ISP Reply to Canadian Food Inspection Agency

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ISP Reply to Canadian Food Inspection Agency

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Wed, 04 Jan 2006 15:19:19 +0000

 

 

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ISIS Press Release 04/01/06

 

ISP Reply to Canadian Food Inspection Agency

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On 27 November 2005, Dr. Mae-Wan Ho wrote to a number of

national and international agencies on behalf of the

Independent Science Panel [1] regarding the powerful immune

response in test animals fed genetically modified (GM) peas,

demanding a ban on all GM food and feed until proper

assessment on the immunogenicity of all transgenic proteins

has been carried out.

 

Ho reported the scientific study [2] in detail, which showed

that a previously harmless bean protein transferred to pea

provoked a debilitating immune response on account of post-

translation processing of the protein in the pea plant which

differs from that in bean. As practically every transgenic

protein involves a transfer of the protein to a different

species, all transgenic proteins are potentially capable of

provoking such immune reactions, unless proven otherwise.

 

The Canadian Food Inspection Agency (CFIA) responded on 19

December, and the United States Department of Agriculture

Animal and Plant Health Inspection Service (USDA-APHIS)

replied on 22 December.

 

The reply from USDA-APHIS explained that while it works in

partnership with the Food and Drug Administration (FDA) and

the Environment Protection Agency (EPA) " to ensure that the

development, testing, and use of the products of

biotechnology occur in a manner that is safe for plant and

animal health, human health, and the environment, " it is the

FDA that " is responsible for ensuring that all plant-derived

foods and feeds, including those developed through

biotechnology are safe and properly labeled. " And while

USDA-APHIS appreciate the information provided regarding the

study, the issues addressed are primarily matters of food

and feed safety, which " fall under the regulatory authority

of FDA " , and suggested that the FDA be contacted directly.

 

The CFIA responded with a detailed discussion on the concept

of " substantial equivalence " and the procedures used by

CFIA, as recommended by the Food and Agriculture

Organization (FAO) [3, 4], to evaluate toxic food impacts

such as allergenicity. The current reply is mainly addressed

to the CFIA.

 

Many commentators have exposed the concept of substantial

equivalence as thoroughly unscientific, starting with Ho and

Steinbrecher [5], who showed how the concept effectively

allows the approval of GM crops without the necessary

safeguards to human and animal health or the environment.

 

Similarly, the tests for allergenicity, which include amino

acid sequence similarities, heat stability and digestibility

(mainly under simulated gastric conditions), have already

been rightly criticized as inadequate [6, 7]; and more

importantly, do not include the tests carried out on the

transgenic pea in the new study. Even the FAO/WHO reports

[3, 4] recommended a combination of additional methods for

assessing allergenicity, such as binding tests of antisera

from allergic patients, and animal exposure studies.

 

CFIA stated: " Characterization data provided by the

proponent is generated with genetically stable, modified

lines that are representative of the final product. "

Unfortunately, there is no evidence that the transgenic

lines are genetically stable. In 2003, French government

scientists found that in all five transgenic lines already

commercialised, the GM insert has rearranged since

characterized by the company for commercial approval [8-10].

 

These considerations point to the inadequacy of the

regulatory regime for GM crops.

 

Indeed, the USDA has just been criticised in a report issued

by its own Inspector General for failing to regulate the

field trials of GM crops [11, 12]. The report found that

USDA " lacks basic information about the field test sites it

approves and is responsible for monitoring, including where

and how the crops are being grown, and what becomes of them

at the end of the field test. " It also said that weaknesses

in regulations and in the internal management controls at

the USDA " increase the risk that genetically engineered

organisms will inadvertently persist in the environment

before they are deemed safe to grow without regulation. "

 

At the end of the long letter, CFIA noted: " You cited a

recent publication by Prescott et al regarding GM field peas

in your message. We consider this study to be an example of

how the appropriate methods are at hand to identify

allergenicity concerns associated with newly expressed

proteins in plants. " It did not say that such methods are

actually being used by the CFIA, however.

 

It is arguable whether the tests carried out by Precott et

al are adequate for safeguarding animal and human health,

but at least they succeeded in detecting the

allergic/hypersensitive reactions to the transgenic protein.

But, none of the transgenic proteins in commercialized food

and feed has been subjected to such tests. CFIA and other

regulatory authorities not only should use similar tests for

assessing every new GM crop, it should retrospectively apply

the tests to all already commercialized GM crops.

 

That is why, in the light of the new evidence, a ban on all

GM food and feed must be imposed as a matter of urgency,

until and unless the transgenic proteins are proven safe by

adequate tests on immunogenicity.

 

" Immune reactions to transgenic protein serious. Independent

scientists demand a ban on GM food & feed while all GM crops

are tested. " ISIS Report 28 November 2005 http://www.i-

sis.org.uk/TPTMMI.php

 

Prescott VE, Campbell PM, Moore A, Mattes J, Rothenberg ME,

Foster PS, Higgins TJV and Hogan SP. Transgenic expression

of bean a-amylase inhibitor in peas results in altered

structure and immunogenicity. J Agricultural and Food

Chemistry 2005, 53, 9023-30.

 

Joint FAO/WHO Expert Consultation on Foods Derived from

Biotechnology – Allergenicity of Genetically Modified Foods

– Rome, 22 – 25 January 2001. Rome, Food and Agriculture

Organisation of the United Nations, (2001).

[http://www.who.int/foodsafety/publications/biotech/en/

ec_jan2001.pdf]

 

FAO/WHO: CodexPrinciples and Guidelines on Foods Derived

from Biotechnology, Rome, Italy, Joint FAO/WHO Food

Standards Programme (2003)

[ftp://ftp.fao.org/codex/standard/en/CodexTextsBiotechFoods.

pdf].

 

Ho MW and Steinbrecher R. Fatal flaws in food safety

assessment. Critique of the Joint FAO/WHO Biotechnology and

Food Safety Report. Journal of Nutritional and Environmental

Interactions 1998, 2, 1-84.

 

Fiers, M.W.E.J., Kleter, G.A., Nijland, H., Peijnenburg, Ad.

A.C.M., Nap, J.P. and van Ham R.C.H.J. BMC Bioinformatics

2004, 5,133. http://www.biomedcentral.com/1471-2105/5/133

 

Ho MW, Pusztai A, Bardocz S and Cummins J. Are transgenic

proteins allergenic? Science in Society 2005, 25, 4-5.

 

Collonier C, Berthier G, Boyer F, Duplan M-N, Fernandez S,

Kebdani N, Kobilinsky A, Romanuk M, Bertheau Y.

Characterization of commercial GMO inserts: a source of

useful material to study genome fluidity. Poster presented

at ICPMB: International Congress for Plant Molecular Biology

(n°VII), Barcelona, 23-28th June 2003. Poster courtesy of

Pr. Gilles-Eric Seralini, Président du Conseil Scientifique

du CRII-GEN, www.crii-gen.org;

 

Ho MW. Transgenic lines proven unstable. ISIS Report, 23

October 2003 www.i-sis.org.uk; also Science in Society 2004,

20, 35. http://www.i-sis.org.uk/isisnews.php

 

Ho MW. Unstable transgenic lines illegal. ISIS Report 3

December 2003; also Science in Society 2004, 21, 23.

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

 

" Lax oversight found in tests of gene-altered crops " , Andrew

Pollack, New York Time 3 January 2006.

http://www.nytimes.com/2006/01/03/science/03crop.html

 

" Report blasts oversight of test fields. Investigators say

the USDA lacks details on what happens with pharma-crops " ,

Phlip Brasher, Register Washington Bureau. 30 December 2005.

http://desmoinesregister.com/apps/pbcs.dll/article?AID=/2005

1230/BUSINESS01/512300334/1030

 

 

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