http://www.dmg.com/central/ver40/index.html)
     In fact, not only Europeans but also Americans have called for a
     recall of GE-foods on the market. (See: anti-FDA lawsuit)

          + Segregation is going to be very expensive. The consumers
     will eventually realize that the cost of segregation is
     prohibitive and they will accept mixed foods.

          - No segregation costs will be incurred in countries and
     areas which have so far refused to commercialize or even
     field-test GE-crops. These areas will therefore enjoy a huge
     advantage compared to those who jumped early into the GE-crop
     bandwagon. Other countries should learn from this experience and
     stop even the field-testing of GE-crops until all the necessary
     studies in biologically confined laboratories have been done and
     there is widespread scientific consensus on the safety of a GE
     product to be released.

4.10. OTHERS

5.   LEGAL CLAIMS: THE GE INDUSTRY IS STRICTLY REGULATED BY GOVERNMENTS

          - Summary: The collusion of corporations who are in a hurry
     to recover their investments in GE research and governments which
     are heavily targetted by corporate lobbyists is forcing GE crops
     on farmers and GE foods on consumers.

          - Lord Sainsbury, the UK Minister of Science, and member of
     the Supermarket chain family, was revealed to have had
     confidential discussions with Monsanto representatives at key
     points over the last months. Sainsbury was further shown to have
     strong personal business interests in the genetic engineering
     food industry. He is a shareholder and investor in GE companies.
     His own company, Diatech, is the patent holder of the cauliflower
     mosaic promoter, which is believed to be at the centre of the
     Pusztai/Rowett Institute controversy. Environmental groups have
     called for his resignation. (See: Guardian UK, 16 Feb 1999)

5.1. CLAIM: LABELLING IS NOT NECESSARY

          + One can always choose not to eat GE food.

          - Because GE food remains unlabeled, consumers cannot choose
     between GE and non-GE food. Should health problems arise, it will
     be difficult to trace their source. Lack of labels also helps
     shield firms that could be potentially liable. (Lappe, M and B.
     Bailey l998. Against the grain: biotechnology and the corporate
     takeover of food. Common Courage Press, Monroe, Maine. 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)

          + "We strongly oppose efforts to have mandatory labelling or
     segregation of genetically engineered products." (US Sec of
     Agriculture Dan Glickman, Dec 1998)

          + Food processors, too, have lobbied against labeling these
     goods. In Maine, where labeling legislation was being considered,
     the Grocery Manufacturers of America testified recently that "the
     FDA has determined that biotechnology-enhanced foods are
     equivalent to foods developed through crossbreeding and
     traditional methods. Thus, compulsory labeling provides no
     significant or useful information to consumers. In fact,
     mandatory labeling of biotechnology products has the negative
     impact of misleading consumers to believe foods derived from
     biotechnology are harmful."

          + With European protests fresh in their minds, U.S. biotech
     firms made a plea to the U.S. government recently: Defend U.S.
     rules that keep GM foods unlabeled or risk a consumer backlash at
     home. "We said to them that we really needed their voice because
     we don't want this to spread to the United States," said Phillips
     of the Biotechnology Industrial Organization. (St. Louis
     Post-Dispatch, Washington Bureau, 11 Aug 1999)

          - U.S.: Glickman also said the administration was
     considering asking the food industry to do voluntary information
     labeling, a practice strongly opposed by the biotech industry but
     one that has been demanded by the Europeans and some American
     consumers. (Marian Burros, Reuters News Service, 14 Jul 1999)

          - U.S.: The government said yesterday that labels were
     likely to be required on U.S. GE foods to give consumers more
     information. "Some type of informational labeling is likely to
     happen," Agriculture Secretary Dan Glickman said in a speech.
     (Reuters News Service, 14 Jul 1999)

          - U.S.: Nonprofit Mothers for Natural Law, of Fairfield,
     Iowa, submitted nearly 500,000 signatures to federal officials
     calling for mandatory labeling of GE foods at a June 17 event in
     Washington, D.C. (Aberdeen American News, S.D.; Knight
     Ridder/Tribune Business News, 1999)

          - U.S.: Even Americans who do not necessarily oppose GE
     believe that such products should be labeled. In a survey by the
     European company Novartis, more than 90 percent called for
     labeling. In addition, more than 500,000 people signed a petition
     to the FDA demanding mandatory labeling of such foods. The Center
     for Food Safety, a nonprofit advocacy group, has filed a lawsuit
     against the FDA to reclassify genetic modification as an additive
     that would require labeling. When the Agriculture Department
     proposed organic food regulations, more than 280,000 people filed
     comments protesting the inclusion of GM foods as organic. (Marian
     Burros, Reuters News Service, 14 Jul 1999)

          - U.S.: The Sierra Club declared with a flourish last week
     that it is joining the debate on GM food. The group's president,
     Carl Pope, wrote to President Clinton that the 550,000-member
     club wants mandatory labeling of GM products. (St. Louis
     Post-Dispatch, Washington Bureau, 11 Aug 1999)

          - U.S. Lawmakers seek labeling for GE food: Everybody who
     eats food made in America deserves to know what's in it, a
     bipartisan group of lawmakers said as they offered legislation to
     create special food labels. "Today's limited scientific knowledge
     warrants allowing consumers to make a better, more informed
     choice," said Rep. Dennis Kucinich, D-Ohio, leader of an effort
     to identify for the marketplace all GE food. (AP, 11 Nov 1999)

          -- Hironori Kijima, director-general of the Japan Tofu
     Association, expects GM labelling will create annual demand for
     300,000 tonnes of non-GM soybeans from Japanese soybean curd
     makers. Japan imported 2.45 million tonnes of soybeans in the
     first half of 1999, of which imports from the U.S. accounted for
     2.11 tonnes or 86.2 percent. In the same period Japan imported
     9.13 million tonnes of corn, of which imports from the U.S.
     accounted for 8.82 million tonnes or 96.5 percent. "We want to
     avoid the GM label as it could hurt the image of our products. We
     plan to switch to non-GM soybeans," Kijima said. (Aya Takada,
     Reuters, 24 Aug 1999)

          - U.K.: In May 1999, the British Medical Association, which
     counts some 80% or nearly 115,000 of Britain's medical doctors,
     issued an official statement 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
     (See: "The Impact of Genetic Modification on Agriculture, Food
     and Health", British Medical Association, May 1999)

          - SOUTH KOREA: The Korea Consumer Protection Board said
     last Thursday its survey had found that 94.7 percent of the total
     526 survey respondents said labelling for GM foods was necessary
     - 71.5 percent said all the time and 23.2 percent in some cases.
     (Reuters, Seoul, 9 Sep 1999)

          - ASIA: Despite biotech industry and US govt complaints,
     mounting public pressure has forced regulatory authorities in
     Australia, New Zealand, South Korea, and Japan to begin to
     implement programs of mandatory labeling of GE foods. Although
     consumer and public interest groups in these countries have
     criticized proposed labeling rules as incomplete and riddled with
     loopholes, US trade officials are "concerned" about the possible
     loss of "billions of dollars" in US grain exports to the region,
     according to a Sep 1 Reuters story. Similar labeling demands are
     building in Malaysia and the Philippines, while farm and consumer
     groups in India have called for an outright ban on GE crops and
     imports. (See: Cummins, Ronnie and Ben Lilliston, Campaign for
     Food Safety News #22, 21 Oct 1999) <http://www.purefood.org;
     http://www.organicconsumers.org>

          - The 15-country European Union, as well as Australia and
     New Zealand, has ordered the labeling of foods with modified DNA.
     The Japanese government has just published a list of 30 GM foods,
     including tofu, that soon must carry labels. (St. Louis
     Post-Dispatch, Washington Bureau, 11 Aug 1999)

          - E.U.: That problem of being able to back up a claim that a
     food either contains or does not contain GE ingredients has
     plagued regulators in the European Union, where a law went into
     effect in September saying all GM foods must be labeled. (Rick
     Weiss, Washington Post, 15 August 1999)

          - Last summer, two consumer groups sued the US FDA, claiming
     that the agency's failure to institute a labeling regimen for GM
     food is in violation of the Food, Drug and Cosmetic Act. The law
     demands that food additives not "generally recognized as safe" be
     labeled. This spring, activists gathered half-million signatures
     calling for labeling of GM food and submitted them to Congress
     and other officials. (Rick Weiss, Washington Post, 15 August
     1999)

          - U.S.: The no-labels policy hinges on a decree by the FDA
     in 1992. The FDA rules that food from new plant varieties is
     "generally recognized as safe" (GRAS) and that it is no different
     from conventional food in nutrition or in storage and handling
     needs. So, no special labeling is needed. That was 4 years before
     farmers, pushed by Monsanto and other biotech firms, began sowing
     millions of acres with GM soybeans and corn. Neither the FDA nor
     US food distributors anticipated the anti-GMO resistance abroad.
     Now the chickens are coming home to roost, with a strong debate
     over the adequacy of American food labeling. (See: St. Louis
     Post-Dispatch, Washington Bureau, 11 Aug 1999)

          - Countries which have adopted mandatory labelling: UK,
     Australia-New Zealand Food Standards Council (Dec 1998),

          - The EU has issued a directive requiring the mandatory
     labelling of all GM crops and foods in the market

          - Countries which are considering mandatory labelling:
     Japan, South Africa, Philippines

          - In Japan, 2,300 out of 3,300 local governments have asked
     the national government to require mandatory labeling of GM food
     (See: "Wake-up Call for Biotech Foods," Wisconsin State Journal,
     22 Apr 1999)

          - Jusco Co Ltd said it will become the first major Japanese
     supermarket operator to label food products based on the genetic
     origin of the crops used. Jusco, which operates over 300 stores
     nationwide, said it has decided to start labelling GE food before
     the government's label requirements are implemented from 2001,
     because of requests from consumers. (Reuters, Tokyo, 8 Sep 1999)

          + Labelling is a form of trade discrimination.

          + Most food processors and retailers are opposed to
     labeling. They note that U.S. regulators have deemed GM food
     safe; they warn that labels could cost consumers millions of
     dollars. Mandatory labels, they say, would wrongly imply
     questions about the safety or nutritional value of these foods.
     "The concern," said Carl Feldbaum, president of the Biotechnology
     Industry Organization, "is that a label would be seen as a
     stigma, like a skull and crossbones." The industry is also wary
     of labels saying "GE free," because such labels might imply
     superiority, as in "fat free." The Grocery Manufacturers of
     America (GMA) recently announced that it and other groups would
     initiate a $1 million advertising and educational campaign to
     counter the nascent U.S. anti-biotech and pro-labeling movements.
     (Rick Weiss, Washington Post, 15 August 1999)

          - Consumers have a right to know and to choose what they
     are eating. In the U.S., labelling falls under First Amendment
     freedoms to exchange information. (See: Philip Bereano, Seattle
     Times, Op Ed: "The Right to Know What We Eat," 11 Oct 1998)

          - RBGH: In 1993, Ben & Jerry's triggered a 3-year legal
     battle by labeling its milk products as free from rBGH, a hormone
     that boosts milk production. "People can say 'dolphin-free tuna'
     and 'stone-ground wheat,' " said Liz Bankowski, a senior director
     for the company in South Burlington, Vt. "We felt strongly that
     people have the right to know how their milk is produced." After
     tangling with federal and state regulators over the issue, Ben &
     Jerry's won the right to keep the label as long as it is
     accompanied by a disclaimer saying the FDA considers the milk
     equivalent to conventional milk, and that in any case there is no
     known way of testing milk to confirm whether it is really free of
     the offending hormone. (Rick Weiss, Washington Post, 15 August
     1999)

          - Below is a list of processed foods that tested positive
     for GE ingredients (September 1999). These tests were not
     "safety" tests; they were only to establish the presence of
     unlabeled GE ingredients. (NYTimes full page ad October 18, 1999)

          - Frito-Lay Fritos Corn Chips * Bravos Tortilla Chips *
     Kellogg's Corn Flakes * General Mills Total Corn Flakes Cereal *
     Post Blueberry Morning Cereal * Heinz 2 Baby Cereal * Enfamil
     ProSobee Soy Formula * Similac Isomil Soy Formula * Nestle
     Carnation Alsoy Infant Formula * Quaker Chewy Granola Bars *
     Nabisco Snackwell's Granola Bars * Ball Park Franks * Duncan
     Hines Cake Mix * Quick Loaf Bread Mix * Ultra Slim Fast * Quaker
     Yellow Corn Meal * Light Life Gimme Lean * Aunt Jemima Pancake
     Mix * Alpo Dry Pet Food * Gardenburger * Boca Burger Chef Max's
     Favorite * Morning Star Farms Better'n Burgers * Green Giant
     Harvest Burgers (now called Morningstar Farms) * McDonald's
     McVeggie Burgers * Ovaltine Malt Powdered Beverage Mix * Betty
     Crocker Bac-Os Bacon Flavor Bits * Old El Paso Taco Shells *
     Jiffy Corn Muffin Mix [Sources: Genetic ID (an independent
     testing firm) and Consumer Reports (September 1999).]
     <http://www.turnpoint.org>

          - List of GE-foods in the U.S.: * Canola (oilseed rape) *
     Chicory, red hearted (Radicchio) * Corn * Cotton * Papaya *
     Potato * Soybean * Squash * Tomato (Source: Union of Concerned
     Scientists) <http://www.turnpoint.org>

          - A high percentage of the following ingredients have been
     made from GE plants, and are commonly found in processed foods: *
     Soy flour * Soy oil * Lecithin * Soy protein isolates and
     concentrates * Corn flour * Corn starch * Corn oil * Corn
     sweeteners & syrups * Cottonseed oil * Canola oil
     <http://www.turnpoint.org>

5.2. CLAIM: THE U.S. HAS THE STRICTEST FOOD REGULATIONS IN THE WORLD

          + The U.S. FDA has determined that GE crops are as safe as
     their conventional counterparts. The U.S. has one of the most
     stringent food regulatory regimes in the world.

          - In February 1999, the Center for Food Safety sued the FDA
     to have all GE foods taken off the market on the grounds that
     they are neither properly labelled nor safety-tested, and that
     lack of mandatory labeling illegally restricts the freedom of
     choice of those who would choose - on religious or ethical
     grounds - to avoid GE foods. (http://www.icta.org)

          - In May 1998, a coalition of public interest groups,
     scientists, and religious leaders filed a landmark lawsuit
     against the U.S. Food and Drug Administration to obtain mandatory
     safety testing and labeling of all GE foods (Alliance for
     Bio-Integrity, et. al. v. Shalala). Nine eminent life scientists
     joined the coalition in order to emphasize the degree to which
     they think FDA policy is scientifically unsound and morally
     irresponsible. Now, the FDA's own files confirm how well-founded
     are their concerns. The FDA was required to deliver copies of
     these files-totaling over 44,000 pages-to the plaintiffs'
     attorneys. The FDA's records reveal it declared GE foods to be
     safe in the face of disagreement from its own experts-all the
     while claiming a broad scientific consensus supported its stance.
     Internal reports and memoranda disclose: (1) agency scientists
     repeatedly cautioned that foods produced through recombinant DNA
     technology entail different risks than do their conventionally
     produced counterparts and (2) that this input was consistently
     disregarded by the bureaucrats who crafted the agency's current
     policy, which treats GE foods the same as natural ones. Besides
     contradicting the FDA's claim that its policy is science-based,
     this evidence shows the agency violated the U.S. Food, Drug and
     Cosmetic Act in allowing GE foods to be marketed without testing
     on the premise that they are generally recognized as safe by
     qualified experts. The FDA admits it is operating under a
     directive "to foster" the U.S. biotech industry; and this
     directive advocates the premise that GE foods are essentially the
     same as others. However, the agency's attempts to bend its policy
     to conform with this premise met strong resistance from its own
     scientists, who repeatedly warned that genetic engineering
     differs from conventional practices and entails a unique set of
     risks. Numerous agency experts protested that drafts of the
     Statement of Policy were ignoring the recognized potential for
     bioengineering to produce unexpected toxins and allergens in a
     different manner and to a different degree than do conventional
     methods. Besides violating basic canons of ethics, the FDA's
     behavior flagrantly violates the U.S. Food, Drug and Cosmetic
     Act, which mandates that new food additives be established safe
     through testing prior to marketing. While the FDA admits that GE
     organisms fall under this provision, it claims they are exempt
     from testing because they are "generally recognized as safe"
     (GRAS), even though it knows they are not recognized as safe even
     by its own scientists let alone by a consensus in the scientific
     community. (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)

          - The FDA's records reveal it declared GE foods to be safe
     in the face of disagreement from its own experts - all the while
     claiming a broad scientific consensus supported its stance.
     Internal reports and memoranda disclose that: 1) FDA scientists
     repeatedly cautioned that foods produced through recombinant DNA
     technology entail different risks than do their conventionally
     produced counterparts; and 2) this input was consistently
     disregarded by the bureaucrats who crafted FDA's policy, to treat
     GE-foods the same as natural ones. (See: Statement by Steven M.
     Druker, J.D., executive director of the Alliance for
     Bio-Integrity, lawsuit coordinator, in collaboration with the
     Legal Department of the Center for Technology Assessment in
     Washington, D.C.).

          - FDA's own scientists repeatedly warned that genetic
     engineering differs from conventional practices and entails a
     unique set of risks. Numerous FDA experts protested that drafts
     of the Statement of Policy were ignoring the recognized potential
     for bioengineering to produce unexpected toxins and allergens in
     a different manner and to a different degree than do conventional
     methods.

          - Dr. Louis Priybl (FDA Microbiology Group): "There is a
     profound difference between the types of unexpected effects from
     traditional breeding and genetic engineering which is just
     glanced over in this document." He added that several aspects of
     gene splicing "...may be more hazardous." (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)

          - Dr. Linda Kahl (FDA compliance officer): The FDA was
      "...trying to fit a square peg into a round hole ... [by] trying
      to force an ultimate conclusion that there is no difference
      between foods modified by genetic engineering and foods modified
      by traditional breeding practices."  She said: "The processes of
      genetic engineering and traditional breeding are different, and
      according to the technical experts in the agency, they lead to
      different risks." (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)

          - Dr. Jim Maryanski (FDA Biotechnology Coordinator)
     acknowledged there is no consensus about the safety of GE foods
     in the scientific community at large, and FDA scientists advised
     they should undergo special testing, including toxicological
     tests. (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)
 
          + Trust the scientists who have assured us that GE food is
     safe.

          - The money for scientific research on GE comes from either
     the biotechnology companies or the government. Both are committed
     to the promises of biotechnology. This means that even when
     scientists have concerns about the safety or commercial
     application of the technology, it is often hard for them to risk
     their careers by being openly critical. (See: "13 Myths about
     Genetic Engineering", Consumers for Education about Genetic
     Engineering, Dunedin Polytech, as posted by
     <dleech@mail.coin.missouri.edu> on the SANET list)

          - A "revolving door" exists between the biotech industry and
     U.S. regulatory bodies, seriously compromising the U.S.
     regulatory process. Many other countries rely on the U.S.
     process, so their approvals for GE field-testing or
     commercialization have been compromised too.

          - Monsanto's top dairy scientists Margaret Miller and
     Suzanne Sechen, were hired by the US FDA to review Monsanto's
     research in the process of approving rBGH.

          - Monsanto's lawyer Michael Taylor was hired by the US FDA
     to write the labelling laws governing rBGH.

          - Suzanne Wuerthele (BS in Biology, MA in Teaching Science,
     PhD in Pharmacology, 7 years of post-doctoral work,
     board-certified toxicologist, worked in a U.S. EPA regional
     office for 13 years, a national expert in toxicology and risk
     assessment): I was introduced to GE a few years back when I was
     shown the "risk assessment" for a GE nitrogen-fixing bacteria,
     Rhizobium meliloti... I learned some very disturbing things about
     regulation of GE:

          o EPA has an official position of "fostering" biotechnology;

          o There is no process - across all U.S. federal agencies -
            to evaluate the hazards of GE organisms (we have such a
            process for chemicals and it works pretty well). For GE,
            however, no formal risk assessment methodologies. No
            science policies... No conferences where scientific issues
            of GE are debated. No understanding of the full range of
            hazards from GE organisms. No discussion of or
            consultation with the public to determine what constitute
            "unacceptable risk". No method to even measure magnitude
            of risks. Etc.

          o When peer review panels are put together, they are not
            necessarily unbiased. They can be filled with GE
            proponents or confined to questions which avoid the
            important issues, so that a predetermined decision can be
            justified.

     ...we are confronted with the most powerful technology the world
     has ever known, and it is being rapidly deployed with almost no
     thought whatsoever to its consequences. In fact, we don't even
     know yet the full extent of what it can do to the environment and
     to our health. The few scientists in regulatory agencies who are
     concerned are ignored or their concerns are dismissed. Or they
     are told to be silent. Good risk assessment and good science,
     which if they were used rationally, would tell us that we're
     making a big mistake, is not being used or is being twisted.
     (Susan Wuerthele, toxicologist)

          - David W. Beier, former head of Government Affairs for
     Genentech, Inc., now chief domestic policy advisor to Al Gore,
     Vice President of the United States.
     (http://www.edmonds-institute.org/door.html)

          - Linda J. Fisher, former Assistant Administrator of the
     United States Environmental Protection Agency's Office of
     Pollution Prevention, Pesticides, and Toxic Substances, now Vice
     President of Government and Public Affairs for Monsanto
     Corporation. (http://www.edmonds-institute.org/door.html)

          - Michael A. Friedman, M.D., former acting commissioner of
     the United States Food and Drug Administration (FDA) Department
     of Health and Human Services, now senior vice-president for
     clinical affairs at G. D. Searle & Co., a pharmaceutical division
     of Monsanto Corporation.
     (http://www.edmonds-institute.org/door.html)

          - L. Val Giddings, former biotechnology regulator and
     (biosafety) negotiator at the United States Department of
     Agriculture (USDA/APHIS), now Vice President for Food &
     Agriculture of the Biotechnology Industry Organization (BIO).
     (http://www.edmonds-institute.org/door.html)

          - Marcia Hale, former assistant to the President of the
     United States and director for intergovernmental affairs, now
     Director of International Government Affairs for Monsanto
     Corporation. (http://www.edmonds-institute.org/door.html)

          - Michael (Mickey) Kantor, former Secretary of the United
     States Department of Commerce and former Trade Representative of
     the United States, now member of the board of directors of
     Monsanto Corporation.
     (http://www.edmonds-institute.org/door.html)

          - Josh King, former director of production for White House
     events, now director of global communication in the Washington,
     D.C. office of Monsanto Corporation.
     (http://www.edmonds-institute.org/door.html)

          - Terry Medley, former administrator of the Animal and Plant
     Health Inspection Service (APHIS) of the United States Department
     of Agriculture, former chair and vice-chair of the United States
     Department of Agriculture Biotechnology Council, former member of
     the U.S. Food and Drug Administration (FDA) food advisory
     committee, and now Director of Regulatory and External Affairs of
     Dupont Corporation's Agricultural Enterprise.
     (http://www.edmonds-institute.org/door.html)
 
          - Margaret Miller, former chemical laboratory supervisor for
     Monsanto, now Deputy Director of Human Food Safety and
     Consultative Services, New Animal Drug Evaluation Office, Center
     for Veterinary Medicine in the United States Food and Drug
     Administration (FDA).
     (http://www.edmonds-institute.org/door.html)

          - Michael Phillips, recently with the National Academy of
     Science Board on Agriculture, now head of regulatory affairs for
     the Biotechnology Industry Organization.
     (http://www.edmonds-institute.org/door.html)
 
          - William D. Ruckelshaus, former chief administrator of the
     United States Environmental Protection Agency (USEPA),,now (and
     for the past 12 years) a member of the board of directors of
     Monsanto Corporation.
     (http://www.edmonds-institute.org/door.html)

          - Michael Taylor, former legal advisor to the United States
     Food and Drug Administration (FDA)'s Bureau of Medical Devices
     and Bureau of Foods, later executive assistant to the
     Commissioner of the FDA, still later a partner at the law firm of
     King & Spaulding where he supervised a nine-lawyer group whose
     clients included Monsanto Agricultural Company, still later
     Deputy Commissioner for Policy at the United States Food and Drug
     Administration, and later with the law firm of King & Spaulding.,
     now head of the Washington, D.C. office of Monsanto Corporation.*
     (http://www.edmonds-institute.org/door.html)

          - Lidia Watrud, former microbial biotechnology researcher at
     Monsanto Corporation in St. Louis, Missouri, now with the United
     States Environmental Protection Agency Environmental Effects
     Laboratory, Western Ecology Division.
     (http://www.edmonds-institute.org/door.html)

          - Jack Watson, former chief of staff to U.S. President Jimmy
     Carter, now a staff lawyer with Monsanto Corporation in
     Washington, D.C. (http://www.edmonds-institute.org/door.html)

          - Clayton K. Yeutter, former Secretary of the U.S.
     Department of Agriculture, former U.S. Trade Representative (who
     led the U.S. team in negotiating the U.S. Canada Free Trade
     Agreement and helped launch the Uruguay Round of the GATT
     negotiations), now a member of the board of directors of Mycogen
     Corporation, whose majority owner is Dow AgroSciences, a wholly
     owned subsidiary of The Dow Chemical Company.
     (http://www.edmonds-institute.org/door.html)

          - Larry Zeph, former biologist in the Office of Prevention,
     Pesticides, and Toxic Substances, U.S. Environmental Protection
     Agency, now Regulatory Science Manager at Pioneer Hi-Bred
     International. (http://www.edmonds-institute.org/door.html)

5.3 CLAIM: BIOTECH FIRMS FOLLOW THE REGULATIONS STRICTLY

          - Monsanto has been condemned for making 'wrong, unproven,
     misleading and confusing' claims in a #1m advertising campaign.
     The Advertising Standards Authority, the industry's official
     watchdog, criticised the firm for wrongly giving the impression
     that GE potatoes and tomatoes had been tested and approved for
     sale in Britain. ASA also dismissed Monsanto's assertion that GM
     crops were grown 'in a more environmentally sustainable way' than
     ordinary crops as unproven. (John Arlidge, Observer (London), 28
     Feb 1999)

          - Almost 200 cotton farmers in Georgia, Florida, and North
     Carolina are suing Monsanto for damages after crop failures of
     Monsanto's Bt and Roundup Ready cotton seeds. In a separate
     lawsuit 25 cotton farmers in Texas, Oklahoma, Mississippi, and
     Louisiana are suing Monsanto for fraud and misrepresentation -
     also in regard to Bt cotton crop failures. (See: Augusta
     Chronicle, Georgia, 25 Jan 1999)

          - Biotech giant Monsanto exported Canadian GE potatoes to
     Ukraine, ignoring the domestic laws which require environmental
     impact assessment, according to a Greenpeace report published
     today... Monsanto NewLeaf potatoes were exported to Ukraine in
     1997 and 1998 with the help of Solanum-PEI, a joint venture
     company created by Monsanto and the government of PEI. (See:
     Canada Newswire, 17 Sep 1999)

          - Monsanto was fined #17,000 by magistrates in Lincolnshire
     for failing to maintain a 6-metre pollen boundary around a field
     trial of GE oilseed rape. The crops were all destroyed. Although
     Monsanto pleaded guilty, the company said that the mistake was
     entirely the responsibility of contractors. The seed producers
     for the trial, Perryfield Holdings, were fined #14,000 and
     ordered to pay #5,000 costs in a prosecution by the Health and
     Safety Inspectorate. (Source: The Guardian, February 18 1999)

          - The Senate Agriculture Committee is demanding that new
     studies of BST be carried out following allegations that BST
     files were stolen at Health Canada, and that scientists
     expressing doubts about Monsanto's safety tests have been
     pressurized to water down their comments. Health Canada refused
     to approve rBST in Canada in January 1999. Controversy has also
     erupted following evidence that a scientist representing Canada
     on the Jecfa panel was suggested by Monsanto.

          - John Hermann, chair of the Joint Expert Committee on Food
     Additives (Jecfa), which reports back to the Codex Commission,
     has admitted that an FDA official on the panel passed
     confidential EU documents to Monsanto. The official, Dr. Nick
     Weber, has been accused by Consumer's International of
     professional misconduct and 'breach of trust'. He was, however,
     defended by Hermann. It also appears that a former Monsanto rBST
     analyst participated in the Jecfa review and helped draft the
     Committee's report, although she did not take part in the actual
     vote approving rBGH. (Gregory Palast, UK Observer, 14 Mar 1999)

          -- Monsanto included false information about a GE crop in a
     safety assessment submitted to U.K. government advisers. The firm
     was forced to redo its research after it emerged last month that
     crucial information about the gene it proposed to put in a new
     strain of maize was incorrect. Monsanto was called "incompetent"
     by scientists of the U.K.'s influential Advisory Committee on
     Releases into the Environment (Acre). The committee accused
     Monsanto of submitting sloppy research, "poor interpretation" and
     work far below required standards. The agro-chemical company
     misdefined the gene it planned to insert into the maize which was
     genetically engineered to be resistant to Monsanto's Roundup
     herbicide. Minutes of Acre's meeting last month show that members
     were furious that Monsanto had asked them to approve a marketing
     application based on inaccurate information. Sources close to the
     meeting say Monsanto was called "incompetent" and that the
     standard of its work was "wholly unacceptable". Acre told
     Monsanto to do its research again after Monsanto scientists -
     asked for clarification about their research - realised that
     their "molecular data . did not support the conclusions". The
     minutes of the meeting, on 13 January 1999, deliver a sharp
     rebuke to Monsanto, saying that ". the molecular data submitted
     by the applicant did not support the conclusions regarding
     genomic organisation of the transgenes". The Monsanto application
     was last month approved by the UK after the company spent several
     months redoing its research and scientists concluded that the GM
     maize would not harm human or animal health. It will now be
     submitted to other European countries for assessment. But the
     decision to grant approval has proved controversial with other
     scientists who say that it casts doubt on other work carried out
     by Monsanto. "It's very worrying. This means that somebody
     somewhere in Monsanto is getting it wrong," said Janey White, a
     molecular biologist. The mistake also has international
     implications because Monsanto's maize is already grown in America
     and will soon be sold around the world. Monsanto has had to tell
     regulatory authorities in Japan and Europe, now considering an
     application to sell the GM maize, that its data is incorrect. The
     same GM maize is exported widely from America and is believed to
     be used in food sold in Britain. "It is our policy to advise all
     the relevant authorities of any new information," said Alistair
     Clemence, regulatory affairs manager for maize in Europe. "We
     haven't totally messed up, but there was a certain part of the
     gene sequence we hadn't defined properly." Licences to sell and
     plant GM crops in Britain are based on work done by the
     agrochemical companies themselves and not on independent tests
     carried out by the Government. (Marie Woolf, Sunday Independent,
     21 Feb 1999)

5.10. OTHERS

6.   MORAL CLAIMS: MORAL IMPERATIVES GUIDE GE TECHNOLOGIES

6.1. CLAIM: GE-CROPS WILL FEED THE WORLD'S HUNGRY

          + GE will make Third World agriculture more productive.

          - Most innovations in agricultural biotechnology have been
     profit-driven rather than need-driven. The real thrust of the GE
     industry is not to make third world agriculture more productive,
     but rather to generate profits (Busch, L., W.B. Lacey, J.
     Burkhardt and L. Lacey (1990) Plants, Power and Profit. Basil
     Blackwell, Oxford. 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) This is illustrated by reviewing the principal
     technologies on the market today: a) herbicide resistant crops
     such as Monsanto's "Roundup Ready"soybeans, seeds that are
     tolerant to Monsanto's herbicide Roundup, and b) Bt crops which
     are engineered to produce their own insecticide. In the first
     instance, the goal is to win a greater herbicide market-share for
     a proprietary product and in the second to boost seed sales at
     the cost of damaging the usefulness of a key pest management
     product (the Bt based microbial insecticide) relied upon by many
     farmers, including most organic farmers, as a powerful
     alternative to insecticides.

          - These technologies respond to the need of biotechnology
     companies to intensify farmers' dependence upon seeds protected
     by so-called" intellectual property rights," which conflict
     directly with the age-old rights of farmers to reproduce, share
     or store seeds. (Hobbelink, H. (1991) Biotechnology and the
     future of world agriculture. Zed Books, Ltd., London. p. 159. 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)
     Whenever possible corporations will require farmers to buy
     company's brand of inputs and will forbid farmers from keeping or
     selling seed. By controlling germplasm from seed to sale, and by
     forcing farmers to pay inflated prices for seed-chemical
     packages, companies are determined to extract the most profit
     from their investment. (Krimsky, S. and R.P. Wrubel (1996)
     Agricultural Biotechnology and the Environment: science, policy
     and social issues. University of Illinois Press, Urbana. 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)

          + Without GE-crops, we cannot feed the world's rapidly
     increasing population.

          - GE crop yields are in general no better than conventional
     crops and in some instances are even worse. (See yield discussion
     under economic claims.)

          - There is no relationship between the prevalence of hunger
     in a given country and its population. For every densely
     populated and hungry nation like Bangladesh or Haiti, there is a
     sparsely populated and hungry nation like Brazil and Indonesia.
     The world today produces more food per inhabitant than ever
     before. Enough is available to provide 4.3 pounds every person
     everyday: 2.5 pounds of grain, beans and nuts, about a pound of
     meat, milk and eggs and another of fruits and vegetables. The
     real causes of hunger are poverty, inequality and lack of access.
     Too many people are too poor to buy the food that is available
     (but often poorly distributed) or lack the land and resources to
     grow it themselves (Lappe, Collins and Rosset l998). (Lappe,
     F.M., J. Collins and P. Rosset (1998). World Hunger: twelve
     myths, p. 270. Grove Press, NY. 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)

          + GE crops will save the world from famine.
 
          - A major cause of famine is the unequal global distribution
     of food. Food mountains exist in much of the western world and
     food is regularly dumped.  Poor people have limited ability to
     buy either GE or non-GE food. There is no evidence that GE crops
     produce higher yields than conventional crops or that GE products
     will be cheaper. (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)
 
          - Dr. Geoffrey Clements (physicist and leader of the Natural
     Law Party, UK): "Perfectly safe natural alternatives are readily
     available, and no one believes the propaganda that GE crops are
     essential to help feed the hungry or to secure food stocks for
     the future. In fact, if the GE revolution is not halted and if
     the balance of Nature continues to be disrupted, we would well
     see the worst famines and disease of all time."

          - The dramatic effects of rotations and intercropping on
     crop health and productivity, as well as of the use of biological
     control agents on pest regulation have been confirmed repeatedly
     by scientific research. The problem is that research at public
     institutions increasingly reflects the interests of private
     funders at the expense of public good research such as biological
     control, organic production systems and general agroecological
     techniques . Civil society must request for more research on
     alternatives to biotechnology by universities and other public
     organizations (Krimsky and Wrubel l996).

          - Much of the needed food can be produced by small farmers
     located throughout the world using agroecological technologies
     (Uphoff, N and Altieri, M.A. l999 Alternatives to conventional
     modern agriculture for meeting world food needs in the next
     century. Report of a Bellagio Conference. Cornell International
     Institute for Food, Agriculture and Development. Ithaca, NY. 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)

          - New rural devt approaches and low-input technologies
     used by farmers and NGOs around the world are already making a
     significant contribution to food security at the household,
     national and regional levels in Africa, Asia and Latin America.
     (Pretty, J. Regenerating agriculture: Policies and practices for
     sustainability and self-relieance. Earthscan., 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)

          - Yield increases are being achieved by using approaches
     based on agroecological principles that stress diversity,
     synergy, recycling and integration; and social processes that
     stress community participation and empowerment. (Rosset, P. l999
     The multiple functions and benefits of small farm agriculture in
     the context of global trade negotiations. Institute for Food and
     Development Policy, Food First Policy Brief No.4. 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)

          - When such features are optimized, yield enhancement and
     stability of production are achieved, as well as a series of
     ecological services such conservation of biodiversity, soil and
     water restoration and conservation, improved natural pest
     regulation mechanisms, etc. (Altieri, M.A., P.Rosset and L.A.
     Thrupp. 1998 . The potential of agroecology to combat hunger in
     the developing world. 2020 Brief 55. International Food policy
     research Institute. 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)

          - Far from being a solution to the world's hunger problem,
     the rapid introduction of GE crops may actually threaten
     agriculture and food security. First, widespread adoption of
     herbicide-resistant seeds may lead to greater use of chemicals
     that kill weeds. Yet, many noncrop plants are used by small
     farmers in the third world as supplemental food sources and as
     animal feed. In the United States, the Fish and Wildlife Service
     has found that Roundup already threatens 74 endangered plant
     species. Biological pollution from GE organisms may be another
     problem. Monsanto is poised to acquire the rights to a genetic
     engineering technique that renders a crop's seeds sterile,
     insuring that farmers are dependent on Monsanto for new seed
     every year. Farming in the third world could be crippled if these
     genes contaminate other local crops that the poor depend on. And
     such genes could unintentionally sterilize other plants,
     according to a study by Martha Crouch, an associate professor of
     biology at Indiana University. Half the world's farmers rely on
     their own saved seed for each year's harvest. (Peter Rosset,
     "World Hunger: Twelve Myths")

          - The biotech industry's actual main motive is to create
     profit windfalls by increasing sales of their pesticides and
     dominating the entire food supply. For example, the patent on
     Monsanto's herbicide known as "Roundup" will expire soon.
     Monsanto has enticed farmers with their experimental GE crops to
     absorb and tolerate their chemical pesticides and their other
     crops which create their own pesticide internally. Monsanto,
     DuPont, and Novartis are also taking direct action to buy out and
     bring the world's largest seed companies under their control.
     (From: pmligotti@earthlink.net)

          + There are no alternatives to GE crops

          - The alternative to GE is ecological agriculture, with
     organic farming at its core. Since 1969, more than 800,000 farms
     have disappeared from America's landscape, as large corporate
     operations consumed smaller family-owned farms. By 2000, the U.S.
     Department of Agriculture predicts that half of all U.S. farm
     production will come from only 1 percent of all farms. For those
     wanting to preserve the livelihood of the family farm, few
     options for survival remain. One of the most viable is organic
     and natural farming, most successfully performed on small plots
     rather than thousands of acres. It's estimated that organic
     products alone will be a $6 billion economy by 2001, with sales
     of organic food growing between 20 percent and 25 percent
     annually. A Food Marketing Institute study reports that organic
     and natural foods are available at approximately 73 percent of
     grocery stores and supermarkets. Of shoppers surveyed in FMI's
     study, more than 50 percent said they purchase organic or natural
     foods at least once a month; 35 percent said they actively seek
     out products that are labeled as "organic"; and 63 percent look
     for products labeled "natural." Purchase of organic products is
     highest among consumers between 18 and 29 (31 percent), with a
     heavier concentration of sales in the West (34 percent),
     according to the 1998 Fresh Trends Report published by The
     Packer. (John Fetto, American Demographics, August 1999)

          - The Rodale Institute of Kutztown, Penn., recently
     completed a 15-year study comparing organic farming methods to
     conventional methods, published in the November 11, 1998, issue
     of the journal Nature. It concluded that yields from organic
     farming equal conventional yields after four years. Experts have
     shown that using pesticides does not guarantee increased yields.
     According to David Pimentel, professor of insect ecology and
     agricultural sciences at Cornell University, ``Although
     pesticides are generally profitable, their use does not always
     decrease crop losses. For example, even with the 10-fold increase
     in insecticide use in the United States from 1945 to 1989, total
     crop losses from insect damage have nearly doubled from 7% to
     13%''. (PRNewswire, 27 August 1999)

          - At the 12th (1999) annual Scientific Conference of the
     International Federation of Organic Agriculture Movements
     (IFOAM), more than 600 delegates from over 60 countries voted
     unanimously against the use of GMOs in food production and
     agriculture. The delegates called on all governments and
     regulatory agencies to immediately ban GE in agriculture and food
     production since it involves: 1) Negative and irreversible
     environmental impacts; 2) Release of organisms which cannot be
     recalled; 3) Removal of the right of choice, both for farmers and
     consumers; 4) Violation of farmers' fundamental property rights
     and endangerment of their economic independence; 5) Practices
     which are incompatible with the principles of sustainable
     agriculture as defined by IFOAM; 6) Unacceptable threats to human
     health. (See: )

          - US sales of organic foods have grown between 20 - 25%
     annually for the last 7 years, with overall sales of between $3.5
     and $4.2 billion.

6.2 CLAIM: LIFE PATENTS ARE NEEDED TO REWARD INNOVATION

          + Patents on life are necessary to enable biotech firms to
     recover their investments in developing GMOs

          - GMO patents will illegalize the age-old farmer practice
     of saving and sharing seeds.

          - A year ago, Monsanto sued Percy Schmeiser for illegally
     growing Monsanto's special GM canola, called "Roundup Ready." The
     68-year-old Percy, who has been farming in Saskatchewan for 40
     years, ushered me outside, walked to a hydro line, and showed me
     a growth of canary-yellow canola. "This is it," he said, then he
     took me to the north side of the building where another shoot of
     Roundup Ready GM canola was growing. "All over the place," he
     said. "It blows in the wind, cross-pollinates." He pulled off one
     of the flowers, popping open a pod of canola, displaying the
     freckle-sized, black seeds. "Little plant like this makes a
     minimum 4,000 seeds...maybe 10,000 seeds," he said. "Now they're
     not saying I stole their seed," Percy said. "Now they're saying
     it doesn't matter how the (Monsanto canola) gets into a farmer's
     field. Doesn't matter if it's blown onto the field or if it's by
     cross-pollination. They say it's their patent and if they find it
     on your field they'll take your crop, they'll sue you, they'll
     fine you." (Martin O'Malley, CBC News Online, 29 Sep 1999)

          - Edward Zielinski, a Saskatchewan farmer, is being charged
     with growing Monsanto GE canola without a licence. Zielinski
     claims that he unwittingly received and planted Monsanto canola
     from seed he swapped with another farmer in exchange for wheat.
     If found guilty, he could be forced to pay $29,000. He would also
     face a 3-year on-spot inspection of his fields by Monsanto patent
     enforcement and a gagging clause that would prevent him from
     disclosing the terms of the agreement. Zielinski's suit comes in
     the wake of a legal suit Monsanto has pinned on another
     Saskatchewan farmer, Percy Schmeiser, for allegedly growing
     Monsanto GE canola without a licence. Schmeiser, whose case comes
     before court in early autumn, maintains that the ReadyRoundUp
     canola pollinated his fields. (See: Sunday Independent, March 14
     1999)

          - There is an urgent need to challenge the patent system and
     IPR intrinsic to the WTO which not only provide MNCs with the
     right to seize and patent genetic resources, but that will also
     accelerate the rate at which market forces already encourage
     monocultural cropping with genetically uniform GM varieties.
     Based on history and ecological theory, it is not difficult to
     predict the negative impacts of such environmental simplification
     on the health of modern agriculture (Altieri l996). (See: "Ten
     reasons why biotechnology will not ensure food security, protect
     the environment and reduce poverty in the developing world";
     Miguel A. Altieri and Peter Rosset, Oct 1999)

          - USDA spent $229,000 of US taxpayers' money to create the
     new "technology protection system" with Delta and Pine Land
     Company. The research was done, according to the inventor himself
     (Melvin Oliver), to improve the bottom lines of U.S. firms.

          - Monsanto announced in October 1999 that it was dropping
     its Terminator seed program, confirming the effectiveness of the
     global campaign against the technology sterile GE-seeds.

          - According to RAFI, every major seed and agrochemical firm
     is developing its own version of Terminator seeds. Novartis,
     AstraZeneca, and Monsanto are among the MNCs who have sterile
     seeds in the pipeline; others like Pioneer Hi-Bred, Rhone
     Poulenc, and DuPont have seed technologies that could easily be
     turned into Terminators. The patents uncovered by RAFI reveal
     that companies are developing "suicide" seeds whose genetic
     traits can be turned on and off by an external chemical "inducer"
     mixed with the company's patented agrochemicals. In the
     not-so-distant future, farmers may be planting seeds that will
     develop into productive (but sterile) crops only if sprayed with
     a carefully prescribed regimen that includes the company's
     proprietary pesticide, fertilizer or herbicide. The latest
     version of Monsanto's suicide seeds won't germinate unless
     exposed to a special chemical, while AstraZeneca's technologies
     outline how to engineer crops to become stunted or otherwise
     impaired if not regularly exposed to the company's chemicals.
     Ignoring potential impacts on farmers around the world, the seed
     and agrochemical industry argues that GE seed sterility is highly
     beneficial to the environment because it will eliminate the
     problem of horizontal gene transfer - it will prevent
     cross-pollination and thus the escape of GE genes from transgenic
     plants to nearby weeds or wild relatives. Suicide seeds could
     eliminate the possibility of genetic pollution and conveniently
     offers a "green" rationale for acceptance of genetic seed
     sterility. Industry also argues that they can't continue to
     develop new, more productive varieties for agriculture unless
     they get a fair return on their investment. A RAFI report
     "Traitor Technology" provides an in-depth analysis of the seed
     sterility patents. For this study and a detailed chart of patent
     claims, visit RAFI's homepage at <http://www.rafi.org/>

          -- Pioneer Hi-Bred International Inc. is seeking to enforce
     its corn patent by suing an Iowa farm-supply dealership. Farm
     Advantage of Belmont, Iowa sold Pioneer's patented corn seed last
     year without its permission. Pioneer has sued Farm Advantage for
     reselling its corn seeds, since Pioneer's patent grants exclusive
     control over the licensing of its product. President of Farm
     Advantage, Marvin Redenius is arguing that the US Patent and
     Trademark Office acted illegally when it granted patents on GM
     plants. Since the first patent on a life-form was awarded in
     1980, an increasing number of scientists, environmental
     organizations, farm organizations, trade organizations, public
     health organizations, and other NGOs (non-governmental
     organizations) have opposed patents on the grounds that they are
     immoral and illegal. Pioneer is currently engaged in several
     other lawsuits, including a "germplasm misappropriation" suit
     against rival life science corporation Monsanto Co. "Pioneer has
     spent decades and billions of dollars developing the world's
     largest plant genetics library," claims Rick McConnell, Pioneer
     senior vice president for research and product development, in a
     February 1999 release. (Jon Akland, Research Director, Foundation
     on Economic Trends, 802-658-1472 phone 802-863-4665 fax)

6.3. CLAIM: GE TECHNOLOGIES WILL HELP THE INCURABLY SICK

          * According to New Scientist, US company GeneWorks of
     Michigan state has 50 to 60 GE birds. Some of these birds carry a
     gene enabling them to produce human growth factor in eggs, and
     others produce a human antibody which could be used to treat
     disease. Another US company. AviGenics, has birds which produce a
     cancer treating interferon. It says the gene - injected into bird
     embryos as a protein contained in a harmless virus - has already
     been passed on to further generations of birds, saving on
     repeating the process. (New Scientist, 13 Nov 1999)

          ** An intense effort to clone rhesus monkeys for medical
     research is underway in the U.S. Tanja Dominko at the Oregon
     Regional Primate Centre said: "We are working really hard to make
     it happen in any way we can." She said this would allow testing
     of new drugs and vaccines on genetically-identical animals, and
     success means a step nearer to human application. She admitted it
     may be years before they succeed in cloning monkeys, despite a
     narrow failure 3 years ago, when two monkeys were born after 166
     nuclear transfer attempts. But they were not identical as the
     nuclei came from different sources. Also, the cells used came
     from embryos, not adults. Dominko's colleague, Don Wolf said: "If
     we can do this in monkeys, most people will see the significance
     of that to humans." Primates are preferred as lab animals because
     they are closely related to humans. Rhesus monkeys are not an
     endangered species and their reproductive organs function almost
     identically to those of humans. Female rhesus monkeys' menstrual
     cycle is even as long as that of humans. This similarity, and the
     similar scarcity of eggs, would mean that any cloning technique
     successful in rhesus monkeys would likely be applicable to
     humans. (BBC, "Multiple monkey cloning attempt," 9 Apr 1999)

          + GE insulin has saved the lives of thousands of diabetics

          - The high incidence of diabetes correlates closely with
     high consumption of refined sugars. A preventive approach to
     diabetes control will reduce, if not eliminate, the need for GE
     insulin. The alarming trend today is that, increasingly, as food
     companies, chemical companies and pharmaceutical companies merge,
     the same giant firms are now creating both the causes of disease
     as well as their cure.

6.4. CLAIM: GE IS CONSISTENT WITH OUR ETHICAL BELIEFS

          - Vegetarians try to avoid all animal food; but without
     labeling they can't be sure that animal genes have not been
     inserted into their vegetables. Jews and Muslims have rigid laws
     against eating certain animals, yet their tomatoes or lettuce may
     one day contain pig genes. (NYTimes full page ad, 18 Oct 1999)

          - Some orthodox rabbis, for example, say their strict
     dietary laws require them to know when a foreign gene - say, a
     pig gene - has been spliced into their food. No pig genes have
     been put into crops, but one has been experimentally engineered
     into salmon to accelerate growth. (Rick Weiss, Washington Post,
     15 August 1999)

          - What of the suffering of genetically altered animals? One
     GE "super pig" was unable to walk or stand. A GE "super salmon"
     had a monster head and couldn't swim, eat, or breathe properly.
     There are hundreds of such outcomes. (NYTimes full page ad, 18
     Oct 1999)

          - More than two dozen genes from human beings have already
     been engineered into various animals. If we eat them, can we call
     it cannibalism? (NYTimes full page ad, 18 Oct 1999)

6.5. CLAIM: RELIGIOUS AUTHORITIES APPROVE OF MOST GE TECHNOLOGIES

          + Vatican experts voiced a "prudent yes" to GE plants and
     animals, but restated Church objections to human cloning and the
     modification of the human genetic code. Members of the Pontifical
     Academy for Life presented on Oct. 12 two volumes of documents on
     ethics and genetic technology, after more than two years of
     discussion and study. "We are increasingly encouraged that the
     advantages of genetic engineering of plants and animals are
     greater than the risks. The risks should be carefully followed
     through openness, analysis and controls, but without a sense of
     alarm," said Bishop Elio Sgreccia, vice president of the
     pontifical academy. "We give it a prudent 'yes,'" he said.  "We
     cannot agree with the position of some groups that say it is
     against the will of God to meddle with the genetic make-up of
     plants and animals." (CNS, 3 Nov 1999)
     <http://www.inverizon.com/nnews1.htm>

          - You cannot resort to authority on moral issues. This is a
     matter to be settled within every individual's conscience, taking
     into account the irreversibility of GE advances.

6.10. OTHERS

7.   QUALITY CLAIMS: THE QUALITY OF GE-FOODS IS BETTER

7.1. CLAIM: GE FOODS ARE HEALTHIER AND MORE NUTRITIOUS

          - No GE food commercialized to date has been shown to be
     more nutritious than non-GE food.  Most GE crops are only
     designed to be resistant to specific herbicides, to produce their
     own insecticides or to have an increased shelf life. (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)

          - 71% of GE acreage is for HT-soya, which encourages farmers
     to use more herbicides. Another 25+% is for Bt crops, which puts
     a toxin in the food itself.

          - RBGH: The use of rBGH to stimulate milk production in cows
     resulted in udder inflamations, infections and other problems
     affecting milk quality (See: ) (http:)

          + Many fungal toxins are harmful to human health (to name a
     few species: Aspergillus flavus, Claviceps purpurea etc), so
     fungi-resistant GE plants could be even safer than their parental
     strain.

7.2. CLAIM: VIT. A AND IRON-RICH RICE WILL SOLVE A WORLDWIDE PROBLEM

          + Most rice varieties today lack iron and vit. A, a health
     problem for people who eat rice daily. In 1999, Swiss researchers
     announced a GE rice variety with more beta-carotene, which the
     body metabolizes to vit. A. Work is also underway on an iron-rich
     rice variety, to be given free to poor farmers in dev. countries
     thru the Rockefeller Foundation. See: <www.rockfound.org> (From:
     m.j.cohen@cgiar.org)

          + BC (beta-carotene) rice will help solve the widespread
     problem of Vit. A deficiency.

          + Iron-rich rice will help solve the widespread problem of
     iron deficiency.

          - The BC rice and the iron-rich rice contain the CaMV
     promoter which, according to scientists Mae Wan Ho, Angela Ryan
     and Joe Cummins, should not be used for GE transformations. They
     also use an antibiotic-resistance marker (ARM) gene which,
     according to the British Medical Association, should be phased
     out.

9.0. Websites On Genetic Engineering:
     http://www.safe-food.org/welcome.html
     http://www.natural-law.ca/genetic/geindex.html
     http://www.greenpeace.org/~usa/reports/biodiversity/roundup
     http://www.greenpeace.org/~comms/cbio/geneng.html
     http://www.indiaserver.com/betas/vshiva/
     http://users.westnet.gr/~cgian/biotech.htm http://www.rafi.ca
     http://www.purefood.org
     http://www.med.upenn.edu/~bioethic/genetics/articles.html
     http://www.ucsusa.org/agriculture/ag.docs.html
     http://www.k2net.co.uk/~savage/ef/earthfirst.html
     http://www.essential.org/crg/
     http://www.envirolink.org/orgs/shag/
     http://userwww.sfsu.edu/~rone/gedanger.htm
     http://www.bio-integrity.org
     http://www.natural-law.org/issues/genetics/ge_hazards.html
     http://www.bio-integrity.org/ http://www.peg.apc.org/~acfgenet/
     http://www.indians.org/welker/genome.htm
     http://www.solbaram.org/articles/clm505.html
     http://www.netlink.de/gen/home.html
     http://www.psagef.org/indexgen.htm
     http://home.earthlink.net/~alto/boycott.html
     http://www.notmilk.com http://www.biotech-info.net

10.  MISCELLANEOUS:

          + The strong anti-GE feelings in Europe is due to the
     Europeans' distrust of their governments following such food
     scares as the "mad cow" disease and the dioxin-tainted food in
     Belgium. This springs from deep-seated cultural differences.
     "There is more reverence for nature there and more of a belief
     that food is sacred. Americans don't mind eating McDonald's and
     junk food... but Europeans eat traditional foods they've eaten
     for thousands of years, as they do in India. They're perceiving
     GM foods as somehow unnatural when really there is no cause for
     alarm." Prakash says that the GE produce and products on the
     American market are safe and "have been thoroughly tested in
     terms of their safety and environmental impacts." (Dr. C.S.
     Prakash, a geneticist and professor of biotechnology at Tuskegee
     University in Tuskegee, Ala.)