COMMENTS BY THE AFRICAN CENTRE FOR BIOSAFETY AND THE CENTRE FOR FOOD SAFETY (USA)
Comments on Syngenta’s Application for Commodity Clearance of Genetically Modified Maize, Event 3272
African Centre for Biosafety & Centre for Food Safety, 29 May 2006
Syngenta’s Event 3272 maize represents the very first genetically modified (GM) industrial crop for which commodity clearance is sought from the National Department of Agriculture. The intended industrial application is for fuel ethanol production: “In those countries where Event 3272 maize will be cultivated (not in South Africa), the grain will be used in the dry-grind fuel ethanol process.” (NDA 2006) In fact, it is the first such GM industrial crop for which any sort of commercial approval (whether for cultivation or import) has been sought anywhere in the world. This raises the question of how such a GM crop should be regulated.
Event 3272 is not just another GM corn variety. It is the first GM crop to be proposed for commercial approval that has been specifically modified for an industrial use. It contains a novel enzyme derived from little-known deep-sea organisms. It belongs to a class of enzymes known to cause allergies, and exhibits extreme thermostability, a characteristic of food allergens.
The hazardous unintended effects that top scientists (such as Harry Kuiper, a leading EU GM food safety expert) believe can be caused by the genetic modification process deserve much more intensive analysis than has been accorded to GM crops in the past. Because maize is a staple food of South Africa, it is incumbent on regulatory authorities to assess this novel crop rigorously certainly more rigorously than the often pro forma assessments conducted by U.S. (and increasingly EU) regulatory authorities, where maize in particular is a minor part of the food supply.
Accordingly, we urge NDA to demand an allergenicity assessment in strict accordance with the internationally recognized standard, FAOWHO (2001). For other safety issues, we recommend the GM crop safety testing scheme outlined in Freese & Schubert (2004). In particular, long-term (lifetime) rodent feeding trials with the whole crop are absolutely essentially to detect more subtle, but potentially quite serious, health impacts such as endocrine disruption, reproductive disorders and cancers.
With respect to reproductive disorders, it is absolutely essential that Event 3272 be tested for the presence of tetrahydrofuran-diol and leukotoxin-diol derivatives of linoleic acid (Markaverich 2002, 2005). It is also unclear why the National Dept. of Agriculture is being asked to give complete food and feed import approval to a crop that its developer says will be limited to use in ethanol production. Granting commodity clearance would remove Event 3272 from any further oversight by NDA, no matter how Syngenta decides to market this crop in the future. It is also worth noting that Event 3272 has not been approved anywhere in the world, even in the U.S., which at present is the only country where approval for cultivation is being sought. What is the rush to approve import of a crop that may never even be approved for cultivation or commercialized?
Surely there is no need to rush this. Finally, the existence of a “stand-alone” version of Event 3272’s incorporated alpha-amylase argues strongly that there is no pressing need for this GM maize variety at all. We respectfully urge you to protect South African citizens by conducting a rigorous assessment of Event 3272, and to defer any decision until such time as all relevant data has been collected and considered.