The Soil Association would like the Science Review panel to review the Newcastle human feeding trial and also Calgene's research on the effects of feeding Flavr Savr tomatoes on rats. We believe that both are evidence of negative health effects whose significance has not been properly communicated and acted upon by the regulatory bodies involved.

Following concerns by independent advisers, the Food Standards Agency commissioned the first known trial of GM food on humans. The FSA was interested in whether antibiotic resistance genes were capable of transfering into the bacteria in the human gut. The results were publicised in July 2002 ("Survival of ingested DNA in the gut and the potential for genetic transformation of resident bacteria", Trudy Netherwood et al.). www.foodstandards.gov.uk/science/sciencetopics/gmfoos/gm_reports.

Contrary to the impression given by the Food Standards Agency, the results were very worrying. The first part of the research found that transgenic material is only fully degraded after it reaches the large intestine. Each meal contained 3000 billion copies of the transgene. The researchers found "to their surprise" that "a relatively large portion of genetically modified DNA survived the passage through the small bowel", up to 3.7% of the total in one case - 100 billion transgenes. The second and more significant part found that during passage in the small intestine horizontal gene transfer occured with some of the genetic material moving out of the GM food and into the gut bacteria. In three of the seven people sampled they found that gut bacteria had taken up transgenic DNA.

Despite the significance of the second part of the research, the FSA, in its public statement it chose to focus on the first part saying that it "showed in real-life conditions with human volunteers, no GM material survived the passage through the entire human digestive tract." However, it is what happens before it is degraded that is important for health, as addressed by the second part of the research. As for the evidence of gene transfer, the FSA said "the research concluded that the likelihood of functioning DNA being taken up by bacteria in the human or animal gut is extremely low". This seems to us a complete misrepresentation of the findings as DNA uptake by the gut bacteria was found in nearly half the subjects after only one GM meal.

We understand that GMOs have an artificially high potential for gene transfer and do not believe that the consequences and risks of this have been properly assessed. Genetic engineering involves overcoming the natural 'species barrier' and we understand that transgenes are engineered to be particularly mobile. As a result we are concerned that potentially all GM characteristics could be transferred into other organisms, such as antibiotic resistance or toxin production.

Calgene's research on Flavr Savr involved three 28-day studies. Groups of rats were fed either a transgenic tomato, a non-trangenic tomato, or deionized water. Two of the three studies found problems. The first study revealed no lesions. In the second study gross lesions were observed in four out twenty female rats fed one of the two lines of trangenic tomato. In the third study gross and microscopic lesions were described in the rats. However, these findings was played down and not publicly communicated by the Food and Drug Administration which approved the tomato for consumption despite lacking any proof of their safety.