GMOs (genetically modified organisms) and Organic Production

The Organic Trust are fundamentally opposed to the concept of GMOs (genetically modified organisms) and organic production - these two concepts are completely incompatible.  Genetic modification and organic production cannot co-exist - the Organic Trust have strenuously objected to the use of genetically modified organisms - one such comprehensive objection is listed below.

Notification under Article 16 (1) of the Genetically Modified Organisms (Deliberate Release) Regulations - S.I. No 500 of 2003

Representation on the notification Ref. No B/IE/06/01 from BASF Plant Science GmbH - from Organic Trust Limited - EU and Irish Approved Organic Inspection & Certification Body - IRL-OIB3-EU

Foreword

Before responding specifically to the above notification, the Organic Trust Limited would like to make the following general points.

1. The mechanism for informing the public of proposed deliberate releases of Genetically Modified Organisms (GMOs) in Ireland is at present inadequate. A single notice placed in a single national newspaper may easily be overlooked by stakeholder bodies, which are largely voluntary in their organisation and which do not have the resources for daily monitoring of the press, and by members of the public at large. The daily monitoring of the public notices in every national newspaper is not a part of normal behaviour and is not possible for most people on grounds of cost.

Had two members of the GMOAC of the EPA not been representatives of stakeholder organisations and therefore been individually notified by the EPA it is likely that the notification would have passed unobserved.

In future the EPA should ask companies submitting notifications to also notify stakeholder bodies or the EPA should notify such bodies itself. Since there is a great depth of information on the subject in third level institutions it would be wise if microbiology, genetics and agriculture departments at these institutions were also notified as a matter of routine.

2. Our first point provided an example of the democratic deficit existing in the process of release of GMOs in Ireland and of the potential for the loss of important information which results from this deficit.
In the case of all those areas of concern which do not fall within the remit of the EPA there is a much greater deficit as there is no mechanism for democratic oversight or information. There is no representation of stakeholder bodies on the Bioethics Committee of the Royal Irish Academy – or rather the stakeholder bodies were viewed only as being the biotechnology industry and academics and medical representative bodies. This perhaps explains which the belated report of the above committee, published in 2005, was largely based on somewhat outdated science. There is also no stakeholder involvement in either the Food Safety Authority advisory group, which does not appear to have met for a very long time if the information on the FSA website is to be believed. While the Department of Agriculture does consult with stakeholder bodies, it appears to give little weight to their input, particularly in regard to the importance of the precautionary principle. The inter-departmental group also has no stakeholder representation.


Whilst we acknowledge that the academic researchers who are the usual advisors to these bodies have no intentional bias, and support the use of the precautionary principle, it seems probable that unintentional bias will be present in their views on many occasions. The concept of the purity of scientific research is long outdated and their own research is funded, directly or indirectly, by those who have a financial interest in a particular outcome which might lead to some weakening of their views of that principle.

We would therefore request stakeholder participation in all the above bodies.
Representation

The Organic Trust Limited believes that keeping confidential the name of the farmer in this case infringes upon EU Law, which requires that neighbouring farmers be informed of deliberate releases. Whilst accepting that the approximate address given in the notification makes it likely that this release is on Teagasc land, this does not mean that the neighbours of Teagasc are not entitled to be informed of the trials. The address at which the release is to take place is not commercial information. If the reason why the address is being concealed is because of the perceived danger of sabotage, this is a matter for An Garda Siochana rather than of commercial confidentiality. The fact that separation distances can be maintained on the farm in question does not mean that the “strong advice” that neighbouring farmers should receive written notification should be ignored.

A notification in January for planting in April/May does not appear to allow time for the requisite appeals process to be carried through.

We note that there is mammal and bird activity at the site and that protection against animals entering the site and moving tubers is to be provided by the use of electric fencing. Electric fencing provides no protection against the activities of rats or crows, the two most common species carrying out the transport of potato tubers under Irish growing conditions. Mini tubers are particularly affected by rodent and bird activity and these are suggested as likely in this trial.  Nor does electric fencing provide any protection against determined human activity.

We further note that whilst we are informed that post-harvest storage will be secure, we are given no details of how this is to be done. Far more importantly we are not told how post-harvest transport is to be carried out securely.

Two of the three breeding lines have abundant flowering, and since there are other potatoes to be grown close by, and the area is one in which there is considerable potato growing, it seems likely that a small percentage of pollen could be carried to other potato lines. The pollen dissemination distances found by Bock et al., 2002 have been challenged in other studies.

Although the fruits are very poisonous, rodents frequently attempt to move them considerable distances. In Ireland members of Organic Trust have found them stored at distances of up to 50m from their point of origin.

Tubers are not destroyed by frost under normal Irish growing conditions and are an important source of rodent and corvine food during the winter and spring. Organic Trust members have found caches of small potatoes at distances of over 100m from their point of origin. Whilst it is accepted that on-site monitoring will destroy volunteers on that site such distances mean that volunteers could be mixed with other conventional crops at considerable distances.

Although it is stated that these potatoes are not intended for use as animal feed (and we wonder what their intended use is in this case since human food would also appear to be ruled out if they are not suitable for animal feed) it is obvious that at some point animals will eat them in a field open to rodents. We are therefore surprised that no animal testing has been done on them.

We are also surprised at the very low level of monitoring proposed for the site, not only in view of past experiences in Ireland with human incursion, but in the light of the speed with which events happen in normal potato growing conditions. Weed growth, pathogen development, insect predation, bird and mammal predation etc can all reach critical levels in a matter of days, or even hours in suitable weather conditions.

We presume that solanum bulbocastanum has been used to provide resistance to p. infestans because it is a source of Rpri-blb1 and Rpi-blb2 which confers broad spectrum resistance to multiple strains of p. infestans, meaning that a solanum bulbocastanum is resistant to all known strains in the wild. Solanum bulbocastanum is a diploid potato which cannot hybridise naturally with solanum tuberosum. However somatic hybridisation has been used to produce sexual hybrids of solanum bulbocastanum which could be used for conventional breeding. The use of genetic modification means that this breeding is conducted more rapidly. In the past resistance has been obtained by using traditional methods to breed from naturally resistant wild genotypes of solanum tuberosum and solanum demissum. However p. infestans has shown itself able to adapt rapidly and to generate new strains which could overcome such resistance. This is stated as being the reason why it is necessary to use genetic modification on this occasion. We fear that the consequence may well be the more rapid mutation of p.infestans to meet the challenge.

We note that there have been no greenhouse trials of these strains under challenging conditions, which is when mutation most frequently occurs.

We further note that somatic hybrids of solanum bulbocastanum have to date shown a certain level of instability. While solanum bulbocastanum is not a natural parent of these strains it is possible that some of this instability may be carried in the transplanted genetic material.

It is suggested that imidazolinone tolerance is intended only for tissue selection. Since imidazolinone is a commonly used herbicide, particularly in the US and Canada where the CLEARFIELD GM crops are modified to tolerate it, we are concerned that this characteristic may be intended as part of an argument to force a change in regulations to permit this herbicide in Ireland, perhaps using the WTO as was recently done in the case of European reluctance to permit GMOs.

We are told that the mechanism of localised cell death is combined with a systemic response which induces expression of defence-related genes in remote parts of the plants – we see no detail on those defence-related genes.

It is suggested that pre-harvest chemical defoliation will take place. This leaves a great deal of plant material lying on the soil surface for digestion by various forms of macro and micro soil life. It is suggested that this provides no hazard for soil life and that there is no risk of take up of transgenic material, which is expressed throughout the plants. The only citations given for this are very old ones and ignore more recent evidence to the contrary. Although current data suggest that take-up is low, it is by no means non-existent.

Again there is an assumption that there is no risk of allergenicity in this case, because of the form of expression of the transgenic material and because the parent is such a closely related species. It is, however, precisely under the circumstances of transgenic material from closely related species that allergenicity has arisen in other transgenic vegetable trials. A ten-year project at CSIRO (Commonwealth Scientific and Industrial Research Organization) in Canberra Australia was ended when peas modified to resist insects weevils caused inflammation in the lungs of mice [1]. The gene coding for the protein, a-amylase inhibitor-1 (aA1) in the common bean (Phaseolus vulgaris L. cv. Tendergreen), was inserted into pea (Pisum sativum L.) to make the pea-plants resistant to attack from weevils. The pea line was destroyed.

If the resistance response is limited to p.infestans then it seems likely that in conventional farming a high level of fungicide use will still be necessary in order to control the various fungal diseases listed in the notification, most of which are at present controlled by the broad spectrum fungicides used to control p.infestans.

In general, risk assessment appears to have been carried out very poorly in this case. We would have liked to see what effects were observed as compared with conventional varieties in the filed trials in other countries mention at 13.

We are concerned at the very high number of lines to be released. This high number suggests that very little in the way of greenhouse trials has been carried out since, in conventional breeding, a great deal of selection would be carried out before field trials. The fact that in this more hazardous situation this work does not appear to have been done adds to our impression that haste and commercial pressure appear to have been the driving forces behind this release, rather than careful scientific evaluation.

A distance of 20m between trials and commercial potato growing is grossly inadequate. As mentioned above Organic Trust members have frequently found that tubers have been moved much greater distances than this by birds and rodents.

It is stated that closed containment will be used for transport. We feel that sealed containment is necessary. Since we are told that conventional harvesting methods will be used we know that there will be a high level of small tubers left in the ground. These will not appear as volunteers until the following spring but can be accessed by birds and rodents throughout the winter. Unless commercial potato crops in the vicinity have been harvested before transgenic crops there is a risk that transgenic tubers can be moved by birds and rodents to the commercial crop and mixed there. “Any leftover tubers identified” – how is the ground to be examined in sufficient detail to identify these tubers?

We are told that tubers originating from the trial will not be used for human or animal food. This will not prevent their being used as food by wild animals and birds. Nor will it prevent future tubers being bred from them for use as human or animal food.

No length is given for the volunteer monitoring programme.

The measures to prevent unintended release as a result of vandalism are inadequate. Removal and destruction of uprooted plants or premature harvesting will do nothing to control the spread of the tubers should vandals remove them from the site.

In the light of the above, the Organic Trust Ltd wish to lodge their most strenuous objections to these totally unwelcome GM trials.

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