by Dr. Michael W. Fox, Senior Scholar/Bioethics The Humane Society of the United
States 2100 L Street, NW Washington, DC 20037

To regard genetically engineered GE crops and food as being infected or adulterated
and therefore posing potential risks to human and other consumers (including insects,
birds, and wild and domesticated mammals) and to the environment is not
unreasonable considering the following scientifically documented findings:

1. There is evidence that foreign DNA can enter the body via the gastrointestinal tract
and cross the placenta (1,2).

2. Genetically modified organisms can produce unanticipated toxins (3,4) or allergens
(5).

3. Gene transfer can occur between transgenic plants and bacteria, the ecological
consequences of which could be catastrophic (6).

4. Milk from cows injected with rBGH, which is not analogous to normal BGH, has
elevated insulin-like growth factor that is implicated as a risk factor in human breast
cancer (8,9).

5. Considering the documented evidence that horizontal gene transfer between species is
a natural phenomenon (10-16), the precautionary principle must be applied in creating
transgenic organisms that could transfer novel genes and viral vectors to other species
(17-19). The ecological, evolutionary, and public health consequences of such transfers
we will only know after the fact. Horizontal gene transfer is even likely to take place in
the digestive systems of protozoa, nematodes, insect larvae, and other soil
macro-organisms (12).

6. That genes, like viruses, can infect the body (20,21), should serve as a warning to us
all of the potential risks of transgenic organisms serving as a resevoir for new diseases,
and as a medium for the evolution of new pathogens because of their altered physiology
and biochemistry. Viral ìpromotersî and ìenhancersî that boost expression of transgenes
could result in the production of high levels of Bt. toxin and other chemicals in
transgenic crops.

7. Unanticipated multiple side effects of of gene insertion (called pleotropic effects) have
been well documented. Genetic alterations in crops like soybeans to make them resistent
to herbicides may result in unpredictable, unnatural genetic recombinations and change
the biochemistry and nutritive value. Higher levels of phyto-estrogens are produced in
beans grown in the presence of the herbicide glyphosate which may be of particular risk
to children (22).

8. Some 99 percent of commercial transgenic crops incorporate virus genes, either as
promoters or to control virus infections. These virus genes can recombine with other
viruses and may result in new diseases and more invasive pathogens (23-27). With the
inclusion of antibiotic-resistance markers, transgenic crops could therefore increase the
probability of new viral and bacterial pathogens and the spread of antibiotic and drug
resistance genes. DNA released from living and dead cells can persist in the
environment and be transferred to other organisms. An organism may be dead, but its
"naked" DNA released from decaying cells may remain biologically active for
potentially thousands of years, especially in certain soils and marine sediments. (28,29).
Naked DNA (nucleic acids) ingested by mice can be transferred to offspring and be
voided and spread in animals' feces (2).

9. The instability of transgenic crops is a major concern. ìThere is, in fact, no data
documenting the stability of any transgenic line in gene expression, or in structure and
location of the insert in the genome. Such data must include the level of gene expression,
as well as a genetic map and DNA base sequence of the insert and its site of insertion in
the host genome in each successive generation. No such information has ever been
provided by industry, nor requested by regulatory authorities.î (28).

10. One must consider not only the ìfateî of transgenic organisms but also the genes and
viruses or parts thereof, that have been inserted into them. Such ìnaked DNAî, in the
form of recombinant and modified nucleic acids, has been found capable of surviving
and remaining functional longer after organisms' death than was assumed previously.
(6, 29) Furthermore, xenobiotics, especially dioxins and various agrichemicals, can act as
mutagens (30), altering the structure and sequence of DNA and also increasing the
permeability of cells and the incorporation of foreign DNA into living organisms.

Contamination of the ìlife streamî by naked recombinant DNA, by transgenic viral
vectors, and antibiotic resistant genes is already taking place. Since a recall is
impossible, our best hope, if it is not already too late to control genetic pollution, is a
five-year worldwide moratorium on the creation and release of all genetically
engineered living entities and products, from new vaccines to transgenic crops, so that
science-based risk assessments can be properly completed.