Please find below my letter to the OECD. Comments need to be send before 15 feb. You
can use the letter or parts of it as a sample letter. The e-mailadress of EOCD is:
> My name is Wytze de Lange and write to you on behalf of Biofood Consultancy.
> Biofood Consultancy is a science-based food advisorygroup with connections
> with many important societal groups in the Netherlands. A large number of
> these organisations have last year asked for a moratorium on the environmental
> release of gmo's. I hereby send you some comments on safetyaspects of GE,
> which have lead to the request for a moratorium.
> At present there is a lot of talking about a risks versus benefits approach.
> This approach is open for very different, subjective interpretations.
> Therefore we think it better to stick to the formulated approach that
> producers of GE crops and foods need to demonstrate that the GE crops are not
> less safe than their non-GE counterparts.
> However, even in a risk-benefit analysis, most groups argue that other
> solutions to the identified problems are fully possible, often more practical,
> cheaper, more simple and less risky. Especially the combination of Integrated
> Pest Management (without GE) and Organic Agricultures needs to be seriously
> considered as an option to fully realise the obejectives of sustainable
> agriculture with the highest possible degree of foodsecurity and foodsafety.
> This does not exclude the use of genomics as a tool of analysis and
> diagnosis. It does however exclude the use of transgenic organisms.
> Risks concerning GE in agriculture are seen in a number of fields:
> agronomical, environmental and foodsafety being the three most dominant ones.
> A basic comment on risk assessment as it is endorsed until now, is that it
> leaves a whole range of issues undealt with. Thus, in spite of the fact that
> possibly millions of field trials may have taken place worldwide, no proper
> insights in the potential risks have been obtained by the simple fact that
> many data have not been gathered. This is true for field trials but is equally
> true for the foodsafety assessments for GE foods. Therefore, we have seen in
> the past few years studies emerge that point to effects of gmo's on non-target
> organisms, effects on soillife, horizontal gene transfer, agronomical
> performance, foodsafety etc. which show that a number of aspects have been
> insufficiently investigated in the trial phase and approval procedures.
> -Our understanding about ecological systems is still very incomplete as is our
> understanding of DNA and genomes. Established biological insights are
> partially ignored in modern biotechnology, which is irresponsable and a denial
> of sound scientific principles. These risks have been pointed out and part of
> them has been shown already.
> New biological insights may reveal new risks which have not been counted with
> until now. This category of risks however can be "foreseen" or expected on the
> ground that gmo's in the environment introduce man-made geneconstructs into a,
> genetically speaking, specifically organised world. "Engineering in nature can
> be extremely precise" was a statement by a speaker from the US Institute for
> Genome Research at a recent Biotechnology congress in The Hague. In the same
> speech he said concerning horizontal gene transfer that we are only just
> finding out how the "web of life" is organised. (The combination of) these two
> points alone is actually enough scientific reason to refrain from introducing
> geneconstructs which suffer human limitations as far as preciseness is
> concerned and of which by definition we cannot fully assess their impact at
> this point in history. This point is illustrated for example by the very
> incomplete knowledge we have about soillife. It is estimated and generally
> acknowledged that we only know 1-10% of all organisms living in soils. This
> makes a full and complete assessment of the impact of decomposting gmo's in
> soils extremely difficult if not impossible. Field trial reports show that the
> impact of gmo's on soils are insufficiently investigated, if at all.
> -The first GE crops (soy and maize) have been introduced with a lot of
> beautiful promises. A great reduction in chemical pesticides would be
> obtained, the crops would be a great contribution to solve the problem of
> hunger in the world etc. However, so far these crops have not lived up to
> their expectations. On the contrary, it seems that critics who warned for an
> increase of herbicide use on herbicide resistent crops have the facts on their
> side. Just last week we saw a report on new, triple resistant canola weeds in
> -The herbicides glyfosate and glufosinate may be less benign than often
> claimed. For glufosinate there are worrying studies which point to brain
> damage by Watanabe et. al. For glyfosate for example there are studies on
> negative effects on fertility by Youssef et al.
> -A clear environmental and agronomical risk concerns the release of gmo-crops
> in the centre of origin of these crops.
> -Concerning foodsafety of gmo's we do NOT share the view of some that these
> risks are small or non-existant. Internal FDA documents which have become
> available clearly show that FDA scientists actually ackowledged already years
> ago the fact that gmo's may lead to new health hazards. The peer-reviewed and
> published study by dr. A. Pusztai and dr. S.Ewen on effects of gmo-potatoes on
> young rats should be taken into full account. We have been shocked to see how
> outrageous parts of the scientific community have behaved towards these
> scientists. It has shown how unwilling GE proponents are to have a reasoned
> and decent debate on the issue. The study supports the point that the concept
> and practice of the Substantial Equivalence-approach is insufficient and
> incomplete in the foodsafety assessment procedures and that the working of the
> whole geneconstruct needs to be studied much better. Other legitimate points
> of concern are the capacity of bacteria in human saliva and in the
> respiratorytract to take up free or "naked" DNA, the capacity of mammalian
> cells to do the same and the use of anti-biotic resistance genes.
> Urgent attention needs to be given to cytopathic viruses, called stealth
> viruses because of their capacity to fool the human immune system. Stealth
> viruses show multiple regions of highly significant homology to various
> bacterial genes, are closely related to human cytomegaloviruses and are
> identified in several human diseases at the Centre of Complex Infectious
> Diseases. See for example W.J. Martin Exp. Mol. Path. April 1999, 66 (1)
> p.8-14. "Pharm" crops, with human genes, could be huge factories where these
> stealth viruses could develop. "Pharm" animals are an even bigger group of
> concern and those using viral vectors need to be immediately studied on this
> point. A recent study indicate that viruses are the main cause in foodborne
> diseases as far as it
> concerns known agents. An overwhelming majority of 80% of foodborne diseases
> concerns unknown agents. (Mead et al. Food Related Illness and Death in the
> United States in Emerging Infectious Diseases Vol 5 nr5).
> Cummins, Ho and Ryan have pointed at the risks connected with the use of
> CaMV35S promoter, used in virtually all GE crops currently on the market. The
> reasoned argument to use this promotor in GE crops is profoundly superficial
> and needs serious reconsideration.
> -A further point that needs much more attention is the effect of the moment of
> application of the used herbicides on the herbicide resistant plants. It can
> be found in patents of companies that the moment of application can
> significantly influence the plantmetabolism. In the present procedures this
> point is mistakenly not taken into account.
> -Animal feed crops need to be much more seriously considered on their
> foodsafety. Regulation in this area is almost missing.
> -A whole other area of concern is about the socio-economic effects of GE in
> The spreading of gmo's by pollen and seeds into fields of farmers who do not
> want to work with gmo's needs to be urgently adressed before further releases
> are allowed.
> Treshold levels are no solution here, since the contamination level will
> steadily rise.
> Therefore, until an acceptable technological solution has emerged, a political
> solution other than tresholdlevels needs to be found. Banning cultivation in
> areas, countries and continents may be the only solution at this point in
> time, if not a total ban worldwide.
> At the very least no new GE crops should be allowed as long as this problem
> Contamination problems are of particular grave concern in developing countries
> where plantbreeding still greatly happens in the fields of farmers and
> -Other socio-economic points of concern are the issue of patenting of seeds,
> plants and other organisms and the intense growth of Trans National Companies
> (TNC) control in the seedsector. Negative effects of plant patents on farmers
> in developing countries already have manifested. Promoting liberalisation and
> free trade on the one hand with in the other hand im- and exportcontrol with
> patents is obviously problematic.
> The aspects mentioned above are among those that are considered for many
> groups to be sufficient reason to ask for a moratorium on GE in agriculture
> and to seriously opt for other approaches which are seen as much more viable and
> Wytze de Lange
> Biofood Consultancy
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