Text of Submission to the Scottish Parliament Re:Farm-scale Trials of Genetically Modified (GM) Oilseed Rape at Munlochy, Scotland; 3 March 2003
 

On the basis of previous experiences elsewhere, and of warnings of possible hazards by some scientists, we believe that GM oilseed rape should not be planted and that the current trials, in particular, the trial at Munlochy, Scotland, should be discontinued. We present below our evidence for this position.

Poor design of the trials

The crop trials were not designed to investigate the effects on the environment of the engineered genes themselves, or even directly to discover the effects of the chemical regimes required to grow GM crops. The fact that the GM oilseed rape is obviously stunted in comparison with the more lush non-GM crop will not be recorded for the purposes of this trial. The obvious differences between the two crops could, of course, be due to the fact that different varieties of oilseed rape were planted, rather than the GM variety and its non-GM parent.¹ This fact should have been recognised as a design fault, as the trial has an extra and unnecessary variable to be taken into account. Farm-scale evaluations, however, require only that ‘equivalent’ varieties be planted.²

The trials were designed only to compare the effects. on a limited number of species of wildlife (not even including mammals), of the chemical system used on the GM plants with that used on the conventional crop.³ The Co-operative Wholesale Society, Britain’s largest farming organisation, pulled out of the trials in 1999 on the grounds that they were flawed.⁴ As for birds, butterflies, insects and wild plants, a summary of 23 comparative studies of population levels of these species has already been made. It shows that nearly all of the species studied are much more plentiful on organic farms than on ‘conventional’ farms: the exceptions are pest butterflies, which are present in similar numbers; and aphids, which are more plentiful on conventional farms.⁵ Similar results would not be surprising for farms growing this GM crop, which are also reliant on chemicals and on monoculture.

Contamination of non-GM oilseed rape

The separation distances between these crops and non-GM crops remain the same as in previous trials, although the Government admits that significant contamination of neighbouring non-GM crops can occur. The European Commission recommends for oil-seed rape a separation of 5 km from the nearest non-GM rape in order to achieve a contamination level of 0.3%. The UK trials aim only to reduce contamination to the higher level of 1% and thus set the separation distances required at only 50 m, while conceding that there is a case for setting a tighter limit, such as 0.1%.⁶ In Scotland, the GM gene of oilseed rape has been found 2.5 km away from test sites.⁷

Establishment and spread of GM oilseed-rape superweeds

‘Scientists have found strong evidence that genetically modified (GM) crops can spread long distances from where they have been planted and spawn “superweeds”’ and that ‘… different GM strains can interbreed, producing superweeds that are resistant to a wide range of herbicides’ that would control them. It was also found that ‘escaped rapeseed was now Canada’s 13^th worst weed.^’8

Cross-pollination with wild relatives, and more superweeds

‘Recent studies have shown that transgenic oilseed rape is able to crossbreed with weedy relatives, making those weeds also resistant to herbicides.⁹ Oilseed rape can cross breed easily with other plants in the Brassica family such as wild turnip and wild radish.¹⁰ Research shows that these too can become herbicide resistant if crossed with the genetically engineered oilseed rape. Therefore the prospect of common weeds becoming agriculture pests (often labelled as “superweeds”) is very real and may lead to more toxic chemicals being used to control them. Interestingly, one company at the forefront of this technology, AgrEvo [Aventis, now part of Bayer], also agrees, suggesting that “...the farmer can always control these resistant weeds with other products”.^’1112 ‘Field trials in Denmark and Scotland long ago confirmed that GM oilseed rape transfers its inserted gene by cross-pollination of wild relatives. In France, transfer of herbicide resistance genes from rape to radish has been documented.’ ¹³

Lower yields

‘A study recently published … has produced some interesting findings in relation to transgenic oilseed rape varieties developed by Aventis, the principal commercial participant in the UK’s controversial fieldscale trials for GM crops.

‘… The study confirms that:

* compared to conventional rape hybrids mean yields from the transgenic varieties were lower.

* compared to conventional rape hybrids yields of the transgenic varieties showed a higher degree of variability.

* the transgenic varieties usually produced reduced financial returns when treated with herbicides compared to when receiving no herbicide treatment at all (any small increases in yield derived from weed control were usually insufficient to cover the extra cost of the herbicide, including glufosinate ammonium [often called ‘glufosinate’]).^’14

Dangers of the applied herbicide

The herbicide ‘Liberty’ required for the GM oilseed rape is also manufactured by Aventis. It is a non-selective herbicide, designed to kill all plants. However: ‘Recent reports have shown that it is not so effective as first thought, with serious weeds such as thistles and couch grass not being killed off. This has led to other herbicides being used.^’15

‘There is evidence that glufosinate tolerant oilseed rape varieties do not show a decrease in the amount of overall herbicides needed in comparison with unmodified crops.¹⁶ In addition, a study in Canada showed that some disease-causing fungi are highly resistant to glufosinate,¹⁷ whilst important fungi that protect plants from disease are highly susceptible to glufosinate.¹⁸ Oilseed rape has a wide range of fungal pests¹⁹ therefore it is possible that widespread use of glufosinate will increase the need to use fungicides.^’20

In general agriculture, this herbicide is banned from use between 1 October and the end of February, to protect groundwater. Nevertheless, Aventis has gained special permission for this herbicide to be used on the farm-scale evaluations. Questions to be raised are: ‘If the trials of this GM crop are successful and the crop gains approval for commercial release, will the ban on winter use of Liberty herbicide be lifted? If this is to be the case, why do the previous objections to winter use of Liberty no longer apply?’

Friends of the Earth (FoE) attempted to obtain the answers in February 2000 from the then Ministry of Agriculture, Fisheries and Food. However, Aventis claimed ‘commercial confidentiality’ and the Government refused FoE’s request. When threatened with legal action by Friends of the Earth, the Government gave way. Aventis then decided, in June 2001, to take the Government to court to prevent it from disclosing its evidence on the safety of its herbicide. On 7 September 2001, FoE said that ‘Aventis has now filed papers with the court and a hearing is expected shortly.^’21

A new question must be asked: ‘If the herbicide is indeed safe, why does its manufacturer take legal action against the government to prevent the public from seeing the proof of its safety?’

The answer may be found in the following extract from an article by a Canadian professor. There is ‘clear evidence that the herbicide caused birth defects in experimental animals. … The chemical acts by causing premature cell death in the immature brain by a process called apoptosis. It also prevents development of glutamate channels in the brain, thus disrupting cellular communication. The birth defects observed in animals included brain defects leading to behavioural changes. Cleft lip and skeletal defects or kidney and urethra injury were observed in treated new-born. The herbicide also caused miscarriage and reduced conception in treated mothers. … The human birth defects cannot be studied using the science epidemiology because the crops are not labelled and the relationship between eating the crops and birth defects cannot be established. … The government agencies regulating genetic engineering appear to be collaborating with the chemical companies to protect them from the liability flowing from the injury caused by their products.…^’22 Other reports show that ‘glufosinate has toxic effects on humans and animals,²³ particularly affecting the nervous system. The US Environmental Protection Agency also states that it is toxic at very low concentrations to many aquatic and estuarine invertebrates.^’2425 The last-mentioned fact is relevant in the present trial, as there is a high risk that the herbicide will be washed down-hill into Munlochy Bay and cause lethal damage to wildlife.

Effects on bees

‘French researchers have discovered that some varieties of transgenic canola [oilseed rape] can harm bees, a farm’s most effective pollinator, by destroying their natural ability to recognize flower smells.^’26

In June 2000 ‘German researchers at Jena University showed that genetic material from GM canola [oilseed rape] crossed the species barrier, and was positively identified in bacteria that reside in the guts of honeybees. I believe this is the first publicly documented case of horizontal gene transfer from GM crops to bacteria.’²⁷

‘Bees in the US are increasingly afflicted with a strain of antibiotic resistant American foulbrood (AFB). Before the advent of antibiotics, this bacterial infection was the most serious bee disease in the world. Tetracycline had been used effectively against AFB for 40 years until 1996. In that year, tetracycline resistance was confirmed in both Argentina and the upper Midwestern states of Wisconsin and Minnesota. Since then, it has spread to at least 17 states in the US, including New York, and to parts of Canada. During the 1990s, millions of acres of Round-up Ready crops were planted in the US, Canada and Argentina. According to my information, the antibiotic resistant gene used in the creation of Round-up Ready crops was resistant to tetracycline. After 40 years of effective usage against an infective bacterium found in the guts of honeybees, suddenly two geographically isolated countries develop tetracycline resistance simultaneously. A common thread between the US, Canada and Argentina is the widespread and recent cultivation of GM crops containing tetracycline resistant genes.²⁸

Not only bees but the honey they produce will be affected. Bees can travel at least 4.5 km to find pollen,²⁹ and any engineered genes in pollen will be present in the honey.

Unpredictability of genetic technology

When independent scientists examined Monsanto’s Roundup Ready soya beans, they found multiple fragments of the inserted gene and, even more alarmingly, an extra, unidentifiable gene sequence of unknown function.³⁰ Even if only the intended gene sequence is inserted, placement within a host chromosome cannot be controlled; and the location in which a gene finds itself influences its functioning in ways that are not yet understood.³¹

Use of Cauliflower Mosaic Virus promoter

Like many other GM crops, GM oilseed rape is engineered with the insertion of a promoter (a genetic ’switch’ to turn on the inserted gene) obtained from the cauliflower mosaic virus. Some scientists point out that the virus as used in genetic modification is no longer intact and, in this fragmented form, has the potential to cause harm by spreading to other plant species and even to animal species, including human beings.³² A grave consequence could, over time, be the creation of new, invasive and virulent diseases.³³

Effects on soil structure

Even on the macroscopic scale, it is already evident that conventional farming methods have unsustainable effects on soil structure.³⁴ For lack of sufficient organic material, topsoil on farms that are managed non-organically is being eroded and may be lost in 50-100 years.³⁵ Soil quality is damaged by the application of chemicals.³⁶

Possible effects on soil fertility

A group of nine experts on soil ecology and related subjects has produced a report warning that GM genes leaking out of crops into soil micro-organisms (a process that has been experimentally demonstrated) and transferred directly (‘horizontally’) into different species of micro-organisms (also demonstrated) may result in altered behaviour leading to reduced soil fertility. In the worst case, the suggested mechanism might cause irreparable, cumulative damage to soil fertility and the GM genes might spread uncontrollably over vast areas.³⁷

Conclusion

Many agricultural, environmental and health problems arise, or may arise, from the growing of GM oilseed rape. A genetic element used in the technology may in time lead to the creation of new and dangerous viruses. The herbicide required for these crops has been linked with serious health problems in human beings, and the run-off herbicide may cause serious harm to wildlife in Munlochy Bay, and part of that Bay is a Site of Special Scientific Interest. In Canada, widespread contamination by GM oilseed rape has become serious enough to lead a group of farmers to seek an injunction against Monsanto to prevent the release of yet another GM crop, wheat.³⁸ Adding to these problems is the poor design of the trials, which will yield data of dubious quality. With widespread opposition to GM foods and GM animal feeds by consumers, the economic viability of GM crops in this country must be questioned. In view of all these negative aspects of the trials and the crops being tested, we urge that the trials be discontinued.

Dr Stuart Parkinson, Chair; Dr Eva Novotny, Co-ordinator for GM Issues

1 Julian Little of Aventis Cropscience, week ending 31 Dec. 2001, Northern Farmer.