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Prof. em. Klaus Ammann, University of Bern

Klaus Ammann, University of Bern, Neuchatel, Switzerland “Genomic Misconception, an old and important mistake in the regulation of GM crops”. Prof. em. Klaus Ammann, University of Bern. Urban Myth Genetic Engineering is fundamentally different from Natural Mutation Wrong:

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Prof. em. Klaus Ammann, University of Bern

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  1. Klaus Ammann, University of Bern, Neuchatel, Switzerland “Genomic Misconception, an old and important mistake in the regulation of GM crops” Prof. em. Klaus Ammann, University of Bern

  2. Urban Myth Genetic Engineering is fundamentally different from Natural Mutation Wrong: Natural Mutation and Transgenesis are identical on the molecular level Ammann, K. (20120706) Genomic Misconception: A fresh look at the biosafety of transgenic and conventional crops, a plea for a process agnostic regulation New Biotechnology, in press, pp 32 http://www.ask-force.org/web/NewBiotech/Genomic-Misconception-20120706-names-def.pdf

  3. NAS National Academy of Sciences, Kelman, A., Anderson, W., Falkov, S., Fedoroff, N., & Levin, S. (1987) Introduction of Recombinant DNA-Engineered Organisms into the Environment: Key Issues. National Academy Press, Washington DC, USA, pp 24 http://www.ask-force.org/web/NAS/NAS-Introduction-Recombinant-DNA-Engineered-Environment-1987.pdf NAS National Academy of Sciences, Committee on Genetically Modified Pest-Protected Plants, Board on Agriculture and Natural Resources, & National Research Council (2000) Genetically Modified Pest-Protected Plants: Science and Regulation, Prepublication and IS: ISBN: 0-309-06930-0, def: 0-309-50467-8 pp 290 http://www.nap.edu/catalog/9795.html AND prepublication: http://www.ask-force.org/web/NAS/National-Research-Council-GM-Pest-Protected-prepublication-2000.pdf http://www.ask-force.org/web/NAS/NAS-Introduction-Recombinant-DNA-Engineered-Environment-1987.pdf AND final copy: http://www.ask-force.org/web/NAS/National-Research-Council-GM-Pest-Protected-def-2000.pdf

  4. “There is no evidence that unique hazards exist either in the use of R-DNA techniques or in the transfer of genes between unrelated organisms”, and: “The risks associated with R-DNA engineered organisms are the same in kind as those associated with the introduction into the environment of unmodified organisms and organisms modified by other genetic techniques.” and: “Assessment of the risks of introducing R-DNA-engineered organisms into the environment should be based on the nature of the organism and the environment into which it will be introduced, not on the method by which it was modified.”

  5. Interestingly, naturally occurring molecular evolution, i.e. the spontaneous generation of genetic variants has been seen to follow exactly the same three strategies as those used in genetic engineering. These three strategies are (after W. Arber, Nobel Laureate 1978) (a) small local changes in the nucleotide sequences, (b) internal reshuffling of genomic DNA segments, and (c) acquisition of usually rather small segments of DNA from another type of organism by horizontal gene transfer. Arber, W. (2002) Roots, strategies and prospects of functional genomics. Current Science, 83, 7, pp 826-828 http://www.botanischergarten.ch/Mutations/Arber-Comparison-2002.pdf Arber, W. (2010) Genetic engineering compared to natural genetic variations. New Biotechnology, 27, 5, pp 517-521 http://www.ask-force.org/web/Vatican-PAS-Studyweek-Elsevier-publ-20101130/Arber-Werner-PAS-Genetic-Engineering-Compared-20101130-publ.pdf

  6. However, there is a principal difference between the procedures of genetic engineering and those serving in nature for biological evolution. While the genetic engineer pre-reflects his alteration and verifies its results, nature places its genetic variations more randomly and largely independent of an identified goal. After ca. 10 years of testing the GM crops are brought to the field by millions in a few years Arber, W. (2002) Roots, strategies and prospects of functional genomics. Current Science, 83, 7, pp 826-828 http://www.botanischergarten.ch/Mutations/Arber-Comparison-2002.pdf

  7. Scatter plot representation of transcriptome comparisons, Baudo et al. 2006 Baudo: comparison in genomic disturbance: GM crops are less disturbed (black dots) than classic breeds transgenic vs. control endosperm 14 dpa 28 dpa 8 dpg Baudo, M.M., Lyons, R., Powers, S., Pastori, G.M., Edwards, K.J., Holdsworth, M.J., & Shewry, P.R. (2006) Transgenesis Has Less Impact on the Transcriptome of Wheat Grain Than Conventional Breeding. Plant Biotechnology Journal, 4, 4, pp 369-380 http://www.botanischergarten.ch/Organic/Baudo-Impact-2006.pdf Shewry, P.R. & Jones, H.D. (2005) Transgenic Wheat: Where Do We Stand after the First 12 Years? Annals of Applied Biology, 147, 1, pp 1-14 http://www.botanischergarten.ch/Organic/Shewry-Performance-2006.pdf 2 conventional lines Endosperm 14 dpa 28 dpa leaf at 8 dpg transgenic vs. conventional Endosperm 14 dpa 28 dpa leaf at 8 dpg

  8. Radiation breeding as field experiments Gamma Field for radiation breeding 100m radius 89 TBq Co-60 source at the center Shielding dike 8m high Better spaghettis, whisky 1800 new plants Institute of Radiation Breeding Ibaraki-ken, JAPAN http://www.irb.affrc.go.jp/

  9. Radiation site for mutation breeding, Co-60 radioactivity source of 89 TBq in the center, Radius of 100m. Gamma Field for Radiation Breeding Was muss man sichdaruntervorstellen? 89 TBq represents the 140-fold of all Radioactivity of material stored in the German permanent storage site of Morsleben insgesamt eingelagerten Radioaktivität. In this radiation field a human being would receive 3 deadly Sievers units of radiation after the exposure times given below 3,5 min 60 min

  10. Reuters, May 10, 2010 UN's International Atomic Energy Agency since 1963, 2,252 new plant varieties, including Italian durum wheat, have been created using radioactive substances such as cobalt and X-rays. 70% of the crops under cultivation worldwide are radiation mutation varieties Charles Margulis of Greenpeace USA: "But now they tell us that scientists have been artificially hybridizing plants since the 1960s.That's, like, really uncool."

  11. Activists, supported by Jane Rissler, called for a ban, since those irradiated varieties have never been tested for food safety, which would have wiped out 70% of the food products on shelfs. Rissler: “Compared to these plants, genetically modified food is about as dangerous as a one-legged man in an ass-kicking contest.” But excellent repair mechanisms working like zippers are reducing radiation damage considerably And worldwide there has been no correlation established between radiation mutation and negative food safety facts. (Reuters 2001 continued)

  12. FRANKENSTEIN Durum Wheat, Triticum durum: all major breeds have gone though massive and inprecise radiation breeding, but with Important success unnecessary fearmongering

  13. European Biosafety and the Cartagena Protocol The biosafety protocol is based on the wrong Premises: See Genomic Misconception in this slides: Natural Mutation and transgenesis are the same on the molecular level. www.strangevehicles.com

  14. In the European Union decision making processes are too complex, obscure and politically inefficient

  15. System map of the principal issues, challenges and feedback loops in the risk management component of the legislation EPEC-SANCO (2011) Evaluation of the EU legislative framework in the field of cultivation of GMOs under Directive 2001/18/EC and Regulation (EC) No 1829/2003, and the placing on the market of GMOs as or in products under Directive 2001/18/EC Final Report, pp. 137. European Commission DG Sanco http://ec.europa.eu/food/food/biotechnology/evaluation/docs/gmo_cultivation_report_en.pdf

  16. EPEC-SANCO (2011) Evaluation of the EU legislative framework in the field of cultivation of GMOs under Directive 2001/18/EC and Regulation (EC) No 1829/2003, and the placing on the market of GMOs as or in products under Directive 2001/18/EC Final Report, pp. 137. European Commission DG Sanco http://ec.europa.eu/food/food/biotechnology/evaluation/docs/gmo_cultivation_report_en.pdf http://www.ghkint.com/

  17. The comments from the EPEC-SANCO show the nearly un-surmountable difficulties of European Regulation, due to a disorganized mix of politics and wrong risk conception of GM crops, all this contrary to the food and environmental safety experience worldwide. EPEC-SANCO (2011) Evaluation of the EU legislative framework in the field of cultivation of GMOs under Directive 2001/18/EC and Regulation (EC) No 1829/2003, and the placing on the market of GMOs as or in products under Directive 2001/18/EC Final Report, pp. 137. European Commission DG Sanco http://ec.europa.eu/food/food/biotechnology/evaluation/docs/gmo_cultivation_report_en.pdf

  18. Nonetheless, consultees’ frustration with the risk assessment phase is modest compared to that caused by the risk management stage. The research conducted for this study suggests that it is the lack of decisions, whether positive or negative, that is of particular concern. The lack of qualified majority is mainly attributed to the polarized views within and among Member States and a significant number of abstentions; EPEC-SANCO (2011) Evaluation of the EU legislative framework in the field of cultivation of GMOs under Directive 2001/18/EC and Regulation (EC) No 1829/2003, and the placing on the market of GMOs as or in products under Directive 2001/18/EC Final Report, pp. 137. European Commission DG Sanco http://ec.europa.eu/food/food/biotechnology/evaluation/docs/gmo_cultivation_report_en.pdf

  19. This situation gives rise to comments, heard repeated in consultations, that the legislative framework is not being implemented as intended. Empirically, the risk management aspects of the framework as implemented are not efficient, transparent or, in aggregate, fit for purpose. Consultees agreed that the current situation with GMO authorizations in Europe is not sustainable. EPEC-SANCO (2011) Evaluation of the EU legislative framework in the field of cultivation of GMOs under Directive 2001/18/EC and Regulation (EC) No 1829/2003, and the placing on the market of GMOs as or in products under Directive 2001/18/EC Final Report, pp. 137. European Commission DG Sanco http://ec.europa.eu/food/food/biotechnology/evaluation/docs/gmo_cultivation_report_en.pdf

  20. Innovation in agbiotech. (a) Location and sector of organizations conducting R&D for the 558 transgenic product quality innovations identified. Private sector consists of corporate and privately held firms. Public sector consists of government research laboratories, universities and nonprofit research institutes. (b) Annual entry, exit and the numbers of innovations active in the R&D pipeline were calculated from observations of the 558 innovations tracked in the primary survey. The number of active innovations stopped growing in 1998, after which those new innovations that entered were more likely to be published and less likely to move toward commercialization. Fig.1 from (Graff et al., 2009b). Graff, G.D., Zilberman, D., & Bennett, A.B. (2009) The contraction of agbiotech product quality innovation. Nature Biotechnology, 27, 8, pp 702-704 http://www.botanischergarten.ch/Regulation/Graff-Contraction-Agbiotech-Innovation-2009.pdf

  21. But the world has seldom seen a greater discrepancy between the inherent hazard of a product and the level of regulatory burden imposed on it than exists today for crops improved through biotech. It is important, here, to be very clear: there is no basis in science for regulation specific to crops and foods improved through biotech or ‘GMOs’ Giddings, V., Potrykus, I., Ammann K., & Fedoroff, N. (2012) Confronting the Gordian knot, Opinion. Nature Biotechnology, 30, 3, pp 208-209 http://www.ask-force.org/web/Regulation/Giddings-Confronting-Gordian-Knot-2012.pdf

  22. By any honest reckoning, the level of scrutiny to which crops improved through biotech are subjected is completely unwarranted by the body of knowledge acquired over three decades of experience with such crops, including 15 years in commercial production. This is true around the world, but nowhere is the chasm between regulatory regime and the implications of facts and experience greater than in Europe. Although Europe is sufficiently wealthy to buy its food, the indirect effects of European regulations and attitudes have had a unconscionably inhibitory effect on the introduction of biotech crops in less developed countries in most need of them, particularly on the African continent. Giddings, V., Potrykus, I., Ammann K., & Fedoroff, N. (2012) Confronting the Gordian knot, Opinion. Nature Biotechnology, 30, 3, pp 208-209 http://www.ask-force.org/web/Regulation/Giddings-Confronting-Gordian-Knot-2012.pdf

  23. http://www.europabio.org/sites/default/files/position/120601_gm_approvals_status_may_2012.pdf#overlay-context=agricultural/positions/undue-delays-eu-approval-safe-gm-productshttp://www.europabio.org/sites/default/files/position/120601_gm_approvals_status_may_2012.pdf#overlay-context=agricultural/positions/undue-delays-eu-approval-safe-gm-products

  24. 1. June 2012 Check for updates at http://www.europabio.org/filter/agricultural/type/position or contact EuropaBio for more info

  25. Check for updates at http://www.europabio.org/filter/agricultural/type/position or contact EuropaBio for more info

  26. Gómez-Galera, S., Twyman, R.M., Sparrow, P.A.C., Van Droogenbroeck, B., Custers, R., Capell, T., & Christou, P. (2012) Field trials and tribulations—making sense of the regulations for experimental field trials of transgenic crops in Europe. Plant Biotechnology Journal, 10, 5, pp 511-523 http://dx.doi.org/10.1111/j.1467-7652.2012.00681.x AND http://www.ask-force.org/web/IP/Gomez-Galera-Field-Trials-Tribulatioins-2012.pdf

  27. Gómez-Galera, S., Twyman, R.M., Sparrow, P.A.C., Van Droogenbroeck, B., Custers, R., Capell, T., & Christou, P. (2012) Field trials and tribulations—making sense of the regulations for experimental field trials of transgenic crops in Europe. Plant Biotechnology Journal, 10, 5, pp 511-523 http://dx.doi.org/10.1111/j.1467-7652.2012.00681.x AND http://www.ask-force.org/web/IP/Gomez-Galera-Field-Trials-Tribulatioins-2012.pdf

  28. The Turkish law on GM crops is even more strict than the European one and it also Affects heavily research, which is practically excluded from Turkey. Brookes, G., Cetiner, S., & Guzel, A. (2012) Economic impacts of the Biosafety Law and implementing regulations in Turkey on the Turkish importing and user sectors PG Economics pp 55 Dorset, DT1 1PW, UK (Report) http://www.pgeconomics.co.uk/page/31/turkey%E2%80%99s-biosafety-law-causing-significant-economic-harm-to-agri-food-chain AND http://www.ask-force.org/web/Turkey/Brookes-Cetiner-Guzel-Economic-Impacts-Biosafety-Law-Turkey-2012.pdf

  29. European safety attitude: a problem for many countries in the developing world European Safety Attitude: let not the Europeans decide about Biosafety in Africa and the Near East, do your own safety assessment

  30. Paarlberg, R. (2009) Starved for Science, How Biotechnology is kept out of Africa Harvard University Press; 1 edition (August 5, 2009) Cambridge, USA, IS: ISBN-10: 0674033477 ISBN-13: 978-0674033474 pp 256 http://www.amazon.com/Starved-Science-Biotechnology-Being-Africa/dp/0674033477/ref=sr_1_1?s=books&ie=UTF8&qid=1331185222&sr=1-1#_

  31. Royal-Society (2009) Reaping the benefits: science and the sustainable intensification of global agriculture, Royal Socienty pp 89 RS Policy document 11/09 London (Report) http://royalsociety.org/displaypagedoc.asp?id=35510 AND http://www.ask-force.org/web/Benefits/RS-Reaping-the-Benefits-200910.pdf

  32. Urban Myth Crop varieties have diminished due to modern biotechnology breeding Wrong: A new worldwide market study shows the contrary: Crop varieties have steadily grown in numbers since WW II

  33. van de Wouw, M., van Hintum, T., Kik, C., van Treuren, R., & Visser, B. (2010) Genetic diversity trends in twentieth century crop cultivars: a meta analysis. TAG Theoretical and Applied Genetics, 120, 6, pp 1241-1252 http://www.botanischergarten.ch/Biotech-Biodiv/van-de-Wouw-Genetic-Diversity-Trends-2010.pdf

  34. Fig. 4 Wheat genetic diversity (a) and crop genetic diversity (excluding wheat) (b) in the twentieth century based on a weighted meta analysis of 20 publications. The diversity in the decade with the lowest diversity was set to 100 Ammann, K. (20120317) Biodiversity and the debate on GM crops - Can GM crops help to enhance biodiversity? . In ASK-FORCE AF-11, Vol. AF-11, pp. 103. K. Ammann, Neuchâtel http://www.ask-force.org/web/AF-11-Biodiversity/AF-11-Biodiversity-Biotechnology-20120317-numbered.doc http://www.ask-force.org/web/AF-11-Biodiversity/AF-11-Biodiversity-Biotechnology-20120317-web.doc http://www.ask-force.org/web/AF-11-Biodiversity/AF-11-Biodiversity-Biotechnology-20120317-web.pdf http://www.ask-force.org/web/AF-11-Biodiversity/AF-11-Biodiversity-Biotechnology-20120317-opensource.doc http://www.ask-force.org/web/AF-11-Biodiversity/AF-11-Biodiversity-Biotechnology-20120317-opensource.pdf

  35. A Century Ago In 1930 commercial seed houses offered hundreds of varieties as shown in this sampling of ten crops 80 Years Later By 1983 few of those varieties were found in the National Seed Storage Laboratory Source: National Geographic, July 2011 with completely wrong numbers based on the old RAFI study Fowler, C. & Mooney, P., R., (1990) US: Shattering : food, politics, and the loss of genetic diversity GB: The threatened gene: Food, politics and the loss of genetic diversity US: The University of Arizona PressGB: Lutterworth Press P.O. Box 60 Cambridge CB12NTPrinted Billing & Sons Ltd, Worcester, US: Tucson GB: Cambridge, IS: ISBN 0 7188 2830 5. , pp xvi, 278 p http://www.amazon.com/gp/product/0816511810/sr=1-1/qid=1320748094/ref=olp_product_details?ie=UTF8&me=&qid=1320748094&sr=1-1&seller= AND from the etc Group: http://www.ask-force.org/web/Biotech-Biodiv/Fowler-Mooney-The-threatened-Gene-1990.pdf

  36. Heald, P.J. & Chapman, S. (2011) Veggie Tales: Pernicious Myths About Patents, Innovation, and Crop Diversity in the Twentieth Century. SSRN eLibrary, pp http://www.ask-force.org/web/IP/Heldt-Veggie-Tales-Pernicious-Myths-2011.pdf

  37. Heald, P.J. & Chapman, S. (2011) Veggie Tales: Pernicious Myths About Patents, Innovation, and Crop Diversity in the Twentieth Century. SSRN eLibrary, pp http://www.ask-force.org/web/IP/Heldt-Veggie-Tales-Pernicious-Myths-2011.pdf

  38. Urban Myth Organic Farming and Modern Agriculture including Genetic Engineering cannot go together Wrong: Organic farming needs crops adapted to the special needs of agro-ecology by modern biotechnological methods

  39. Why high tech farmers should adopt Organic management Ammann, K. (2008) Feature: Integrated farming: Why organic farmers should use transgenic crops, open source citations. New Biotechnology, 25, 2, pp 101 - 107 http://www.botanischergarten.ch/NewBiotech/Ammann-Opinion-Integrated-Farming-20080825-names-links-edited.pdf Ammann, K. (2009) Feature: Why farming with high tech methods should integrate elements of organic agriculture. accepted, corrected proof, open links. New Biotechnology, 4, pp http://www.botanischergarten.ch/NewBiotech/Integrated-Farming-Biotech-Org-20090803-openlink.pdf

  40. Ronald, P.C. & Adamchak, R.W. (2008) Tomorrow's Table: Organic Farming, Genetics, and the Future of Food Oxford University Press, USA (April 18, 2008) IS: ISBN-10: 0195301757 ISBN-13: 978-0195301755 pp 232 Book review by J. Gressel 2009 http://www.botanischergarten.ch/Gressel-Book-Ronald-2009.pdf

  41. Amish farmers in biotech-debate: subsequent partial adoption of transgenic crops: 1999, see: http://www.ifpri.org/2020conference/PDF/summary_ammann.pdf

  42. Prevalence of E.coli on Semiorganic, organic and Conventional farms from Which at least one contaminated sample was collected in A 2003 B 2004 Mukherjee, A., Speh, D., Jones, A.T., Buesing, K.M., & Diez-Gonzalez, F. (2006) Longitudinal microbiological survey of fresh produce grown by farmers in the upper midwest. Journal of Food Protection, 69, 8, pp 1928-1936 http://www.botanischergarten.ch/Organic/Mukherjee-Longitudinal-MicrobiolSurvey-2006.pdf

  43. Urban Myth Agro-Ecology and organic farming result in more yield compared to biotech crops Wrong: All comprehensive statistics show that agroecology in average has 20-30% less yield

  44. Organic Winter Wheat represented 0.8% of 2008 acres but only 0.5% of total production 100% conversion to Organic would have required 10.4MM additional acres, a 49% increase Savage, S.D. (2008) A Detailed Analysis of US Organic Crops. (publ. Steve Savage) (Audio-Visual Material) http://www.ask-force.org/web/Organic/Savage-Detailed-Analysis-US-Organic-2008.ppt AND http://www.ask-force.org/web/Organic/Savage-Detailed-Analysis-US-Organic-2008.pdf see also Applied Mythology http://appliedmythology.blogspot.com

  45. Organic Soybeans represented 0.13% of 2008 acres in the US, 0.09% of total production, but 0.17% of total soybean payments. Organic soybeans sold at 2 times the price for conventional so with 66% of the yield that represented a net advantage of 1.3 times the gross per acre income. To have produced all the 2008 soybeans Organically would have required 38.2MM additional acres – a 51% increase Savage, S.D. (2008) A Detailed Analysis of US Organic Crops. (publ. Steve Savage) (Audio-Visual Material) http://www.ask-force.org/web/Organic/Savage-Detailed-Analysis-US-Organic-2008.ppt AND http://www.ask-force.org/web/Organic/Savage-Detailed-Analysis-US-Organic-2008.pdf see also Applied Mythology http://appliedmythology.blogspot.com

  46. Organic Tomatoes: No better quality There is scientific proof of the following 1. Tomato quality differs heavily on environmental conditions Chassy, A.W., Bui, L., Renaud, E.N.C., Van Horn, M., & Mitchell, A.E. (2006) Three-year comparison of the content of antioxidant microconstituents and several quality characteristics in organic and conventionally managed tomatoes and bell peppers. Journal of Agricultural and Food Chemistry, 54, 21, pp 8244-8252 http://www.ask-force.org/web/Organic/Chassy-AW-Three-Year-Comparison-Tomatoes-2006.pdf http://dingo.care2.com/pictures/greenliving/1078/1077877.large.jpg 2. The claim that organic tomatoes have higher content of antioxidants is false Mitchell, A.E., Hong, Y.J., Koh, E., Barrett, D.M., Bryant, D.E., Denison, R.F., & Kaffka, S. (2007) Ten-Year Comparison of the Influence of Organic and Conventional Crop Management Practices on the Content of Flavonoids in Tomatoes. J. Agric. Food Chem., pp http://www.botanischergarten.ch/Organic/Mitchell-tenyears-tomato-2007.pdf AND http://www.botanischergarten.ch/Organic/Mitchell-2007-Fig-4.ppt AND rebuttal Hudson Institutehttp://www.botanischergarten.ch/Organic/Tomato-Flavonoids-Hudson-2007.pdf 3. The claim that organic food has higher quality has been falsified by several studies Dangour, A.D., Dodhia, S.K., Hayter, A., Allen, E., Lock, K., & Uauy, R. (2009) Nutritional quality of organic foods: a systematic review, including controversy. Am J Clin Nutr, 90, pp ajcn.2009.28041 and 680-685 http://www.botanischergarten.ch/Organic/Dangour-Nutritional-Quality-Organic-2009.pdf AND http://www.botanischergarten.ch/Organic/Benbrook-Methodological-Flaws-Dangour-2009.pdf AND http://www.botanischergarten.ch/Organic/Gibbons-Reply-Dangour-2009.pdf AND http://www.botanischergarten.ch/Organic/Dangour-Reply-to-Gibbon-Benbrook2009.pdf

  47. Slavo Mac (20110824) Complexity Theorists Predict Food Crisis, Riots and Civil Unrest By April 2013. In SHTFplan.com http://www.shtfplan.com/forecasting/complexity-theorists-predict-food-crisis-riots-and-civil-unrest-by-april-2013_08242011

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