Introduction
GE Free New Zealand in Food and Environment and the Soil & Health Association of New Zealand (“we” and “the submitters”) welcome the opportunity to comment on the application A1139 Food derived from Potato Lines F10, J3, W8, X17 & Y8 (“Application”).
GE Free New Zealand in Food and Environment (“GE Free NZ”) is an Incorporated Society. It is a non-Governmental Organisation governed by a Board and has a nationwide membership base. It represents its members when making submissions and helps with gathering and disseminating information concerning genetically modified organisms (“GMO”) to its members and the wider public through regular newsletters and its website (www.gefree.org.nz).
The Soil & Health Association of New Zealand Inc. (“Soil & Health”) is a charitable society registered under the Incorporated Societies Act 1908. It is the largest membership organization supporting organic food and farming in New Zealand and is one of the oldest organic organisations in the world, established in 1941. Soil & Health’s objectives are to promote sustainable organic agricultural practices and the principles of good health based on sound nutrition and the maxim: “Healthy soil, healthy food, healthy people”. Its membership is chiefly composed of home gardeners and consumers, organic farmers and growers, secondary producers, retailers and restaurateurs. Soil & Health publishes the bi-monthly ‘Organic NZ’ magazine – New Zealand’s leading organics magazine.
We recommend that FSANZ decline the Application. We submit FSANZ cannot approve the potato lines in the Application without a serious breach of its duty of care as well as the principles of its own mission statement.
We note that there are insufficient data on both the sprays and novel proteins detailed in the Application.
We note that FSANZ’s legal requirements as stated in its mission statement are:
To protect, in collaboration with others, the health and safety of people in Australia and New Zealand through the maintenance of a safe food supply.
FSANZ Values are:
- To be impartial, open and accountable;
- To use the best available sciences and evidence to guide decision-making; and
- To seek, respect and be responsive to the issues raised by others.
FSANZ Responsibilities are:
- Provide information to consumers to enable better consumer choice;
- Undertake dietary exposure modeling and scientific risk assessments; and
- Provide risk assessment advice on imported food.
We have read the assessments for this Application and consider that FSANZ have led stake holders and consumers astray. We outline our concerns below.
Detailed submission
It is illegal to import viable GE plants or plant parts into New Zealand. Potato plants can readily regenerate from even small parts of raw tubers, therefore making any raw imported GE potatoes equivalent to live GE plant material. This will endanger the biosecurity status of New Zealand. It would be illegal to approve the entry of these GE potatoes/potato pieces into the country.
Not labeling GE-containing foods at the point of sale is a breach of consumer rights. The lack of labeling of GE potatoes sold in any form by restaurants is deceptive, as consumers will be unaware of this. FSANZ should support rather than oppose the enforcement and monitoring of compliance around GE food labeling.
No independent food safety experiments have been carried out on these GE potato lines. Instead FSANZ has relied on data from within the GE industry, i.e., the applicant data. This shows that FSANZ has not been impartial, open or accountable to the public. FSANZ has not required that any independent experimental food safety assessments be undertaken on these potatoes. It can therefore not provide advice on the safety of these imported potato lines, such advice being its core responsibility.
The executive summary of the FSANZ evaluation reads:
The changes to levels of free amino acids and reducing sugars are not nutritionally consequential as they do not affect the levels of essential amino acids or other key nutrients important to potato.
This statement assumes that any changes in the amino acids, free or otherwise, do not affect the levels of all other compounds present in the GE potatoes. The amino acid glutamine, for example, plays an important role in maintaining a healthy immune system, digestive tract and muscle cells. Any changes to amino acid balance may cause alterations to the assimilation of other amino acids. Studies have shown glutamine to reduce morbidity and mortality in periods of critical illness. [1] This demonstrates that any changes to endogenous amino acid levels should not be ignored.
Statement on Compositional analyses:
A detailed compositional analysis was performed on W8, X17, Y9, F10 and J3 to establish the nutritional adequacy of tubers produced from these lines and to characterise any unintended compositional change. Analyses were done of proximates, fibre, vitamins, minerals, total amino acids, free amino acids, sucrose, reducing sugars (fructose and glucose), and anti-nutrients (glycoalkaloids). These showed that, even with the intended changes to sucrose, reducing sugars and asparagine, the levels of all analytes fell within the natural variation found across the range of conventional potato lines used for human consumption. No conclusion could be reached in relation to line E56 as no compositional data was provided. (iii)
The changes in concentrations of glutamine and asparagine in the GE potato lines may be of some concern. Altered levels of asparagine can result in complications in fetal development, causing brain and neurological problems.[2]
There are concerns over the meaning of “biological relevant differences” as stated in the summary document:
Analysis of the events W8, X17, and Y9 have not revealed any biologically relevant differences compared to the conventional varieties, except for the intended late blight protection, low free asparagine, low reducing sugars, and low polyphenol oxidase activity.
Assuming “biologically relevant differences” translates as food safety, there are no feeding studies to back up this statement, so such assumptions are unable to be made.
Published research on GE potatoes has shown unexpected harmful effects on animals fed with these crops. A 1999 study (Ewen and Puzstai) conducted on rats fed with transgenic potatoes found that abnormalities occurred in the gastrointestinal tract (small intestine and caecum) within a short time.[3] This study found that the GE potatoes caused gut abnormalities with or without (an ‘empty construct’) the lectin gene. Lectin is a harmless insecticidal compound produced by a number of plants. The authors concluded that:
“(b)ecause caecal thickness was similar in rats given boiled parent potatoes in the presence or absence of spiked GNA (a harmless lectin from the plant species Galanthus nivalis), we suggest that the decrease in caecal mucosal thickness seen in rats fed boiled GM-potato diets was the consequence of the transfer of the GNA gene into the potato.”
These GE potatoes were not subsequently commercialised.
Similar results were obtained in feeding experiments using GE potatoes by Fares et al.[4] , who found that there were changes to the mucosal lining and other cells of the ileum of mice. They called for comprehensive feeding tests to avoid any potential risks:
“Although transgenic crop plants used in food and feed production carry different beneficial transgenes… before releasing for marketing thorough tests and all possible consequences of these new types of heredity and new genetic structures must be evaluated to avoid any potential risks”
A 2007 study showed that the consumption of GE potatoes has been observed to cause an increase in immunoglobulin (Ig) levels in human participants.[5]
This is cause for concern, as antibody levels may well have increased as a result of novel proteins present in the GE food.
These afore-mentioned studies are but three of many published studies on the harmful effects of GE foods. Please refer to the submission of the Physicians and Scientists for Global Responsibility (PSGR) for a more comprehensive list of publications on the harmful effects of GE crops, as observed in feeding experiments.
The obligation of FSANZ is to make themselves aware of such studies and treat all GE foods as potentially harmful. It would be completely irresponsible to allow these potatoes onto the market. Feeding studies need to be conducted on the GE potato lines in this application before the potatoes are released. This will determine whether these lines have negative health impacts, or even life threatening responses, such as an allergic reaction.
Changes in Metabolites
Cellini et al. (2004) reported widespread changes to metabolite levels, both expected and unexpected in GE potato lines. They recommended that data analysis tools need to be used.[6]
A study of potato metabolite production has found that field-grown vs laboratory-grown potato tubers showed a tenfold and greater differences across a range of compounds.[7] The potatoes with modified sucrose metabolism or inhibited starch synthesis revealed unexpected disaccharides (trehalose, maltose and isomaltose).[8] Such changes in metabolites cannot be overlooked, when assessing this application.
A particular cause for concern is that FSANZ has deemed the six GE potato lines in this application as “safe”, when there is no compositional data on one line E56.
Applicant data to APHIS[9]
We have outlined the comments from the data provided to APHIS about the potatoes.
7.3 Soft root testing with tubers
Of the events in that trial (E12, E24, F10, J3, J55, and J78), the only significant difference was that event F10 was more resistant to this disease than the control. (APHIS p.46)
Late blight foliage testing
Considering both studies, we conclude that the events have similar susceptibility to bacterial soft rot as the controls. (APHIS, p.46)
7.4 Reducing Sugars.
Tubers of the events G11, H37, and H50 contain the same amount of reducing sugars as tubers of their untransformed (non-GE) counterparts. The inability of the silencing construct to limit glucose/fructose formation in H37 and H50 may be due to the fact that the H variety is naturally low in glucose and fructose. Thus, we concluded that silencing of the promoters associated with the PhL/R1 genes effectively lowered reducing sugars near the time of harvest in most events but these differences were not sustained throughout storage for 2-5 months”. (APHIS,p. 47)
Disease susceptibility – Appendix 8
Thus, independent lines of two chipping varieties and two French fry varieties with low Ppo expression in tubers were shown to have similar susceptibility to bacterial soft rot to the corresponding untransformed control for each variety.
Considerations
The APHIS document on the GE potatoes details some significant differences in the compositions between the GE lines and non-GE controls. These GE potatoes are of no nutritional benefit to consumers and could contain higher levels of anti-nutrients.
FSANZ has overlooked three fundamental issues, when allowing this application to proceed:
- There are currently non-GE potato varieties available that are ideal for chipping and processing .
In section 2.4.3 of the application it states that the applicant has indicated that reduced blackspot bruising of these GE potato lines can reduce wastage during storage and processing, and that the potatoes are resistant to the fungal disease known as foliar late blight. There are already several non-GE varieties of blight-resistant potatoes (including ‘Waneta’ and ‘Lamoka’), which have been released by plant breeders from the University of Cornell (US). These varieties are ideal for chips, because they store very well and produce a good colour when cut 9. The Cornell breeding programme develops chipping and tabletop varieties, focussing on colour, size, shape, texture and disease- and pest-resistance.
- New Zealand has a range of excellent climates and soils in which to grow these non-GE varieties of potatoes. This would support NZ growers and potato processing plants. Furthermore, the importation of potato products from the other side of the world, is an unnecessary source of carbon emissions that will contribute to what is already a major world problem.
- Acrylamide production can be reduced by the use of sensible cooking methods. There is much information available on this topic.
Conclusions
We ask that FSANZ decline approval of A1139.
- An adequate risk assessment and evaluation of the effect/s of novel genes/proteins and subsequent changes in the A1139 potato lines has not been carried out.
- No independent feeding test risk assessments have been undertaken or evaluated by FSANZ.
- The Applicant information provided on safety is insufficient and lacking up to date metabolic profiling using proteomic testing for entry into the food chain.
- The lack of information does not allow the consumer to make informed decisions and removes consumer choice
- By not allowing for labeling of A1139, FSANZ has not provided information to consumers that will enable better consumer choice.
- The assessment has no information about any novel protein/s, which may have been produced during the GE process.
- There is a lack of scientific data necessary to protect and maintain a safe food supply for the health and safety of people in Australia and New Zealand.
The best available science has not been used to properly guide decision-making.
- The reliance on applicant’s data has not shown impartiality, openness and accountability.
[1] Lacey, J., & Wilmore, D. (2009). Is Glutamine a Conditionally Essential Amino Acid?. Nutrition Reviews, 48(8), 297-309.
[2] Ruzzo,E., Capo-Chichi, J., Ben-Zeev., Chitayat, D., Mao, H., & Pappas,A. et al. (2013). Deficiency Asparagine Synthetase Causes Congenital Microcephaly and a Progressive Form of Encephalopathy. Neuron, 80(2), 429-441.
[3] Ewen, S., & Pusztai, A. (1999). Effect of diets containing genetically modified potatoes expressing Galanthus nivalis lectin on rat small intestine. The Lancet, 354(9187), 1353-1354.
[4] Fares, N., & El-Sayed, A. (1998). Fine Structural Changes in the Ileum of Mice Fed on δ-Endotoxin-Treated Potatoes and Transgenic Potatoes. Natural Toxins, 6(6), 219-233.
[5] Tacket, C. O. (2007). Plant-Based Vaccines Against Diarrheal Diseases. Transactions of the American Clinical and Climatological Association, 118, 79–87
[6] Cellini, F., Chesson, A., Colquhoun, I., Constable, A., Davies, H., & Engel, K. et al. (2004). Unintended effects and their detection in genetically modified crops. Food And Chemical Toxicology, 42(7), 1089-1125.
[7] Roessner, U., Wagner, C., Kopka, J., Tretheway, N., Willmitzer, L., 2000. Simultaneous analysis of metabolites in potato tubers by gas chromatography-mass spectrometry. Plant Journal 23, 131–142.
[8] Acrylamide Potential and Reduced Black Spot Bruise: Events E12 and E24 (Russet Burbank); F10 and F37 (Ranger Russet); J3, J55, and J78 (Atlantic); G11 (G); H37and H50 (H) – 2013 https://www.aphis.usda.gov/brs/aphisdocs/13_02201p.pdf
[9] www.isaa.org/kc/cropbiotechupdate/article/default.asp?ID=7422
A win for clean, green, GE-free New Zealand
/in Farming, GEThe Soil & Health Association is celebrating the decision by Federated Farmers to abandon its appeal against the right of councils to control the use of genetically modified organisms (GMOs) in their territories. Federated Farmers filed its latest appeal earlier this year in the Court of Appeal, after its appeals to the Environment Court and High Court had been dismissed.
“We congratulate Federated Farmers on this pragmatic and sensible decision,” said Soil & Health Chair Graham Clarke.
“Both the High Court and Environment Court have ruled that regional councils have jurisdiction under the Resource Management Act (RMA) to regulate the use of GMOs through regional policy statements or plans. The recent RMA amendments further entrench the legal rights of councils to do so. Challenging these decisions would only have cost us, the other parties involved and Federated Farmers themselves a lot of unnecessary time and money.”
Federated Farmers had argued that the Environmental Protection Authority had sole responsibility for the regulation of GMOs under the Hazardous Substances and New Organisms Act (HSNO).
The decision to withdraw its appeal comes after recent amendments were made to the RMA, which confirmed the High Court ruling, leading Federated Farmers to believe that they “are likely to have materially reduced the prospects of the appeal being prosecuted successfully.”
The RMA changes, which passed in April this year via the Resource Legislation Amendment Bill, included a controversial section which allows the Minister for the Environment to bypass parliament and make fundamental changes to the law if it is deemed that council plans duplicate or deal with the same subject matter as central Government laws. This would have allowed the Minister to strip councils of their ability to create GE-free food producing zones.
The National Government at the time needed the Maori Party votes to pass the changes. However, the Maori Party stated in December last year that it would not support changes to the RMA if they extended to allowing the Minister to overrule planning provisions controlling the use of GMOs.
Before the final reading of the Bill, an exemption was introduced under section 360D specifically for GE crops, effectively preventing the minister from permitting GMO crops in regions that had elected to remain GMO free or impose controls on the use of GMOs.
“We are so grateful to Maori Party for their determination to ensure that appropriate clauses in the RMA were included to protect regions from uncontrolled GMO use. Had they not stood firm against the changes, then we might not have had this decision from Federated Farmers to withdraw their appeal,” says Soil & Health National Council member Marion Thomson.
“The RMA amendment further confirms the ability of all local councils to determine GMO policies in their regions. Local communities can now have confidence that their values and concerns about the use of GMOs in their regions can be considered when drafting policy statements and plans.” says Thomson.
The economic sustainability of a wide range of agricultural export activities reliant on GMO-free status is also protected by this ruling. The global non-GMO food market is currently valued at US$250 billion, and trends show this is only going to grow. New Zealand producers benefit from access to this huge non-GMO market.
Soil & Health has found no economic, health or environmental case for GMOs. There are huge uncertainties around the adverse effects of GMOs on natural resources and ecosystems. The risks are large and consequences irreversible. If GMOs were to be released into the environment, they would be very difficult, if not impossible, to eradicate in circumstances where they adversely affected the environment. There is also potential for serious economic loss to regions marketing their products and tourism under New Zealand’s ‘clean green’ brand, if GMO land use were permitted.
Background:
Significant gaps exist in the law around GMOs in New Zealand. In the HSNO Act there are inadequate liability provisions (e.g. ‘polluter pays’) for any unintended or unforseen adverse impacts resulting from the outdoor release of an approved GE crop or animal, meaning those causing harm may not be held liable. There is no mandatory requirement for the EPA to take a precautionary approach to the outdoor use of GMOs.
Due to these gaps in the law, a number of councils around New Zealand have been moving to protect their primary producers and communities by introducing precautionary or prohibitive policies.
The Northland Regional Council is one such council which, after receiving hundreds of submissions from Northland ratepayers, district councils, Northland Conservation Board, iwi authorities, hapū and community groups, chose to adopt a precautionary approach around the outdoor release of GMOs in the proposed Northland Regional Policy Statement.
Federated Farmers of New Zealand lodged an appeal with the Environment Court in 2015 opposing these precautionary GMO provisions in the Northland Regional Policy statement. Principal Environment Court Judge L. Newhook however found that there is jurisdiction under the Resource Management Act for regional councils to make provision for the outdoor use of GMOs through regional policy statements and plans. Since comprehensively losing the appeal (which it initiated) on all points of law, Federated Farmers filed a second appeal against the Environment Court’s decision with the High Court.
Soil & Health, GE Free Northland, Taitokerau mana whenua, Far North District Council and several other groups and individuals joined the appeal in the High Court as section 274 (interested) parties pursuant to the RMA, in support of respondents Northland Regional Council and Whangarei District Council. Soil & Health was represented by Dr. Royden Somerville QC and Robert Makgill.
Dr Somerville argued that Environment Court Judge L. Newhook was correct in his decision that the RMA and HSNO Act hold complementary and not overlapping roles. The two Acts offer different purposes and functional responses to the regulation of GMOs in New Zealand. Thus, regional planning documents can control the use of GMOs as part of promoting sustainable management under the RMA, taking account of regional needs. This argument has been confirmed by High Court Judge Mary Peters.
Contact: Graham Clarke
Chair, Soil & Health Association
027 226 3103
Councils retain right to regulate GE trees
/in Media ReleasesThe Soil & Health Association is thrilled that newly released standards for forestry no longer include a controversial clause that would have allowed the planting of genetically engineered (GE) trees across New Zealand.
Released by MPI last week, the National Environmental Standard for Plantation Forestry (NES-PF) provides regulations to manage the environmental effects of forestry. Soil & Health made a submission on the proposed policy document and, along with nearly 16,000 others, opposed the clause that would have permitted the planting of GE trees.
“We are thrilled by this result and congratulate all who submitted against the clause, and MPI for listening to us. They have done a great service to New Zealand in doing so,” said Soil & Health chair Graham Clarke.
The removal of the GE clause means that there will be no blanket approval for GE trees anywhere in New Zealand. Applications for GE trees to the Environmental Protection Authority must be assessed on a case-by- case basis, like all GE applications, with the opportunity for the public to make submissions. Any approvals are subject to regional and district plan provisions which may require additional conditions, or ban the planting of GE trees altogether.
“Including the GE clause would have jeopardised local authorities’ ability to manage the outdoor use of GMOs, and put at risk the economic sustainability of a wide range of agricultural export activities reliant on GE-free status,” said Mr Clarke.
Last year the High Court upheld the landmark Environment Court decision that regional and territorial authorities can manage the outdoor use of genetically modified organisms in the same way as any other land use in their regions, under the RMA. Soil & Health, which was a party in the High Court decision, considered the ruling a win not only in the fight against GE, but also for democracy in allowing local communities to have a say in the GE policies in their areas.
“The decision to remove the GE tree clause from the NES-PF confirms the ability of councils to respond to community concerns about the planting of GE trees and other crops in their region,” said Mr Clarke.
The Soil & Health Association of NZ is the largest membership organisation supporting sustainable, organic food and farming in New Zealand, and is one of the oldest organic organisations in the world, established in 1941. Our aim is to empower people and communities to grow, buy and support locally based sustainable, safe, GE-free and organic food in Aotearoa NZ.
Organic farmer new chair of Soil & Health
/in Media Releases8 August 2017
A fourth-generation farmer has been selected as the new chair of the Soil & Health Association, following its AGM. Until 2014 Graham Clarke was a sheep and beef farmer for over 30 years in South Otago at Marama Farm, which was certified organic by BioGro for close to 10 years. “I’m passionate about sustainable food production and see organic food as being essential to getting better quality nutrition to New Zealanders,” says Graham Clarke.
Mr Clarke, who was first elected onto the National Council of Soil & Health in July 2016, brings experience and enthusiasm for organics to the council table. He has had governance experience with Federated Farmers, the Beef Council and the Animal Health Board.
“I have now chosen to serve Soil & Health in the hope that this can mean more farmers can be supported to grow great nutrition for New Zealanders, and more people can achieve good health through their food. Organics needs to go mainstream,” said Mr Clarke.
Having experienced huge health improvements himself through eating well, Mr Clarke is now a certified Integrative Nutrition health coach and helps people improve their health and their lives through what they eat and other lifestyle choices. In his spare time, he leads a team of caregivers who look after a young man with disabilities caused by a car accident, with nutrition one of the key planks in his greatly improved health.
Graham Clarke paid tribute to outgoing chair Marion Thomson: “Marion has dedicated a huge amount of energy to Soil & Health for many years, particularly championing the rights of communities to control or ban GE in their areas, via several court cases. The Association is lucky to have her stay on as a member of the National Council and continue our important work,” said Mr Clarke.
“Times are changing locally and globally and the weight of evidence concerning the challenges of many of the current farming methods and the consequences of some of them continues to grow. This is both a health and environmental concern. Soil & Health is aiming for a fully organic New Zealand to address these concerns.”
Contact: Graham Clarke
Chair, Soil & Health Association
027 226 3103
Health not herbicides: time to phase out glyphosate
/in Food, Health, Media Releases, OrganicsOur public agencies must protect human health and ecosystems, and use rigorous independent science rather than industry data, says the Soil & Health Association. Soil & Health welcomes the release of a paper by the Green Party that exposes many flaws in an Environmental Protection Authority (EPA) report on glyphosate-based herbicides (such as Roundup).
The EPA commissioned a report last year that found glyphosate to be safe and unlikely to be carcinogenic. Only months before, the world-leading authority International Agency for Research on Cancer (IARC) determined that glyphosate was a ‘probable carcinogen’.
The paper released by the Green Party last week revealed that the EPA’s conclusion was based on flawed science and data provided by industry. The paper dispels the so-called safety claims made by the EPA and highlights the urgent need to reassess the authorisation of products like Roundup that contain glyphosate.
“Many countries have banned the use of glyphosate due to its toxicity,” says Soil & Health chair Graham Clarke, who is a fourth generation farmer. “Even exposure to very low doses, below the risk analysis guidelines, creates a very real risk to human health. This paper raises serious concerns about the adequacy and quality of the EPA’s hazardous substances assessments.”
“Roundup in particular has been a cornerstone of chemical agriculture in New Zealand for decades but as each day goes by new compelling evidence emerges showing the downside of this product,” says Clarke.
“Soil & Health congratulates organic farmers, home gardeners and others who are using safe and effective ways to grow food and to control weeds, with no need for harmful herbicides. We’d like to see more government support for research into non-chemical alternatives to glyphosate as demonstrably the high chemical input system is not serving anyone in New Zealand well except the marketers of said products.”
Glyphosate is sprayed on numerous crops, including about 80% of genetically engineered crops that are bred to be tolerant to the herbicide. It is also used in New Zealand and overseas as a pre-harvest desiccant, so crops such as wheat are uniform at harvest time, and to make crops like potatoes easier to harvest. Residues of glyphosate (or its metabolites) are likely to be in many foods that Kiwis are eating every day, with the notable exception of organic foods. Buying certified organic foods is the best consumer guarantee to avoid residues of harmful chemicals such as glyphosate. The herbicide is also widely used in home gardens and public places including roadsides, parks and playgrounds.
“By deeming glyphosate safe and allowing for its widespread sale and use in New Zealand we believe the EPA has failed in their statutory obligation to protect the health and safety of people and communities, by preventing or managing the adverse effects of hazardous substances,” says Clarke.
Soil & Health believes that glyphosate should be phased out immediately.
“The use of glyphosate in public places, home gardens and for pre-harvest desiccation should cease immediately as these are the routes that expose most people to glyphosate. Other uses should be restricted and phased out as soon as possible,” says Clarke.
Links
Soil & Health’s policy on pesticides:
https://soilandhealth.org.nz/policies/pesticides/
Green Party paper:
https://www.greens.org.nz/sites/default/files/Published%20Paper%20-%20Why%20did%20the%20NZ%20EPA%20ignore%20the%20World%20Authority%20on%20Cancer%20-%20July%202017.pdf
IARC report:
http://www.iarc.fr/en/media-centre/iarcnews/pdf/MonographVolume112.pdf
EPA report:
http://www.epa.govt.nz/Publications/EPA_glyphosate_review.pdf
Joint Submission on the A1139 Potato to Food Standards Australia New Zealand
/in SubmissionsIntroduction
GE Free New Zealand in Food and Environment and the Soil & Health Association of New Zealand (“we” and “the submitters”) welcome the opportunity to comment on the application A1139 Food derived from Potato Lines F10, J3, W8, X17 & Y8 (“Application”).
GE Free New Zealand in Food and Environment (“GE Free NZ”) is an Incorporated Society. It is a non-Governmental Organisation governed by a Board and has a nationwide membership base. It represents its members when making submissions and helps with gathering and disseminating information concerning genetically modified organisms (“GMO”) to its members and the wider public through regular newsletters and its website (www.gefree.org.nz).
The Soil & Health Association of New Zealand Inc. (“Soil & Health”) is a charitable society registered under the Incorporated Societies Act 1908. It is the largest membership organization supporting organic food and farming in New Zealand and is one of the oldest organic organisations in the world, established in 1941. Soil & Health’s objectives are to promote sustainable organic agricultural practices and the principles of good health based on sound nutrition and the maxim: “Healthy soil, healthy food, healthy people”. Its membership is chiefly composed of home gardeners and consumers, organic farmers and growers, secondary producers, retailers and restaurateurs. Soil & Health publishes the bi-monthly ‘Organic NZ’ magazine – New Zealand’s leading organics magazine.
We recommend that FSANZ decline the Application. We submit FSANZ cannot approve the potato lines in the Application without a serious breach of its duty of care as well as the principles of its own mission statement.
We note that there are insufficient data on both the sprays and novel proteins detailed in the Application.
We note that FSANZ’s legal requirements as stated in its mission statement are:
To protect, in collaboration with others, the health and safety of people in Australia and New Zealand through the maintenance of a safe food supply.
FSANZ Values are:
FSANZ Responsibilities are:
We have read the assessments for this Application and consider that FSANZ have led stake holders and consumers astray. We outline our concerns below.
Detailed submission
It is illegal to import viable GE plants or plant parts into New Zealand. Potato plants can readily regenerate from even small parts of raw tubers, therefore making any raw imported GE potatoes equivalent to live GE plant material. This will endanger the biosecurity status of New Zealand. It would be illegal to approve the entry of these GE potatoes/potato pieces into the country.
Not labeling GE-containing foods at the point of sale is a breach of consumer rights. The lack of labeling of GE potatoes sold in any form by restaurants is deceptive, as consumers will be unaware of this. FSANZ should support rather than oppose the enforcement and monitoring of compliance around GE food labeling.
No independent food safety experiments have been carried out on these GE potato lines. Instead FSANZ has relied on data from within the GE industry, i.e., the applicant data. This shows that FSANZ has not been impartial, open or accountable to the public. FSANZ has not required that any independent experimental food safety assessments be undertaken on these potatoes. It can therefore not provide advice on the safety of these imported potato lines, such advice being its core responsibility.
The executive summary of the FSANZ evaluation reads:
The changes to levels of free amino acids and reducing sugars are not nutritionally consequential as they do not affect the levels of essential amino acids or other key nutrients important to potato.
This statement assumes that any changes in the amino acids, free or otherwise, do not affect the levels of all other compounds present in the GE potatoes. The amino acid glutamine, for example, plays an important role in maintaining a healthy immune system, digestive tract and muscle cells. Any changes to amino acid balance may cause alterations to the assimilation of other amino acids. Studies have shown glutamine to reduce morbidity and mortality in periods of critical illness. [1] This demonstrates that any changes to endogenous amino acid levels should not be ignored.
Statement on Compositional analyses:
A detailed compositional analysis was performed on W8, X17, Y9, F10 and J3 to establish the nutritional adequacy of tubers produced from these lines and to characterise any unintended compositional change. Analyses were done of proximates, fibre, vitamins, minerals, total amino acids, free amino acids, sucrose, reducing sugars (fructose and glucose), and anti-nutrients (glycoalkaloids). These showed that, even with the intended changes to sucrose, reducing sugars and asparagine, the levels of all analytes fell within the natural variation found across the range of conventional potato lines used for human consumption. No conclusion could be reached in relation to line E56 as no compositional data was provided. (iii)
The changes in concentrations of glutamine and asparagine in the GE potato lines may be of some concern. Altered levels of asparagine can result in complications in fetal development, causing brain and neurological problems.[2]
There are concerns over the meaning of “biological relevant differences” as stated in the summary document:
Analysis of the events W8, X17, and Y9 have not revealed any biologically relevant differences compared to the conventional varieties, except for the intended late blight protection, low free asparagine, low reducing sugars, and low polyphenol oxidase activity.
Assuming “biologically relevant differences” translates as food safety, there are no feeding studies to back up this statement, so such assumptions are unable to be made.
Published research on GE potatoes has shown unexpected harmful effects on animals fed with these crops. A 1999 study (Ewen and Puzstai) conducted on rats fed with transgenic potatoes found that abnormalities occurred in the gastrointestinal tract (small intestine and caecum) within a short time.[3] This study found that the GE potatoes caused gut abnormalities with or without (an ‘empty construct’) the lectin gene. Lectin is a harmless insecticidal compound produced by a number of plants. The authors concluded that:
“(b)ecause caecal thickness was similar in rats given boiled parent potatoes in the presence or absence of spiked GNA (a harmless lectin from the plant species Galanthus nivalis), we suggest that the decrease in caecal mucosal thickness seen in rats fed boiled GM-potato diets was the consequence of the transfer of the GNA gene into the potato.”
These GE potatoes were not subsequently commercialised.
Similar results were obtained in feeding experiments using GE potatoes by Fares et al.[4] , who found that there were changes to the mucosal lining and other cells of the ileum of mice. They called for comprehensive feeding tests to avoid any potential risks:
“Although transgenic crop plants used in food and feed production carry different beneficial transgenes… before releasing for marketing thorough tests and all possible consequences of these new types of heredity and new genetic structures must be evaluated to avoid any potential risks”
A 2007 study showed that the consumption of GE potatoes has been observed to cause an increase in immunoglobulin (Ig) levels in human participants.[5]
This is cause for concern, as antibody levels may well have increased as a result of novel proteins present in the GE food.
These afore-mentioned studies are but three of many published studies on the harmful effects of GE foods. Please refer to the submission of the Physicians and Scientists for Global Responsibility (PSGR) for a more comprehensive list of publications on the harmful effects of GE crops, as observed in feeding experiments.
The obligation of FSANZ is to make themselves aware of such studies and treat all GE foods as potentially harmful. It would be completely irresponsible to allow these potatoes onto the market. Feeding studies need to be conducted on the GE potato lines in this application before the potatoes are released. This will determine whether these lines have negative health impacts, or even life threatening responses, such as an allergic reaction.
Changes in Metabolites
Cellini et al. (2004) reported widespread changes to metabolite levels, both expected and unexpected in GE potato lines. They recommended that data analysis tools need to be used.[6]
A study of potato metabolite production has found that field-grown vs laboratory-grown potato tubers showed a tenfold and greater differences across a range of compounds.[7] The potatoes with modified sucrose metabolism or inhibited starch synthesis revealed unexpected disaccharides (trehalose, maltose and isomaltose).[8] Such changes in metabolites cannot be overlooked, when assessing this application.
A particular cause for concern is that FSANZ has deemed the six GE potato lines in this application as “safe”, when there is no compositional data on one line E56.
Applicant data to APHIS[9]
We have outlined the comments from the data provided to APHIS about the potatoes.
7.3 Soft root testing with tubers
Of the events in that trial (E12, E24, F10, J3, J55, and J78), the only significant difference was that event F10 was more resistant to this disease than the control. (APHIS p.46)
Late blight foliage testing
Considering both studies, we conclude that the events have similar susceptibility to bacterial soft rot as the controls. (APHIS, p.46)
7.4 Reducing Sugars.
Tubers of the events G11, H37, and H50 contain the same amount of reducing sugars as tubers of their untransformed (non-GE) counterparts. The inability of the silencing construct to limit glucose/fructose formation in H37 and H50 may be due to the fact that the H variety is naturally low in glucose and fructose. Thus, we concluded that silencing of the promoters associated with the PhL/R1 genes effectively lowered reducing sugars near the time of harvest in most events but these differences were not sustained throughout storage for 2-5 months”. (APHIS,p. 47)
Disease susceptibility – Appendix 8
Thus, independent lines of two chipping varieties and two French fry varieties with low Ppo expression in tubers were shown to have similar susceptibility to bacterial soft rot to the corresponding untransformed control for each variety.
Considerations
The APHIS document on the GE potatoes details some significant differences in the compositions between the GE lines and non-GE controls. These GE potatoes are of no nutritional benefit to consumers and could contain higher levels of anti-nutrients.
FSANZ has overlooked three fundamental issues, when allowing this application to proceed:
In section 2.4.3 of the application it states that the applicant has indicated that reduced blackspot bruising of these GE potato lines can reduce wastage during storage and processing, and that the potatoes are resistant to the fungal disease known as foliar late blight. There are already several non-GE varieties of blight-resistant potatoes (including ‘Waneta’ and ‘Lamoka’), which have been released by plant breeders from the University of Cornell (US). These varieties are ideal for chips, because they store very well and produce a good colour when cut 9. The Cornell breeding programme develops chipping and tabletop varieties, focussing on colour, size, shape, texture and disease- and pest-resistance.
Conclusions
We ask that FSANZ decline approval of A1139.
The best available science has not been used to properly guide decision-making.
[1] Lacey, J., & Wilmore, D. (2009). Is Glutamine a Conditionally Essential Amino Acid?. Nutrition Reviews, 48(8), 297-309.
[2] Ruzzo,E., Capo-Chichi, J., Ben-Zeev., Chitayat, D., Mao, H., & Pappas,A. et al. (2013). Deficiency Asparagine Synthetase Causes Congenital Microcephaly and a Progressive Form of Encephalopathy. Neuron, 80(2), 429-441.
[3] Ewen, S., & Pusztai, A. (1999). Effect of diets containing genetically modified potatoes expressing Galanthus nivalis lectin on rat small intestine. The Lancet, 354(9187), 1353-1354.
[4] Fares, N., & El-Sayed, A. (1998). Fine Structural Changes in the Ileum of Mice Fed on δ-Endotoxin-Treated Potatoes and Transgenic Potatoes. Natural Toxins, 6(6), 219-233.
[5] Tacket, C. O. (2007). Plant-Based Vaccines Against Diarrheal Diseases. Transactions of the American Clinical and Climatological Association, 118, 79–87
[6] Cellini, F., Chesson, A., Colquhoun, I., Constable, A., Davies, H., & Engel, K. et al. (2004). Unintended effects and their detection in genetically modified crops. Food And Chemical Toxicology, 42(7), 1089-1125.
[7] Roessner, U., Wagner, C., Kopka, J., Tretheway, N., Willmitzer, L., 2000. Simultaneous analysis of metabolites in potato tubers by gas chromatography-mass spectrometry. Plant Journal 23, 131–142.
[8] Acrylamide Potential and Reduced Black Spot Bruise: Events E12 and E24 (Russet Burbank); F10 and F37 (Ranger Russet); J3, J55, and J78 (Atlantic); G11 (G); H37and H50 (H) – 2013 https://www.aphis.usda.gov/brs/aphisdocs/13_02201p.pdf
[9] www.isaa.org/kc/cropbiotechupdate/article/default.asp?ID=7422
GE potatoes set to sneak into our food
/in Food, GE, GM, Media Releases, OrganicsThe Soil & Health Association has serious concerns about another GE food line being approved in New Zealand – this time for six food lines derived from potatoes.
Food Standards Australia New Zealand (FSANZ), the organisation that controls food approvals for New Zealand and Australia, is calling for submissions on an application to permit GE potatoes for human consumption. The potatoes have been genetically engineered to reduce bruising, to reduce acrylamide formed during cooking, and to protect the potatoes from a type of blight.
Soil & Health is concerned about the growing number of genetically engineered foods approved for sale in New Zealand and the long-term and cumulative health effects of consuming them. While New Zealand does not grow any GE crops or animals, there are many imported GE ingredients in food for sale here.
“Since 2000 FSANZ has approved every single application for GE food lines, and there are now a staggering 71 different GE food lines approved for sale in New Zealand,” says Soil & Health chair Marion Thomson.
“An estimated 70% or more of processed non-organic foods for sale in New Zealand contain genetically engineered ingredients, but consumers have no idea because our labelling laws mean that almost all GE ingredients don’t have to be listed on the packaging.”
“In addition to human food, New Zealand imports large quantities of animal feed that is almost certainly genetically engineered, but again, not labelled as such,” says Marion Thomson.
While a FSANZ safety assessment on the GE potato application has not identified any public health and safety issues, previous FSANZ assessments have been shown to be incomplete, with an absence of biological studies on the impacts of the foods when eaten. Further, assessments have largely been reliant on industry assurances of safety, with no independent science to back up industry assertions.
“One of the main concerns about eating GE foods is that many have been grown with dangerous levels of pesticides,” says Thomson. “Many GE crops are designed to be resistant to pesticides. These crops are designated ‘safe’ for human consumption by FSANZ and the Ministry for Primary Industries, despite not having undergone adequate safety tests independent of the companies developing them.”
The best way to avoid consuming GE foods is to grow, buy and eat certified organic food, says Soil & Health.
The GE potatoes application is open for public submission until 7 July 2017.
Nitrogen fertiliser: the elephant in the room
/in Farming, Health, Media ReleasesHigh nitrate levels recently measured in the Tasman’s Waimea Plains signal yet another alarm bell for the health of our waterways, and the urgent need to reduce or eliminate the use of soluble nitrogen fertilisers, says the Soil & Health Association.
“Fencing off waterways and riparian planting is all well and good, but it’s not enough on its own to reduce the nitrogen leaching through soils to groundwater. We need to stop the problem at its source, namely the soluble nitrogen fertilisers being used by many farmers. It’s the elephant in the room,” says Marion Thomson, chair of the Soil & Health Association.
“The introduction of a resource consent for fertiliser use is a step in the right direction, but what is ultimately required is a transition to more sustainable methods of farming and cropping that do not rely on soluble nitrogen fertiliser applications,” says Thomson.
“We applaud the Freshwater Rescue Plan launched last week, and would like to see taxpayer money diverted from the Government’s irrigation fund put towards helping farmers transition towards high-value, climate-friendly organic and sustainable farming practices.”
“Healthier fresh water is achievable by shifting to organic and biological fertilising regimes and it’s heartening to see increasing numbers of farmers adopting these sustainable practices. Organic farming methods improve the soil biology and soil structure, which means better water retention and less nutrient leaching. Organic and biological farmers also make use of natural fertilisers, instead of soluble nitrogen fertilisers that are more prone to leaching.”
The soil is not a lifeless medium to pour nutrients into, according to Soil & Health. Organic farming encourages healthy living soils teeming with a biodiversity of species that all play their part in the ecosystem and the food chain, helping to make nutrients available to plants and animals.
Demand for organic food is growing exponentially as consumers seek out produce that is residue-free, tasty, nutritious and better for the environment and waterways.
https://www.freshwaterrescueplan.org
Take off the blindfold and eat!
/in Food, Media ReleasesKiwis want to take off the blindfold we have when it comes to buying food. That’s the message of the Soil & Health Association, which welcomes the Consumers’ Right to Know (Labelling of Country of Origin of Food) Bill currently before a parliamentary select committee. The Bill requires all single component foods, packaged and unpackaged, to display their country of origin.
Soil & Health has been campaigning for mandatory country of origin labelling for over a decade, since the government opted out of joining Australia in mandating country of origin labelling under the Food Standards Code on the grounds it would be an impediment to trade. With the exception of wine, country of origin labelling is only voluntary in New Zealand.
“All of New Zealand’s major trading partner countries have country of origin labelling including Australia, the US, the UK, countries in Europe and many Asian countries,” says Karen Summerhays, spokesperson for Soil & Health.
“While footwear and clothing is required to identify where it comes from, food isn’t. This bill aims to extend that requirement to fresh fruit, meat, fish and vegetables, and other single component foods such as grains, nuts, bulk flour and oil.”
“It’s becoming more common that New Zealanders are wanting to avoid genetically engineered food, food with pesticide residues, or food coming from countries with poor labour conditions, poor environmental and animal welfare standards, but cannot easily choose to avoid products from those countries when shopping here.”
“Pesticide residues in imported food and the health effects of them are an urgent consumer and health issue. Although good labelling exists in some supermarkets, voluntary labelling is often either not working or is poorly utilised, and is definitely not enforceable under the law.”
“Consumers must be able to make their own, informed food choices. Mandatory country of origin labelling is a step towards allowing consumers to do this,” says Summerhays.
There has been widespread support in New Zealand for country of origin labelling. A recent survey conducted by Consumer NZ and Horticulture NZ found that 71% of Kiwis want mandatory country of origin labelling and 65% said they looked for country of origin labelling when they were shopping.
The submission period for the Bill closes this Thursday the 18th of May at 5pm.
Soil & Health is one of the oldest organic organisations in the world and advocates for the consumer’s right to have fresh, healthy, organic food free of GE, pesticides and additives, and the right to know what is in their food and water.
Contact: Karen Summerhays
Spokesperson, Soil & Health Association
021 043 7858
Submission on Consumers’ Right to Know (Country of Origin of Food) Bill
/in SubmissionsCommittee Secretariat
Primary Production
Parliament Buildings
Wellington
Introduction
Detailed submission
Conclusion
Yours sincerely
Name: Mischa Davis
Position: Policy Advisor
The Soil & Health Association
PO Box 340002
Birkenhead
Auckland 0746
Phone: 06 8775534
Mobile: 0212667754
Email: advocacy@organicnz.org.nz
Website: www.organicnz.org.nz
Clean Water Consultation 2017
/in SubmissionsClean Water Consultation 2017
Ministry for the Environment
PO Box 10362
Wellington 6143
Clean Water Consultation 2017
Overview
Detailed submissions
Macroinvertebrate Community Index
Relief:
Dissolved inorganic nitrogen and dissolved reactive phosphorus
Relief:
Gaps
Relief:
Swimming
Terminology
Relief:
Qualifying as swimmable
Relief:
Waterbodies to which the target applies
Relief:
Monitoring
Relief:
Overarching Goal
Relief
NPSFM Consultation version text
Timeframes
Relief:
Objectives A2 and B1 – economic wellbeing
Relief:
Objective A2 – maintain or improve
Relief:
Policy A3 and Appendix 3
Relief:
STOCK EXCLUSION
Relief:
Measures not addressed in the Consultation Document
Yours sincerely
Name: Mischa Davis
Position: Policy advisor
The Soil & Health Association
PO Box 340002
Birkenhead
Auckland 0746
Phone: 021 266 7754
Email: advocacy@organicnz.org.nz
Website: www.organicnz.org.nz
[1] LWF letter to Ministers 19 August 2016.
[2] LWF letter to Ministers 19 August 2016.
[3] NPSFM Consultation Version pg 5 preamble.
[4] NPSFM Consultation Version 1 pg 10 interpretation, pg 23 Objective A3, pg 14 Policy A5.
[5] Ministry for the Environment & Stats NZ (2017). New Zealand’s Environmental Reporting Series: Our fresh water 2017. Retrieved from www.mfe.govt.nz and www.stats.govt.nz.
Photo credit: Mischa Davis