Submission to GM Crop Moratorium Review

GM Crop Moratorium Review Panels of New South Wales, Victoria and South Australia
Dear Panel Member
Executive Summary 
The GM Moratorium needs to be extended until long-term, generational studies become part of the OGTR regulations for approval. GM has to be treated as an introduction of a self-reproducing chemical. Marketing and trade of Australian products will be severely affected once health and environment impacts of GM become quantified and public. GM investment will be wasted. Direct R&D to a productive, profitable and more sustainable biological agriculture for the health and wellbeing of citizens and environment. Such farming systems will be able to adapt to climate change and markedly reduce the dependence on petrochemical inputs in a world with diminishing oil availability.

The following quote from the attached article (read more… ) shows that remaining GM-free is the best solution to avoiding economic problems later relating to health and environment:

“Rhetoric from Washington (repeated by Canberra’s CSIRO, OGTR, FSANZ ed.) since the early 1990s proclaims that genetically modified (GM) foods are no different from their natural counterparts that have existed for centuries. But this is a political, not a scientific assertion. Numerous scientists at the FDA consistently described these newly introduced gene-spliced foods as cause for concern. In addition to their potential to produce hard-to-detect allergies and nutritional problems, the scientists said that “The possibility of unexpected, accidental changes in genetically engineered plants” might produce “unexpected high concentrations of plant toxicants”. GM crops, they said, might have “Increased levels of known naturally occurring toxins, appearance of new, not previously identified toxins”, and an increased tendency to gather “toxic substances from the environment” such as “pesticides or heavy metals.” They recommended testing every GM food “before it enters the marketplace”. But the FDA was under orders from the first Bush White House to promote the biotechnology industry, and the political appointee in charge of agency policy was Monsanto’s former attorney-later their vice president. The FDA policy ignored the scientists’ warnings and allowed GM food crops onto the market without any required safety studies. From the few safety tests that have been conducted, the results are disturbing-lab animals fed GM diets show damage to virtually every system studied. Reports from farmers are even less encouraging-thousands of sick, sterile and dead animals are traced to GM feed.”

Australia seems to trust and follow the US food regulator in most issues while Europe is critical and independent even though the second biggest GM player, Bayer, hails from Germany.

Single genes are but a small part in the complex system of nature with its cyclical processes towards adaptation. Genes are interacting and switching on or off due to environmental circumstance. GM science is linear thinking at the cutting edge of new understanding. Each day we discover gene functions we didn’t know that we didn’t know. Danger for the future as it is always more expensive or impossible for society to solve problems arising from released technologies.

GM is a commercial venture needing markets in shortest possible time. Scientists involved work with the ‘substantial equivalent’ principle, which is not a scientific method as it is not the precise content in a volume but the nature of its packaging that is important. Federal regulators seem willing partners. GM is a short-term solution with long-term costs. Going with this unproven technology is fraud with dangers.

At the beginning, for example, scientists were telling us that avoiding neighbouring canola paddocks would be sufficient to avoid contamination of non-GM. However, segregation is impossible. For example, by 2003 27% of Canadian registered seed of non-GM canola varieties was already contaminated with GM.

There are no data available that show yields of the new GM against the best current varieties, only promises of higher yields. However, the GM genes are not related to yield, they are stacked on high yielding factors. Any yield increase can be achieved by breeding using markers, the useful component of gene technology, and by appropriate agronomy.

GM crops that can tolerate climatic and soil stresses such as drought, salinity and frosts? Increased nutritional value? Pharmaceuticals in crops? These promises have been made since the start of genetic engineering but only herbicide tolerance and insect resistance have been achieved and released. However, both are resulting in problems on farms with the arrival of resistant weeds, and new pests and diseases. Many weeds are now becoming resistant ten years after herbicide-tolerant GM crops were introduced. Insects will become resistant after, say, 20 years? What then? Fertility of farm animals is also already affected.

Herbicide tolerance was in 2006 accounting for 81% of overall GM crop acreage. Only in the first years after introduction is there a reduction in herbicide use. In subsequent years the weeds not killed by glyphosate become a problem, followed by glyphosate resistance in other weeds. Analysis of USDA data revealed increased pesticide use in the US by 60 million kilograms from 1996 to 2004. The 67 million kilograms of increased herbicide use off set by 7 million kilograms reduction in use of insecticide.

There is an alternative, and GM promises are increasingly being achieved with well-managed organic and biological crops on healthy, biological active soils. Dryland salinity paddocks are reclaimed to full production in just two years and yields are higher in droughts. Their higher mineral and nutritional contents give us required resistances through (slow) food. This research field is ignored here in Australia but gathers momentum in public funded science overseas. Biological farming is the transition from current as it allows use of some microbe-friendly fertilizers and herbicides as-need-be. It thus reduces the heavy dependence on petrochemical inputs with their ever increasing costs and diminishing availability past Peak Oil.

GM technology is working on a symptom of our problems in agriculture. It does nothing on the cause, soil degradation, which will keep productivity on the edge and sliding down. We need to re-generate our soils, increase soil organic carbon content and active soil biology to achieve sustainable farming. Once soil carbon goes up with associated soil biology, then plants become resistant to insects and diseases under biological management. Such living soils will also be able to adapt to impacts of climate change.

GM science is not guiding us past pitfalls through use of appropriate risk. Risk is a principle calculated with numbers. However, such numbers don’t exits for GM and risk is based on assumptions. Studies are being conducted with the aim of getting GM approved and scientists tend to design experiments to get the answers they want (I know the system from the inside). For example, only 30-90 day animal feeding studies and one to three-year environmental studies during GM introduction have been published. There is no published science giving us long-term, generational answers regarding the environmental and food safeties of GM crops.

So, who is in control of GM science? We need to determine for each GM introduction the cumulative, long-term impact in the environment on microbes and insects, the foundation of life on Earth. In humans and animals study the impact on health factors such as the condition of the liver, a main detoxifier for the body (see examples in attachment). This is an economic imperative. As long as these studies are not conducted, we should not release GM food crops as a precaution for incurring economic costs in the future.

Yours sincerely,
Maarten Stapper BAgSc AgEng PhD FAIAST
Farming Systems Agronomist
BioLogic AgFood
15 August 2007

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