Lots of interesting detail on 3 separate studies.
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All plantings of Bt maize in Europe are harmful and illegal
Dr Brian John

Summary: IT IS NOW INCONTROVERTIBLE THAT ALL PLANTINGS OF BT MAIZE VARIETIES (eg MON810 and Bt176) IN EUROPE ARE HARMFUL AND THUS ILLEGAL UNDER DIRECTIVE 2001/18. HOW MUCH MORE EVIDENCE DO THE 'EXPERTS' AT DEFRA, ACRE, FSA, ACNFP, EFSA ETC. ACTUALLY NEED? ARE THEY ALL STUPID? WHATEVER THEIR PERSONAL PROBLEMS MAY BE, THEY ARE CERTAINLY GUILTY (EACH ONE OF THEM, PERSONALLY) OF THE WILFUL SUPPRESSION OF EVIDENCE AND OF CRIMINAL NEGLIGENCE.

Directive 2001/18 is enshrined in law, and every time a Bt variety is planted, cultivated or harvested ("deliberately released into the environment") the law is being broken (1) (2).

The notes below just refer to plant toxicity, microbiology and insect life. There are other studies too (eg Bt cotton), relating to mammals including human beings. There is now so much evidence of harmful toxic effects associated with Bt varieties that all past approvals by the EC must be revisited. The approvals procedures for GM varieties "in the pipeline" must also be stopped instantly. If they are not, that would be interpreted by any reasonable person as connivance in environmental damage and in the extension of public health risk by EFSA and by Commissioners Dimas and Kyprianou in particular.

Evidence of ecological damage associated with Bt varieties is presented below from Germany, Hungary and Australia. Some of this material has been in the public domain for 2 years or more, but it has been systematically and cynically disregarded by the EC.

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(1) GERMANY

Thanks to Jonathan Latham for drawing attention to this:

Lang,A and Vojtech, E: "The effects of pollen consumption of transgenic Bt maize on the common swallowtail, Papilio machaon L. (Lepidoptera, Papilionidae), Basic and Applied Ecology 7 (2006), pp 296-306

This is a careful lab-based peer-reviewed study which used moderate pollen densities in accordance with densities found in the field. The authors point out that field pollen densities can be much higher in the pollen shedding period, which lasts from 5 - 14 days. During this period the toxic effects of Bt exposure will clearly be more marked (including greater larvae mortality rates and reduced reproductive success in butterflies) than those revealed in the study. Note that these effects are specific to Bt176 pollen -- they have nothing to do with herbicide applications.

The study used Bt176 maize from the Navares (Syngenta) cultivar. The work was financed by the State Government of Bavaria.

Quotes:

"Bt toxins are produced in most tissues of the Bt maize, and pollen with toxin may be transported by wind into adjacent areas, deposited on plants, and consumed by larvae of non-target species feeding on these plants."

"Consumption of Bt176-maize pollen had adverse effects on life history traits of the common swallowtail. P machaon larvae fed with Bt pollen had a lower survival, a lower weight increase rate, a longer development time, and lower body-weight and smaller wing size as adults, and these effects were significantly associated with Bt pollen density."

"The study demonstrated toxic effects pf Bt176 maize pollen on P. machaon..."

"Bt consumption enhances the negative impact of bacterial infections on Lepidoptera larvae..."

"This study and the papers of Felke et al showed that the Bt176 maize has the potential to adversely effect larvae of European butterflies."

"We conclude that possible effects of Bt maize on European butterflies and moths must be evaluated more rigorously before Bt maize should be cultivated over large areas."

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(2) HUNGARY

Recent Hungarian work also confirms that Inachis io (L) (European Peacock) and Vanessa atalanta (L) (Red Admiral) (Nymphalidae) can be affected negatively by Bt pollen from the MON810 maize line. Both species (which are protected) feed on great nettle, a common weed in the water furrows of maize fields in Hungary. The eggs of these species hatch at exactly the time of maize pollination. See this:

Darvas, b et al: "Some data on the risk analysis of Bt-corn pollen and protected Lepidoptera species in Hungary", Novenyvedelem 40 (9) (2004) pp 441 - 449

A furious row has broken out between EFSA and the Hungarian Agriculture Ministry, which has imposed a temporary prohibition order on plantings of MON810 maize in the country. This prohibition was based upon environmental and ecotoxological studies in the field by a team of Hungarian scientists, and part of the row centres on the fact that EFSA has chosen to pass judgement on these studies without having any expertese in the relevant areas.

The Hungarian team found the following for MON810 maize:

1. "The Bt maize produces 1500-2000 times as much Bt-toxin as is released through a single treatment in conventional crop protection, with the chemical called DIPEL, which contains Bt toxin." 2. "Other experiments have found that the residues of Bt plants are slower to decompose than their isogenic lines. Some 8% of the toxin produced by the plant remained in the field after harvesting. Indeed, a substantial share of this active toxin quantity could be identified in the soil 11 months later." 3. "In the soil of the field under the transgenic plant, the entire biological activity was lower than in the control field." 4. "The caterpillars thriving on herbs in and on the edges of maize fields, hatching during the pollination period, are the most substantially affected by the Bt toxin produced by MON 810."

On this basis, the Hungarians argue that any use of MON810 in maize plantings is in direct contravention of the National Nature Conservation Plan with respect both to protected habitats and protected insect species.

The Hungarians are also furious that EFSA invited Monsanto to comment on the Hungarian research work and accepted an anonymous critique from the company and circulated it to Member states without comment and indeed without prior notification of the research team. This action is referred to as "unacceptable" and "deeply offensive". The Hungarians are also furious with Monsanto, which has refused to supply seeds for a continuation of the research work and has refused to supply standards for the content of Cry 1Ab toxins in the relevant maize varieties. The EC is effectively accused of conniving with Monsanto in this refusal to cooperate with the research.

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(3) AUSTRALIA

A reminder of this (circulated via GM-Act in May of this year):

Some Australian research not widely reported... It refers to Cry1Ac toxin and backs up the findings of the Hungarian team including Bela Darvas. It relates to Bt cotton plants, but the conclusions can reasonably be extrapolated to Bt maize and to other cultivated pl;ants containing Bt toxins.

From Gupta and Watson:

Quote: " ..... We have shown that different plant parts of Bt cotton (leaves, stubble and roots) contain large concentrations of Bt toxin and therefore have the potential to be a reservoir of Bt toxin in agricultural fields of Australia."

Quote: "............ our results suggest that Bt toxin has the potential to enter the soil system throughout the Bt cotton growing season, through both a root release process and root turnover. Levels of Bt toxin entering the soil system could therefore be significantly higher than previously suggested ......."

Quote: " ..... roots with Bt toxin are in constant contact with the soil system (including soil biota) and Bt toxin levels in fine roots were found to be as high as that in younger leaves. In view of the results reported above (large concentrations of Bt toxin in Bt cotton roots and demonstrated root release), more detailed investigations on the environmental fate of the root-derived Bt toxin, binding to soil components and build up, and movement beyond the rhizosphere and root zone, are warranted."

The concerns of the authors shine through, although they are careful (so as to keep their paymasters happy) not to flag up "harm" or even the potential for harm. We can see the heavy hand of CSIRO here, in playing down the significance of the findings. But this research is very relevant, given the new revelations about sheep deaths in India among animals grazing on Bt cotton plants.

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"Ecological impacts of GM cotton on soil biodiversity -- Below ground production of Bt by GM cotton and Bt cotton impacts on soil biological processes" Dr Vadakattu VSR Gupta and Dr Stephanie Watson Consultancy report by CSIRO Land and Water, August 2004

http://www.deh.gov.au/settlements/publications/biotechnology/gm-cotton/summary.html

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NOTES

(1) There are many clauses in the Directive than can be invoked, including Article 8 Clauses 1 and 2 which state (a) that if and when new information becomes available relating to the risks to health and the environment associated with a GM crop, the notifier (or seed owner) shall take appropriate protective steps; and (b) the competent authority shall evaluate the new information, communicate it to the public, and if necessary suspend or terminate the release authorisation. Neither Monsanto nor Syngenta has shown any inclination to protect either the environment or the public, and the EC and its advisory bodies have proved themselves to be incapable of standing up to the multinationals or revisiting past decisions. The Safeguard Clause may be invoked by member states (Article 23) to provisionally restrict of prohibit a GM variety deemed to be unsafe or harmful; however, the EC always seeks to overturn "precautionary" actions by various nations based upon this clause. The Cartagena Protocol (Article 32) is for the purposes of GM assessments disregarded by the EC. The preamble to the Directive states that where there are risks to the environment, preventive action must be taken; but it never is. The precautionary principle must also -- in theory -- be taken into account in the implementation of the Directive; on the contrary, it has been comprehensively abandoned by the EC. The various national laws which contain the essence of Directive 2001/18/EC are in many cases more severe -- for example, the UK Environmental Protection Act 1990 places more stress on the Precautionary Principle and supposedly affords additional protection to designated wildlife sites and other protected landscapes and ecosystems. The UK GMO Deliberate Release Regulations 2002 are also "tighter" in some respects than Directive 2001/18; but in the event the UK government has a tendency to see all GMOs as wonders of biotechnology, and invariably votes for GM approvals however inadequate and corrupt the applicant's supporting information may be.

(2) See also Clause 36 of the following legal advice to FoE Europe, published in January 2005: http://www.foeeurope.org/press/2005/Coexistence%20-%20Lasok%20Advice.pdf

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