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Department of Agronomy, Univ. of Wisconsin, 1575 Linden Dr., Madison, WI 53706 USA
hfkaeppl{at}facstaff.wisc.edu
| ABSTRACT |
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Abbreviations: GM, genetically modified FDA, Food and Drug Administration USEPA, U.S. Environmental Protection Agency USDA, U.S. Department of Agriculture APHIS, Animal and Plant Health Inspection Service GRAS, generally recognized as safe ECSCF, European Commission Scientific Committee for Food
| INTRODUCTION |
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Throughout the development and commercialization of transgenic crops, health and food safety concerns have been raised and regulatory procedures established to ensure the safety of GM foods. The main concerns voiced have been questions about the potential of GM crops to:
Issues of food safety from GM crops came to the fore with a report that a greater number of laboratory rats (Rattus rattus) suffered from abnormalities in their small intestines after 10 d of feeding on GM potato diets (Solanum tuberosum L.), relative to those feeding on non-GM potato diets (Ewen and Pusztai, 1999). In an extraordinarily unusual step within the scientific field, the same journal that published the paper simultaneously published the rebuttal (Kuiper et al., 1999). The rebuttal made it clear that the potato diet was inappropriate for rats, that similar intestinal abnormalities are well known in rats fed similar diets, and that the sample size (six rats) was too small to draw any conclusions.
The report by Ewen and Pusztai (1999) was seized upon by anti-GM advocates to support their contention that proper regulatory oversight is either lacking or inadequate. This paper was written to address those concerns and to provide information on the assessment criteria and regulatory mechanisms that are in place in the U.S. to ensure the safety of GM foods.
| Safety Assurance for Foods Derived from Genetically Modified Crops |
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The Federal Food, Drug, and Cosmetic Act grants the FDA authority to regulate commercialization and marketing of most domestic and imported foods in the U.S. market. Under the 1992 Policy interpretation (USFDA, 1992), GM foods and food ingredients must comply with the same standards that apply to other food products. This means that GM foods must be as safe and nutritious as their non-GM counterparts in grocery stores today. The Act places legal duty on developers to ensure that the foods they market to consumers are safe to eat. Transgenic crops containing novel proteins classified as food additives are subjected to additional testing and must receive premarket approval by the FDA before commercialization, while whole foods made from transgenic crops passing GRAS (generally recognized as safe) standards are subject to FDA regulation after commercialization. The FDA has the broad authority to take legal action against developers of any food or food additive that poses a hazard to the public.
The FDA published its 1992 policy to assist developers in addressing food safety and regulatory issues before products reach the market. The policy statement contains a comprehensive "guidance to industry" section that discusses scientific issues for assuring food safety and identifies scientific and regulatory questions that developers must consider to determine if they should consult with the FDA before commercial release of a genetically engineered food crop. Developers are encouraged to consult with the FDA through the Office of Premarket Approval of the Center for Food Safety and Applied Nutrition and the Office of Surveillance and Compliance of the Center for Veterinary Medicine before the commercialization of a new GM variety to ensure that the variety will meet all safety requirements. The FDA requires a full evaluation of a genetically engineered food crop when uncharacterized DNA sequences are used, or when food products may contain significantly altered nutrient levels, different compositions from substances currently found in foods, allergenic proteins, new antibiotic resistance markers, or levels of toxins significantly above those found naturally in edible varieties of the same species.
| Inadvertent Synthesis or Increase in Toxins |
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Another concern is the potential for silent toxin pathways to be reactivated in GM crops due to the genetic engineering process. Plants, like other organisms, have metabolic pathways that no longer function due to mutations that occurred during evolution. Products or intermediates from some of these pathways may be toxins. Questions have been raised as to the potential for genetic engineering to reactivate those pathways. However, a determination was made that the likelihood of such events occurring in food plants with a long history of safe use is remote, and that the potential would likely have been detected during breeding evaluations of the crop and its use for food (reviewed in Kessler et al., 1992). Currently, all transgenic food crops approved for commercialization in the USA (e.g., corn, soybean, potato, etc.) have long histories of breeding and use as foods, and this history can be used to evaluate potential for toxin production. Transgenic crops that have breeding and/or food use histories that indicate a potential for toxin production are subject to a full food safety evaluation prior to commercialization. Similar safety evaluations would be necessary for new crops lacking a long history of breeding and use in food, since the potential for toxin production would be difficult to predict in these crops.
Toxins present in the food supply do not necessarily come from the plant itself, but rather can come from pathogens growing on the plant. A recent report (Munkvold et al., 1999) indicates that corn engineered to resist the European corn borer (Ostrina nubilalis) has lower concentrations of the fungal mycotoxin, fumonisin. The corn borer wounds the plant and facilitates infection by Fusarium ear rot (Fusarium verticilliodes), hence reductions in insect damage lead to reductions in fungal infection, which ultimately lead to lower levels of fungal toxin accumulation.
| Changes in Essential Nutrients |
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Genetically modified crops are being developed with enhanced nutritional qualities, such as increased iron or vitamin A content in edible plant parts (Goto et al., 1999; Ye et al., 2000). In such cases, the transgenic crop could be subject to a full food safety evaluation before approval for commercialization and to labeling requirements following commercialization (USFDA, 1992).
A recent paper by Lappé et al. (1998) reported that GM soybean had lower levels of isoflavones, considered important for human health, than non-GM soybean, which allegedly demonstrates the inadequacy of the current regulatory system. The American Soybean Association promptly reacted by providing documentation that the changes observed by Lappé et al. (1998) were well within the normal range of isoflavone concentrations for soybean (ASA, 1999).
| Introduction of Allergens |
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Guidelines for assessing the allergenic potential of GM crops were established by the FDA following extensive review of research on food allergies and consultation with leading researchers in the areas of food safety, food allergies, immunology, biotechnology, and diagnostics (USFDA, 1994). Under FDA guidelines, developers of crops engineered with transgenes from any of the foods listed above are instructed to demonstrate scientifically that the allergenic substance is not present in the new food.
All known food allergens are proteins, many of which share several features: amino acid sequence similarity to each other, molecular weight between 10 and 70 kDa, glycosylation, acidic isoelectric points, and resistance to heat, acid treatment, proteolysis, and digestion (reviewed in Lehrer et al., 1996; Taylor and Lehrer, 1996). Nevertheless, exceptions exist. Therefore, to ensure that new GM crops do not contain a new allergen, its allergenic potential must be assessed based on:
To aid in evaluation of those criteria, a decision tree strategy was formulated (Metcalfe et al., 1996). If the answer is yes to any of the questions posed in the diagram, specific tests and assays are recommended. If allergenic potential is indicated, the FDA will require labeling to inform consumers of the allergenic potential, or to take legal action against commercialization.
To illustrate how the regulatory system works, Pioneer Hi-Bred International scientists introduced a gene from the Brazil nut (Bertholletia excelsa Humb. & Bonpl.) into soybean to improve the methionine content of the protein. Because allergic reactions to Brazil nut had been previously documented, skin prick tests, inhibition immunoassays, and immunoblotting were recommended for testing the allergenic potential of the Brazil nut protein engineered into soybean. During the required evaluation process, the protein made by the introduced gene was found to be allergenic (Nordlee et al., 1996), and Pioneer announced it was discontinuing the work with the Brazil nut gene.
| Reduced Efficacy of Antibiotics |
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Early in the development of transgenic crops, a concern was raised that the transfer of the antibiotic resistance transgene from plants to pathogens in the environment or in the gut of humans or animals would compromise antibiotic therapy by rendering pathogens immune to the effects of the antibiotic. Accordingly, the 1992 FDA policy statement (USFDA, 1992) and the recently published Guidance for Industry: Use of Antibiotic Resistance Marker Genes in Transgenic Plants (USFDA, 1998) specifically discuss the safety evaluation of GM crops and food products containing antibiotic resistance transgenes, by addressing:
These guidelines were established following consultation with experts in the fields of microbiology, medicine, bacterial and mycotic diseases, and food safety. Additional confirmation of the guidelines' ability to ensure that GM crops containing antibiotic resistance transgenes are safe was provided by national and international food safety regulatory agencies including the USEPA, the European Commission Scientific Committees for Food and Animal Nutrition, the Nordic Working Group on Food Toxicology and Risk Assessment, and the World Health Organization/Food and Agriculture Organization (ECSCF, 1996; Karenlampi, 1996; USEPA, 1994; WHO, 1993, 1996).
The antibiotic resistance transgene used to develop the GM crop plants currently in the market is the NPTII or APH(3')II gene, which provides resistance to the antibiotics kanamycin and neomycin by detoxifying them (reviewed in Flavell et al., 1992). A detailed description of the safety assessment of the NPTII gene and its protein product is provided by Calgene (1990), by USFDA (1994) and in the USFDA Guidance to Industry: Use of Antibiotic Resistance Marker Genes in Transgenic Plants (1998). In accordance with the criteria listed earlier, the NPTII gene was deemed safe for use (Calgene, 1990; reviewed in Flavell et al., 1992) based on the following:
Similar data were presented to demonstrate the safety of the NPTII gene in animal feed and in exposure of soil microorganisms to GM crops in large-scale production scenarios (USFDA, 1998).
Because the DNA used for genetic engineering is produced inside bacteria, a second antibiotic resistance gene, one expressed only in bacteria, is used to permit the preferential growth of bacterial cells containing the engineered DNA. One gene used frequently for the purpose is the bla or ampR gene, which gives resistance to ampicillin. Whenever a gene gun is used to engineer a plant, the bla gene can also get incorporated into the plant. Such is the case with Bt maize (Zea mays L.) developed by Novartis. However, the ampicillin gene is designed to express only in bacteria, and never in a plant tissue. Because no protein product is produced in plants by the ampicillin gene, its use has been deemed safe (USFDA, 1998).
The conclusion that the NPTII and the ampicillin resistance genes are safe to use in GM crops has also been reached by other scientific panels and regulatory agencies (USEPA, 1994; Karenlampi, 1996; ECSCF, 1996; WHO, 1993). Agreement among independent international organizations regarding the approval and safety of antibiotic resistance markers should reassure consumers of the safety of GM foods containing antibiotic resistance genes.
Nevertheless, the opposite has happened. The presence of the bla gene, and fears that it will be transferred from GM crops into pathogens in the environment, was cited as the specific reason why the European Union denied approval of the Novartis Bt maize (Salyers, 1996). Ironically, the ampicillin resistance gene was found and isolated in London, in 1963 (Sutcliffe, 1978), indicating the ampicillin resistance gene is already present in the European environment, and has been since long before GM crops were ever envisioned.
Finally, although evaluation of the safety of antibiotic resistance markers will continue as needed, it may become unnecessary in the future as new, nonresistance based selectable markers are being developed and used in place of antibiotic resistance markers (Ebinuma et al., 1997; Haldrup et al., 1998; Kaeppler et al., 2000).
| Summary |
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lrd/biotechm.html = FDA/CFSAN Biotechnology page
lrd/fr92529b.html = 1992 FDA Policy Statement
Received for publication January 31, 2000.
| REFERENCES |
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This article has been cited by other articles:
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J. G. Jewett, J. Barton, and M. Jordan Comments on the "Biotechnology Forum" section. Agron. J. 92:792-806 (2000). Agron. J., November 1, 2001; 93(6): 1405 - 1406. [Full Text] [PDF] |
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J. E. Barton and M. Dracup Genetically Modified Crops and the Environment Agron. J., July 1, 2000; 92(4): 797 - 803. [Abstract] [Full Text] |
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