Over the last five years much new information has come forward relevant to the assessment of GM crops, yet it the gene regulators evaluation system has apparently ignored it. It is time to change that.
Overlooking of new published evidence on the toxicity and teratogenic qualities of GM crops places the entire Australian population at risk and contradicts the stated aims of the policy which is to protect the health and safety of the Australian people and environment.
If the purpose of the act is indeed to ensure the health of the Austrlian people and safety of the environment then the gene technology act needs to be rewritten to reflect the discoveries made over the last five years (1,2,3,4), on the toxic effects of GM crops and to specifically address those toxicities.
The previous version of the gene technology act is written under the assumption that no differences would be discorvered between genetically modified (GM) foods and non-GM foods. Now that a wide range of differences have been proved in the laboratory (1,2,3,4), the act needs to be rewritten to take into account those differences, the same way the bushfire act is amended after a major bushfire.
Briefly just sone of the proved differences between GM crops and non-Gm crops that ahve been dicovered since the last writing of the gene technology act include; damage to kidney and liver cells by GM crops (2,3), mutagenicy and teratogenic effects from consuption of GM crops which are sprayed with glyphosate (Roundup) herbicide (4), survival of the GM bacillus thuringiensis (BT) insecticide into the bloodstream of humans and embryos (1).
The act needs to be rewritten to that it will be more objective in its assessment of GM crops and less supportive in its assessment of GM crops. The therapeutic goods act is not written to be supportive of indivisual products, but clearly the gene technology act is highly supportive of GM crops, which of course was appropriate before discoveries of toxic effects from GM crops were proven (see references 1,2,3,4 below). The assessment begins as if GM crops are substantial equivalent to non-GM crops, which is an invalid assumption and an assumption that has been proven untrue by references one through four below.
The height of the hurdle required to prevent the release or initiate a recall of GMcrops is not specified. The are no examples given of the kind of findings which would prevent the release of a GM crop. Several specific examples of the kinds of discoveries that would prevent the release of the GM crop should be given by the regulator. This would make the regulation process more transparent and easier to manage. For example if mammals are shown to have kident damage by consumption of GM crops (Ref 2) then such GM crops should not be released or long-term multi-year trials of mammals consumption of GM crops should be initiated to ensure no harm comes from such kidney damage. For example, if insecticidal proteins inserted into GM crops are discovered in pregnant women, the GM crops should be recalled and not released and multi-year studies of the long-term effects of such insecticidal proteins begun, as was recommended by Seralini et al (Ref 3).
The precautionary principle is not being observed. By assuming GM crops are totally safe and substantially equivalent to non-GM crops, the reverse of the precautionary principle occurs. Yet the act focuses on the safety of people and the environment, thus the poluct does not implement the intent of the act in relation to safety of the population.
Now that substantial differences have been scientifically demonstrated between GM crops and non-GM crops (reference 1,2,3,4) proper implementation of the policy, would be to assume possible adverse effect from GM crops and require the GM crop to be proved to be safe, in a simial way that therapeutic goods have to be proven safe. The act is not implemented by assuming GM crops are safe when the studies below suggest danger from GM crops.
As Seralini et al 2011 write on this topic, "it is unacceptable to submit (Australians) and several billion of consumers worldwide to the new pesticide GM-derived foods or feed, this being done without more controls (if any) than the 3-month-long toxicological tests and using only one mammalian species, especially since there is growing evidence of concern. This is why we propose to improve the protocol of the 90-day studies to 2-year studies with mature rats, using Toxotest approach, which should be rendered obligatory, and including sexual hormones assessment too. The reproductive, developmental, and transgenerational studies should also be performed. The new SSC statistical method of analysis is proposed in addition. This should not be optional if the plant is designed to contain a pesticide, as it is the case for more than 99% of cultivated commercialized GMOs.
A study for three months of the health effects of asbestos at Whitenoon in West Australia would ahve determined that asbestos was totally safe, since asbestosis takes 20 or 30 years to develop. In this case all Australians are exposed to the GM product, now proven to be not substantially equivalent to the non-GM product (1,2,3,4) so much more rigorous testing is required than if only one township is exposed to the product. A policy based on the assumption that GM products are not substantially different to non-to GM products will be quite different to the present policy, which assumes substantial equivalence. This is just one change that needs to be implemented in addition to Seralini above-mentioned suggestions.
Glyphosate (Roundup) may be registered for killing weeds in crop situations, but has it been tested and shown to be safe when sprayed directly on ediblecrops that are resistant to Roundup? Clearly Carrasco study (Ref 4) shows that edible crops are not safe when sprayed with Roundup. The precautionary principle must be exceedinly cautiour because the whole population is exposed and not just a small part of the population exposed.
In relation to environmental protection from GM crops which the act specifies. One of the key environmental species is the Bee. In assessing the safety of GM crops in relation to bees only direct mortality of GM crops on Bees was assessed. Indirect mortality or sublethal effects of GM crops on Bees were never assessed. It has now been shown that GM crops have substantial sublethal effects on bees, which eventually can reult in delayed indirectly lethal effects on the Bees.
Reference 5 shows below that insects such as the Bee, can survive the BT insecticide which is incorporated into many GM crops, by having a strong immune respose, which protects them from the Bt insectiside. Furthermore, reference 6 shows that insects such as the Bee experience imapired associative learning if they get an immune response. (Reference 5 showed that bees and all insects get an immune response from BT insecticide.)
In Reference 7, Ramirez-Romero et al. show that learning in Bees is indeed impaired after exposure to Bt Cry toxins: quote "honey bees exposed to 5000 ppb of Cry1Ab had disturbed learning performances".
Thus it is proved (Ref 5) that the Bt toxin is produce an immune response in all insects including bees. It is proven that when experiencing an immune response bees exhibit impaired learning abilities (Ref 6,7,9). It is also demonstrated that bees do indeed exhibit impaired learning ability from BT toxins (Ref 5,6,7).
Of course such impaired learning ability does not kill a bee. The Bees life cycle is totally dependent upon a perfect learning ability for complex navigational tasks. If a bee exhibits impaired learning ability it would also not be able to memorise the location and sents of flowers, which it does by memorising instructions given to him by other bees in the beehive. Nor would bee be able memorise the location of the beehive, thus the Bee would become lost in the field and the beehive would become enptry. Bees use protein in constructing memories and also use protein in constructing their immune respose. Thus such a learning would be most impaired in winter when pollen protein supplies are limited. Such is indeed the case. (Refs 7,8)
Thus we would request that sublethal effects of GM BT pollen should be assessed on key environmental species such as the bee. Since the BT pollen is already demonstrated to adversley affect bees. (Refs 7,8,9)
The GM crops should be proven not to affect cognitive functions of the Bees, because are key envirnonmental pollinator.
Science is always finding more results not less results and as more results on the toxicity of GM crops are discovered, the regulatory systems needs to provide for factors that may be discovered in the future.
The gene regulator limits his assessment of information on GM crops to peer reviewd papers. A wider rangeof material should be considered by the gene regulator. For example soy allery jumped from 10% in 1998 to 50% in 1998 in Britain when GM soy from USA was imported (Ref10).
Contamination of organise agriculture and financial impact upon said organic agriculture through contamination through airborne pollen not considered by the gene regulator. Thus financial burden is places on the organis industry by the GM crops is unfair and harms the organic industry unduly.
The period of testing of GM crops is totally inadequate acording to recent peer reviewd public published study (Ref 3). Due to 100 percent of population being exposed to GM crops period of study should be longer and more intense than study for which only a small percent of population is affected. Therapeutic goods with 1% of the population use, must be tested for many years, not so for GM crops for which 100 percent of population is exposed. The precautionary principle fail to be implemented. But financial principle is fully implemented. Financial motivation is overriding precautionary principle.
Recent drops in USA fertility rate. The Australian government opposed the Vienna study showing infertility in rats in an academic basis, yet infertility in the USA population is at a record level. The government displays a bias in favour of GM crops and thus biased in favour of placing population at risk when the act says safety of people and the environment is the priority.
The Government does not implement the act through its support of GM crops.
The Government does not have a neutral position but has positive position towards GM crops, in contradiction of the safety aspects of the act.
The implementation of the act is to allow GM crops to be grown, not to test whether they are safe, they are assumed to be safe and the references below suggest they are not safe and change is needed.
Lot 4 Mill Rd
1. Reproductive Toxicology
Volume 31, Issue 4, May 2011, Pages 528-533
Maternal and fetal exposure to pesticides associated to genetically modified foods in Eastern Townships of Quebec, Canada
Aziz Arisa, Samulen Leblancc
2. New analysis of a rat feeding study with a genetically modified maize reveals signs of hepatorenal toxity.
Seralini GR, Cellier D, de Vendomois JS.
Arch Environ Contam Toxicol. 2007 May;52(4):596-602. Epub Mar 13
quote: Chemistry measurements reveal signs of hepatorenal toxicity, marked also by differential sensitivities in males and females. Triglycerides increased by 24-40% in females; urine phosphorus and sodium excretions diminished in males by 31-35%.
3. Genetically modified crops safety assessments; present limits and possible improvements
Gilles-Eric Seralini, Robin Mesnage, Emilie Clair, Steeve Gress, Joel S de Vendomois and Dominique Cellier
Environmental Sciences Europe, 2011, 23:10
4. Glyphosate-Based Herbicides Produce Teratogenic Effects on Vertebrates by Impairing Retinoic Acid Signaling
Alejandra Paganelli, Victoria Gnazzo, Helena Acosta, Silvia L. Lpez, and Andrs E. Carrasco
Chem. Res. Toxicol., 2010, 23 (10), pp 1586-1595
Publication date (Web): August 9, 2010
5. Griffitts, J.S and R.V Aroian, "Many roads to resistance: how invertebrates adapt to Bt toxins",
Bioessays 2005 Jun; 27(6):614-624; DOI:10.1002/bies.20239
quote: Bt "Cry toxin resistance may be induced in invertebrates [insects] as an active immune response".
6. Mallon E.B., A. Brockmann, P. Schmid-Hempel,"Immune response inhibits associative learning in insects"
(Ecology and Evolution, ETH Zurich, ETHZentrum NW, CG-8092 Zurich, Switzerland), Proc. R. Soc. Biol. Sci. 2003 Dec7; 270(1532):2471-73
7. Rameriz-Romero, R., N. Desneux, A. Decourtye, A. Chaffiol, M.H. Pham-Delgue (Instituto de Ecologia, Veracruz, Mexico)
"Does Cry1Ab peotein affect learning performances of the honey bee Apis mellifera L.(Hymenoptera, Apidae)?", Ecotoxicol. Environ. Saf. 2008 Jun; 70(2):327-33; epub 2008 Feb 21
8. Tyler, E.R., S. Adams, E.B. Mallon, "An immune response in the bumblebee, Bombus terrestric, leads to increaded food consumption",
BMC Physiol. 2006 Jul 17; 6:6; PMID:16846495
9. Riddell, C.E. and E.B. Mallon (Department of Biology, University of Leicester, UK),
"Insect psychoneuroimmunology: immune response reduces learning in protein starved Bumblebees (Bombus terrestris)",
Brain Behav. Immun. 2006 Mar; 20(2):135-8; e-pub 2005 Aug 9; PMID: 16084688
Original submission in PDF format (PDF 230 KB)
In this section
- Occasional papers series
- Plasma Fractionation Review
- Regulatory Plan 2007-08
- Regulatory Plan 2008-09
- Regulatory Plan 2006-07
- PHERP Review Reports
- Margaret River Consumer for GM Free Food Submission to the review Gene Technology Act 2000
- 2002 Reviews of the National HIV/AIDS and Hepatitis C Strategies and Strategic Research
- 2006 Aged Care Homes Survey
- 2006 – 2007 Jurisdictional Summary Report against the National Strategic Framework for Aboriginal and Torres Strait Islander Health (NSFATSIH)
- A National Aboriginal Health Strategy: An Evaluation 1994
- A National model for the collection and analysis of a minimum data set with outcome measures for private, hospital-based, psychiatric services
- Alcohol and other drugs: a handbook for health professionals
- Alerting the community to the link between illicit drugs and mental illness: developmental research
- An analysis of research on preventing falls and falls injury in older people: Community, residential care and hospital settings (2004 update)
- Anorexia nervosa: Australian treatment guide for consumers and carers, 2005
- Building on success 1: a review of gay and other homosexually active men's HIV/AIDS education in Australia
- Building on success 2: towards a national strategy for HIV/AIDS health promotion for gay and other homosexually active men
- Building on success 3: the Commonwealth Government response to towards national strategy for HIV/AIDS health promotion for gay and other homosexually active men
- COAG mental health early intervention measure - early childhood component: study to scope potential service delivery
- Coordinated Care - Evaluation Report of 2nd Round Trials
- Coping with depression: Australian treatment guide for consumers and carers, 2005
- Council Of Grain Grower Organisations submission to the Gene Technology Act 2000 Review
- Deakin University submission to the Gene Technology Act 2000 review
- Deep vein thrombosis and air travel
- Department of Health and Ageing (DoHA) - Medicare Australia Memorandum of Understanding (MoU)
- Developing a casemix classification for mental health services: summary
- Discussion Document Towards a Fourth National HIV/AIDS Strategy April 1999
- Drug and Alcohol Service Report (DASR): 2006-2007 Key Results
- Drug and Alcohol Service Report (DASR): 2007-2008 Key Results
- Evaluation of the second national mental health plan
- Evidence of effective interventions to improve the social and environmental factors impacting on health: Informing the development of Indigenous Community Agreements
- Falls prevention activities for older people: a national stocktake
- Gene technology Act 2000 review from Guy Izzett
- gettin em n keepin em
- Government response to the House of Representatives Inquiry into Indigenous health: 'Health is life'
- Guidelines on the interpretation and application of the MAIF Agreement by the Advisory Panel on the Marketing in Australia of Infant Formula (APMAIF)
- Improving mental health literacy: a review of the literature
- Innovative grants program: project summaries
- Interpretations of the Advisory Panel on the Marketing in Australia of Infant Formula on the MAIF Agreement
- Key performance indicators for Australian public mental health services
- MAIF Guidelines - Marketing Of Infant Formulas Via Electronic Media
- Measuring Remoteness: Accessibility/Remoteness Index of Australia (ARIA) Revised Edition. Occasional Papers: New Series Number 14
- National Aboriginal and Torres Strait Islander Sexual Health and Blood Borne Virus Health Promotion Report
- National evaluation of the Sharing Health Care Initiative demonstration projects
- National HIV/AIDS Strategy 2005-2008: Implementation Plan
- National mental health plan 2003-2008
- National mental health policy
- National mental health report 2005
- National mental health report 2007
- National mental health report 2007: additional tables
- National mental health report 2010
- National Strategic Framework for Aboriginal and Torres Strait Islander Health Context July 2003
- National strategy for heart, stroke and vascular health in Australia
- Outcomes and indicators, measurement tools and databases for the national action plan for promotion, prevention and early intervention for mental health 2000
- Panic disorder and agoraphobia: Australian treatment guide for consumers and carers, 2005
- Principles for the consideration of interactions with health care professionals for the purpose of interpreting the MAIF Agreement
- Private Sector Outreach Services - Review of Private Sector Outreach Services Legislation
- Promotion of Therapeutic Goods
- Public discussion paper - Adoption of the Globally Harmonised System for Classification and Labelling of Chemicals in Respect to Domestic and Consumer Chemicals Including Pesticides
- Quality Use of Pathology Program (QUPP) Historical Reports
- Reforming the Australian
health care system:
the role of government. Occasional Papers: New Series Number 1
- Regulatory Plan 2009-10
- Regulatory Plan 2010-11
- Regulatory Plan 2011-2012
- Review of 2011 Gene Technology ACT (2000) - Public Submission
- Review of the Gene Technology Act 2000
- Review of the Gene Technology Act 2000 by Anne Goddard
- Review of the Gene Technology Act 2000 from I F Turnbull
- Review of the Gene Technology Act 2000 from Slater & Gordon Lawyers on behalf of The Safe Food Institute
- Royal Perth Hospital Comments on the Gene Technology Review 2000
- Scoping study to inform the establishment of a new peak national mental health consumer organisation
- Self-harm: Australian treatment guide for consumers and carers, 2005
- Sexual Health Promotion for Aboriginal and Torres Strait Islander People – A community guide to evidence-based best practice in social and behavioural interventions
- Stigma and discrimination
- Strong Fathers Strong Families
- Submission by Anne Goddard regarding Terms of Reference in the Gene Technology Act 2000
- Submission by Dr Monica Leggett to the Gene Technology Act 2000 review
- Submission by the Office of the Gene Technology Regulator to the Review of the Gene Technology Act 2000
- Submission by The University of Newcastle for the 2011 Review of the Gene Technology Act 2000
- Submission from Bayer CropScience to the Gene Technology Act 2000 Review
- Submission from AgForce to the Statutory Review of the Gene Technology Act 2000
- Submission from Agrifood Awareness Australia Limited reviewing the Gene Technology Act 2000
- Submission from an Individual to the Review of Gene Technology Act 2000
- Submission from an Individual to the Review of the Gene Technology Act 2000
- Submission from AusBiotech to the 2011 Review of the Gene Technology Act 2000 (the Act)
- Submission from Beatrice Ludwig to the 2011 Review of the Gene Technology Act
- Submission from Croplife Australia to the Review of the Gene Technology Act 2000
- Submission from Department of Agriculture, Fisheries and Foresty to the Review of the Gene Technology Act 2000
- Submission from Elizabeth Hamilton to the 2011 Review of the Gene Technology Act 2000
- Submission from Graham Wearne to the Gene Technology Act 2000 Review
- Submission from Individuals at the Institutional Biosafety Committee to the Gene Technology Act 2000 Review
- Submission from Individuals to the Review of Gene Technology Act 2000
- Submission from Monsanto to the Review of the Gene Technology Act 2000
- Submission from Nuseed Australia to the Review of the Gene Technology Act 2000
- Submission from Peter Olson to the Review of Gene Technology Act 2000
- Submission from Queensland Institute of Medical Research to the Review of Gene Technology Act 2000
- Submission from the Australian Seed Federation to the Statutory Review of the Gene Technology Act 2000
- Submission from the Department of Innovation, Industry, Science and Research and The Commonealth Scientific and Industrial Research Organisation to the 2011 Review of the Gene Technology Act (2000)
- Submission from the Gene Technology Interdepartmental Committee to the Review of the Gene Technology Act 2000
- Submission from the GM-free Australia Alliance to the Review of the Gene Technology Act 2000
- Submission from the Grains Research and Development Corporation to the 2011 Review of the Gene Technology Act 2000
- Submission from the National Association for Sustainable Agriculture Australia WA Inc to the Review of the Gene Technology Act 2000
- Submission from the National Farmers' Federation review to the Gene Technology Act 2000
- Submission from the Producers Forum to the Review of the Gene Technology Act 2000
- Submission from the Western Australian Farmers Federation Review of the Gene Technology Act 2000
- Submission to the Gene Technology Act 2000 Review by Mary Gardner
- Submission to the Gene Technology Act 2000 Review from the Minister for Primary Industries and Water
- Submission to the Review of Gene Technology Act 2000 from Phil Aitken
- Submission to the Review of Gene Technology Act 2000 from Organic and Biodynamic Meats
- Submission to the Review of Gene Technology Act 2000 from Tracey Skippings
- Sumbission from Individuals from the Wambyn Organic Olive Farm for the Gene Technology Act 2000
- Sumission to the Department of Health and Ageing from the Pioneer Hi-Bred Australia Pty Ltd to the Review of the Gene Technology Act 2000 (the Act)
- Summative evaluation of the national mental health plan 2003-2008
- Technology, Health and Health Care. Occasional Papers: Health Financing Series Volume 5
- The Ageing Australian Population and Future Health Costs: 1996-2051. Occasional Papers: New Series Number 7
- The Australian Government Response to the 2002 Reviews of the National HIV/AIDS and Hepatitis C Strategies
- The Dairy Industry Submission to the Statutory Review of the Gene Technology Acy 2000
- The Mental health of Australians
- The National Hepatitis C Strategy 2005-2008
- The National Slips and Falls Prevention Project
- The Quality of Australian Healthcare: Current Issues and Future Directions. Occasional Papers: Health Financing Series Volume 6
- The Use of Antibiotics in Food-Producing Animals: Antibiotic-Resistant Bacteria in Animals and Humans
- Towards national benchmarks for Australian mental health services
- Training frontline workers: young people, alcohol and other drugs
- Using Mathematical Models to Assess Responses to an Outbreak of an Emerged Viral Respiratory Disease
- Valuing the past ... investing in the future- Evaluation of the National HIV /AIDS Strategy 1993-94 to 1995-96
- Trachoma Surveillance Report 2006 to 2010
- Regulatory Plan 2005-06
- Regulatory Plan 2004-05
- Regulatory Plan 2003-04