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Assessing Benefits and Risks of Genetically Modified
Organisms
The term "Genetically Modified Organism" or GMO has been applied
to plants and animals in which techniques of recombinant DNA have been
used to introduce, remove, or modify specific parts of the genome of an
organism. The resulting organism may now stably express a novel protein,
a protein with novel properties, or carry a change in the regulation of
some of its genes. Usually, such a change is designed to improve the ability
of the organism to grow, for instance by resisting pests or using nutrients
more efficiently, or to improve the usefulness of the organism to us,
for instance by improving its nutritive value, by using it to manufacture
pharmaceutically important molecules, or employing it to carry out environmentally
important processes such as digesting environmental toxins.
Public discussion of the risks of Genetically Modified Organisms turn
on a number of different and not always related issues. The discussion
document below is meant to serve as an outline of the most important scientific
points for many of these issues and to provide references to more detailed
discussions of the subject. This document explicitly does not address
the social and economic impact of the use and commercialization of GMOs.
Some general issues to consider:
1. A new technique such as genetic engineering
may allow novel products to be produced, but there is no scientific basis
for the technique used to initially generate the plants or animals to
be a source for concern. Therefore, it will be necessary to consider products
on a "case-by-case" basis. In some cases, a GMO may not be different
in any significant way from a classically bred organism; in most cases,
the differences from a parent organism will be more defined and better
understood than in a classic breeding experiment.
2. In a given case,
is the concern about the organism's interactions with the environment
while it is growing, or about the interaction of a product with the user?
Both are possible, but if only one is of concern in a given case, the
solutions are rather different. Particularly in the latter case, the levels
of the novel material should be relevant to determining risk. As detection
methods for GMOs per se become more and more sensitive, it becomes possible
to detect very small quantities of a GMO. The distinction between a small
contamination with an organism able to propagate itself and a small contamination
by a protein or metabolic product, in a form no longer able to propagate
itself, should be kept in mind. The primary focus of concern lies with
invasive, self-propagating organisms.
3. Some of the concerns about GMOs
reflect general concerns about loss of genetic diversity and dependence
on large companies for seeds and other materials. These are scientifically
and socially valid concerns that are worthy of discussion, but are not
the subject of this document. From the viewpoint of geneticists, reduction
in genetic diversity of crop plants, for whatever reason, can increase
the risk of invasion by a single virulent pathogen. Solutions to the problem
of loss of genetic diversity, which are not unique to GMOs, are quite
distinct from the possible solutions for organisms believed to pose a
direct threat to us or to the environment. There is nothing about GMOs,
per se, that limits the genetic diversity of food crops, and it is possible
that heirloom strains could be revived with this technology.
4. Have both
risk and benefit been considered in evaluating concerns? It is never possible
to totally eliminate the unknown complication, even when using plants
and animals that arise naturally and have been in use for many years.
A sense of proportion needs to be maintained in evaluating the nature
of the expected benefit and the nature of the possible problems.
I. How
does a "GMO" differ from the product of traditional methods
of breeding and selection?
One of the arguments generally advanced in support of GMOs is that all
of the plants and animals used today in agriculture and manufacturing
processes are the result of years of selection and breeding. Specific
traits were chosen while others were discarded. This is what one might
call conventional genetic modification or breeding, in which we choose
what we want out of the many random possibilities arising from mutation
and the natural exchange of genetic information. Over the past century,
the definition of conventional (or natural) breeding was expanded to include
crosses between distantly related species, forced hybridization by cell
fusion, and mutagenesis. In general, crops produced by these methods are
not regulated, genetic test crosses are not required, and there is little
effort to characterize changes in traits unrelated to the property of
interest. For GMOs, the changes are specific and directed, so that we
know what they are. In addition, however, the limits of what can be changed
are much broader. Genes from animals may normally enter plants (and vice
versa) in limited quantities under very special circumstances; genetic
engineering allows specific genes to be stably expressed in a plant, possibly
at high levels. Therefore, while it is not always the case, frequently
a GMO will have genetic information we would be surprised to find by classical
genetic manipulation methods.
It is important, however, to keep in mind that it is not the method of
introducing foreign genes by molecular techniques per se that is likely
to make a given GMO different from anything that might have appeared or
has appeared naturally, but the nature of the specific change that is
made. Therefore, a scientifically valid evaluation of risks (and benefits)
needs to be tailored to the specific plant and/or product that is under
consideration; the properties of one GMO are unlikely to be shared by
another. Much of the concern by scientists about labeling reflects the
emphasis that has been placed on every GMO, that is, on the method of
construction per se, an issue which is not scientifically supportable.
Labeling to indicate significant changes in the composition of the final
product, independent of the method of construction, would be a scientifically
valid approach to this issue, and indeed is currently required by the
Food and Drug Administration (FDA).
II. Can we evaluate whether or not
a given GMO is likely to pose unexpected (or expected) risks that should
limit its use?
From the beginning of the use of recombinant DNA or genetic
engineering, first in bacteria and eventually in plants and animals as
well, there has been active discussion of whether these methods might
lead to unexpected properties of the engineered organisms and whether
those properties might be harmful. The Recombinant DNA Advisory Committee
of the National Institutes of Health (NIH) first developed guidelines
in 1976 for assessing these issues and for working safely with organisms
in laboratories. The general principles developed by that committee and
put to the test for the last two decades are directly relevant to the
issues discussed here, with one major addition. Initially, recombinant
DNA was for use in the laboratory, and while some engineered organisms
might be expected to escape the laboratory environment, they were generally
not designed to thrive and establish themselves outside the laboratory.
More recently, as this technology has been applied to plants and animals,
many of these organisms have been specifically designed for use in agriculture
or the environment, where the laboratory ideas of containment are not
relevant. Therefore, the evaluation of risks and benefits needs to take
this into account, and is the basis for many of the concerns about general
use of this technology.
A. What needs to be evaluated? Are the methods
for carrying out adequate evaluations available?
Here is an outline of the types of questions that are asked in evaluating
the possible risks of introducing a new organism: The general question
is: In what ways might the introduced changes expand or contract the possible
properties of the final product, with what possible consequences? For
an example of an in-depth analysis of a specific postulated risk of one
type of GMO, see the set of studies published in the Proceedings of the
National Academy of Sciences, vol. 98, issue 21 (2001), assessing the
risk to the Monarch butterfly population from corn expressing Bacillus
thuringiensis (Bt) toxin. These studies conclude that the risk of all
but one sort of the currently used corn containing Bt toxin to the overall
Monarch population is negligible. Note that risk assessment per se does
not consider expected benefits, an important part of the equation as well.
1. As a living organism:
a. Is the new gene expected to change where this organism can grow? How
fast it grows? Is it likely to change the organism's ability to exchange
genetic information with other organisms?
b. Will this new gene be exchanged/spread to neighboring organisms by
any of the currently understood mechanisms? Is it likely to be expressed
in the new context? What might the consequences of that be?
c. Is the engineered organism supposed to affect other organisms (act
as a pesticide, for instance?). If so, how specific is its action? How
specific are alternative treatments? Will the capacity of this organism
to grow and spread affect the evaluation of effects on other organisms?
d. How stable are the properties of this organism? Would a simple change
that might be expected to arise during wide-spread growth increase the
concerns about the properties of the organism?
2. As a food/other preparation:
1. Is the new gene/other modification expected to produce a change in
the protein composition of the final product? What new protein(s) should
be produced? Would they be expected to be biologically active in the final
product? After ingestion/appropriate use of the final product? Would they
be expected to be allergenic in the final product?
2. How much of this material should be present in the final product? A
very small amount of a potentially harmful product should be considered
differently from a large amount of the same product.
B. What is the process
for evaluating organisms to be used in the environment?
The current process of evaluation and approval of organisms is described
in great detail in the pertinent documents prepared by the relevant regulatory
agencies. This is well summarized on the
www.colostate.edu
web site, which also provides links to the specific agency regulatory
documents. A brief summary is provided here:
1. Department of Agriculture (USDA) process: covers plant pests, plants,
veterinary biologics
a. Notification required of intention to field test, including characteristics
that suggest no toxicity or pathogenicity for non-target organisms stability;
if less characterized or more questionable crops/genes, more information
must be provided
b. To commercialize, data on effects, possibilities of spread, etc. must
be provided.
c. USDA can retract permission if there is evidence plant is becoming
a pest.
2. Food and Drug Administration (FDA) process: covers food, feed,
food additives, veterinary drugs, human drugs and medical devices
a. Notification by developer to FDA 120 days before marketing, and producers
are required to prove product safety, including information on allergenicity.
Additional testing will depend on expectations of harmful ingredients,
new ingredients, antibiotic resistance, etc.
b. FDA has authority to remove food from market if deemed unsafe.
3. Environmental Protection Agency (EPA) process: covers microbial/plant
pesticides, new uses of existing pesticides, novel microorganisms used
commercially.
a. Reviews data on nature of product, its risks and benefits.
C. How do
we assess relative risks?
In some cases, the "precautionary principle" is often applied
to new technology, asserting that if there is any risk at all to a new
technology, then that technology should be avoided. Another method of
assessing new technology is to apply the standard of relative risk assessment
in which current methods are compared to the proposed technology. With
regard to genetically modified foods, this avenue has led to the consideration
of the risks relative to conventional breeding and current agricultural
practices. For example, if one variety of a plant contains a gene for
herbicide resistance that was identified by mutagenesis and selection,
and another variety contains a gene (or even the same allele) that was
introduced by recombinant technology, is the relative risk of using these
plants different? A more complicated issue arises when disparate comparisons
are required: Does the risk of spraying chemical pesticides on crops outweigh
the risks of introducing crops containing genes that confer pesticide
resistance biologically?
III. Putting GMOs in perspective:
Every year, thousands of Americans become ill and die from food contamination.
This is not a consequence of using GMOs, but instead reflects contamination
from food-borne bacteria. "Natural" food supplements are widely
used but are generally not well-defined, purified, or studied. As of 2000,
53% of the US soybean crop, 65% of the corn crop, and 80% of rennet cheese
was genetically modified. As of this writing, we are not aware of any
confirmed illnesses or other harmful effects resulting from genetically
modified foods. Although recent reports of contamination of corn meal
by GMOs not approved for human consumption led to several claims of allergic
response, to date, none of those individuals has been shown to contain
antibodies to the GM protein.
References: A comprehensive set of information and links to other sites can be
found at: http://cls.casa.colostate.edu/TransgenicCrops/
National Academy of Sciences report
Genetically Modified Pest-Protected Plants: Science and Regulation
(http://books.nap.edu/catalog/9795.html).
US and other Government sites
describing regulatory process and evaluation of risks and benefits:
United States Regulatory Oversight in Biotechnology:
http://www.aphis.usda.gov/biotech/OECD/usregs.htm
General outline of roles of various government agencies.
Roles of specific agencies:
USDA Agricultural Biotechnology Information
U.S. Food and Drug Administration, Bioengineered Foods page
U.S. Environmental Protection
Agency Biopesticide Web Page
U.S. House of Representative,
Committee on Science
The report "Seeds of Opportunity", released in April 2000, assesses
the benefits and risks of genetically-modified crops and foods.
Report of the New Zealand Royal Commission on Genetically Modified Organisms
Document developed by GSA Board of Directors, November, 2001.
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