The 750 studies that GMO regulatory bodies often ignore

New review from Brazilian Ministry of Agrarian Development highlights hazards and uncertainties of GM crops

The Brazilian Ministry of Agrarian Development (MDA) has just published an important new online book in English: “Transgenic crops hazards and uncertainties: More than 750 studies disregarded by the GMOs regulatory bodies”. It examines research showing hazards to human and animal health, as well as risks to the environment, and agronomic or socioeconomic problems.
To take an example of the kind of scientific publication neglected by risk assessors, but which this book highlights, a study from China shows how GM Bt cotton failed to reduce insecticide sprays, even though this is the supposed advantage of Bt crops. The study examined the effects of pesticide applications on pests (aphids and acarid mites) and predators (ladybeetles and spiders) in both GM Bt insecticidal cotton and non-GM cotton. The study found that Bt cotton did not cause changes in populations of acarids, while its effects on aphids were inconsistent. Although insecticides were not applied against the main pest, cotton bollworm, on GM Bt cotton, the total number of insecticide applications in three years was no less than the total applied on non-GM cotton. The study concluded that “the use of Bt cotton should be evaluated carefully in China”.
A separate study from India examined the costs and returns from the cultivation of different types of cotton in a rainfed village in the Vidarbha region of Maharashtra. Expenditure on chemical pesticides was higher for Bt cotton than for other varieties of cotton. Variability in production was also higher for Bt cotton than for other types of cotton.
In the section on health risks, the book’s authors note that the scientific literature shows “immune and allergic reactions” in animals and humans to Bt toxins of the type engineered into GM Bt plants. The authors warn that over time, continuous immunological reactions “can ultimately result in allergenic and/or inflammatory reactions”. In addition, due to synergy effects and feedback responses, “simple immune responses against certain molecules are likely to turn into complex allergenic reactions against other molecules”. In other words, eating GM Bt crops could sensitise people to other food or non-food allergens.
This wide-ranging review clearly shows that in contrast to the claims of GMO promoters, there is no consensus in the scientific community about genetic engineering and its impacts.
Coming from a federal ministry of a country that is the second largest producer of GM crops in the world after the US, this book is a remarkable indictment of these crops and their associated pesticides. It exposes the bad science and negligence of the regulatory authorities, not only in Brazil but in every country that has allowed GM crops and foods into its food and farming systems.
Below is an excerpt from the book’s Introduction. The book is available as a free download (pdf) at A Portuguese version of the book is also available.

Transgenic crops hazards and uncertainties: More than 750 studies disregarded by the GMOs regulatory bodies

Gilles Ferment, Leonardo Melgarejo, Gabriel Bianconi Fernandes, Jose Maria Ferraz
Agrarian Studies and Rural Development Centre/ Coordination of Strategic Management,
Monitoring and Evaluation (NEAD), Brasília, Brazil


The book “Transgenic Crops – Risks to the Health and the Environment – More than 750 studies disregarded by the GMOs regulatory bodies” incorporates results of an extensive bibliographic research covering the subject of the hazards and uncertainties associated to the use of transgenic plants.

The main scientific publications referenced by specialized editorial boards related to the growth or transgenic plants (in commercial or experimental scale), to the management of those crops and to the animal and human consumption of their products were examined.

Being highlighted the issues related to biosafety, prioritizing environmental, human and animal aspects associated to the use of the concerned technologies, we accounted around 750 referenced articles, published between 1980 and 2015. Maintained in invisibility because their findings are opposite to the numerous pro-GMO marketing campaigns, such studies launch new perspectives about the subject. The abundance and the importance of such documents, as well as the invisibility imposed to them in the discussions conducted by the regulatory agencies, justify this publication, the objective of which is to enhance the scientific controversy concerning the biosafety of the transgenic plants. It is, as the documents gathered here evidence, a strong and active debate, weighing the attempts to impose false consensuses by the biotechnology industry and their associated lobbies. Opposite to what has been stated by foundations, institutes, associations and NGOs which incorporate the ideology of the biotechnology companies upon budget supports and members in their administration boards, the scientific community remains deeply divided.

The controversy, involving all the subjects related to the transgenic plants biosafety, can be summarized in terms of risks to the human and animal health and risks to the environment, being subdivided into sub-subjects and particularities associated to the involved transgenes, to the host organisms, to the technological packages and associated pesticides, among others. As it will be shown over this book, hundreds of studies evidence risks and weaknesses of affirmatives stating absence of toxicity of Bt proteins for human beings and farm animals. The same can be verified concerning the impact of underdosages and the results of sublethal effects of Cry toxins on non-target organisms or concerning the damages causes by crops that are tolerant to herbicides on the soil microbiota and the agricultural-ecological systems they are inserted to.

The statements about the impossibility to restrain the gene flow between GM species and these with native or agricultural species are also questionable. Thee impacts to the agrobiodiversity are greater as more extensive are the possibilities, the mechanisms and pollination vectors, but are not limited to this. The studies also reveal possibilities of horizontal transfers of genes and their fragments, increasing the risks resulting from overcoming the natural barriers between the species.

Highlight must further be given to the expansion in the use of pesticides associated to transgenic crops, to the hazards of glyphosate-, ammonium glufosinate-based herbicides and other pesticides succeeding the first ones in growing spiral of toxicity, as well as the risk evaluation processes practiced by the regulatory bodies. We call the attention to the fact that a similar research work - and not less wide - would be required to approach the set or socioeconomic risks represented by such plants. Effective agronomic performance analyses, such as the balance of costs and benefits taking into consideration medium term perspectives, were never conducted on an impartial and independent way, taking into consideration the possibility to reject such technologies. The objective of establishing a systemic balance, analyzing the risk/benefit of the biotechnology applied to the agriculture domain, what should guide the National Biosafety Council decisions – in Brazil – has never been among CTNBio’s concerns. If sought, this objective would certainly be supported not only in the studies gathered here, but also add those generated in another universe of specialized scientific magazines to these so as to cover the economy and sociology subjects.

The form this book is presented also differs from the usual format of books on which the bibliographic references used are indicated in the texts. In this case, an explanation of the approached subject is conducted and the quotes are listed with references so that the reader can access the original publications in full and use them as desired and draw their own conclusions about the several approached subjects.

We hope this effort reaches the purpose of challenging the scholars on such fields to complete this research, so as to consolidate the range of knowledge required for the National Biosafety Council (CNBS) to better comply with its duty to evaluate the opportunity and convenience to support CTNBio’s supposedly scientific decisions, which, ignoring this collection, invariably recommends unrestricted authorization for planting and consumption (human and animal) of transgenics in Brazil.

The first part of this publication, entitled Unpredictable and non- intentional genetic modification effects, focuses in studies pointing to the absence of control by the biotechnologist over the actions and the mechanisms he/she uses by imposing the transformed organism a new biological function. Despite of being random in terms of construction process, this function and others engaged by it will be fixed on a perennial and stable way in its role over the future generations, of that being and by others affected by it.

The difficulties involved in voluntarily (and correctly) inserting certain gene sequences in other organisms by means of classic genetic modification techniques appear right in the beginning of the gene transformation process. These consolidate themselves, among other examples, by inserting a number of copies of the interest transgene in the transformed organism, which fix, in full or in part, in random places of the new transgenic being’s genome.

In fact, without conducting long lasting and expensive tests and studies allowing to characterize the obtained transformation, the researchers will not know, strictly speaking, what they have performed. The basic fact is that the insertion mechanisms does not allow to anticipate the site where the desired genomic sequences will be incorporated, or how this will be completed, or even how many of them (and on which state, if as a whole or by parts) will be incorporated to the receiving DNA, or even what the transformed genome reaction will be in face of such transgenic invasion. Also, there is no way to anticipate if the plant will accept the transgenes and their functions, repairing, as possible, the damages caused by the method in the DNA, or if, to the contrary, it will silence the incorporated transgene, blocking its expression.

In parallel, the researchers also state that there are no mechanisms allowing to follow all the genetic and/or metabolic functions of the genomic sequences to be inserted. Indeed, it is possible that there is no scientific structure allowing at least to estimate, or know, all the metabolic relationships involved in the relationships triggered by a single gene, taking into consideration the environmental changes and the horizon of life of any individual.

The central dogma the genetic modification is supported by, frequently reiterated in the regulatory agencies and expanded with the assumption of the substantial equivalence, more than 20 years ago revealed itself as failed and without scientific support. A gene does not encode a single protein which will play a clear and defined role. A gene, under the influence of the environment, will make possible the expression of a wide set of proteins which, in their turn will interact of different ways with the macro set of proteins of the transformed organism and its relationships with the environment.

Finally, the genetic modification technique itself operates on an unrelated way to the set of involved relationships, abstracting or ignoring the epigenetic phenomena which regulates a number of biological mechanisms of the organisms, including the hereditary ones. By concentrating in less than a single support of the biological information, a DNA fragment, assumes that the organisms result from the simple addition of their parts, as if, knowing the genome, we had a map that is able to organize life creation. In other words, the genetic modification success in transposing a new function to an organism which naturally did not have it, rests above everything on the chance, where the success probability is substantially lower than that of the lotteries.

In a second part, entitled Agronomic issues related to the growth of transgenic plants, the selected articles focus on biosafety studies noting agronomic problems related to planting and handling of commercially released transgenic plants.

Such problems refer to the development of insect populations and ruderal plants genetically resistant to transgenic technology – sensitivity to Cry proteins and herbicides, respectively, to existing biological interactions, potentially causers of the inefficacy of the virus-resistance technology, as well as to the occurrence of ecological disturbs in the agricultural systems. All these aspects result in a number of agronomic problems such as attacks of secondary pests and transgenic dissemination in genetically related organisms, with economic, social and ecological impacts which far extrapolate the areas cultivated by those farmers who decide to adopt such technologies.

It is worth emphasizing that some articles related to productivity, to the use of pesticides and to the economic profit of the transgenic plants producers were included, despite of being slightly out of the scope of this publication. Likewise, the coexistence subject is particularly approached with reference to some articles about the gene flow, horizontal and vertical, adding cases of contamination between transgenic and non-transgenic commercial crops. It is worth emphasizing that the “coexistence” subject, in addition to the consideration of biological studies and arguments found in the scientific literature, requires an approach adding social, economic and cultural elements appropriate to each administrative region (country, region, etc.) and their different agricultural-ecological systems and biomes.

The third part, entitled Risks to the environment associated to the growth and/or use of transgenic plants, covers a set of hazards and uncertainties associated to the growth and dissemination of genetically modified plants in the environment.

The systemization of such articles is particularly structured concerning the risks involving Bt plants. At this point, the controversy about the Bt proteins specificity theory, their persistence in the environment and in the trophic chains and the negative impacts – direct and indirect - of such proteins about non-target macro-organisms (NTOs) and the soil microbiota communities is included.

In a second time, studies addressing plants tolerant to herbicides (HT), specially the glyphosate-based one, were systematized. Here, articles related to the negative impact of the herbicides associated to HT plants on the environment, are included. In fact, the risk evaluation of the herbicides associated to the use of transgenic plants provides important biosafety information about the subject of the environmental hazards resulting from HT crops, even when the metabolism of the substances occur on a different way for the two types of plants (natural and GM).

Finally, references about the transgenic dissemination/contamination risks in non-agricultural species come to complement the issues related to the transgene dissemination in agricultural systems, analyzed in the second part of this publication.

The fourth part of this work is entitled Risks to the health associated to the growth and/or use of transgenic plants. Here, around 200 references are joined about this subject - from articles pointing out to the insuffciency of scientific data to conclude for the absence of risks to the health, when genetically modified plants or their parts are consumed, to details about problems related to Bt and HT plants, separately addressed, on a similar way to that conducted in parts two and three of this book.

Concerning plants synthesizing Bt toxins, the interactions of such proteins with mammalian cells, as well as their potentially toxic and allergenic effects (in vivo and in vitro) are highlighted.

In case of HT plant, following a brief review or articles indicating negative effects on the human and animal health of herbicides associates to these crops, especially the glyphosate-based ones, studies pointing out hazards and uncertainties connected to the consumption of such plants and their parts will be systematized. In addition, some references about the hazards and uncertainties to the health from non-Bt transgenic plants and tolerant to other herbicides are supplied, in addition the glyphosate-based ones.

Finally, this chapter joins studies pointing out hazards related to the horizontal gene transfer in mammalian cells and their symbiontic organisms, as well as uncertainties associated to epigenetic mechanisms (especially RNAi).

In the fifth and last part of this book, entitled Scientific controversies and criticisms to the transgenic plants risk analysis process, the growing academic and scientific clash, conducted in international scale is analyzed concerning the supposed absence of risks related to the planting and consumption of transgenic plants. For that purposes, more than 90 articles which criticize from the risk evaluation process indicating the safety of such plants under the toxicological, allergenic, nutritional and environmental perspective, to those pointing out evidences of problems with this respect, such as toxicological, allergenic, nutritional and environmental hazards and damages will be systematized.

Credibility damaging campaigns for researches and authors mentioning such hazards and uncertainties are also described. The chapter further includes a number or reports about subjects suggesting explanations for the absence of consensus between the scientists, covering from conflicts of interest and methodological weaknesses to the commitment with possible research results and their eventual economic deployment.