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BASF abandons plans for Irish GMO potato experiment

On 24 May 2006, the world's largest chemicals company BASF gave up its plans for a controversial patented GMO potato experiment in Co. Meath this year, and may cancel it altogether. See press release.

BASF said it made the decision because of the conditions imposed in the provisional consent given by the Environmental Protection Agency on 8 May. These included obligations for the company to reduce the risk of cross-contamination of neighbouring farmers and wildlife, and to pay the costs of an independent monitoring of health and environmental impacts. BASF complained that such conditions had not been imposed for similar experiments in Sweden.

The cancellation may also have been influenced by nationwide opposition from more than 100 farm and food industry groups, resistance by TDs from all the parties, two motions passed unanimously by Meath Co. Council, and the threat of further legal action on planning and constitutional grounds. Meath Co. Council unanimously passed two motions on Monday 8 May, that are widely expected to force the world's largest chemicals company BASF to abandon a controversial experiment with patented GMO potatoes which it hoped to launch this week at Summerhill, Co. Meath.

The Council's first motion declares Meath a GMO-free zone. This makes Meath the sixth county on the island to prohibit GMO seeds and crops, along with Cavan, Clare, Fermanagh, Monaghan and Roscommon, and the towns of Galway, Navan, Newry and Clonakilty. The Council's second motion calls on the EPA to not allow the experimental growing of any GMO seeds or crops in Ireland. Councillors said the EPA's decision would produce experimental transgenic potatoes that could not be placed on the market either as animal feed or food, and that the EPA and BASF failed to apply for the planning permission that is consequently required by law for re-zoning the farmland from agricultural to development use. Download May 9 press release.

They also said the legal requirement imposed by the EPA for BASF to protect the site with a high-security electrical fence does not conform with normal agricultural practice under Section 5 of the Planning Act. Frank Corcoran, Chairman of An Taisce (the National Trust for Ireland), said the Meath Co. Council decisions will trigger a lengthy legal procedure that will effectively prevent the release of GMO crops in Meath for the foreseeable future.

Farmers, food producers, chefs and consumers around Europe celebrated the decision as a victory for common sense and local democracy. GM-free Ireland Network co-ordinator Michael O'Callaghan said "Meath Co. Council has shown the wisdom of the subsidiarity principle, whereby political decisions on GM farming are best taken democratically at the local level by the farmers and citizens who will be affected by them, rather than by unaccountable bureaucrats in Dublin, the European Commission in Brussels, and the WTO in Geneva.

Commenting from Berlin, Benedikt Haerlin, who organises the annual European GMO-free Regions conference, said the EC's policy to force member states and regions to accept contamination of agricultural seeds and crops by GMOs is fundamentally and legally flawed. "We welcome Co. Meath's initative which is backed by 175 regions and 3,500 local authorities in 22 EU member states" he said.


EPA approval subject to 10 conditions

Ireland's Environmental Protection Agency (EPA) announced on 4 May 2006 that it had given the go-ahead to BASF's experiment with geneticially modified potatoes in Co. Meath, subject to 10 conditions. For details please visit the EPA web site at www.epa.ie.

An emergency community discussion was held Friday 5 May in Navan. This was a follow-up to a meeting held near the proposed experiment site at the Summerhill Community Centre, Summerhill, Co. Meath on Tuesday 25 April (download press release).

32,000 Irish farmers, environmental groups, doctors, restaurants, and consumers have expressed total opposition to a patented GMO potato experiment which the global chemicals giant BASF plans to start at or near the Teagasc Grange Research Centre in the Boyne Valley near the Hill of Tara – one of the oldest cultivated sites in Europe. Leading geneticist Prof. Joe Cummins said the GMO potatoes could lead to contamination, with toxic effects on humans and wildlife (see section 6 below). This would jeopardise the Irish seed potato industry worth €5.8 million a year and also destroy our image as Ireland – the food island.

Hundreds of people took part in a related national protest and press conference on 22 February, attended by Marian Harkin MEP and Senator David Norris who revealed that Mella Frewen, Director of Government Affairs (Europe-Africa) for Monsanto Services Intl. was on the official Irish Government delegation to the World Trade Organisation talks in Hong Kong and Cancún! (Download transcript.) Senator Norris said it is disgraceful that the Irish delegation was used as a Trojan horse by Monsanto. "I call upon Bertie Ahern and the Government to explain what that Monsanto representative was doing at the WTO trade discussions purporting to represent the Irish people. They do not represent Ireland!"

Government secrecy and the Freedom of Information Act

The site of the proposed experiment is a 2 Ha plot at Arodstown, Summerhill, Co. Meath (see maps). This appears as a small hill 2km north of the R156 road between Dunboyne and Summerhill in the lower right corner of the Discovery Series map no. 42 (approximate OS grid reference: N 885 500), close to the Teagasc Grange Research Centre. The EPA and Teagasc refuse to reveal the exact location of the site.

The site belongs to Nicholas McCabe, a former Fianna Fáil Councillor from Co. Louth who bought lands around Moynalvy some years ago. But without knowing the exact location of the field where the experiment would take place, neighbouring farmers are effectively prevented from taking adequate measures to inform and protect themselves from contamination if the experiment goes ahead.

On 20 February 2006, the Irish Independent newspaper revealed that the Department of the Environment is trying to exclude GMO crop data from the Freedom of Information Act, making it impossible for members of the public including researchers and scientists to obtain access to certain details of GMO crop strains required for thorough risk evaluations. Information Commissioner Emily O'Reilly criticised the exclusion, saying there was sufficient provision in the Act to protect the commercial nature of information without excluding it. In a report to the Joint Oireachtas Committee on Finance and the Public Service, she also noted the EPA's obligation to consider the public interest in any request for confidentiality.

Who decides?

Under EC law, all GMO seeds and crops require formal approval before being released in EU member states. The approval procedure involves vetting by the controversial European Food Safety Authority (EFSA) for foods, and the European Environmental Protection Agency for seeds and crops, followed by a vote in the European Parliament. If the Parliamentary vote does not produce a so-called "qualified majority" for or against the application, the so-called "comitology" procedure kicks in, whereby the Council of Ministers gets to vote; but if the latter also fails to reach the "qualified majority", then the Commission automatically rubberstamps the approval. Ireland has never voted against the approval of a GMO food or crops in either the Parliament or the Council of Ministers.

Once the EC has approved a GMO for field trials or for placing on the market, the Member States "competent authority" must also give the go-ahead.

Under relevant EC Directives, the Irish Environmental Protection Agency (EPA) [http://www.epa.ie/] is the "competent authority" to approve or prevent the "deliberate release" of GMO crops in the Republic of Ireland. Anyone wishing to release a GMO crop must notify the EPA. The EPA must notify the public and accept related submissions during the following 28-day period. The EPA's GMO Advisory Committee must then review both the notification and the submissions, and deliver minutes to the EPA on all points raised. The EPA then passes the dossier on to an Inter-departmental Working Group which reviews it and passes its advice on to the Minister for Environment and Local Government and the Minister for Agriculture and Food.

(Note that applications for the placing of GMO foods on the market are processed in a separate track involving three organisations: (a) the Food Safety Authority of Ireland (FSAI) run by Dr. John O'Brien, by a former Director of the biotech industry lobby group called the International Life Sciences Institute, (b) the Department of Health and Children, and (c) the Department of Agriculture, Food and Rural Development.

Democratic deficit and vested interests in the decision-making process

At the GM-free Ireland press conference held on 22 February (see transcript), the EPA's GMO Advisory Committee member Kathryn Marsh said "There is a complete democratic deficit in the treatment of GMOs in Ireland. There is only one route for ordinary Irish people to get their voices heard. And only four individuals in Ireland who are members of the EPA advisory committe have had a chance to use that route... Everybody else, on every committee that rules on GMOs in this country, has an interest in furthering biotechnology and GMOs. They are all either university scientists with their research funded by the biotechnology companies, or they are actually employees of biotechnology companies themselves. This is something to be borne in mind when we see that the Food Safety Authority says it's OK, the Bioethics Committee of the Royal Irish Academy says it's OK, the Inter-Departmental Committee on GMOs says it's OK. All of those are advised entirely or almost entirely... by those with a financial stake in the biotechnology industry."

The story so far

13 January 2006: BASF Plant Science GmbH notified the EPA of its intention to conduct the experiment from April 2006 to October 2010:

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Register of GMO Users in Ireland, Notification Ref. No. B/IE/06/01 (3-page Word document).

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BASF's Summary notification format for the release of genetically modified higher plants According to Council Decision 2002/81/EC, Notification number B/IE/06/01; (4-page Word document from BASF Plant Science GMbH).

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BASF's Notification for the release into the environment of genetically modified potatoes with improved resistance to Phytopthora infestans (2006 - 2010); (52-page Word document from BASF Plant Science GmbH.)

26 January 2006: the EPA made the BASF notification public in a single notice in the Irish Independent, (which you can download as an Ms.Word file), although the official EC Joint Research Centre published its offical notification on 14 January. Nevertheless, the EPA set 22 February as the deadline for public submissions.

The EPA web site (www.epa.ie) published a General information note in relation to the making of representations to the EPA regarding a notification under the Genetically Modified Organisms (Deliberate Release) Regulations - S.I. No. 500 of 2003. (2-page Word document from the EPA).

28 January 2006: at GM-free Ireland's request, Prof. Joe Cummins, a leading geneticist, wrote a paper on the health and environmental risk of the proposed experiment entitled Genes from a wild plant Solanum bulbocastanum used to resist potato blight fungus. See summary below or download the full paper as a 154kb PDF file.

22 February 2006: despite the short deadline, the EPA received 95 submissions opposing the experiment, one in favour, and 25 submissions which it did not accept either because they arrived late or did not include the mandatory €10 fee. The only submission in favour of the experiment was from the Irish Bioindustry Association (IBA) - an arm of IBEC - which repeated the totally discredited biotech industry hype that GMO crops have been grown commercially for a decade with "no adverse effects to human health or the environment".

You can download all the accepted submissions directely from the EPA web site here:

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part A (large 7MB pdf file).

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part B (large 8MB pdf file).

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part C (large 4MB pdf file).

The EPA found a large number of flaws in the BASF notification, and requested the company to provide answers to a first long list of questions regarding various aspects of the proposed experiment.

24 February 2006: BASF provided a response to the EPA's first list of questions. Download questions and answers as 18-page 248kb PDF file.

28 February 2006: Prof. Joe Cummins provided comments on BASF's response to the EPA's first list of questions. Download comments as 8-page 48kb PDF file or see summary below.

Dr. Arpad Pusztai, a GMO potato expert who discovered major health risks with GM potatoes in 2000, provided a detailed submission commenting on BASF's proposed experiment. Download the full text of his comments as a 5-page 160kb pdf file or see summary below.

13 March 2006: the EPA sent BASF a second list of questions regarding its notification (see questions and answers under 22 March below).

22 March 2006: BASF provided answers to the EPA's second list of questions. Download questions and answers as 13-page 240kb PDF file.

24 March 2006: the EPA's GMO Advisory Committee met to discuss those submissions and comments it has both received and accepted. Draft minutes of this meeting can be obtained under the Freedom of Information Act.

Some members of the Advisory Committee wondered if the people who wrote the BASF proposal had ever seen – let alone grown – a potato. The questions which the Advisory Committee asked BASF about the protocol of the experiment are said to be considerably tougher than questions asked by any other country where BASF has sought permission to grow the GMO potatoes.

22 April 2006: GM-free Ireland held an emergency community meeting at Summerhill, to inform local people about the GMO potato experiment. Local farmers expressed strong concerns over the ecomonic impact which the experiment could have on them. See press release.

4 May 2006: The EPA gave the go-ahead to the experiment, subject to conditions. See EPA web site for details.

5 May 2006: Meath Co. Council unanimously passes two motions (a) to declare Meath a GMO-free zone and (b) for the EPA not to allow any GMO crops experiments. Download press release.

10 May 2006: Irish politicians call for Ireland to become GMO-free zone for food security of other EU member states and for the EC to recognise the democratic right of its member states and regions to ban GMO seeds and crops if they wish to do so.

23 May 2006: BASF announces it will not go ahead with the GMO potato experiment in 2006, and may cancel it altogether. Download press release.

What happens next?

Meath Co. Council and organisational members of the GM-free Ireland Network are currently taking legal advice on possible interventions to block the experiment should BASF try to re-launch it in 2007.

Permission for similar GMO potato trials has already been granted in other countries for 2006 and will also be granted in the Netherlands for 2007. If any of the GMO potato strains being trialled are successful in another EU member state and also pass its food safety tests and gain approval by that state, then they can also legally be grown in Ireland on condition that the Department of Agriculture is duly informed and that various agreed "co-existence" measures such as GMO crop separation distances etc. are properly implemented. Note that no such "co-existence" measures have yet been agreed in Ireland. The danger here is that an approval based on weak risk assessment in another EU member state could lead to the GMO potatoes being introduced in Ireland.

Given our Government's hardline pro-GMO track record, the fact that the vast majority of the EPA's GMO Advisory Committee members have strong ties to the agri-biotech industry, and the fact that Dick Roche (Irish Minister for the Environment and Local Government) failed to appoint any of the people nominated by the Irish NGO sector to the EPA's main advisory committee, the EPA decision to approve the experiment is no surprise.

The GM-free Ireland Network is therefore calling for reform of the EPA and for comprehensive and independent environmental and health risk assessments (using a scientific protocol openly agreed and approved by independent scientists and representatives of the public and consumer groups) that are needed. We support the elected representatives, farmers and citizens of Co. Meath and Ireland who are standing up for their right to keep this country free of GM food and farming.


Detailed information

The rest of this page contains a profile of BASF, information about the aim of this experiment, general dangers of GMO crops, two independent risk assessments of this GMO field experiment by Prof. Joe Cummins and Dr. Arpad Pusztai, links to related documents published on the EPA web site, a partial list of objections sent to the EPA by members of the GM-free Ireland Network, basic information on the dangers of GM food and farming, and what you can do to prevent the GMO invasion.


1. BASF company profile

BASF Plant Science GmbH is an affiliate of the world's largest chemicals & drugs corporation BASF - Badishe Analin und Soda Fabrik, whose net profit jumped by 50% to €3.007 billion on sales of €42.745 billion in 2005.

Based in Germany, BASF is a former member of the notorious IG Farben conglomerate which was the financial core of the Hitler régime. IG Farben owned the patent and was the main supplier of the cyanide-based insecticide Zyklon-B, used by Nazi Germany to murder millions of Jews in concentration camps. IG Farben built a factory at Auschwitz using 83,000 slave labourers. After the war, IG Farben split into its original companies some of which survive today as Agfa, BASF and Bayer, while Hoechst merged with the French Rhône-Poulenc Rorer to form Aventis. After the war, IG Farben co-founded the Chemagrow Corporation to develop and test chemical warfare agents in collaboration with the U.S. Army Chemical Corps. In 1967, the IG Farben Trust entered into a joint venture with Monsanto. BASF, Bayer, Aventis and Monsanto are leading producers of GMO crops. None of the above is meant to denigrate the scientists who work at BASF today, who no doubt believe GM crops are good for humanity. The point is that the agribiotech and weapons industries are historically linked.

Bayer CropScience L.P. is currently being sued in US Federal Court along with Monsanto Co. and Delta & Pine Land Co. by 90 Texas cotton farmers who say they have suffered widespread crop losses because the companies failed to warn them of a defect in their GM cotton. The lawsuit, filed in Federal Court in Texas, seeks an injunction against what it calls a longstanding campaign of deception and asks the court to award both actual and punitive damages. One of the plaintiffs, farmer Alan Stasney, said the crop failure cost him $250,000 in lost sales and forced him to refinance his farm.

In November 2001, the European Commission imposed fines of € 833.23m on BASF and several other companies for running a series of cartels in 12 vitamin markets between 1989 and 1999. BASF was fined a total of € 296.16 m. for its part in eight cartels (vitamins A, E, B2, B5, C, D3, beta-carotene and carotenoids); the fine was subsequently reduced to € 236.9m. Separate charges were brought in the US, resulting in fines of more than $2 bn to federal and state governments and private plaintiffs.


2. Aim of this experiment

BASF's stated aim is to generate patented GMO potatoes with improved resistance to the late potato blight fungus Phytopthora infestans. BASF intends to plant up to 45,000 of 430 different kinds of GMO potatoes each year from 2006 to 2010, up to 450,000 GMO potatoes in total.

Increased blight resistance is a desirable trait, but at least two varieties of blight-resistant potatoes, produced by safe non-GMO traditional breeding methods, are already available to Irish farmers.

Since potatoes are a staple of the Irish diet, the introduction of patented GMO varieties could be part of a long-term BASF strategy to take control of the entire Irish potato market (in the same way that Monsanto aims to control the entire European maize market through it patented GMO maize).

BASF may also have selected Ireland as the location for its GMO potato experiment in hopes of appropriating the well-known tragedy of the Irish famine as the emotionally compelling spin for its global GMO potato marketing strategy. Note that the blight responsible for Ireland's mid-19th century potato crop failure might have been prevented if farmers had access to the natural diversity of potato varieties used in South America. Moreover, the famine was not caused by any lack of food; while a million people died of hunger, and millions more were forced to emigrate, Ireland exported vast quantities of food to England throughout the famine period.


3. Patent rights

These GMO potatoes have a world patent (publication no. WO/2003/066675 [or WO/2003/066675A1 ?], international application no. PCT/NL2003/000091) requested by the Dutch company KWEEK- EN Researchbedrijf Agrico B.V. Details available on the World Intellectual Property Organisation (WIPO) web site at www.wipo.int.

Under the Trade-Related Intellectual Property Rights (TRIPS) agreement – a cornerstone of the World Trade Organisation's so-called "free trade" agreement put in place by Irishman Peter Sutherland – a GMO patent may enable the patent owner to claim ownership of any farmers' crops contaminated by its patented genes, to file patent infringement lawsuits against contaminated farmers, and force any farmers found growing the potatoes (whether by contamination or not) to pay annual patent royaties. This is part of the transnational corporate strategy to control the food supply through GMO crop patents.

According to the Irish Patent Office, the global TRIPS agreement now superceeds EU and Irish patent law and the latter offer no protection to Irish farmers who may be sued for patent infringement after becoming contaminated by GMO crops.

For more on this, see our interview with Canadian farmer Percy Schmeiser who lost ownership of his crops after being contaminated by Monsanto's patented GMO seeds in 1996.


4. How are these GMO potatoes different from ordinary spuds?

These GMO potatoes have been modified by introducing mixtures of foreign genetic material:

genes from a wild Mexican potato variety Solanum bulbocastanum (Ornamental nightshade) that provides some resistance to the late potato blight fungus Phytopthora infestans;

marker genes from mouse-ear cress Arabidopsis, a plant related to cabbage and mustard that conveys tolerance to "Imazamox" herbicide (which contains banned Imidazolinones);

two vector genes from pathogenic bacteria called Agrobacterium tumefaciens.

It appears that no animal feeding studies have been done, and that no environmental or health impact studies are planned.


5. General dangers of GMO crops

See our separate sections on the health, environmental, and legal risks of GM food and farming.

Irish farmers contaminated by GMO crops may lose ownership of their own produce, face patent infringement lawsuits, and be forced to play annual patent royalties. See our interview with Canadian farmer Percy Schmeiser.

Modified genes can escape and contaminate other crops, wildlife, and produce "superweeds". Visit www.gmcontaminationregister.org for info on GM contamination of seeds, food and feed around the world.

There is growing scientific evidence that GM foods and crops pose unacceptable health and environmental risks, including overwhelming evidence of deaths attributable to GM products among laboratory and farm animals and in the human population. The biotech industry and regulatory bodies have attempted to cover up the evidence:
New evidence of harm from GM food triggers call for immediate ban, by Dr. Brian John.
Most Offspring Died When Mother Rats Ate Genetically Engineered Soy, by Jeffrey M. Smith.
GM Potatoes in County Meath, by Séan McDonagh SCC.

Since GMO potatoes must carry a GM label and there is no market for GM food in Europe, contaminated farmers will lose market share. See No market for GM-labelled food in Europe (download as large 2mb PDF file).


6.

Independent risk assessments of this GMO field experiment
by Professor Joe Cummins and Dr. Arpad Pusztai


A.

Joe Cummins
Emeritus Professor of Genetics, University of Western Ontario, London, Ontario, Canada:


Prof. Cummins has kindy provided detailed scientific comments on the dangers of this GMO experiment:
Genes from a wild plant Solanum bulbocastanum used to resist potato blight fungus (154kb PDF file).

Professor Cummins warns that the environmental release of these GMO potatoes is unwise because BASF makes specious assumptions that could lead to contamination, with toxic effects on humans and wildlife. He says "the people and wildlife of Ireland should not be exposed to inadequately tested genetic constructions". His findings include:

There is clear risk of cross-contamination of Irish potatoes.

The transfer of genes between the potato Solanum tuberosum and its wild relative Solanum bulbocastanum may lead to novel proteins with powerful or fatal immune responses, potential inflammation as well as allergenicity effects.

If the GM potato proves to be immunologically active, the impact on both human and animals may be severe.

It appears that no animal feeding studies have been done.

It appears that no environmental or health impact studies are planned.

The expression of the modifiying genes in glasshouse experiments was not studied under real outdoor weather conditions such as drought, waterlogging, heat, cold, nitrogen excess or starvation which could lead to unexpected toxicity.

Risk assessments of the impact of the experiment on non-target organisms seem to be based on an assumption of safety, and do not provide for an adequate monitoring scheme.

The isolation distance 20 meters to cultivated potatoes does not seem adequate.

Post-release treatment of the test site does not seem adequately monitored nor will it achieve a clean post-harvest site.

The considerations of human and environmental safety seem primarily based on wishful thinking rather than on on any serious efforts to gather or obtain factual information on the safety of the GM constructs.

Monitoring also seems based on wishful thinking rather than serious efforts to detect negative impacts.

Field testing of broad spectrum NBS-LRR genes has begun with the potato blight resistant strains. Broad spectrum pest resistant strains of rice, maize, soybean, and numerous food crops will soon follow. It is imperative that the safety of these genetic modifications to humans and the environment be fully evaluated before the GM crops are commercialized.

The proposition that the NBS-LRR family of plant pest resistance genes and their products provide safe transgenes for human consumption and for environmental release because they are found in food crops (and for that reason require no further testing) is simply foolhardy.

The suggestion that NBS-LRR genes can be assumed safe until proven hazardous certainly appeals to greedy promoters of GM crops but does not serve the public good.

Professor Cummmins has also provided comments on the further information provided by BASF in response to detailed questions by the EPA concerning the original Notification. He raises the following issues:

BASF should provide a karytopye (microscopic picture) of the potato chromosomes.

BASF should provide information on the segregation of particular genes in the potato "volunteers" for consideration by the EPA.

BASF's claim that "there are no compoments of the vectors [genes] known to code for harmful substances" can not be justified only by comparison of data bases for evidence of toxicity, because inflammation (a potent immune response) is not considered in allergy data bases, and would likely be ignored because available data bases do not include information about inflammation from plant proteins.

Regulatory genes in the GMO potatoes may produce a strong response without producing a great deal of protein, which may contribute to pest resistance. This should have been studied in glasshouse rather than field experiments to provide a controlled study environment.

BASF claims that the occurence of epigenetic and pleiotropic effects (control by a single gene of several distinct effects and changes in cellular biochemistry) caused by the introduded genetic material is "remote". Prof Cummins says the modified DNA is bound to produce both of these phenomena because they govern a range of responses leading to cell death, and that such impacts need to be considered.

BASF admits that none of the GMO potato lines intended for release in Co. Meath have been analysed for the main toxic and anti-nutritional substances found in potatoes, but that this does not matter because none of the genes introduced from the wild potato species are "known to exert any toxic or allerenic effects on human health." But Prof. Cummins points out that "inter-specific gene transfer has led to the formation of a toxin causing inflammation in mammals", and that "it seems unwise to ignore that finding and proceed based on blind supposition. Certainly the regulatory proteins are known to be immunologically active but these and toxic effects of the proteins from S. bulbocastanum have not been studied adequately regarding their impact on mammals."

In response to BASF's claim that "the overall impact on human health is negligible", Prof Cummins point out that "The Canadian Food Inspection Agency reviewed a mutant ahas gene used to confer resistance to imidazolinones in spring wheat. That mutant was not a transgene but was a mutation selected in spring wheat. There is no real justification in implying that the mutation and its consequences are the same as the results of an inter-species transgene transfer between Arabidopsis (bearing a different mutation) and potato. At any rate the Canadian Agency assumed that mutant and natural ahas were substantially equivalent but did not do nay experiments to support their superstition. BASF was wrong, I believe, not in mentioning the Canadian review but in failing to mention what ahas mutation had been studied in spring wheat."

In response to BASF's admission that no animal feeding trials have been carried out on any of the GMO potatoes intended for the release, Prof Cummins writes: "Have animals feeding experiments been initiated or completed using material from the Swedish field trials? Those trials should have provided more than enough material for animal feeding studies and would have provided useful information about the impact of two of the three genes."

In response to BASF's claim that "none of the genes are known to exert any toxic or allergenic effects to human health" Prof Cummins states "the search of DNA sequence data is necessary but not sufficient to establish safety of transgenes. Even interspecies plant gene transfers can lead to toxic products. In one reported case the plant to plant gene transfer led to protein modifications that cause immunotoxicity leading to inflammation. Common sense leads us to the need for direct animal feeding experiments for all of the transgenic crops, whether plant to plant, bacteria to plant, fungus to plant or human to plant."

The ERA has asked BASF "Please comment on whether the introduction of your GM blight resistant potatoes might alter the pathogenicity of the potato blight fungus under Irish soil conditions thus facilitating the dissemination of infectious diseases and/or creating new reservoirs or vectors."

BASF replied that the likelihood of a change in the pathogenicity of the late potato blight fungus "is considered negligible." Prof Cummins comments: "The basic question is 'how soon will the fungus grow resistant to the transgenic potato?' Appropriate glasshouse experiments should provide a useful estimate as to the time to resistance. Turning to the S. bulbocastanum-S.tuberosum somatic hybrids. I understand that the hybrids proved too unstable to produce commercial lines. If the lines were stable then there would not likely be any need for BASF to promote transgenic lines."

"It is worth pointing out that there do not appear to be any published reports on the experiments where the somatic hybrid potatoes were fed to mammals in a laboratory situation. Since breeding clones of blb2 have been grown in the Netherlands since 1999 it is surprising that no effort has been reported on the tests of such clones in animal feeding experiments. Of course, it would be negligent to withhold such studies, should they exist."

Prof. Cummins' conclusion is that the BASF proposal to release transgenic potatoes to the Irish environment seems premature because of the need for "fuller laboratory and glasshouse studies to insure the safety of the recombinant organisms. In particular, there was little or no reference to evidence that plant to plant gene transfer may lead to formation of proteins toxic to mammals."


B.

Dr. Arpad Pusztai, FRSE
Biochemist, Norwegian Institute of Gene Ecology.
Former Senior Research Fellow, Rowett Research Institute, Scotland:


Dr. Pusztai has also kindy provided a detailed submission on the dangers of this GMO experiment (160kb PDF file). His findings include:

"Although the permission sought only for the field trial of these GM potatoes, if the field trial is deemed successful, they are obviously intended for human (and animal) consumption."

"In view of this, it is regrettable that although the purpose of the release is 'to compile data on agronomical performance and environmental effects and evaluate resistance against Phytophthora infestans and collect material for further (and unspecified) analyses...', none of the scope of these studies, nor the methods to be employed are detailed."

"This serious omission is further compounded by the fact that the only reference to possible toxic or allergenic effects of the GM potatoes is described in a scientifically totally unacceptable sentence that 'no toxic or allergenic effects are expected on the basis of... the expressed AHAS protein'. Indeed, under [the Summary Notification provided by BASF], subsection F: 'Summary of planned field trials designed to gain new data on the environment and human health impact of the release' is dismissed as not applicable."

"This sort of cavalier treatment of the regulatory authorities and consumers is totally unacceptable particularly in view of the accumulating worrying evidence for the potential negative health effects observed with many other GM potato lines. Every part of the potato plant is toxic for human and animals and even the tuber may become toxic when exposed to sunlight, etc. Thus because all cells of the potatoes carry the same genetic information, the importance of the exclusion of possible unintended alterations resulting from gene-splicing ought to have featured prominently in the submission. It is not even mentioned."

"This is further aggravated by the fact that most experimental work reported in science journals is full of negative findings and most GM potato lines do not even satisfy the conditions of substantial equivalence with their isogenic parent lines."

Dr. Pusztai concludes: "In view of all the accumulating data showing that GM potatoes of all kinds investigated to date have shown unacceptable compositional, metabolic, immunological effects and potentially toxic behaviour, it is imperative for the Irish EPA to reject this request by BASF for field trial of their GM potatoes until and unless they are first subjected to independent environmental and health risk assessments using a scientific protocol openly agreed and approved by independent scientists and representatives of the public and consumer groups."


7. Related documents

Employing a composite gene-flow index to numerically quantify a crop's potential for gene flow: an Irish perspective

By Marie-Louise Flannery (Teagasc), Conor Meade and Ewen Mullins (Gene-flow Laboratory, Institute of Bioengineering and Agroecology, National University of Ireland, Maynooth.

According to this study: "The dispersal of potato pollen is an issue in certain regions of Ireland where potato is cultivated for both tuber and true potato seed (TPS) production. Dispersal distances for potato pollen are typically less than 10 m (McPartlan and Dale, 1994; Tynan et al., 1990) and while most commercial varieties are sterile, hybridization can occur, hence a potential exists for the resulting TPS (true potato seed) to establish into a viable population: CPC (crop pollen-to-crop) = 5. The appearance of potato volunteers emerging from overwintered groundkeepers is a serious problem for potato growers and hence a feasible mechanism for seedmediated gene flow: CSV (seed-to-volunteer) = 3. Similarly, groundkeepers can develop into viable ferals if they evade typical control measures applied within the confines of cultivation: CSF (crop seed-to-feral) = 3."

The notion that GMO potato pollen would only disperse 10m is absurd, given Ireland's gale force winds, abundant wildlife, roaming insects and migratory birds, not to mention farmers who travel all around the country and across the border to and from Northern Ireland.


8. Related documents published on the EPA web site (www.epa.ie) as of 26 February 2006

Advertisement in the Irish Independent of 26 January 2006

Register of GMO Users in Ireland, Notification Ref. No. B/IE/06/01
(3-page Word document)

Summary notification format for the release of genetically modified higher plants
According to Council Decision 2002/81/EC.
Notification number B/IE/06/01.
(4-page Word document from BASF Plant Science GMbH).

Notification
for the release into the environment of genetically modified potatoes with improved resistance to Phytopthora infestans (2006 - 2010)
(52-page Word document from BASF Plant Science GmbH.)

General information note
in relation to the making of representations to the EPA
regarding a notification under the Genetically Modified Organisms (Deliberate Release) Regulations - S.I. No. 500 of 2003.
(2-page Word document from the EPA).

New: Further information provided by BASF Plant Science GmbH.
in response to detailed questions by the EPA concerning the original Notification.
(19-page Word document from the EPA).

See also Professor Joe Cummins' comments on the above.


9. Related objections sent to the EPA (partial list)

We are informed that, as of 19 March 2006, the EPA has received 95 submissions objecting to the experiment, one submission in favour, together with a further 25 submissions which the EPA has rejected (presumably because they were either received after the 22 February deadline set by the EPA and/or did not include the requisite €10 submissison fee.

Professor Joe Cummins (download as 6-page 164kb pdf file)

Futher comments by Joe Cummins (download as 7-page 48kb pdf file)

Dr. Arpad Pusztai (download as 5-page 160kb pdf file)

GM free Ireland Network (download as 15-page 1.5MB pdf file)

Attached document: NBS-LRR proteins signalling (download as large 4.4MB pdf file).

Doolough Conservation Group (download as 11-page 276kb pdf file)

Leitrim Organic Farmers Cooperative 27 February 2006 (download as 124kb Word file)


10. Related media coverage

Irish print media coverage

Irish Organic Farmers and Growers Association press release

Euro-Toques press release

Joint press release by GM-free Leitrim, Leitrim Farmers Coop, the Organic Centre Rossinver, and Cavan Leitrim Environmental Awareness Network (CLEAN).

GM-free Kerry press release


11. GM-free Ireland press conference of 22 February 2006

List of speakers

Transcript (download as 204kb pdf file)


12. National protest against the GMO potato experiment, 22 February 2006

About the protest

Protest photographs


13. Useful background information on the dangers of GM food and farming

The Future of Food video / DVD

Available for mailorder credit card purchase from www.thefutureoffood.com.

This award-winning documentary provides an in-depth look at the genetically modified foods controversy. Shot on location in the U.S., Canada and Mexico, the film examines the complex web of market and political forces that are changing what we eat as huge multinational corporations seek to control the world's food system through patented GM crops which invade conventional and organic crops and require contaminated farmers to pay annual patent royalties or face patent-infringement lawsuits. The film explores alternatives to large-scale industrial agribusiness, placing organic and sustainable agriculture as solutions to the global farm crisis. Produced by Deborah Koons Garcia. 90 minutes.

Seeds of Deception:
exposing corporate and government lies about the safety of genetically engineered food


Web site: www.seedsofdeception.com.
On sale at the Cultivate bookshop, Essex St. West, Temple Bar, Dublin, tel (01) 491 2327.

This briliant book by Jeffrey M. Smith has a foreword by former UK Environment Minister Michael Meacher MP who said it "combines shrewd dissection of the true nature of GM technology, a devastating critique of the health and environmental hazards of GM crops, and scarifying examples of the manipulation of both science and the media by the biotech industry. It is a call to arms, not only to prevent the contamination of the nation's food supply, but even more to tackle the poisoning of the nation's decision-making system by the undercover wielding of economic and financial muscle and PR manipulativeness of Big Biotech."


14. Maps of the GMO experiment site:

Wide area map.

Local area map.


15. What you can do to prevent the GMO invasion

Read the transcript of our press conference (download as 204kb pdf file).

Sign the GM-free Ireland petition.

Use our protest materials (downloadable placards, posters and flyers) to organise a protest, for example as part of your local St. Patrick's Day parade.

Tell our Minister for Environment (Dick Roche) and Minister for Trade (Michael Ahern) to stand up to the WTO and protect our right to restrict GM crops and food: http://www.bite-back.org/objection/our_food.php.

In County Meath:

Contact Séan McDonagh SCC • tel (087) 236 7612 • email: smcdonagh10@hotmail.com

On the national level:

See the what you can do section of our home page and/or contact us at this address.


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