Dear sir or madam,

Thank you for providing the opportunity for the public to comment on the GM Science Review.

Please find attached my contribution to the consultation.

Richard Scullion,
Professional Scientist,
Leeds

GM food and feed safety

The recurring theme of the First Report is that too little is known about this issue. In the section below we comment on some particular cases of this problem. The points are raised in the order in which they appear in the report.

(5) Health

(.2) We need read no further than p. 10 of the report in order to conclude that it would be reckless to introduce GM crops into general agriculture now. For there we are told that no one has been monitoring the health of those who have already been consuming food derived from GM crops. There is therefore no evidence that eating such food does not harm human health.

(.3) The lack of agreement on how to test for allergenicity is particularly serious for the following reasons.

· It is clear from p. 79 that we do not currently have trustworthy tests for or ways to control potential problems arising from GM food allergies. Furthermore (see 5.3.4 on p. 81) there is no confidence that specific tests can be improved.

· Since avoidance is the main clinical response (p. 86) to allergies and GM allergens could occur in a diverse range of foodstuffs, the 'GM scenario' presents substantial problems in risk management. This would be all the more serious if crops were also to be grown for purposes other than food or animal feed (because GM crops derived from conventional food or feed organisms would be less likely to contain unknown allergens).

· Although using GM crops 'does not imply an increase in the likelihood or severity of risks of normal allergens' (p. 87), the next section (5.3.6) makes it plain that we currently have little ability to check this.

(.4) Although the report emphasises that most transgenic DNA which is consumed is degraded after digestion, it remains active as it passes through the gut and has been found in the blood and other parts of the host (5.4.4). There is little certainty about the long-term effects of such transfer of GM material.

(.5) Similar comments from the above apply to the use of GM feed for animals.

Conclusion

We can only conclude, as on p. 135 of the report, that far more research needs to be done to shed light on the problems highlighted above. Too little is known yet for the risks to be managed properly.

Environmental Impact of GM crops

The recurring theme of the First Report is that too little is known about this issue. In the section below we comment on some particular cases of this problem. The points are raised in the order in which they appear in the report.

(6) The Environment

(.2) The gaps in our knowledge (the 'considerable uncertainty', p. 116; see also Section 6.2.6 on p. 117) about the invasiveness of certain GM crops seem important.

· Again we lack historical data to help decide which stages in a plant's life will affect its invasiveness. This could take many generations to assess.

(.3) Although not emphasised in the executive summary, it is important to note from p. 128 that many GM pest-resistant crops have been found to harm wildlife. Moreover, on p. 124, we find that no GM crop designed to discourage pests has been shown to be harmless to non-target species.

· It is also concerning that there are no published studies of the effects of GM toxins on vertebrates, for example, birds which eat the crops.

· The claim on p. 14 that GM crops resistant to specific pests could improve local biodiversity is therefore misleading. It is all the more so when it is admitted (as on p. 132) that commercial crops often require more pesticides and herbicides.

(.4) The final sentence on p. 15 makes it clear that we do not know about, and would find it very difficult to speedily prevent, the emergence of insects, weeds, and diseases resistant to the chemicals which GM crops are designed to tolerate.

(.5) There appears to be too little published about the effect of GM herbicide tolerant (GMHT) crops on biodiversity. The report emphasises that even if the results of the first UK farm scale trials are complete, the results will not necessarily apply to the ways (for example, planting GM crops in rotation) crops might be used in practice. It is therefore vital to look again at this problem.

Conclusion

We can only conclude, as on p. 135 of the report, that far more research needs to be done to shed light on the problems highlighted above. Too little is known yet for the risks to be managed properly.

Gene flow, detection, and impact

The recurring theme of the First Report is that too little is known about this issue. In the section below we comment on some particular cases of this problem. The points are raised in the order in which they appear in the report.

(7) Gene Flow

(.2) This is an important area in which probably too little is known to adequately assess risks.

· Hardly anything appears to be known about the flow of genes over long distances. Nor is it clear how further research into this would proceed.

(.3) An important gap in our understanding appears to be the consequences of gene flows to weeds (see p. 19) which has only just started to have been studied. As ever, the long-term effects cannot be predicted yet (p. 224).

(.4) Section 7.5.4 (p. 245) only reports partial agreement among scientists that the effect of GM genes transferring plant viruses is negligible. Yet such transfers can and do occur (see p. 241) so it seems important to understand better what strains of virus might arise and how they could be controlled. This is all the more urgent as it has been suggested (see p. 240) that 'irreversible ecosystem or crop damage' could occur.

Conclusion

We can only conclude, as on p. 135 of the report, that far more research needs to be done to shed light on the problems highlighted above. Too little is known yet for the risks to be managed properly.