Open letters

Retrouvez les lettres ouvertes du Criigen envoyées à de nombreux interlocuteurs (Présidence de la République, EFSA, entreprises...) pour les avertir des risques potentiels liés à une mauvaise évaluation de certains produits industriels, comme les OGM, les pesticides... 

Open Letter to the CEOs of GMO Manufacturers

Friday 27 February 2009

Open Letter to the CEOs of GMO Manufacturers


From the President of CRIIGEN to:


BASF Agro, 


Paris, 27 July 2001


Subject: List of the risks to study for GMOs – OPEN LETTER



Dear Sir,


CRII-GEN is an Independent Committee of Research and Information on Genetic Engineering.


As such, its mission is to ask the questions that need asking and to attract attention on the risks already envisaged, identified or well known, in relation to Genetically Engineered Organisms.


For this very reason, we have the honour of bringing to your knowledge the risks which have already clearly been identified where health and the environment are concerned. 


Even if current research does not make it possible — for reasons that have mostly to do with choices that were deliberately made in relation to the fields of research and with how much money was invested into them — to define the scope of the risks and extent of their consequences, we want to make it very clear that the knowledge of the existence of such risks excludes the possibility for firms developing GMOs to invoke in the future — where their liability might be concerned — the development risk exclusion clause on faulty products.


As a matter of fact, for the development risk exclusion clause to apply, the fault of the product would need to be such that the developer or his proxy could not possibly have discovered it, at the time of the commercialization of the product for the simple reason that the objectively accessible scientific and technical knowledge was not available of the time.


However, it is quite clear that it is not a case of development risk exclusion clause anymore, inasmuch as there is no possibility to have ignored or not have been able to imagine the risk.


That is the reason why we wish, by the present letter, to point out to you a non-exhaustive list of the risks which appear to have been perfectly identified up to now.


It goes without saying that the decision not to go deeper in the research work on risks, or to commercialize some products before their complete evaluation has been carried out, is a decision for which you must take full responsibility, with all the potential consequences in terms of damages and compensation.


The main risks posed by GMOs, which have been highlighted by our Scientific Council, are the following:


Firstly, the health risks, which must be assessed in a much  deeper manner:


(a) The risk linked to insecticide proteins produced by 28 % of commercialized GMOs the world around, which have never been approved as pesticides or weed-killers, the toxicity of which should certainly be reassessed on mammals.


The fact that there is no in vitro bursting of human red cells in the presence of truncated proteins (a phenomenon demonstrated for Bt proteins), and no effect on electrolytical exchanges, or on the porosity of intestinal walls of mammals, will have to be well-documented, as it is known that the Bt proteins used will have this type of effect on insects, causing infections.


(b) The risks linked to herbicides, to the products of the metabolization of such herbicides by plants or animals, and to adjuvants and their metabolites associated with the herbicides, must be analyzed according to a reinforced approval procedure of each herbicide involved, specially concerning long- and middle-term hormonal, neurological and immunological effects in mammals.


As a matter of fact, this issue has never been treated before for herbicides associated with GMOs, mainly because the plants treated with this type of weed-killer were generally destroyed, not consumed. Now, today some herbicides can be absorbed in large quantities by herbicide-tolerant plants (about 70% of GMOs). Unfortunately, the herbicides associated with GMOs were found to be neurotoxic and mutagenic, causing reproduction problems in the long run.


(c) The risk linked to the use of viral sequences introduced in most GMOs is not taken into account in its temporal and evolutive function. Don’t they (the viral sequences) favour genetic recombinations and the plant susceptibility to viral infections? What will happen when the agricultural or industrial interest for a transgene becomes obsolete, whilst the transgen itself lasts without control in new varietals, by adding itself to the other transgenes? What kind of experiments did the GMO manufacturers carry out to make sure about this?


(d) The risk of allergy development. Skin tests must be commercialized to detect the potential allergies relative to all new GMOs, as they are now part of a vast majority of foodstuffs, by means of their by-products.


(e) Deaths have already happened, due to the uncontrolled dissemination of the antibiotic-resistant genes (by resistant infections), hence such GMOs, containing antibiotic-resistant genes, must be withdrawn from official seed catalogues at once, and banned for any method of cultivation, even an experimental one. 


(f) The risks of metabolic disorders, directly or indirectly caused by a GMO, either plant or micro-organism, may be linked to the random insertion of the involved transgene, or to useless supernumerary sequences, which disrupt the GMO metabolism in a way not easily detected by the analysis of the substance equivalence. Hence they should be evaluated through preliminary long-term nutrition and toxicology tests on mammals.


(g) The risks of genetically modified micro-organisms (GMM). The European directive 98/81/CE modifying the directive 90/219/CEE relative to the confined use of GMMs excludes from its application domain some techniques such as mutagenesis and self-cloning. Such a formulation means that GMMs in the legislative sense cover only a part of GMMs in the scientific meaning: however high the quality of genetic constructions carried out, the objective loss of meaning of the term GMM leads to the impossibility of any traceability, bringing on new risks in food, on the one hand, and leads to no freedom of choice for consumers, on the other hand; in both cases, this is due to the absence of labelling obligation.


While study protocols and post-commercialization biovigilance implementation are still pending, any marketing of such products should be suspended.


Secondly, the risks on the environment caused by GMOs must be better evaluated:


(a) Risks of dissemination and crossbreeding (vertical and horizontal genetic transfers), of genetically modified plants, animals and micro-organisms in the environment (GMO in the sense of European directives or not, like micro-organisms modified by selfcloning). Which insurance will pay in case of agronomical, food-processing or environmental damage? As a matter of fact, major genetic modifications of the living in natural conditions can neither be put right or made up for, nor recycled.


Importantly, 99% of the characteristics introduced in GMOs come from invaders (production of insecticide or ability to live in the presence of weed-killers), so in that sense they put the whole biodiversity of ecosystems into question.


(b) Risks of contamination of non-GM seeds or crops by GMO traces, even by experimental GMOs, the detection sequences of which will have to be properly declared in a public register. Similarly, the food chain contaminations will have to be taken care of by the owners of the events involving such genetic transformations.


(c) Risks due to the introduction of viral sequences in most GMOs, that could generate the appearance of new viruses by a series of recombinations (cf 1 c).


(d) Risks induced by the use of insecticides or herbicides in excess of the expectations, even on contaminated fields or non-agricultural zones, in order to manage the disseminations of  GMOs or of insects linked to them.


What results from such an impressive array of events is not only that the development risk clause must be completely excluded in the case of GMOs, but also that today a certain number of risks are sufficiently identified to conclude that it would be really imprudent to commercialize these products without carrying out first the evaluations that WHO have just recommended in the framework of the Codex Alimentarius modification.


And last but not least, there are major sociological and ethical consequences as well:


(a) The consequences linked to the new implementations of GMO thresholds for food, in agriculture and for food distribution, as well as proved and potential health risks caused by GMO contaminations, must be financially taken care of by GMO manufacturers.


(b) The risks linked to taking out patents on living organisms, therefore to the appropriation of resources, but also to the standardization and the trivialization of the use of living beings, through integrating them in the technical domain, are to be carefully assessed, as they will entail social modifications.


(c) One must also take into account the risks linked to the fact that alternative research works leading to comparable or better non-GMO innovations could be delayed or non-existent.


Consequently, we solemnly insist on setting a date for the future, as far as the total responsibility of your firm and of yourself as an individual is concerned, relative to the choice made by you, with full knowledge of the facts, to commercialize and disseminate GMOs.


Yours Faithfully



Corinne LEPAGE, President of CRIIGEN

Open letter to the CEOs of firms developing GMOs, Fall 2007

Friday 27 February 2009

Open letter to the CEOs of firms manufacturing GMOs   

From the President to:
Paris, Fall 2007
RE: list of the risks to assess for GMOs – OPEN LETTER
Dear Sir,

In our letter dated July 27th 2001, we have drawn your attention on the existing risks pertaining to GMOs according to the state of knowledge at the time of the mentioned letter, with a view to make sure that the risk of development could not be conjured up in any way in the future, in order to alleviate your responsibility, on the one hand in the contamination of non genetically modified seeds or fields, where human health is concerned, and on the other hand in the unfortunate event when such effects might appear.

Indeed, in the existing state of knowledge at the time of the letter, the potential negative effects on health and the environment were sufficiently known for you to assume totally the inherent risk related to your technology.

For your perfect information and for the record, you will please find enclosed a copy of the letter you had received at the time. Please note that none of the elements envisaged at the time was contradicted by the knowledge acquired since then. 

Since then, and within the framework of Directive 2001/18, the first studies you used do highlight significant effects on rat populations that consumed genetically modified organisms.

It is correct that the latter studies, which you refused to reveal, in violation of the dispositions of the European Community legislation, to the citizens and thus to your clients, have been brought to the knowledge of the Publics Authorities, who seem to have chosen, for some of them, to be in a state of denial due to an intense lobbying effort on your part.

However it is just as true that, as producers, you are perfectly informed of the potential dangers concealed in your product, and therefore completely responsible for the potential consequences of the latter, notwithstanding any authorization from the Public Authorities, whatever it may be.

We would particularly like to draw your attention to the fact that since the European Parliament and Council Directive 2004/35 of 21 April 2004 only pertains to the environmental responsibility, and not to the public health responsibility , you would not be able to refer to the provisions of article 8.4 which enable the Member States to allow the operator not to bear the cost of remedial actions taken pursuant to this Directive, if they demonstrate that they were not at fault or negligent and that the environmental damage was caused by (a) an emission or event expressly authorised by, and fully in accordance with the conditions of, an authorisation conferred by or given under applicable national laws and regulations which implement those legislative measures adopted by the Community specified in Annex III, as applied at the date of the emission or event;

(b) an emission or activity or any manner of using a product in the course of an activity, which the operator can demonstrate was not considered likely to cause environmental damage according to the state of scientific and technical knowledge at the time when the emission was released or the activity took place.

Indeed, in relation to the first point, all the conditions linked to the authorization were not fulfilled in the sense that the studies you were withholding remain confidential and will not be subject to regular information of the public as provisioned by the Community Directive, and furthermore for the reasons that were pointed out to you in 2001, it goes without saying that according to the state of scientific and technical knowledge of the time when your activity took place, you could not possibly pretend that your activity could not be considered likely to cause any damage.

Yours sincerely

The President

Corinne LEPAGE