Genetically modified plants for food use and human health—an...

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Policy document 4/02 February 2002 ISBN 0 85403 576 1 This report can be found at www.royalsoc.ac.uk Genetically modified plants for food use and human health—an update

Transcript of Genetically modified plants for food use and human health—an...

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Policy document 4/02

February 2002

ISBN 0 85403 576 1

This report can be foundat www.royalsoc.ac.uk

Genetically modifiedplants for food use andhuman health—an update

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Contents

Preparation of this report 2

Summary 3

1 Introduction 4

2 The use of substantial equivalence in the safety assessment of GM food 5

3 Possible effects of GM food on human nutrition 7

4 Possible allergic responses to GM foods 7

5 Potential effects on human health resulting from the use of viral DNA in plants 8

6 The fate of GM plant DNA in the digestive system 9

7 Conclusions and recommendations 10

8 References 11

Appendix 1 Press Release 14

Appendix 2 List of respondees to the study 14

Appendix 3 Legislation 15

Appendix 4 Recommendations from the Royal Society 1998 report Genetically modified

plants for food use 16

Appendix 5 Glossary 18

Other recent Royal Society reports 19

Preparation of this report

In 1998 the Royal Society issued the report Genetically modified plants for food use. The Society periodically issuesupdates on reports (recent examples include updates on bovine spongiform encephalopathies and stem cells) and thefollowing update, which is based on research published in the last three years, specifically addresses human healthaspects of genetically modified foods and the principle of substantial equivalence. The statement has been prepared bya working group chaired by Professor Jim Smith FRS (Wellcome CRC Institute, Cambridge). Other members are Dr EricBrunner (Dept of Epidemiology and Public Health, University College London), Professor Douglas Fearon FRS (WellcomeTrust Immunology Unit, University of Cambridge), Dr Edward Holmes (Dept of Zoology, University of Oxford), ProfessorAlan Jackson (Institute of Human Nutrition, University of Southampton), Professor Chris Leaver FRS (Dept of PlantSciences, University of Oxford), Professor Tom Meade FRS (MRC Epidemiology and Medical Care Unit, St Bartholomew’sand the Royal London School of Medicine and Dentistry), Dr Clare Mills (Institute of Food Research, Norwich), ProfessorDavid Sherratt FRS (Dept of Biochemistry, University of Oxford), Professor David Walker FRS (Dept of Animal and PlantSciences, University of Sheffield) and Dr Josephine Craig, Dr Rebecca Bowden and Mr Bahader Singh (Secretariat, RoyalSociety). This report has been endorsed by the Council of the Royal Society.

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Summary

1 In 1998 the Royal Society published a report,Genetically modified plants for food use, whichconcluded that the use of genetically modified (GM)plants had the potential to offer benefits in agriculturalpractice, food quality, nutrition and health, but thatthere were several aspects of GM technology thatrequired further consideration. The Royal Societyappointed a group of experts to update this reportbased on research since 1998. This update focuses onthe effects that GM foods might have on humanhealth and the use of the principle of substantialequivalence in GM food safety testing.

2 Few, if any, GM food products are currently available tobuy in Europe and the UK. Commercial varietiesproduced elsewhere, in the USA and Canada forexample, are designed to confer resistance to pestsand to produce tolerance to specific herbicides. Overthe next decade biotechnology will be aimed atimproving many qualities of crops, including nutritionand agronomic performance. We support thecontinuation of research in this area as valuable in itselfand as the only way to assess the true potential of GMplants.

3 We endorse the conclusions of the 21st report of theRoyal Commission on Environmental Pollution (1998)that scientific assessments must inform policydecisions but cannot pre-empt them, and that publicopinion must be taken into account throughout. Webelieve that the public debate about GM food musttake account of wider issues than the science alone.We also wish to stress the importance of informingdebate with sound science.

4 We have some concerns about the regulatoryprocesses governing the development and use of GMplants. We agree with the FAO/WHO 2000 report thatthe criteria for safety assessments should be madeexplicit and objective and that differences in theapplication of the principle of substantial equivalence,for example in different Member States of theEuropean Union, need to be resolved. We welcome thedevelopment of consensus documents by the OECD1

for different crops so that the principle of substantialequivalence can be applied uniformly. It may not benecessary or feasible to subject all GM foods to the fullrange of evaluations, but those conditions which haveto be satisfied should be defined.

5 In the future safety assessments of GM and non-GMfoods could make use of various new profilingtechniques. Long-term research is required before thesetechniques can be applied. We recommend that

research should continue to develop such technologiesand thereby define the ‘normal’ compositions ofconventional plants. We welcome the funding initiativesalready put in place by the European Union Framework Vprogramme and the UK’s Food Standards Agency.Collaboration between the chemical industry, academiaand regulators to develop techniques and sharereference data will help ensure that agreement is reachedon interpretation of results and use of new technologies.

6 One potential application of GM technology is toimprove the nutritional quality of crops. It is possiblethat GM technology could lead to unpredicted harmfulchanges in the nutritional status of foods (MRC, 2000).Such alterations might also occur in the course ofconventional breeding. Nutritional assessments aremade as part of the safety assessment of GM crops,but more detailed guidelines would be beneficial.Vulnerable groups such as infants need specialguidelines. To date no GM food for use in infantproducts has been submitted for approval. Detailedguidelines and legislation already exist for infantformulas and follow-on foods but it is not clear howthey interact with GM food regulations. Therefore werecommend that both the Government and theEuropean Commission should ensure that these twosets of regulations are complementary. Guidelines suchas those described by COMA (1996) for nutritionalassessment of infant formulas and more recently byAggett et al. (2001) should be adopted for both noveland GM foods.

7 There is at present no evidence that GM foods causeallergic reactions. The allergenic risks posed by GMplants are in principle no greater than those posed byconventionally derived crops or by plants introducedfrom other areas of the world. One shortcoming incurrent screening methods, which applies to bothconventional and GM foods, is that there is no formalassessment of the allergenic risks posed by inhalationof pollen and dusts. We therefore recommend thatcurrent decision trees be expanded to encompassinhalant as well as food allergies.

8 Plant viral DNA sequences are commonly used in theconstruction of the genes inserted into GM plants, andconcern has been expressed about this. Havingreviewed the scientific evidence we conclude that therisks to human health associated with the use ofspecific viral DNA sequences in GM plants arenegligible.

9 One concern associated with GM foods is thepossibility that genes introduced into GM plants mightbecome incorporated into the consumer’s geneticmake-up. Since the Royal Society’s 1998 report various

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1 http:// www.oecd.org./oecd/pages/home/displaygeneral/o,3380,EN- document-52814-no-27-9461-528,ff.html

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papers have been published on this topic. The resultsneed to be viewed in the context of a normal diet,which for humans and animals comprises largeamounts of DNA. This DNA is derived not only from thecells of food sources, but also from any contaminatingmicrobes and viruses. Given the very long history ofDNA consumption from a wide variety of sources, weconclude that such consumption poses no significantrisk to human health, and that additional ingestion ofGM DNA has no effect.

1 Introduction

The Royal Society report, Genetically modified plants forfood use (1998), concluded that the use of geneticallymodified (GM) plants potentially offered benefits inagricultural practice, food quality, nutrition and health,but that there were several aspects of GM technologywhich required further consideration. We recognise thatthere is public concern about GM technology, particularlywith respect to the safety of GM food for humanconsumption and to the possible effects of thetechnology on the environment. Since the 1998 reportthere has been new research which the working grouphas evaluated. This update focuses on the effects that GMfoods might have on human health and the use of theprinciple of substantial equivalence in GM food safetytesting. We plan to review developments on theenvironmental aspects of GM crops at a later date.

The 1998 report provides the background for this update,but we will redefine some of the key terms and issues atthis point. Mankind has cultivated plants for thousands ofyears, during which time crop plants have continuallybeen selected for improved yield, growth, diseaseresistance or food characteristics. The improvement of aplant species by ‘conventional’ techniques involves theselection for breeding purposes of certain plants thatexpress desired characteristics. Plant breeders use sexualand asexual reproduction (including crosses betweendifferent species of plants) and other techniques (such asembryo rescue2 and irradiation or chemical mutagenesis)to develop new plant varieties. Genetically modifiedplants differ from their conventional counterparts in thatthey are created by the deliberate insertion of specificgenetic material using recombinant DNA technology. Thistechnology may allow plant breeders to develop newvarieties of crops at a faster rate than by conventionalmeans, and it also allows the introduction of geneticmaterial from other species, families or even kingdoms,which in many cases is not possible by conventionalmeans. More specifically it allows the introduction ofsingle genes and modification of a specific trait. Custers(2001) provides an overview of the techniques used in

both conventional breeding and genetic modification.Recently the role of GM plants in world agriculture hasbeen considered by seven national academies includingthe Royal Society (Transgenic plants and worldagriculture, Royal Society, 2000). The report concludesthat the real potential of GM technology to help addresssome of the most serious concerns of world agriculturehas only recently begun to be explored. Although GMtechnology has not yet developed to the point that a widevariety of GM crops is available, commercially producedvarieties in countries such as the USA and Canada includeGM crops that are designed to confer resistance to insectpests and to produce tolerance to specific herbicides(James, 2000). One significant effect of these measuresmight be a reduction, both quantitatively andqualitatively, in the use of pesticides (see Royal Society,2000 for further details). Over the next decadebiotechnology will aim to improve the nutritional qualitiesof crops and agronomic performance by targeting traitssuch as yield and stress tolerance. GM technology maytherefore help meet the demand for food by anexpanding world population with less impact on theenvironment. It is clear, however, that realisation of thispotential will require continued development andevaluation.

At the start of this study we issued a call requestingscientific evidence (Appendix 1) relating to the followinghuman health aspects of GM foods:

• the use of the principle of ‘substantial equivalence’ inthe safety assessment of GM foods

• possible effects of GM foods on human nutrition• possible effects of GM foods on allergic responses• potential effects on human health resulting from the

use of viral DNA in plants • the fate of GM plant DNA in the digestive system.

The organisations and people who responded are listed inAppendix 2. In addition to receiving written evidence, weinvited the Advisory Committee on Novel Food andProcesses, Friends of the Earth, Greenpeace, Monsanto,Syngenta and several individuals to present oral evidenceto the Committee (Appendix 2). A record of this evidenceis posted on the Royal Society’s website(http://www.royalsoc.ac.uk/policy/).

Some respondents raised social and ethical concernsabout GM technology. We have confined ourselves tocommenting on the scientific issues involved in geneticmodification of plants because this is where our expertiselies. Social and ethical concerns have been discussed bythe Food and Agriculture Organisation/World HealthOrganisation (FAO/WHO, 2001b), the Nuffield Council onBioethics (1999) and the Church of Scotland.3 The seven

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2 see glossary in appendix 5 for ‘embryo rescue’ and other technical terms3 http://www.srtp.org.uk

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academies report (Royal Society, 2000) Transgenic plantsand world agriculture, which is aimed specifically atdeveloping countries, addresses issues relating to foodsecurity such as intellectual property.

In June 1999, the Royal Society published a report,Review of data on possible toxicity of GM potatoes, inresponse to claims made by Dr Pusztai (Ewen & Pusztai,1999). The report found that Dr Pusztai had produced noconvincing evidence of adverse effects from GM potatoeson the growth of rats or their immune function. Itconcluded that the only way to clarify Dr Pusztai’s claimswould be to refine his experimental design and carry outfurther studies to test clearly defined hypotheses focusedon the specific effects reported by him. Such studies, onthe results of feeding GM sweet peppers and GMtomatoes to rats, and GM soya to mice and rats, havenow been completed and no adverse effects have beenfound (Gasson & Burke, 2001).

We endorse the conclusion of the 21st report of the RoyalCommission on Environmental Pollution (1998) that‘scientific assessments, and analyses of technology,economics, risk and implementation issues, must informpolicy decisions but cannot pre-empt them. Setting astandard or target is a practical judgement which has tobe made in the light of all relevant factors. People’s valuesmust be taken into account throughout, beginning at thestage of defining a problem and framing the questionsthat need to be addressed’. Thus we believe that thepublic debate about GM food must take account of widerissues than the science alone, but we wish to stress theimportance of informing debate with sound science.

2 The use of substantial equivalence in the safety assessment of GM food

In 1993, anticipating the need to develop a means ofassessing the safety of GM foods, the Organisation forEconomic Co-operation and Development (OECD)published the findings of a working group, whichintroduced the principle of ‘substantial equivalence’.Substantial equivalence is based on the principle that if anovel or GM food can be shown to be essentiallyequivalent in composition to an existing food then it canbe considered as safe as its conventional equivalent. Thisprinciple, which was endorsed by a joint FAO/WHOconsultation in 1996, also recognises that foodstuffsrepresent highly complex mixtures of many differentcompounds and that the detailed composition andnutritional values of many crops will depend, amongother things, on growth conditions, climate, and time ofharvesting. It also recognises that toxicological testing ofwhole foods has limitations due to bulkiness (thedifficulties in ingesting sufficient quantities of the whole

food in the diet) compared with food additives ormedicines. Indeed, application of such tests to manyconventional crops with a ‘history of safe use’ may causethem to be defined as unsafe.In recognition of these difficulties, the principle ofsubstantial equivalence requires that GM plants be assessedby comparing the GM plant with its conventionalcounterpart. In scientific language, the conventional crop isregarded as the control. The FAO/WHO report (1996)identifies three possible outcomes of such an evaluation,which then are used to structure the safety assessmentrequired for a particular GM product.

First, the GM foodstuff might be regarded as substantiallyequivalent to its conventional counterpart bothtoxicologically and nutritionally. An example of afoodstuff recognised to be substantially equivalent to itsconventional counterpart is oil derived from a GM plantsuch as maize or soya, as it does not include detectableprotein or DNA derived from the GM plant. When aproduct has been shown to be substantially equivalent,no further safety assessment is required.

Second, it might be substantially equivalent apart fromcertain defined differences. Sometimes the GM foodproduct includes the components deliberately introducedby genetic modification. In this case the GM food productmight be regarded as ‘substantially equivalent to itsconventional counterpart except for a small number ofclearly defined differences’. Assessment is then limited toexamining the implications of the difference(s), perhaps bytesting the novel components of the GM plant in isolation.

And third, the GM product might be regarded as notsubstantially equivalent to its conventional counterpart,or there might not be a suitable reference available forcomparison. The product will then need a highly detailedsafety assessment.

At present, safety evaluations include detailedconsideration of the genetic modification procedurewith respect to both the DNA sequences that areintroduced and the site of their integration in thegenome of the parent plant. Phenotypic data anddetailed chemical composition data covering a widerange of nutritionally important parameters are usuallyconsidered, as well as an assessment of the allergicpotential arising from foreign DNA (transgenes) in GMfoods.4 If there are differences between the GM productand its conventional counterpart, then furtherinvestigations are carried out. These may includetoxicology assessments (for example of the introducedprotein) and animal feeding studies.

The amount of comparative data required to establishsubstantial equivalence involves a somewhat subjective

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4 A summary of current EU legislation is given in Appendix 3

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judgement (Medical Research Council (MRC) report,2000) and thus has been questioned. We believe that atpresent there is no evidence to suggest that those GMfoods that have been approved for use are harmful.Nevertheless, the principle of substantial equivalencehas been the subject of considerable criticism andcomment (Royal Society of Canada, 2001). In particular,it has been argued that the approach is subjective andinconsistent and even that it represents ‘pseudo-science’ (Millstone et al., 1999). It has been suggestedthat the principle was introduced to provide an excusefor not carrying out the appropriate toxicological tests.One particular concern has been that the application ofsubstantial equivalence may not reveal any unexpectedeffects of genetic modification. For instance, theintroduction of a gene (or, especially, of multiple genes)into a plant species may cause there to be a presence,perhaps at very low levels, of previously unknowntoxins, anti-nutrients or allergens. This controversy wasrecognised in a second FAO/WHO report in 2000, whichreferred to the ‘mistaken perception that thedetermination of substantial equivalence was the endpoint of a safety assessment rather than the startingpoint’. It went on to recommend ways in whichsubstantial equivalence might best be applied in thefuture, including, as we discuss below, animal testing,profiling techniques, nutritional analyses andallergenicity testing.

We accept that it is usually not feasible to evaluate thesafety of genetically modified foods by the standardsapplied to certain food additives or medicines (MRC,2000). Some form of ‘substantial equivalence’, startingwith a direct comparison of the novel foodstuffs withtheir unmodified counterparts, appears to be the onlypractical solution. We agree with the 2000 FAO/WHOreport, however, that the criteria for safety assessmentsshould be made explicit and objective and thatdifferences in the application of substantial equivalence,for example in different Member States of the EuropeanUnion, need to be resolved (OECD, 2000). We welcomethe development of consensus documents for differentcrops by the OECD which will help to facilitate theuniform application of substantial equivalence. Werecommend that potential effects of the transformationprocess should continue be taken into consideration inthe safety assessment, and that the phenotypiccharacteristics to be compared between foods derivedfrom GM plants and their comparators should be defined.These will include, but may not be limited to,composition, nutritional value, allergenicity and toxicity. Itwill be important to define the choice of growingconditions of the comparative plants, the scope of thecomparisons, and the acceptable margins of measureddifferences in composition. It may not be necessary orfeasible to subject all GM foods to the full range ofevaluations, but those conditions which have to besatisfied should be defined.

In the future, safety assessments might make use of newprofiling techniques such as micro-array technology fordetailed studies of mRNA expression, quantitative two-dimensional gel electrophoresis and mass spectrometryfor protein analysis, and metabolomic analyses to look atchanges in all metabolites and metabolic intermediates.Application of such techniques to characterisedifferences between the GM crop and the appropriatecomparator should help provide a rigorous scientificbasis for hazard identification. However, muchdevelopment work remains to be done, in particular todetermine the utility of this approach in relation to thewide natural variation in composition between cropsgrown in different environments. Long-term research isrequired before these techniques can be applied to safetyassessments of GM and non-GM foods. We recommendthat research should be undertaken to develop suchtechnology and to define the ‘normal’ compositions ofconventional plants. We welcome the funding initiativesalready put in place by European Union Framework Vprogramme and the UK’s Food Standards Agency (FSA).We also recommend that the biotechnology industrycollaborate with academia and regulators to developtechniques and share reference data. This will helpensure that the new techniques are wisely applied andthat agreement is reached on interpretation of results.

As with genetic modification, conventional plantbreeding technology (which can involve chemical orradiation-induced mutagenesis or cross-specieshybridisation) might also cause rearrangements of thegenome, and therefore might also cause the activationof previously unknown toxins, anti-nutrients or allergens.Examples, though uncommon, include an insect-resistant line of celery proved to accumulate psoralen inresponse to light and thereby cause skin burns (Amesand Gold, 1999), and the Magnum Bonum potato linewhich accumulated toxic levels of solanine in coolweather (Van Gelder et al., 1988). This raises thequestion of whether the same safety assessment criteriashould be applied to conventionally modified foods as toGM foods.

The feasibility and value of studies in humans to assessthe health effects of GM foods have been considered bythe MRC’s expert group (2000). They concluded that thevalue of epidemiological studies in assessing the post-marketing effects on human health is limited. This isbecause there are no reasonably firm hypotheses aboutwhich human health end-points GM foods might affect,because individual exposure to GM foods will be difficultto assess, and because the level of consumption of GMfoods at the present time is very low. Randomisedcontrolled trials were considered to be feasible. Whilstthese were not suggested as a routine method ofassessing new foods, such studies could be used to satisfypublic concern at least about the short-term healtheffects of individual GM foods of nutritional importance.

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The Food Standards Agency has commissioned a two-year study to look at the feasibility of monitoringconsumption of GM foods; results of this work areexpected in 2003.

3 Possible effects of GM food on human nutrition

As described in the Introduction, one potential applicationof GM technology is to improve the nutritional quality ofcrops and thereby improve human health (for furtherinformation see MRC, 2000; Royal Society, 2000). In thecommercial market at present there are no GM foods thatare modified to enhance nutrition. Although GMtechnology offers the potential for beneficial changes inthe composition of a food, such changes need to beconsidered within the context of the overall diet. Goodhealth requires a balanced diet which contains all theessential nutrients in an optimal range of proportions.Studies of the effects of GM food on nutrition need to takeaccount of the effects of small changes that might resultfrom the consumption of a particular GM food in abalanced diet. Studies also need to be made of thepotential health effects in sub-groups of the populationthat have particularly high intakes or particularsusceptibilities. Although it is possible that geneticmodification might lead to unpredicted and harmfulchanges in the nutritional status of the food, such changesmight also occur in the course of conventional breeding(MRC, 2000).

Nutritional assessments are made as part of the safetyassessment of a GM food. Guidelines have been issued bythe European Commission Scientific Committee for Food(1997). The assessment reviews the composition of thenovel food, its preparation, and the role it is expected tohave in the diet. The novel food is compared to traditionalcounterparts and the significance of any differences isassessed; this may include the use of animal models toestablish some aspects of nutritional quality. Fullnutritional assessment may need to be made in humansubjects. Nutritional implications are assessed at ‘normal’and ‘maximum’ levels of consumption. Nutrientcomposition data take into account the effects of storage,further processing and cooking. Attention is paid to theparticular physiological characteristics and metabolicrequirements of vulnerable groups such as infants,children, pregnant and lactating women, the elderly andthose with chronic disease.

Although vulnerable groups are mentioned in the EuropeanCommission’s guidelines more detailed guidelines arerequired to cover experimental design, consider the form inwhich the food is provided, and consider the adequacy ofthe food in terms of energy and nutrients. Where necessary,

data from feeding studies should be included in theassessment. In animal studies, any changes in tissuestructure or metabolic function of various organs (liver,kidney, lungs, brain and cardiovascular organs) should beassessed. In human studies, measures of general health,development and psychological well being should beincluded (see section 2). We recommend that, in the case ofinfants, guidelines such as those described by theCommittee on Medical Aspects of Food and Nutrition policy(COMA, 1996) for nutritional assessment of infant formulasand more recently by Aggett et al. (2001) should beadopted for both novel and GM food. Labelling of novelfoods that provides nutritional information and guidancefor vulnerable groups is currently under consideration by theAdvisory Committee on Novel Foods and Processes(ACNFP).

Products that are designed to be consumed as a single foodover extended periods of time by those who are especiallyvulnerable should be investigated most rigorously. Theseinclude infant formulas and follow-on foods. Within the UK,infant formulas and follow-on foods are the responsibility ofthe Department of Health. To date no GM foods for use ininfant products have been submitted for approval, but it isexpected that approval of such foods would be referred viathe ACNFP to the Scientific Advisory Committee onNutrition.5 There is a lack of clarity about the interaction ofregulations on infant foods and GM foods. This needscareful examination to ensure that these two sets ofregulation are complementary and we recommend that theGovernment review the enforcement of these regulations.Commission Directive 91/321/EEC, which is currently underreview by the European Commission, covers infant formulasand follow-on foods. We recommend that the Commissionconsider the use of novel and GM foods in infant foods aspart of this review.

4 Possible allergic responses to GM foods

Food allergies occur in 1–2% of adults and 6–8% ofchildren (Metcalfe et al., 1996; Sampson, 1997),although severe allergic reactions (anaphylaxis) to foodsare relatively rare, occurring in approximately 3.2individuals per 100,000 people per year (Burks andSampson, 1997). As almost all known allergens areproteins, we restrict our discussion to protein products ofGM plants and not, for example, to highly refined oils,which pose little allergenic risk because processingremoves virtually all protein (Hourihane et al., 1997).

The introduction of a new gene into a plant, or a changein the expression of an existing gene, may cause thatplant to become allergenic. That is, it may induce allergicresponses in individuals who are already hypersensitive tothe allergen in question, or it may cause individuals

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5 The Scientific Advisory Committee on Nutrition (SACN) replaced the Committee on Medical Aspects of Food and Nutrition (COMA) in 2001.

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previously not allergic to the allergen to become so.Therefore known allergens should not be introduced intofood crops and every effort should be made to avoid this.There is at present no evidence that GM foods that arecommercially available cause any clinical manifestationsof allergenicity, and assertions to the contrary have notbeen supported by systematic analysis (Center for DiseaseControl, 2001). The allergenic risks posed by GM plantsare in principle no greater than those posed byconventionally-derived crops or by plants introduced fromother parts of the world, such as the introduction of kiwifruit into Europe. Nevertheless, it is important to considerpotential allergenic risks posed by GM plants and to placethem in the context of risks posed by introduced plantsand plants produced by conventional or organic means.There are already examples of such risks from non-GMcrops, such as allergens from fungal spores on mouldyhay, on cereal grains or on crops with high infestations offungal pathogens (this may occur in crops not treatedwith an appropriate fungicide). These have been shownto be potent inducers of asthma resulting in a conditioncommonly known as farmer’s lung.

Allergic sensitisation to a GM plant, as with aconventionally derived plant, could occur via the lungs(perhaps through inhaling pollen or dust created duringmilling) or through skin contact (for example, duringhandling), as well as via the gastrointestinal tractfollowing ingestion of foods. Occupational allergies toconventional plants can take the form of eitherimmediate hypersensitivity or delayed hypersensitivityreactions. The latter frequently occur as a consequence ofhandling plant materials and generally express themselvesas contact dermatitis. Of immediate hypersensitivityallergies to plants, those that involve inhalation ofparticulates are particularly common. These includeallergic diseases, such as baker’s asthma which resultsfrom inhalation of flour particles, and latex allergy whichis thought to arise from inhalation of the powder used tocoat latex gloves (to which some latex from the glovesbecomes associated). Those at risk from pollen includethe general population and, in particular, farm workers.Individuals involved in the harvesting of crops and in foodprocessing techniques that generate dusts are at risk ofsensitisation through both inhalation and skin contact.Therefore, in order to adequately assess any risks, it isimportant to evaluate the allergenic potential of GMplants through inhalation and skin contact as well as viaingestion.

Decision trees for assessing the allergenic risks of GMfoods have been developed by the International FoodBiotechnology Council in collaboration with theInternational Life Sciences Institute (1996) and mostrecently by FAO/WHO (2001a). This hierarchical approachincludes determining whether the source of theintroduced gene is from an allergenic plant, whether GMfoods react with antibodies in the sera of patients with

known allergies, and whether the product encoded bythe new gene has similar chemical and biologicalproperties to known allergens. It also involves animalmodels of allergy that can be used to screen geneticallymodified foods. Ongoing research to develop moreadequate animal models for allergenicity testing willincrease the assurance of this process still further. Thecurrent practice of screening described above means anyfood that is allergenic is unlikely to reach the market.

However, one shortcoming in current screening methods,which applies to conventional foods as well as to GMfoods, is that there is no formal assessment of the allergicrisks posed by inhalation of pollens and dusts. Wetherefore recommend that current decision trees beexpanded to encompass inhalant as well as food allergies.In the longer term, should GM foods be re-introducedinto the market in the UK, we suggest that the FoodStandards Agency considers whether post-marketingsurveillance should be part of the overall safety strategyfor allergies, especially of high-risk groups such as infantsand individuals in ‘atopic’ families. The collection ofproperly collated longitudinal public health data is one ofthe only ways to identify rare allergies, to any food, in thepopulation. Whether such monitoring is feasible for GMfood is not yet clear; it is discussed in section 2.

5 Potential effects on human health resulting from the use of viral DNA in plants

Two types of plant viral DNA sequence are commonlyused in the construction of genes inserted into GM plants.The first includes ‘promoters’, usually short sequences ofDNA that are required for the expression (‘switching on’)of all genes. In GM plants the inserted gene is oftencombined with a promoter derived from the cauliflowermosaic plant virus (the so-called CaMV 35S promoter).The second type of sequence comprises genes thatencode the outer protective coat proteins of viruses,which when expressed in the host plant interfere withinfecting viruses and confer resistance. However, to dateno commercial GM crops using this second type of geneare grown.

It has been suggested that the introduction of viral DNAsequences into GM plants could produce new virusesthrough recombination (‘gene exchange’), either with theremnants of viral DNA sequences that are commonlyfound in the genomes of all species or with naturallyinfecting plant and animal viruses. There are, however,natural barriers to this process (Aaziz & Tepfer, 1999;Worobey & Holmes, 1999). Most importantly, virusesgenerally infect a limited range of species and althoughthere are genetic similarities between some viruses thatinfect plants and animals, suggesting that they may havejumped between these kingdoms in their evolutionarypast, such events must be rare; the gene sequences of

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plant and animal viruses are usually so dissimilar thatplant viruses cannot infect animal cells. Indeed, there isonly one reported case of recombination between a plantand an animal virus (Gibbs & Weiller, 1999) and althoughhumans have eaten virally infected plants for millennia,there is no evidence that this has created new viruses byrecombination or has caused serious disease. In theextremely unlikely case of recombination producing anovel virus, this would probably be defective, becausemost recombination events disrupt functional genes.These sub-optimal viruses would be removed from thepopulation by natural selection, as is the case for mostrecombinant viruses produced naturally. Though unlikely,there is a potential risk that the use of complete viralgenes to create transgenic plants resistant to viralinfections may create new plant viruses. These novelrecombinants could result in plant diseases but thisprocess has not been documented to date.

Concern has been expressed over the use of the CaMV35S promoter (Ho et al., 1999; Ho et al., 2000) becausethis functions in a wide variety of species, including somevertebrates, and has been shown to undergorecombination in laboratory studies (Kohli et al., 1999;Morel & Tepfer, 2000). However, the promoter sequencesused in GM plants are a normal constituent of commonplant viruses that frequently infect food plants and thereis no evidence that these sequences have been involved inthe creation of new viruses. In the case of cauliflowermosaic virus (CaMV), studies have shown that 10% ofcabbages and 50% of cauliflowers are infected with thevirus (cited in Hull et al., 2000) and CaMV has never beenshown to cause disease in humans or to recombine withhuman viruses. It is also highly unlikely that the CaMV 35Spromoter could reactivate the remnants of viruses that areintegrated into the genomes of most species. Althoughthere is a great variation among species, most integratedviruses are inert because they contain multiple mutationsand cannot be reactivated by the simple acquisition of theCaMV 35S or any other promoter. In humans,approximately 1% of total DNA is composed ofintegrated viruses, but only one of these viruses, HERV-K,may be active (Turner et al., 2001).

It has also been suggested that genetic modification mayactivate transposable elements already present in thehuman genome. Like viruses, transposable elements – shortDNA sequences that have the ability to move around thegenomes of eukaryotes and bacteria, increasing in numberas they do so – have been commonly associated with hostorganisms since early in evolution. Because of their mobility,transposable elements have the ability to insert themselvesinto and thereby damage host genes and thus potentiallylead to pathological effects such as tumours (Hiom et al.,1998). These elements comprise up to 40% of the totalDNA of higher animals and plants. There is strong evidencethat transposable elements have repeatedly beentransferred among different species during evolution (Capy

et al., 1994; Kidwell, 1993; Silva & Kidwell, 2000; RoyalSociety, 2001). Consequently, it seems improbable that theaccidental mobilisation of transposable elements during theconstruction and use of GM plants would have any broadimpact on the biology of humans, animals or plantscompared with what takes place under natural conditions.

We conclude that the risks to human health associatedwith the use of specific viral DNA sequences in GM plantsare negligible.

6 The fate of GM plant DNA in the digestive system

One concern associated with GM foods is the possibilitythat genes introduced into the plant might becomeincorporated into the consumer’s genetic make-up. TheRoyal Society 1998 report concluded that there was noevidence for transfer of intact genes to humans eitherfrom bacteria in the gut or from foodstuffs, despite dailyconsumption of DNA in the diet. Since 1998 a number ofpapers have been published on this topic, and these arereviewed below.

Most ingested DNA is rapidly broken down in theintestinal tract (see Royal Society, 1998, section 3.4),although it can persist for some time in saliva (Schubbertet al., 1994). Nevertheless, low levels of uptake of gene-sized DNA into cells of the gastrointestinal tract havebeen detected (Duggan et al., 2000; Schubbert et al.,1996; Doerfler, 2000; Einspanier et al., 2001; Flachowsky,2000). The uptake may be due to specialised cells of thelining of the gastrointestinal tract (so-called M-cells),which actively sample gut contents as part of the processof protecting the body from infection (Nicoletti, 2000).This will normally have no biological consequencesbecause the DNA will be degraded in the cell. There havebeen no reports of transgenes detected in the cells ofcows fed GM maize, although the presence of plantchloroplast genes, which are present at about 1000 timeshigher concentration than any transgene, could bedetected (Einspanier et al., 2001; Flachowsky, 2000). Thissuggests that DNA present in food can find its way intomammalian cells at some low frequency. In the unlikelyevent that the DNA is recombined into a hostchromosome, the probability that it will exert anybiological effect on that cell is very low. The likelihood ofany biological consequence for the whole organism iseven more remote. There is no obvious way that a cellwith altered biological properties due to foreign DNAuptake could transmit this effect to other cells or affectthe germ-line of the host organism.

Any untoward consequences of DNA consumption wouldprobably be due to ingestion and transmission of intactautonomous genetic elements rather than to transfer offragments of DNA. Such elements might include the

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complete genomes of viruses or transposable elements,or large pieces of DNA from normal intestinal microbialflora. Indeed, there is strong evidence that gene transferevents of this sort have occurred during evolution(Kidwell, 1993; Capy et al., 1994). In particular,transposable elements, which comprise a large part of themammalian genome, have close relatives in distantgenera, while some transposable elements derived fromnematodes and insects have been shown to transposefollowing introduction into mammalian cells in thelaboratory (Luo et al., 1998; Schouten et al., 1998).Uptake of fragments of transgenic DNA from geneticallymodified food should therefore be seen in the context ofan ongoing biological process involving intactautonomous genetic elements, which has had nodetectable negative consequences.

An alternative scenario might involve the entry of a novelDNA sequence into gastrointestinal microbial flora, whereit would replicate and persist in its new host and deliver aproduct into its surroundings. This has occurredthroughout mammalian evolution and has apparentlyhad little biological consequence (Stanhope et al., 2001).The use of antibiotic resistance genes as a marker forselection of GM plants has resulted in the concern thatgenes may be transferred into the bacteria present in thestomach of the consumer; this would make the bacteriaresistant to antibiotics. This was discussed in the RoyalSociety 1998 report, where we supported theGovernment’s advisory bodies in their conclusion thatsuch markers should not continue to be used in thehuman or animal food chain.

All these observations need to be viewed in the context ofa normal diet, which for humans and animals compriseslarge amounts of DNA. For example, a 600 kg cow isestimated to ingest about 600 mg of DNA a day (Beeverand Kemp, 2000) and indeed digestion of DNA in thegastrointestinal tract may make a significant contributionto nutrition. This DNA will be derived not only from thecells of food sources, but also from any contaminatingmicrobes and viruses. Given the very long history of DNAconsumption from a wide variety of sources, it is likelythat such consumption poses no significant risk to humanhealth, and that additional ingestion of GM DNA has noeffect. Consequently, it is unlikely that the ingestion ofwell-characterised transgenes in normal food and theirpossible transfer to mammalian cells would have anysignificant deleterious biological effects.

7 Conclusions and recommendations

We recognise the valuable potential and current impactof plant biotechnology on the quality of food and itsimportance in the development of new crops. We supportcontinuation of research on GM plants as valuable in itselfand as the only way to assess the true potential of GM

plants. However, the Royal Society recognises theconcerns expressed with regard to the technology andbelieves that these should continue to be addressedthrough collaboration and dialogue betweenindustrialists, public sector scientists, regulatoryauthorities and non-government organisations. It isimportant that the public debate about GM food takesaccount of wider issues than the science alone, but wewish to stress the importance of informing debate withsound science.

We agree with the FAO/WHO 2000 consultation that thecriteria for safety assessments of GM foods should bemade explicit and objective and that differences in theapplication of substantial equivalence, for example indifferent Member States of the European Union, need tobe resolved (OECD, 2000). Therefore we welcome thedevelopment of consensus documents for different cropsby the OECD, which will help to facilitate the uniformapplication of substantial equivalence. We believe thatthe risks to human health associated with the use ofspecific viral DNA sequences in GM plants are negligible.Given the very long history of DNA consumption from awide variety of sources, it is likely that such consumptionposes no significant risk to human health, and thatadditional ingestion of GM DNA has no effect.

We have the following recommendations.

• Safety assessments should continue to considerpotential effects of the transformation process. Thephenotypic characteristics to be compared betweenfoods derived from GM plants and their conventionalcounterparts should be defined. It may not benecessary or feasible to subject all GM foods to the fullrange of evaluations but those conditions that have tobe satisfied should be defined.

• Research should be undertaken to develop modernprofiling techniques and to define the ‘normal’compositions of conventional plants. The workinggroup welcomes the funding initiatives already put inplace by the European Union Framework Vprogramme and the UK’s Food Standards Agency(FSA).

• The biotechnology industry should collaborate withacademia and regulators to develop and share suitablereference data sets. This will help ensure that the newtechnologies are wisely applied and that agreement isreached on the appropriate interpretation of the datathat they will generate.

• The UK Government should review the enforcement ofthe regulations on infant foods and GM foods toensure these regulations are complementary.

• The European Commission should consider the use ofnovel and GM foods in infant foods as part of itsreview of Directive 91/321/EEC that covers infantformulas and follow-on foods.

• The current decision trees used to assess allergy should

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be expanded to encompass inhalant as well as foodallergies.

• In the longer term, should GM foods be re-introducedinto the market in the UK, we suggest that the FoodStandards Agency considers whether post-marketingsurveillance should be part of the overall safetystrategy for allergies, especially of high-risk groupssuch as infants and individuals in ‘atopic’ families.

8 References

Aaziz R & Tepfer M (1999). Recombination in RNA virusesand in virus-resistant transgenic plants. Journal ofGeneral Virology 80,1339–1346

Aggett P J, Agostino C, Goulet O, Hernell O, Koletzko B,Lafeber H L, Michaelson K F, Rigo J & Weaver L T (2001).The nutritional and safety assessment of breast milksubstitutes and other dietary products for infants: acommentary by the ESPGHAN Committee on Nutrition.Journal of Pediatric Gastroenterology and Nutrition 32,256–258

Ames B N & Gold L S (1999). In Fearing Food (eds Morris Jand Bate R) 18–38. Butterworth Heinemann: Oxford

Beever D E & Kemp C F (2000). Safety issues associated withDNA in animal feed derived from genetically modified crop:A review of scientific and regulatory procedures. NutritionAbstracts and Reviews 70, 175–182

Burks A W & Sampson H A (1997). Anaphylaxis and foodallergy. In Food Allergy: Adverse Reactions to Food andFood Additives (eds Metcalfe D D, Sampson H A & SimonR) 245–257. Blackwell Science: Cambridge, MA

Capy P, Anxolabehere D & Langin T (1994). The strangephylogenies of transposable elements: are transfers theonly explanation? Trends in Genetics 10, 7–12

Center for Disease Control (2001): Investigation ofHuman Health Effects Associated with Potential Exposureto Genetically Modified Corn: A Report to the US Foodand Drug Administration from Center for Disease Controland Preventionhttp://www.cdc.gov/nceh/ehhe/Cry9cReport/cry9creport.pdf

COMA (1996). Guidelines on the Nutritional Assessmentof Infant Formulas. Report of the Working Group on theNutritional Assessment of Infant Formulas of theCommittee on Medical Aspects of Food and NutritionPolicy (COMA). Report on Health and Social Subjects No47. DH: HMSO

Custers R (2001). Safety of genetically engineered crops.(ed Rene Custers R). Belgium: VIB

http://www.vib.be/downloads/bioveiligheidseducatie/report.pdf`

Doerfler W (2000). Foreign DNA in mammalian systems.Wiley-VCH Verlag GmbH

Duggan P S, Chambers P A, Heritage J & Forbes J M(2000). Survival of free DNA encoding antibioticresistance from transgenic maize and the transformationactivity of DNA in ovine saliva, ovine rumen fluid andsilage effluent. FEMS Microbiology Letters 191, 71–77

Einspanier R, Klotz A, Kraft A, Aulrich K, Poser R, SchwageleF, Jahreis G & Flaschowsky G (2001). The fate of forage plantDNA in farm animals; a collaborative case studyinvestigating cattle and chicken fed recombinant plantmaterial. European Food Research Technology 212, 2–12

European Commission Scientific Committee for Food(1997). Opinions on the assessment of novel foods111/5915/97. EU: Brussels

Ewen S W B & Pusztai A (1999). Effects of diets containinggenetically modified potatoes expressing Galanthusnivalis lectin on rat small intestine. The Lancet 354, 1353-1354

FAO/WHO (1996). Biotechnology and food safety. Reportof a joint Food and Agriculture Organisation/WorldHealth Organisation Consultation. FAO/WHO: Rome

FAO/WHO (2000). Safety aspects of genetically modifiedfoods of plant origin. Report of a Joint Food andAgriculture Organisation/World Health OrganisationConsultation. FAO/WHO: Rome

FAO/WHO (2001a). Evaluation of allergenicity ofgenetically modified foods. Report of a Joint Food andAgriculture Organisation/World Health OrganisationConsultation. FAO/WHO: Rome

FAO/WHO (2001b). Genetically modified organisms,consumers, food safety and the environment. Food andAgriculture Organisation Ethics Series 2. FAO/WHO: Rome

Flachowsky G (2000). GMO in animal nutrition – results ofexperiments at our Institute. Proceedings from the 6thInternational Feed Production Conference, Piacenza.291–307

Gasson M & Burke D (2001). Scientific perspectives onregulating the safety of genetically modified foods.Nature Reviews Genetics 2, 217-222

Gibbs M J & Weiller G F (1999). Evidence that a plant virusswitched hosts to infect a vertebrate and then recombinedwith a vertebrate-infecting virus. Proceedings of theNational Academy of Sciences USA 96, 8022–8027

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Hiom K, Melek M & Gellert M (1998). DNA transpositionby RAG1 and RAG2 proteins: a possible source ofoncogenic translocations. Cell 94, 463–470Ho M W, Ryan A & Cummins J (1999). Cauliflower mosaicvirus promoter – a recipe for disaster. Microbial Ecology inHealth and Disease 10, 33–59

Ho M W, Ryan A & Cummins J (2000). Hazards oftransgenic plants containing the cauliflower mosaic viruspromoter. Microbial Ecology in Health and Disease 12,6–11

Hourihane J O, Bedwani S J, Dean T P & Warner J O(1997). Randomised, double blind, crossover challengestudy of allergenicity of peanut oils in subjects allergic topeanuts. British Medical Journal 314,1084–1088

Hull R, Covey S & Dale P (2000). Genetically modifiedplants and the 35S promoter: assessing the risks andenhancing the debate. Microbial Ecology in Health andDisease 12, 1–5

International Life Sciences Institute (1996). The safetyassessment of novel foods; guidelines prepared by ILSIEurope novel food task force. ILSI, European Branch:Brussels

James C (2000). Global status of commercialised transgeniccrops. ISAAA Briefs No.21: Preview. ISAAA: Ithaca, NY

Kidwell M (1993). Lateral transfer in natural populationsof eukaryotes. Annual Review of Genetics 27, 235–256

Kohli A, Griffiths S, Palacios N, Twyman R M, Vain P, LaurieD A & Christou, P (1999). Molecular characterization oftransforming plasmid rearrangements in transgenic ricereveals a recombination hotspot in the CaMV 35Spromoter and confirms the predominance ofmicrohomology mediated recombination. The PlantJournal 17, 591–601

Luo G, Ivics Z, Izsvák Z & Bradley A (1998). Chromosomaltransposition of a Tc1/mariner-like element in mouseembryonal stem cells. Proceedings of the NationalAcademy of Sciences USA 95, 10769–10773

Metcalfe D D, Astwood J D, Townsend R, Sampson H A,Taylor S L & Fuchs R L (1996). Assessment of the allergenicpotential of foods from genetically engineered cropplants. Critical Reviews in Food Science and Nutrition36(S), S165–186

Millstone E P, Brunner E J & Mayer S (1999). Beyond‘substantial equivalence’. Nature 401, 525–26

Morel J-B & Tepfer M (2000). Pour une évaluationscientifique des risques: le cas du promoteur 35S.Biofutur 201, 32–35. (English translation available)

MRC (2000). Report of a Medical Research Council expertgroup on genetically modified (GM) foods. MedicalResearch Council: LondonNicoletti C (2000). Unsolved mysteries of intestinal Mcells. Gut 47, 735–739

Nuffield Council on Bioethics (1999). Geneticallymodified crops: the ethical and social issues. The NuffieldFoundation: London

OECD (1993). Safety evaluation of foods produced bymodern biotechnology – concepts and principles.Organisation for Economic and CooperativeDevelopment: Paris

OECD (2000). Report of the task force for the safety ofnovel foods and feeds. Organisation for Economic andCooperative Development: Paris

Royal Commission on Environmental Pollution (1998).21st report: Setting Environmental Standards. HMSO:Norwich

Royal Society (1998). Genetically modified plants for fooduse. Royal Society: London

Royal Society (1999). Regulation of biotechnology in theUK. Royal Society: London

Royal Society (1999). Review of data on possible toxicityof GM potatoes. Royal Society: London

Royal Society (2000). Transgenic plants and worldagriculture. Royal Society: London

Royal Society (2001). The use of genetically modifiedanimals. Royal Society: London

Royal Society of Canada (2001). Elements of Precaution:Recommendations of the regulation of foodbiotechnology in Canada. Royal Society of Canada:Ottawa

Sampson H A (1997). Immediate reactions to foods ininfants and children. In Food Allergy: Adverse Reactionsto Food and Food Additives (eds Metcalfe D D, SampsonH A & Simon R A) 169–182. Blackwell Science:Cambridge, MA

Schouten G J, van Luenen H G A M, Verra N C V, Valerio D& Plasterk R H A (1998). Transposon Tc1 of the nemotodeC.elegans jumps in human cells. Nucleic Acids Research26, 3013–3017

Schubbert R, Lettmann C & Doerfler W (1994). Ingestedforeign phage M13 DNA survives transiently in thegastrointestinal tract and enters the bloodstream of mice.Molecular & General Genetics 242, 495–504

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Schubbert R, Renz D, Schmitz B & Doerfler W (1996).Foreign M13 DNA ingested by mice reaches peripherallymphocytes, spleen and liver via the intestinal wall mucosaand can be covalently linked to mouse DNA. Proceedings ofthe National Academy of Sciences USA 94, 961–966

Silva J & Kidwell M (2000). Horizontal transfer andselection in the evolution of P elements. MolecularBiology Evolution 17, 1542–1557

Stanhope M J, Lupas A, Italia M J, Koretke K K, Volker C &Brown J R (2001). Phylogenetic analyses do not supporthorizontal gene transfers from bacteria to vertebrates.Nature 411, 940–944

Turner G, Barbulescu M, Su M, Jensen-Seaman M I, KiddK K & Lenz J (2001). Insertional polymorphisms of full-length endogenous retroviruses in humans. CurrentBiology 11, 1531–1535

Van Gelder W M J, Vinke J H & Scheffer J J C (1988).Steroidal Glycoalkaloids in tubers and leaves of solanumspecies used in potato breeding. Euphytica 38, 147–158

Worobey M & Holmes E C (1999). Evolutionary aspects ofrecombination in RNA viruses. Journal of General Virology80, 2535–2544

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Appendix 1 Press Release (Issued 13 March 2001)

The Royal Society is undertaking an independent studyinto human health issues surrounding GM plants for fooduse, it was announced today. In its widely acclaimed 1998report Genetically modified plants for food use , the RoyalSociety found that the use of GM organisms has thepotential to offer real benefits in agricultural practice,food quality nutrition and health. However it did findsome uncertainties: ‘The current system of relying onidentification of known allergens in the GM plant,coupled with the reliance on “substantial equivalence”,may result in potential allergenicity problems beingimpossible to predict if there are no data available on thesubstances in question, particularly since mechanisms ofallergenicity are often poorly understood’. Itrecommended ‘that any over-arching body analyses thecurrent regulations, giving particular attention toconsideration of whether long-term animal feedingstudies are necessary to provide greater information onallergenicity or toxicity’.

Since the 1998 report there has been considerable newresearch, so the Royal Society is convening a working groupof 10 scientists in order to update its 1998 report. Theworking group will advise on any policy implications andissue a report later this year. Dr Jim Smith FRS, the Chairmanof the working group, said ‘There has been much publicconcern and debate in the media about possible adversehealth effects of GM food. The Royal Society wants tofacilitate the debate on this issue by providing the public andpolicy makers with an up-to-date and independentoverview of the scientific evidence in the area’.

The study will consider evidence that has been collectedsince the publication of the Society’s last report inSeptember 1998. We welcome submissions frominterested parties who have scientific evidence theywould like us to consider in our study by 3 April 2001.Evidence received by 3 April will be examined by theworking group at its first meeting later in April. We aim topublish the report in late summer, so have a fairly tighttimetable. If you would like to submit written evidencebut cannot do so by 3 April, please let us know. We mayalso invite some of those submitting written evidence topresent their evidence in person to the working group.

In the study the working group will look at:

• Potential risks to human health resulting from the useof viral DNA in plants

• Prospective implications for human nutrition• Potential problems with allergenicity of GM plants for

food use• Fate of DNA in the digestive system• The use of substantial equivalence in the risk

assessment of GM food.

We welcome comments on any other issues to do withthe human health aspects of GM plants not covered bythe above that we should be considering at this time.

The Royal Society has issued several reports on GM plantsfor food use, including Genetically modified plants forfood use (1998), Review of data on possible toxicity ofGM potatoes (1999) and Regulation of biotechnology inthe UK (1999).

References can be found in Section 8.

Appendix 2 List of respondees to the study

The following organisations and people responded to thecall for evidence:

Academy of Medical SciencesAnaphylaxis Campaign Food Standards AgencyFriends of the EarthGreenpeaceInstitute of Science in SocietyMedical Research CouncilMonsantoNew Zealand Life Sciences NetworkRoyal College of PhysiciansScientists for Global ResponsibilitySoil AssociationSyngenta

Luke Anderson (e-mail respondent)Professor Janet Bainbridge, University of Teeside,

Middlesbrough, UKDr Judy Carman, Flinders University, South AustraliaDr Patricia Elliot (e-mail respondent)Dr Brian Fenton, Scottish Crops Research Institute,

Dundee, UKMaurice Lex, Directorate-General European Commission,

Brussels, BelgiumDr Ulrich Loening, Centre for Human Ecology, Edinburgh,

UKDr Mark Tepfer, Institut National de la Recherche

Agronomique-Versailles, France

In addition oral evidence sessions were conducted with:

Professor Janet Bainbridge, Chair of Advisory Committeeon Novel Foods and Processes (ACNFP)

Adrian Bebb and Peter Riley, Friends of the EarthCamilla Beech, Biotechnology Regulatory Affairs,

SyngentaDr Andrew Cockburn, Director of Scientific Affairs

(Europe/Africa), MonsantoProfessor Mike Gale FRS, John Innes Centre, and Dr Bill

Angus, Nickerson’s SeedsSue Hattersley, Food Standards AgencyDr Erik Millstone, Reader in Science Policy at SPRU,

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University of SussexDoug Parr, Chief Scientist, Greenpeace UK, and Janet

Cotter, Research Laboratory, Greenpeace International

Appendix 3 Legislation

Legislation governing the regulation of geneticmodification is set by the European Union andimplemented at national level by individual nationalregulators.

At EU level, there are two directives, which cover releaseand marketing (Directive 90/220/EEC) and use incontainment (Directive 90/219/EEC) of geneticallymodified plants. A new, updated Directive 2001/18/EC onthe deliberate release of genetically modified organisms(GMOs) will come into effect in October 2002 and willintroduce mandatory information to the public andgeneral rules on mandatory labelling and traceability at allstages of the placing of GMOs on the market. Productswhich are not GM but are derived from GMOs areassessed for safety in accordance with the requirementsof the EC Novel Foods Regulation (258/97) which sets outrules for authorisation and labelling of novel foodproducts containing, consisting of or produced fromGMOs.

Further to the updated Directive 2001/18/EC, newregulations on GMOs have been proposed recently (July2001) by the European Commission and are currentlyunder examination by the European Parliament andCouncil of Ministers. The proposed regulation on GMfood and feed establishes detailed rules for labelling,replaces the existing approval procedures for GM foodsand introduces for the first time specific rules for theapproval and labelling of GM animal feed. In comparisonwith the labelling system already in place (foodsconsisting of or containing GMOs are required to belabelled), all foods produced from GMOs irrespective ofwhether there is DNA or protein of GM origin in the finalproduct and all genetically modified feed will be labelled.Food produced with the help of enzymes from GMsources and food from animals fed GM feed will notrequire labelling. The proposal also acknowledges thatadventitious contamination cannot be totally avoided andallows for GMOs that have been favourably assessed bythe EU Scientific Committee, but not yet fully approved,to be present in food or feed up to a maximum of 1%.The Commission’s proposal places the new EuropeanFood Authority, rather than individual Member States, atthe centre of the approval process, but Member Stateswill take the final decisions on applications. The proposedregulation on GM traceability and labelling aims toelaborate on the requirements in Directive 2001/18/EC totrace live GMOs, and to extend them to derived productsthroughout the supply chain.

In the UK, the Genetically Modified (Contained Use)Regulations 2000 require all work with GM plants to besubject to a risk assessment for effects on human healthand safety. As part of this, the GM plant is assessed on thebasis of whether it is more likely to cause harm to humansthan the non-modified parental organism. Any plant thatposes a greater risk of harm to human health and safetythan the non-modified equivalent must be notified to theHealth and Safety Executive under the GeneticallyModified (Contained Use) Regulations 2000 before workcan commence. The Environmental Protection Act 1990(EPA1990) requires risk assessment of all GMOs. TheGenetically Modified Organisms (Risk Assessment)(Records and Exemptions) Regulations 1996 are madeunder the EPA1990. The EPA1990, together with theassociated Regulations, requires that anyone keeping GMplants must carry out an assessment of the risks to theenvironment. The assessment must include hazardsarising from the escape of the plants, and the risk of suchhazards occurring. The assessment enables the keeper ofthe GM plant to put in place suitable containmentmeasures to minimise damage to the environmentresulting from escape.

GMOs may not be released into the environment unlessthey have received consent under the GeneticallyModified Organisms (Deliberate Release) Regulations1992 (as amended 1995 and 1997). Applications forconsent must describe the GMO, and give details of theproposed release, and must contain a full risk assessment.Applications are submitted to the Department ofEnvironment, Food & Rural Affairs (DEFRA), and reviewedby both DEFRA and other Government departments.Each application is also reviewed by an independentcommittee of experts, the Advisory Committee onReleases to the Environment (ACRE). ACRE conductsenvironmental risk assessment ensuring compliance withEC Directive 90/220/EEC by reviewing all applications torelease and market GMOs.

The Food Standards Agency (FSA) is responsible for allaspects of the safety of GM foods. It is the UK foodscompetent authority, and therefore the UK body directlyresponsible for the approval of all novel foods, under theNovel Foods Regulation (EC Regulation 258/97). It isassisted in this by the Advisory Committee on Novel Foodsand Processes (ACNFP), an independent body of expertscontaining consumer representatives that assesses thesafety of novel foods and processes used in foodproduction. The safety assessment is based on theconcept of substantial equivalence, which involves acomparison of a GM food with its conventionalequivalent and a detailed examination of any differences.There are a number of other expert bodies, which advisethe FSA, for example, advice on food labelling is providedby the Food Advisory Committee (FAC) and advice ontoxicology by the Committee on Toxicology (COT).

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Recommendation

Antibiotic resistance markers, if used in future,should be removed at an early stage in developmentof the GM plant, and where possible, alternativemarker systems should be used.

We strongly support mechanisms by whichconsumers can be informed about developments inbiotechnology, including the labelling of foodscontaining GM material where the equivalence of afood is substantially changed, according toestablished criteria and provided such labelling isappropriately monitored. We recommend that theGovernment departments continue to work with theEuropean Commission and all interested partiestowards increased clarity in the labelling regulations.

We recommend that an over-arching body or ‘super-regulator’ should be commissioned by theGovernment to span departmental responsibilitiesand have an ongoing role to monitor the wider issuesassociated with the development of GM plants. Inaddition, the proposed Food Standards Agencymight have a role to play.

Appendix 4 Recommendations from the Royal Society 1998 report Genetically modified plantsfor food use

Current position

In 1998 the Government’s advisory committees onGM crops (the Advisory Committee on Releases intothe Environment (ACRE) and the Advisory Committeeon Novel Foods and Processes) had both maderecommendations to this effect.

The ACRE guidelines on Best Practice in GM cropdesign discuss the alternative marker systemsavailable.http://www.defra.gov.uk/environment/acre/bestprac/guidance/index.htm

New rules on labelling and tracing of GMOs haverecently been proposed by the European Commission(25 July 2001). The new system meets the requests byMember States Governments, the EuropeanParliament and consumer organisations, and hasbeen drafted in close dialogue with all stakeholdersand Member States. The proposals are subject to co-decision with the European Parliament and Counciland should enter into force in 2003 at the latest.These rules will provide consumers with informationby labelling all food and feed consisting of,containing or produced from a GMO. The labellingprovisions in respect of food and feed will bereviewed after two years of operation.http://europa.eu.int/comm/food/index_en.html

However the UK’s Food Standards Agency (FSA) hascriticised these proposals; it is not convinced they areenforceable, practical and affordable. Instead the FSAsuggests maintaining the current labelling rules butsupplementing these with the introduction of aprovision of ‘GM-free’ labelling.http://www.foodstandards.gov.uk/press_releases/statements/st010921.htm

In 1999 the Government reviewed its advisory andregulatory framework on biotechnology. It concludedthat a broader approach was needed for strategicissues. The Agriculture and EnvironmentBiotechnology Commission (AEBC) forms part of thenew strategic framework. It will look at the broadpicture taking ethical and social issues into account aswell as the science. The Commission will offerstrategic advice to Government on biotechnologyissues which impact on agriculture and theenvironment. It will liase closely with but notduplicate the work of the FSA which includes withinits responsibilities all aspects of the safety and use ofgenetically modified food and animal feed.http://www.foodstandards.gov.uk/index.htmhttp://www.aebc.gov.uk/aebc/index.htm

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Recommendation

We recommend that the current regulations areanalysed, with particular attention to whetherallergenicity and toxicity of GMOs receive adequateconsideration

Current position

The Medical Research Council report on GM foods(MRC, 2000) concluded that mechanisms of foodallergy should be the subject of further research andthat this would facilitate the design and developmentof novel approaches for the identification andcharacterisation of potential protein allergens. TheMRC has called for research proposals on foodallergenicity in relation to GM foodstuffs.http://www.mrc.ac.uk/gmfood.html

A FAO/WHO Expert Consultation evaluatedallergenicity of GM foods in January 2001(FAO/WHO, 2001a). A new decision tree forassessment of allergic potential of foods has beensuggested. In addition the consultation concludedthat further research is needed on the developmentand validation of suitable animal models andprocedures for the assessment of allergenicity offoods derived from biotechnology.http://www.fao.org/es/ESN/gm/allergygm.pdfReferences can be found in Section 8.

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Appendix 5 Glossary

Allergen any substance that causes anallergic reaction.

Anaphylaxis an acute allergic reaction oftissue due to exposure to apreviously encountered allergen

Atopic pre-disposition to allergicresponse, usually inherited

Chromosome a large DNA molecular chain inthe cell along which genes arelocated

DNA deoxyribonucleic acid, which ispresent in almost all living cellsand contains informationcoding for cellular structure,organisation and function

Embryo rescue two species which would notnaturally hybridise are crossed,thereby resulting in an non-viableembryo. The embryo is removedfrom the plant and allowed todevelop further in vitro

Eukaryote an organism having cells eachwith a nucleus within which thegenetic material is contained.The cells of higher plants,animals, fungi, protozoa andmost algae are eukaryotic

Expression not all genes are active. When agene is read and the product ofthe gene (always including RNAand usually a protein) isproduced, the gene is said to beexpressed

Gene the basic unit of heredity; anordered sequence of nucleotidebases, comprising of a segmentof DNA. A gene may contain thesequence of DNA that encodesone protein chain

Genome the entire chromosomal geneticmaterial of an organism

Metabolomic the study of the complement ofmetabolites present in a singlecell/tissue under specifiedconditions

Mutagenesis the process of an agentpromoting mutation

Phenotypic the appearance or othercharacteristics of an organism,resulting from the interaction ofits genetic constitution with theenvironment

Promoter a region of DNA involved inbinding the enzyme thatsynthesizes RNA from the DNA

Recombination the rearrangement, for exampleby crossing over, of nucleic acidmolecules to produce newsequences

RNA ribonucleic acid; similar instructure to DNA, plays animportant role in proteinsynthesis and other chemicalactivities of the cell. Manyviruses are composed entirely ofRNA

Transgenic adjective describing anorganism in which a foreignDNA gene (a transgene) isincorporated into its genome

Transposable element small piece of DNA carrying agene and other information,that allows it to integrate intomany chromosomal positionswithin the genome

The following online dictionaries contain further definitions of terms:

http://www.fao.org/DOCREP/003/X3910E/X3910E00.htmhttp://www.hon.ch/Library/Theme/Allergy/Glossary/allergy.htmlhttp://www.sciencekomm.at/advice/dict.html

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Response to the Policy Commission on the future offarming and food. (4 page response to the PolicyCommission, 22/01, October 2001)*

Response to the consultation on DEFRA’s aims andobjectives. (2 page response to DEFRA consultation,21/01, September 2001)*

Royal Society response to PIU Energy projectscoping note. (5 page response to cabinet officeconsultation, 20/01, September 2001)*

The role of land carbon sinks in mitigating globalclimate change (2 page summary, 11/01, July 01, ISBN 085403 561 3 and 32 page document, 10/01, July 01,ISBN 0 85403 562 1)*

European Commission’s white paper ‘Strategy for afuture chemicals policy’ (5 page response to the inquiryby the House of Lords European Union Committee,19/01, July 2001)*

The second stage of the quinquennial review of theResearch Councils (17 page response to OSTconsultation 13/01, July 01)*

Draft code of practice for scientific advisorycommittees (3 page response to OST consultation14/01, July 01)*

Investigating the use of animals in scientificresearch (3 page response to call for evidence by theHouse of Lords Animals in Scientific ProceduresCommittee, June 2001 Professor PPG Bateson FRS)*

Stem cells research-second update (4 page response tothe inquiry by the House of Lords Science and TechnologyCommittee 09/01, June 2001 ISBN 0 85403 560 5)*

Transmissible spongiform encephlopathies (11 pagestatement 08/01, 5 June 2001)*

The health hazards of depleted uranium munitions,Part 1(88 page document 06/01,22 May 2001, £17.50ISBN 0 85403 3540)*The health hazards of depleted uranium munitions,Part 1(2 page summary 07/01,22 May 2001)*

The use of genetically modified animals (46 pagedocument 05/01, 21 May 2001, ISBN 0 85403 556 7)*

The Science of Climate Change (2 page joint statementfrom 16 scientific academies, 17 May 2001)*

Quinquennial Review of Royal Botanic Gardens, Kew(4-page response to MAFF’s public consultation,document 04/01, submitted 6 April 2001)*

Genetics and Insurance (4-page response to the inquiryby the House of Commons Science and TechnologyCommittee, 03/01, March 2001)*

Cost/Benefit Assessment and the Animals (ScientificProcedures) Act 1982 (7-page response to consultation,02/01, March 2001)*

The future of Sites of Special Scientific Interest(SSSIs) (21-page document, 01/01, February, ISBN 085403 5524)*

Response to House of Commons EnvironmentalAudit Committee Inquiry into Renewable Energy(5-page letter, 29 January 2001)

A code of practice for scientific advisory committees(6-page document 14/00, December 2000)*

Research policy and funding (9-page document,13/00, December 2000)*

Consultation on work plan for AEBC (2-page letter, 30November 2000)*

Stem cell research and therapeutic cloning: anupdate (8-page document, 12/00, November 2000,ISBN 0 85403 5494)*

Consultation on MAFF’s research strategy for theperiod 2001-2005 (5-page letter, 24 October 2000 )*

The role of the Renewables Directive in meetingKyoto targets (12-page document, 11/00, October2000, ISBN 00 85403 5486)*

Developing a national strategy for science (8-pagedocument, 10/00, July 2000, ISBN 0 85403 5451)*

Transgenic plants in world agriculture (19-page fullreport, 08/00, July 2000, ISBN 0 85403 5443)*Transgenic plants in world agriculture (2-pagesummary, 09/00, July 2000)*

Other recent Royal Society reports

Further copies of these reports can be obtained from: Science Advice Section The Royal Society6–9 Carlton House Terrace London SW1Y 5AG

* The full text, or summary, of these reports can be found on the Royal Society’s web site (www.royalsoc.ac.uk)

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