Open Letter to the CEOs of GMO Manufacturers
From the President of CRIIGEN to:
Paris, 27 July 2001
Subject: List of the risks to study for GMOs – OPEN LETTER
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.
Corinne LEPAGE, President of CRIIGEN
Open letter to the CEOs of firms manufacturing GMOs