Is there sufficient knowledge about environmental effects to justify release of GE organisms?




General conclusion

Potentially serious environmental hazards are considered conceivable that justify the need for very thorough long-term ecological studies that must be done under carefully confined conditions. No such studies have been made. The "risk analyses", that the biotechnology industry has made instead, do not have the experiential basis required to enable reliable judgements.

Until long-term ecological studies have been made, there is no scientific basis for maintaining that GE organisms are ecologically safe or represent minor risks.

There is no scientific basis for the notion "careful releases", used by the governments to justify present releases, as released genes cannot be controlled or recalled and as there is insufficient knowledge of what to be careful about.

For these reasons no releases of GE organisms of any kind into the environment can presently be considered safe or justifiable. A long-term moratorium is necessary including a withdrawal of presently released organisms.


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Contents

1. Is there enough knowledge of environmental effects of GE organisms to assess the risk of ecological damage? 2. Potentially harmful environmental effects of GE organisms

3. "Careful releases"

4. Comment on release approval on the basis of "technology assessment"


1. Is there enough knowledge of environmental effects of GE organisms to assess the risk of ecological damage?


Introduction

To understand this issue, it is important to remember that, in nature, the interdependence of living organisms is enormously complex. It is the result of an evolution that has taken millions of years. This "Web of life" is still incompletely understood in spite of extensive research. But it has been well established that changes even of a few organisms in the system may have farreaching effects on the whole ecology causing important damage in the worst case.

It is also important to remember that, differently from any previous releases of man-made products into the environment, released genetically engineered genes or parts of them may in the worst case multiply and spread indefinitely not only to related species but, through horizontal transfer, also to other kinds of organisms like bacteria and viruses (see Horizontal transfer - an introducton [EL]).

It is impossible to recall a released GE gene. A "successful" gene may ultimately spread all over the world and persist indefinitely.

Because of this, it is much more important than for any kind of previously released products, to understand the consequences of releases of genetically engineered genes exhaustively and in great detail. Below you will find that the extreme opposite is the case.


Important requirements for environmental assessment of ecological effects

  1. Long-term studies are necessary. To assess the ecological effects of the introduction of a new crop, it is necessary to study its consequences over a period of several years, as some ecological effects will not become apparent immediately.

  2. The study must encompass a considerable area outside the field where the studied GE plants are cultured. In different ways explained below, the effects of a release may affect the surroundings within a range of up to several kilometers. This depends on the nature of the crop and whether there are natural relatives with which it may cross-breed in the environment.

  3. The study must encompass all possible forms of life that might be affected. This includes soil microorganisms, insects, birds and animals.

    Needless to say, such environmental studies are very expensive, demanding big resources. Before it has been reasonably ascertained that irreparable consequences cannot ensue, the studies must be done under strictly contained conditions (e.g. carefully sealed large greenhouses).

Present status of knowledge

No comprehensive studies fullfilling the above criteria have been made on the effects of genetically engineereed food organisms before commercial release.

To be able to detect long-term effects of released organsims, a base-line reference is needed. Not even this basic requirement is fulfilled:

"Getting the detailed baseline data that researchers need... will require extensive monitoring programs to watch for diseae outbreaks or pest infestations in agricutural systems", she said. "We have some long-term ecological research sites that are meant to begin this process, but these are only a decade or two old in most cases. So it is difficult to argue that the baseline monitoring data we have right now are sufficient for many of the kinds of ecological risks that we are interested in."

Source: Ecological Monitoring of Genetically Modified Crops: A Workshop Summary (2000), US National Academy of Science Commission on Life Sciences http://books.nap.edu/books/0309073359/html/14.html#pagetop


For a comprehensive analysis of environmental effects, see "Transgenic Crops: An Environmental Assessment" . It is an extensive and thorough examination prepared by the Henry A. Wallace Center, January 10, 2001. This study concludes a/o:

"At this writing we only have a small core of scientific information to understand the short- and long-term environmental effects of these crops"

Source: "Transgenic Crops: An Environmental Assessment,"

A major reason why the knowledge is so incomplete is that research funding on biotechnology risk reseach has been a trickle compared to the huge investments into developing new GE crops.

"The US Department of Agricultures biotechnology risk assessment program has awarded an average of $1.5 million dollars annually - only 1 percent of USDA biotechnology research spending - to fund risk assessment of agricultural biotechnology applications (USDA ARS, 2000). The USDA's Agricultural Research Service spends approximately $5.4 million annually on biotechnology risk assessment research (Radin, 2000). The total of approximately $7 million per year on risk research is approximately 4 percent of public agricultural research funding of biotechnology."

Source: "Transgenic Crops: An Environmental Assessment,"


Still, the biotechnology industry has been maintaining that there is enough knowledge to conclude that releases are unproblematic, referring to the large number of "commercial release studies".

Commercial release studies

Such studies do not fulfill the requirements above. Their main purpose in reality has been essentially to test the behavior of the genetically engineered plant in a natural environment. In some cases superficial examination of the surrounding environment has been done. Such studies provide no basis for evaluting ecological effects.

The ecologist Philip Regal says about commercial field studies: "It is hard even to imagine a case where one might have concerns that ecological problems might arise from widespread release, and where one would expect to see 'problems' by simple inspection of field plots, especially if they contained no potential native competitors! ....Yet this sort of nondata on nonreleases has been cited in policy circles as though 500 true releases have now informed scientists that there are no legitimate scientific concerns", see "Judging potential hazards: field plots and commercialization".


Risk assessments

Instead of making expensive ecological studies, the industry has invested in "risk assessments". These have commonly concluded that the risks for environmental complications are insignificant. But it is completely impossible to make any reliable prediction about the risk of a release with the present scarcity of knowledge of short- and long-term environmental consequences. So this has been a guesswork with room for considerable arbitrariness, serving the intended purpose to save the industry from having to make large investments into qualified environmental studies. Se further "Faulty risk-analysis methodology". [EL] .

"Our inability to accurately predict ecological consequences, especially long-term, higher-order interactions, increases the uncertainity associated with risk assessment."

Source: L.L. Wolfenberger and P.R. Phifer (2001)"The ecological risks and benefits of GE plants", Science 290:2088-2093


Conclusion

There exists very little scientific knowledge of the environmental effects of the genetically engineered food organisms now released for large scale agriculture. Consequently there is no reliable scientific basis for risk evaluation.

Independent scientists have envisaged a number of potential ecological hazards, some of which are enumerated below.


2. Potentially harmful environmental effects of GE organisms

Some of the potential hazards, suggested by ecologists are:

In addition, the knowledge about DNA is far too incomplete to enable science to exclude that the abnormality introduced into DNA through gene transfer may make such genes harmful to the environment in ways that cannot be imagined presently. For more about this, see Does science have enough knowledge about DNA to be able to predict and master the effects of genetic engineering?


Concerns about risks posed by transgenic agricultural crops generally focus on direct risks to human health. There is, however, a set of potential ecological risks that bears equal scrutiny. Transgenic crops designed to resist or kill herbivores, for example, may spread their genes to non-crop species, producing virulent weed species. Likewise, these crops may negatively affect populations of beneficial insects, as was the case in the recent controversial finding that transgenic corn may increase mortality in monarch butterfly caterpillars. Assessing such risks is inherently difficult, but the impact of ignoring them could be devastating.

Michelle Marvier, "Ecology of Transgenic Crops" published in American Scientist, Volume 89, No. 2 March-April 2001,


Conclusion

Diverse potential hazards have been envisaged or experimentally verified. They may cause ecological disturbances that are impossible to repair and may increase over time and spread widely without any possibility to control them. In addition, there may exist important complications that are presently unimaginable because of the very incomplete knowledge about DNA.


3. "Careful releases"

Biotechnology advocates often recognize the need to consider potential ecological hazards by emphasizing that "great care" should be applied in releasing GE organisms. This implies that the spread of the genes can be controlled after release. This is generally not true. Without any possibility to control the spread of the genes it is of course impossible to maintain that releases can be "careful".

Furthermore, carefulness of releases would, in addition to full control of the spread of the genes, also require an understanding of potential ecological risks. As such knowledge is almost completely absent, the notion of "careful releases" has no scientific basis.


4. Comment on release approval on the basis of "technology assessment"

"As the environmental safety of the products can not be established on the basis of present scientific knowledge, it has been suggested that the evaluation should be based on an evaluation of the safety of the technology. Thereby the issue would be transformed from Risk Assessment (RA) to Technology Assessment (TA). If the technology yields products that are not essentially different from breeding it is suggested that there is no need for assessment of the environmental consequences" (Excerpt from Comment on a suggested EU policy concerning release of GE organisms).

This is the same kind of judicial trick as that behind substantial equivalence in the assessment of food safety. In the absence of scientific knowledge about the safety of GMO:s one tries to transform the safety issue to one of comparison of technologies. It has no scientific basis. - Every instance of genetic engineering is unique and may have unique environmental effects. Therefore the "comparison of technologies" tactic is as invalid as the principle of substantial equivalence (see Substantial equivalence versus scientific food safety assessment). Both were designed by the biotechnology lobby to make regulators adopt approval routines that disregard science in safety assessment. Considering the potentially serious and irreparable consequences of GE organism releases such routines are unacceptable.


General conclusion

(This is the same text as the that on top of the page )

Potentially serious environmental hazards are considered conceivable that justify the need for very thorough long-term ecological studies that must be done under carefully confined conditions. No such studies have been made. The "risk analyses", that the bioechnology industry has made instead, do not have the experiential basis required to enable reliable judgements.

Until long-term ecological studies have been made, there is no scientific basis for maintaining that GE organisms are ecologically safe or represent minor risks.

There is no scientific basis for the notion of "careful releases", used to justify present releases, as released genes cannot be controlled or recalled and as there is insufficient knowledge of what to be careful about.

For these reasons no releases of GE organisms of any kind into the environment can presently be considered safe or justifiable. A long-term moratorium is necessary including a withdrawal of presently released organisms


Physicians and Scientists for Responsible Application
of Science and Technology (PSRAST)


Published in May 1999. Last update: April 5, 2001.


Related text:

Comment on a suggested EU policy concerning release of GE organisms


To: "Is there sufficient scientific knowledge to ensure safe commercial exploitation of genetically engineered foods?"


Literature

The reductionistic methodology used by natural sciences yields a fragmented picture of reality. It is now becoming recognized that this methodology is unable to yield an exhaustive understanding of complex interdependent conditions like those in ecosystems, see "Is the scientific approach used by natural sciences sufficient to yield exhaustive knowledge of biological systems?". Because of this, there is a considerable risk for underestimation of ecological complications among scientific experts. An excellent book that discusses this problem and gives an idea of the great interdependence of living organisms is the "The Web of Life" by Fritjof Capra (Harper Collins, London, UK, 1996), available at amazon.com.


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