Select Committee on European Communities Second Report - Written Evidence

Memorandum by the Soil Association


  The impending introduction of genetically modified organisms into UK agriculture poses the most serious threat ever to the objectives and progress of the organic farming movement in developing and introducing viable systems-based approaches to agriculture.

  The issue goes to the heart of what the Soil Association has been endeavouring to achieve for more than 50 years, and brings into focus the directly opposing approach of the organic farming movement and most of the agricultural supply industry towards the sustainability of agricultural production systems.

  Even if genetic engineering brings small reduction in the amount of pesticide applied to some individual crops, the whole approach of the genetic engineering industry is to make farmers more, not less reliant on chemical inputs, in particular soluble artificial fertilisers and pesticides. The development of herbicide-resistant crops, for example, will lead to further loss of biodiversity, the "sterilisation" of agricultural crop land and the virtual elimination of food sources for predatory species which can otherwise exist within a cropped area and which can provide a high level of control against agricultural pests. As such the approach is directly opposite to that adopted by organic producers and others using techniques of integrated pest management which have acknowledged benefits for wildlife.

  While the techniques of genetic engineering are being used to introduce new genes into agricultural crops it is clear that, due to the selection criteria that are used, the overall trend will be to make farmers reliant on plant varieties which are derived from a substantially smaller genetic base. This will make agriculture as a whole potentially more vulnerable to the development of new pathogenic organisms that may arise in the future.

General Note:

  The Soil Association is in general agreement with the submission to the Select Committee made by GeneWatch. To avoid duplication our evidence should be seen as additional to that of GeneWatch.


(a) research

  The Soil Association is concerned that most research on genetically engineered (GE) organisms has been conducted by or on behalf of the biotechnology companies. Very little genuinely independent research into the possible effects of GE organisms has been carried out because the research is viewed as "near market" and most university research faculties are now also financially linked to biotechnology companies. We believe this to be a fundamental problem which the EU is well placed to address. The development of biotechnology in agricultural crop production poses potential major health and environmental problems. In our view it is not sufficient to evaluate research by independent committees, there is a genuine and urgent need for additional independent research. The EU has a European Federation of Biotechnology Task Group on Public Perceptions of Biotechnology which funds work on countering public resistance to biotechnology seen as the biggest problem for the industry. Generous grants are given to support "public understanding".1

  Our experience has been that this promotion assumes that biotechnology is the only viable way forward without even considering evidence that shows organic methods offer a viable and safe future for world agriculture.2

(b) release into the environment

  The release of GE crops poses a specific threat to the integrity of organic production. Legally binding organic farming standards make it clear that genetically modified organisms are not acceptable in organic farming (see Appendix) yet it is already becoming difficult to ensure that organic crops are not "contaminated" by genetically modified material.

  We feel it is vital that the regulatory process for licensing genetically modified crops should include an evaluation of the potential impact this may have on organic producers in the area. So far such evaluation has not been undertaken. The potential exists for the transfer of GMOs by cross pollination and other means, such as slow migration of soil bacteria carrying modified DNA, or more rapid transfer by an intermediary such as insects, invertebrates or birds. There is also the potential of continuing reproduction, spread, contamination and hybridisation. This raises questions about the organic status of affected land in addition to organic certification of individual crops.

    —  In the UK, organic farmers are already deeply concerned about contamination of their crops from the numerous GE test sites around the country. If commercial planting goes ahead as planned, it will be extremely difficult, if not impossible, for organic farming to stay free from contamination due to cross pollination from GE crops and the spread of genes through the micro-organisms in the soil3;

    —  organic food produced to Soil Association standards is the consumer's only certain guarantee—in the absence of adequate labelling—of GE-free food sources. Infringement of this will affect people's right to choose;

    —  Bacillus thuringiensis (Bt) is a bacterium which has been a cornerstone in sustainable organic agriculture since the 1960s. It is used in occasional applications as an acceptable organic pesticide for serious threats to food crops. Large numbers of crops are now being engineered to express the Bt toxin continuously. Evidence has led the US EPA to predict that these crops could result in resistant pests within 3 to 4 years. The widespread use of GE Bt plants could permanently destroy the effectiveness of Bt against the world's primary agricultural pests and threaten organic farming everywhere.

  2. The Soil Association is deeply concerned about so-called fast track procedures. These are to be extended and simplified, in particular in the UK. We regard it as imperative that the opposite should occur.

    —  More time should be given to the public to respond (as is their democratic right) to the announcement of an intended release than the current 14 days.

    —  Any Member State government should be allowed more than the current 90 days for the adequate assessment of any application.

  3. The precautionary principle should be the guiding light for all releases. Why create a possible hazard where there is no palpable human need? The onus should be on those corporations wishing to release transgenic organisms into the environment to prove that no harm will be done. At present, the burden of proof seems to rest with NGOs who are, by comparison to the corporations, almost without resources. GE organisms are released until such time as it is found that unexpected and harmful effects occur—by which time in the case of living and reproducing plants it is too late to do anything. Artificial genomes (and the living beings they code for) can no more be stopped than natural ones and there is real danger of an entirely unintentional epidemic of disease due to unexpected recombination4 of viral genes via transgenic hosts.

  In view of the gross inadequacies in food safety regulation and the scientific evidence pointing to serious hazards, Drs Mae-Wan Ho and Ricarda Steinbrecher have recommended a number of measures to safeguard the health of consumers and to protect biodiversity. The precautionary principle also demands that a moratorium on further release should be imposed until these measures are implemented:

    (i)  No food crops are to be engineered for producing pharmaceuticals and industrial chemicals, as the engineered crops could be mistaken for food, or cross-pollinate with non-engineered food crops. The onus must be on the producer to prove that any plant genetically engineered is not a food crop.

    (ii)  All projects involving genetic manipulation of baculovirus for insecticidal purposes should be discontinued, as this virus is being used in human gene therapy and invades human liver cells readily.

    (iii)  Complete characterisation of inserted gene sequence(s) of the GE organism (GEO) must be provided in the application for market approval. This should include any antibiotic marker gene(s), promoter(s) and enhancer(s) and their effects on the expression of neighbouring genes. The presence of mobile genetic elements and other proviral sequences in the host genome likely to contribute to secondary mobility of inserts must also be stated.

    (iv)  No GEOs with uncharacterised foreign gene inserts are to be considered for release. No parts of such GEOs, nor of animals from failed GE experiments or xenotransplant animals are to be used as human food or animal feed.

    (v)  No GEOs containing antibiotic resistant genes are to be considered for release or to be used as human food or animal feed.

    (vi)  A detailed record of the stability of the GEO over at least five successive generations of field conditions (including drought and heat) is a precondition for market approval. (Field conditions does not mean open field conditions). This must be supported by appropriate data indicating the stability of the insert as well as the level of gene expression under different conditions in successive generations.

    (vii)  Data on the frequency of unintended gene transfers, including horizontal gene transfer from the GEO under field conditions, must be included in application for market approval.

    (viii)  Data on the frequency of horizontal gene transfer from GEO to gut bacteria must be included in applications for market approval.

    (ix)  Data on the ability of transgenes and marker genes in the GEO to invade mammalian cells must be included in applications for market approval.

    (x)  A specified set of tests must be carried out to establish "substantial equivalence", which are sufficiently discerning to reveal unintended as well as intended effects. The comparator must be the unmodified recipient organism itself, and results of repeated tests must be provided to support the stability of the characteristics over at least five successive generations.

    (xi)  Safety assessment must include the GEO's potential to generate pathogens through genetic recombination.

    (xii)  Safety assessment must include pesticide residues where they are integral components of the product, as in herbicide-resistant transgenic plants.

    (xiii)  Product segregation, labelling and post-market monitoring are non-negotiable conditions for market approval.

  4. The biotechnology corporations have tried to create the impression of a need for GE organisms to "feed the world's poor"5 or create better quality food. To date, the only crops they are attempting to grow commercially in Europe have been those which involve using their particular herbicides6 and in which they retain control of seed production. Their claim that the new crops will use less herbicide is disingenuous and indications are that the opposite is true7. This will be especially true as Darwinian evolution operates as it always has in the herbicide target plants. They will inevitably develop resistance (just as Colorado potato beetles8 have to all insecticides bar Bt and the diamondback moth9 already has to GE plants expressing the Bt toxin through its modified genome). This means that farmers will be forced to apply other herbicides to control the resistant crops10.

  5. Many new forms of old diseases (like the various forms of food poisoning in which cases double almost every year) are appearing. Why this is so is uncertain but many scientists suspect a link between overuse of antibiotics in feed and prophylactics in farm animals coupled with new genetic material created in laboratories in and often disposed of into the sewerage system. Antibiotic resistance is a desperately serious situation today with the common pathogen Staphylococcus aureus resistant, in some strains and in some hospitals, to almost all known antibiotics11. A study in eastern Germany12 gives an idea of the rapidity with which antibiotic resistance can develop and spread by horizontal gene transfer, and yet persist after antibiotic ceased to be administered. The antibiotic streptothricin was administered to pigs beginning in 1982. By 1983, plasmids encoding streptothricin resistance were found in the pig gut bacteria. This spread to the gut bacteria of farm workers and their family members by 1984 and to the general public and pathological strains of bacteria the following year. The antibiotic was withdrawn in 1990, yet the prevalence of the resistance plasmid has remained high when monitored in 1993 confirming the ability of microbial population to serve as stable reservoirs for replication, recombination and horizontal gene transfer in the absence of selective pressure. Using antibiotic markers in transgenic organisms only hastens the inevitability of further resistance and a return to the pre-penicillin days of septicaemia and a range of other diseases we have almost forgotten about. The transgenic tomatoes currently marketed here and in the US both carry genes for kanamycin resistance. Kanamycin is used to treat TB which is reaching epidemic proportions across the world, the TB bacteria are already resistant to many antibiotics13.

  6. Post-release monitoring of GE crops is not currently carried out. This is a serious omission and the Soil Association strongly urges that a minimum requirement of 10 years should be applied. Negative environmental influences may be subtle or slow to manifest themselves. The observations that "nothing has happened" in the field tests to date are unhelpful. In many cases, adverse impacts are subtle and would almost never be registered when scanning a field. The field tests do not provide a track record of safety but a case of "don't look, don't find"14. The interconnectedness of the complex trophic webs (from soil microbes to large animals) is not even considered by the biotechnology industry, yet the whole biosphere depends on the proper operation of these systems. Risk assessment does not take account of the time factor which would enormously increase risk, nor of the cumulative factor.

  7. Horizontal gene transfer. This issue has been almost totally ignored and yet may turn out to be the most important—and irreversible—effect of the deliberate release of GE organisms into the environment. Similarly, the potential for cross pollination has been treated in cavalier fashion by GE proponents. Yet we already know that such pollination can affect weed relatives of the crops15 and, in particular, nearby non-GE and organic crops16. We also know that both insect and wind pollination17 can be effected over considerable distances (at least 8 kilometres) making risible the current regulations for separating GE trial crops from non-GE relatives. Evidence from Dr Peter Kareiva and Dr Ingrid Parker, department of Zoology and botany in the University of Washington in their work, "Environmental risks of genetically engineered organisms and key regulatory issues" stated that "several quantitative analyses of gene flow were undertaken with transgenic plants—while most gene flow clearly does extend to the nearest plants, regardless of the isolation approach, some pollen always seems to move to the distant most sampling stations (Kareiva et al 1994 (1), Monasse 1992 (2)). Indeed one of the lessons of ecological genetics over the last decade is that gene flow in plant populations consistently includes some rare long distance moves of pollen." (Ellstrand 1988 (3), Ellstrand and Hoffman 1990 (4), Klinger et al 1992 (5).

  8. The conventional process whereby genes move from one plant to another is via pollination. Evidence proves that genes can spread from one crop to another if they are related. The genes are transferred via cross pollination and will also pollinate related weeds, e.g., oil seed rape has been shown to spread to wild relatives through cross pollination of distances over 2.5 km. The threat of cross-pollination is a real one and is taken seriously by the Soil Association and the consumers who buy organic food. Existing regulations do not demand that this type of data be independently investigated before any application can be taken into consideration. The Soil Association considers it vital that these aspects are taken seriously with appropriate regulation being enforced, if possible, world-wide.

(c) Novel foods and their labelling

  1. The Directive should allow individual Member States to ban the import and use of a specific GE organism or food on other than scientific grounds if such a ban reflects what the population wish. Numerous opinion polls throughout the EU have shown that a majority of people are deeply concerned about GE and do not wish to consume foods derived from it. It is important to separate other research on and potential of GE for medical purposes which is altogether different from GE foods. If, for example, the British population are to be consulted by plebiscite on whether they approve UK integration into European Monetary Union, how much more important it would be if the population were to be consulted about GE crops and foods. The GE issue has implications as wide for the future as does the EMU. Fundamentally, people elect governments one of whose duties is to ensure the health and welfare of their electorate. People do not elect multinational corporations who are effectively today in control of the food supply (viz. the link-up between Monsanto and Cargill18, the start of a new trend) and, increasingly, dictate to governments what regulatory system (if any) they require, always ready to wield the big stick of threats to employment. It is a truism that "corporations have neither bodies to be punished nor souls to be damned." They, unlike governments, are unaccountable.

  2. The principle of substantial equivalence (SE) is deeply flawed and unscientific. SE is defined thus: Selected characteristics are compared between the GE product and any variety within the same species. If the two are grossly similar, the GE product will not need to be rigorously tested or labelled on the assumption that it is no more dangerous than the non-GE equivalent. The use of the principle of SE for risk assessment of GE foods—as has been applied by the FAO, the US Food and Drug Authority and the EU—is thus potentially dangerous as it neglects the potential presence in these products of unexpected new molecules. A product could not only be SE, but even be identical with its natural counterpart in all respects bar the presence of a single harmful compound. Indeed, a tame tiger is "substantially equivalent" to a wild tiger. It looks the same and roars the same, but you would only be in danger from the second. Thus SE is irrelevant and useless from a scientific standpoint as a criterion for food safety. The following is a series of objections to substantial equivalence (SE):

    —  a GE potato, grossly altered, with deformed tubers was nevertheless tested and passed as SE;

    —  according to SE, 1-tryptophan19 that was derived from GE bacteria and implicated in the deaths of 37 people in 1989 contained less than 0.1 per cent of unexpected toxins, would have been regarded as SE and passed as safe for human consumption;

    —  there is no scientific alternative to rigorous toxicological testing to ensure satisfactory safety for GE foods as none of these foods currently on the market has undergone testing that is even close to such rigorous assessment required to ensure safety;

    —  there is no completely reliable method for identifying unexpected harmful substances, even with the most rigorous safety assessment methodologies available;

    —  there is no body of existing information upon which to base prediction of unanticipated side effects due to the insertion of a foreign gene into a GE organism.

  3. Labelling: The Soil Association believes that any product derived from GE organisms should be labelled regardless of whether it is an unprocessed food (like squash or potato) or whether it contains derivatives such as proteins, oils, DNA, sugars, lecithin, starch etc. Trace levels of unexpected toxins could be present in oils refined from GE crops (e.g., rape/canola, sunflower, corn/maize) so labelling should be mandatory if there are any GE derivatives. There are two reasons for this:

    (i)  Traceability—if something does go wrong as a result of some specific GE food component and people become ill or die, it is imperative that the toxic agent can be traced back to source so that the source itself can be removed from the food chain. The l-tryptophan incident (1989, USA) is an example of how important this is since the GE tryptophan was not labelled and, as a result, the epidemic or illness and deaths took months to trace to source.

    (ii)  Consumers have a right to know and Europe-wide consumers associations (e.g., Consumers International, the UK Consumers Association) have strongly supported proper labelling of GE. Despite this, their demands were rejected by the UN Codex Alimentarius commission in June 1998. Public perception is such that they do not trust "experts" and scientific-sounding advisory panels and, indeed, their own governments when it comes to fundamentals such as food safety and wholesomeness. Accordingly, people have a right to know what their food contains so that they may make their own choices about what they, rightly or wrongly, perceive as dangerous. If their governments' advice is not to be trusted, their fallback position is proper labelling. Present EU plans to label GE foods exclude between 95-98 per cent of almost 30,000 products in the supermarkets. A recent Guardian survey20 showed that 95 per cent of people in the UK specifically wanted clear labelling of all GE foods including derivatives which will not be labelled under current plans. A Citizens' Jury21 ruled that GE was unnecessary and could have irreversible consequences. A MORI poll conducted throughout Europe showed that 60 per cent of Europeans were opposed to GE food. Thus EU governments are failing their own people by bowing to the dictates of Codex (an unelected body itself) and the biotechnology industry.


  In May, the EU passed the Directive on the Protection of Biotechnological Inventions. The Soil Association believes that this Directive has been deliberately tailored to the requirements of the biotechnology industry. It will allow patenting of genes, plants (including their seeds) animals, cells, body parts and micro-organisms. This, we believe, flies in the face of the original intention of patents. Now patents on genes extend a huge incentive to the biotechnology industry to create new GE organisms which they can then patent and over which they can then exert monopoly control. Since patents are mostly for 20 years, the companies have a strong incentive to recoup the money they invested as soon as possible regardless of safety or ethical concerns. Accordingly, they may exert pressures on the regulators (i.e., governments) to minimise the testing of GE crops and introduce "fast-track" procedures. Such pressure is compounded by threats of possible job losses if the company fails to get its way.22

  Several simple but vital questions23 relating to projected food policy and implications of GE still have not been addressed by any governments.

  The availability of safe, sustainable, natural methods of breeding and husbandry utilising the many thousand different varieties of any given food crop makes the risks associated with GE foods simply not worth taking. These risks are even less acceptable when one takes into account the fact that once released into the environment, any mistakes cannot be cleaned up or recalled but will be passed on to all future generations indefinitely.

9 June 1998


  1 For example, the chairman of this group, John Durant, who is also Assistant Director of the Science Museum, has been given £0.5 million to promote biotechnology with a large exhibition mounted by the Science Museum including a woollen jumper made from the wool of Dolly the Sheep. In a public debate with Dr Mae-Wan Ho (debated at the Linnaean Society, Burlington House, London), he denied that he was working to overcome public resistance to genetic engineering. But he did assure the audience that the biotechnology was absolutely safe, so segregation and labelling of GE products was unnecessary.

  2 Jules Pretty. The Sustainable Intensification of Agriculture. Natural Resources Forum 1997 (UN). Volume 21, No. 4, pp. 247-256.

  3 Frank Gebhard and Kornelia Smalla Transformation of Acinetobacter sp. Strain BD413 by Transgenic Sugar Beet DNA Appl Environ Microbiol, April 1998, p. 1550-1554, Volume 64, No. 4.

  4 Vaden V S & Melcher U 1990 Recombination sites in cauliflower mosaic virus DNA . . . Virology 177, 717-726.

  Lommel S A & Xiong Z 1991 Recombination of a functional red clover mosaic virus . . . J Cell Biochem 15A, 151.

  Greene A E & Allison R F 1994 Recombination between viral RNA and transgenic plant transcripts Science 263, 1423-5.

  Wintermantel W M & Schoelz J E 1996 Isolation of recombinant viruses between cauliflower mosaic virus and a viral gene . . . Virology 223, 156-64.

  5 Recently, agricultural scientists working in the Philippines announced that they had used sophisticated traditional breeding techniques to develop a rice variety that increased the proportion of the plant devoted to rice grains in ways that improved rice yields by 20 per cent, a stunning achievement considering the importance of rice in the human diet (interestingly, the announcement was not accompanied by headlines like "Traditional crop breeding can feed the world") Union of Concerned Scientists. In Latin America, organic growing and fertilisation schemes have tripled or quadrupled yields within one year.

  6 Furthermore, claims that glyphosate (Roundup) and glufosinate (Basta) are environmentally benign are strongly disputed, as shown by the following reference list:

  Cessna A J and Cain N P (1992) Residues of glyphosate and its metabolite AMPA in strawberry fruit following spot and wiper applications. Can J Plant Sci 72:1359-1365.

  Chakravarty P and Chatarpaul L (1990) Non-target effect of herbicides: I Effect of glyphosate and hexazinone on soil microbial activity. Microbial population, and in-vitro growth of ectomycorrhizal fungi. Pestic Sci 28:233-241.

  Chakravarty P and Sidhu S S (1987) Effects of glyphosate, hexazinone and triclorpyr on in-vitro growth of five species of ectomycorrhizal fungi. Eur J For Path 17:204-210.

  Cox C (1995 a) Glyphosate, Part 1: Toxicology, Herbicide Factsheet, Journal of Pesticide Reform, Fall 1995 Volume 15, No. 3, (from the Northwest Coalition for Alternatives to Pesticides).

  Cox C (1995 b) Glyphosate, Part 2: Human Exposure and Ecological Effects, Herbicide Factsheet, Journal of Pesticide Reform, Winter 1995 Volume 15, No. 4, (from the Northwest Coalition for Alternatives to Pesticides).

  Crawley M (1996) "The Day of the Triffids". New Scientist 6 July pp. 40-41.

  Crawley M J, Hails, R S, Rees, M, Kohn, D & Buxton, J (1993) Ecology of transgenic oilseed rape in natural habitats. Nature 363: 620-623

  Estok D, Freedman B and Boyle D (1989) Effects of the herbicides 2, 4-D, glyphosate, hexazinone, and triclopyr on the growth of three species of ectomycorrhizal fungi. Bull. Environ Contam Toxicol 42:835-839.

  Folmar L C, Sanders H O and Julin A M (1979) Toxicity of the herbicide glyphosate and several of its formulations to fish and aquatic invertebrates. Arch Environ Comtam Toxicol 8:269-278.

  Greenpeace (1995) Pestizide im Grundwasser, Ergebnisse einer Befragung Deutscher Gesundheitsaemter 1994, Greenpeace Bericht.

  Hino A (1994) Safety assessment system of field tests in Japan. Proceedings of the 3rd International Symposium on the Biosafety Results of Field Tests of Genetically Modified Plants and Micro-organisms. 13-16 November 1994, Monterey, California. University of California: Oakland. pp. 177-182.

  Jewell L D (1998) Agricultural Statistics 1987 United States Department of Agriculture, Washington.

  Kareiva, P & Parker, I (1994) Environmental risks of genetically engineered organisms and key regulatory issues. Greenpeace International: Amsterdam.

  Keeler, K H (1989) Can genetically engineered plants become weeds? Bio/Technology 7: 1134-1139.

  Nordlee J A, Taylor S L, Townsend J A, Thomas L A and Bush R K (1996) Identification of a brazil-nut allergen in transgenic soybeans, The New England Journal of Medicine, Volume 334, No. 11:688-692.

  Pease W S et al. (1993) Preventing pesticide-related illness in California agriculture: Strategies and priorities. Environmental Health Policy Program Report. Berkeley, CA: University of California. School of Public Health. California Policy Seminar.

  Piccolo A et al. (1994) Absorption and desorption of glyphosate in some European soils. J Environ Sci Health B29(6):1105-1115.

  Sidhu S S and Chakravarty P (1990) Effect of selected forestry herbicides on ectomycorrhizal development and seedling growth of lodgepole pine and white spruce under controlled and field environment, Eur J For Path 20:77-94.

  Springett J A and Gray R A J (1992) Effect of repeated low does of biocides on the earthworm Aporrectodea caliginosa in laboratory culture. Soil Biol Biochem 24((12):1739-1744.

  Taylor, S L (1994) Evaluation of the allergenicities of foods developed through biotechnology. Proceedings of the 3rd International Symposium on the Biosafety Results of Field Tests of Genetically Modified Plants and Micro-organisms. 13-16 November 1994, Monterey, California. University of California: Oakland. pp. 185-198.

  USDA/AHPIS (1994) Response to Monsanto petition P93-258-01 for determination of non-regulated status for glyphosate tolerant soybean line 40-3-2. United States Department of Agriculture, Animals and Plant Health Inspection Service, Biotechnology, Biologics and Environmental Protection.

  US EPA Office of Pesticide Programs. Special Review and Registration Division (1993) Reregistration eligibility decision (RED): Glyphosate, Washington, D C (September).

  Wang Y, Jaw C and Chen Y (1994) Accumulation of 2, 4-D and glyphosate in fish and water hyacinth. Water Air Soil Pollut 74:397-403.

  Williamson, M (1994) Community response to transgenic plant release: predictions from British experience of invasive plants and feral crops. Molecular Ecology 3: 75-79.

  World Heath Organisation, United Nations Environmental Program, International Labour Organisation (1994) Glyphosate, Environmental Health Criteria 159. Geneva, Switzerland.

  Yates W E, Akesson N B and Bayer D E (1978) Drift of glyphosate sprays applied with aerial and ground equipment. Weed Sci 26(6):597-604.

  7 The New York Times recently reported that farmers in the States were using more herbicides on their crops because they knew they could do it with impunity and ensure maximum kill of the weeds. Monsanto have doubled their capacity to produce Roundup. The sales for glufosinate are predicted to rise by $200 million per year as a result of GE crops.

  8 New Scientist Chips are down for killer potato, 6 April 1995, 9.

  9 New Scientist A growing irony 8 March 1997, 3. A single gene change in diamondback moth can confer resistance to four Bt toxins. Here is scope for rapid resistance spread if indiscriminately used. Monsanto's Bt cotton flopped when many pests survived. This could act as a super-selector for resistant insects, making Bt useless.

  10 It has been said that "potential development of insect resistance to the Bt toxin cannot be considered an adverse environmental effect as existing agricultural means of controlling such resistant species will still be available". In a similar vein, one could claim that pollution of a river does not matter because there are other rivers available.

  11 New Scientist, 14 September 1996, 50; 27 August 1996, 7.

  12 Tschpe H. The spread of plasmids as a function of bacterial adaptability. FEMS Microbiol, Ecol 1994; 15: 23-32.

  13 New Scientist, 4 May 1996.

  14 M Mellon & J Rissler 1995 Transgenic crops: USDA Data on small-scale tests contribute little to commercial risk assessment. Bio/Technology 13: 96.

  15 Experiments have now shown that there can be appreciable and effective hybridisation of transgenic canola with Brassica campestris, the wild and weedy form of Brassica rapa:

  Mikkelsen, T R, Andersen, B & Jorgensen, R B 1996 Nature 380, 31.

  And with hoary mustard, Hirschfeldia incana, with effective gene flow from crop to weed: Lefol E et al 1995 J Appl Ecol, 32, 803-808.

  16 Riverford Farm, Devon—Britain's largest organic farm situated within a few hundred metres of a test site for glufosinate-resistant maize.

  17 (1) Kareiva P, W Morris + C M Jacobi 1994 studying and managing the risk of cross fertilisation between transgenic crops and wild relatives. Molec ecol 3:15-22.

  (2) Monasse R, 1992 ecological risks of transgenic plants: effects of special dispersion on gene flow. Ecological applications 2:431-38.

  (3) Elstrand N, 1988, pollen as a vehicle for the escape of engineered genes/ TREE3:S30-S32/TIBTECH 6: S30-S32.

  (4) Elstrand N AND c Hoffman 1990 hybridisation as an avenue of escape for engineered genes. Bioscience 40: 438-42.

  (5) Klinger T, P Arriola and N Elstrand. 1992. Crop-weed hybridisation in radish: effects of distance and population size. American J bot 79: 1431-35.

  18 Farmers Weekly, June 1998.

  19 Mayeno A N & Gleich G J 1994 Eosinophilia-myalgia syndrome and tryptophan production: a cautionary tale TIBTECH 12, 346-352.

  Raphals P. 1990 Does medical mystery threaten biotech? Science 249, 619.

  Brenneman D E et al. A decomposition product of a contaminant implicated in l-tryptophan . . . J Pharmac & Exper Therapeutics 266(2), 1029-1035.

  Love L A et al. Pathological and immunological effects of ingesting l-tryptophan . . . J Clinical Investigation, Inc, 91, 804-811, March 1993.

  Raphals P EMS deaths: Is recombinant DNA technology involved? The Medical Post, Maclean-Hunter, Toronto, 16 November 1990.

  20 The Guardian 4 June 1998.

  21 A cross section of the British population who were asked about agriculture and food, designed by East London University and reported on Channel 4 News on 2 June 1998.

  22"Given the importance of Novartis on the Irish market, (not allowing glyphosate-tolerant sugar beet trials) would have serious implications for the Irish sugar beet industry" Affidavit to Irish High Court, section 47d, 1997 by Monsanto Europe.

  23 Taken from questions to the Advisory Committees prepared by Ricarda Steinbrecher (WEN and Genetics Forum) and Ian Taylor (Greenpeace).

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