Last August, Consuelo Madre of Seminis, Monsanto’s Vegetable seed Business, announced that Seminis was going to sell a transgenic sweet corn product for 2012. The announcement was made at a media event at Monsanto’s global headquarters in St. Louis. 1 As well as being intended for the production of canned sweet corn that product is also being directed at the fresh market and is presumably hitting grocery store shelves now.
This is not the first biotech sweet corn. Syngenta, via its vegetable seed business, Rogers Brand Vegetable Seeds, introduced its Attribute brand GMO sweet corn seed in 1998. Attribute is BT11. It is the same trait as Agrisure CB.
Most biotech trait releases are associated with regulatory events, typically FDA acceptance of biosafety data followed by a statement that no unresolved issues exist, or EPA regisration in the case of plant produced pesticides. The events involved in the new Monsanto/Seminis products were approved long ago. The timing of the decision to release now relates to Monsanto’s image and public relations objectives.
The product has been branded by Seminis as Performance Series™ sweet corn. The stack that defines Performance Series™ sweet corn is made up of Mon88017 and Mon89034. This is the same combination which makes up Genuity® VT Triple PRO TM in field corn, which was introduced in 2010 after the approval of Mon89034 is a dual corn borer Bt product expressing Cry1A.105 and Cry2Ab2. 2 The product was registered by EPA in June 2008. 3 Mon88017 is a combination of a corn root worm and glyphosate resistance trait. The corn root worm resistance Bt involved is Cry3Bb1. Mon88017 had been registered earlier and used in combination with Mon810 in YieldGard VT Triple®. 4 It was the registration of Mon88034 which provided the regulatory approval for Genuity® VT Triple PRO. The Performance Series sweet corn did not require further regulatory approval.
Corn for the fresh market does have a certain psychological impact for consumers. Most people can picture themselves eating an ear of BT corn. Fortunately for the biotech originators we can also picture ourselves biting into a worm or even just encountering one when we shuck the ear. The choice against insects in the final product overrides any residual concerns about an extra gene in the genome of the kernels we bit into. Of course in practice Bt corn is an alternative to spraying for control of insects which damage ears for corn on the cob. Using insecticides to control earworm has always been a difficult task. The young worms live in the whole of the plant and are somewhat protected. One gets a chance for good control when the tassel emerges and the worms migrate to the ear. Once in the ear they are again protected and hard to kill with insecticide. Bt expressed in the whole plant makes control easier and avoids the use of much of the insecticide which is used in production of ear corn.
Insect-resistant Bt sweet corn (on left) helps growers reduce the number of sprays they need to produce a high-quality crop. Photo from Syngenta Seeds © 2011
Opposition to Monsanto’s New Sweet Corn Products
The groups which are opposed to biotechnology are disappointed that there is no regulatory event to protest associated with Performance Series hybrids. 5 The opposition takes particular offense that the product could be sold at local markets where organic consumers go for GM free products. In the sprite of not letting a potential crisis go to waste, the Center for Food Safety has organized opposition to the Monsanto move. Those of you who follow this site will be familiar with the involvement of the Center for Food Safety in opposition to GM turfgrass, GM sugarbeets, GM alfalfa, and 2,4-D tolerance. The man who runs it, Andrew Kimbrell, trained with Jeremy Rifkin and knows how to put together an activist campaign, and perhaps more importantly, he knows how to use the environmental impact provisions of the National Environmental Protection Act in federal court. Lacking a government office to target in this situation they have collected hundreds of thousands of signatures for a petition asking Wal-Mart not to sell the new Monsanto product. 6 They are currently promoting a campaign asking members of the public to send emails to the leadership of major sweet corn related businesses. 7 The suggested message includes the sentence:
Monsanto has announced it will sell this risky new corn for frozen and/or canned food companies, but since GMO foods are not labeled, consumers cannot tell when they shop if they may be buying this experimental new food [emphasis added]
Note that the focus is on risk and labeling justified by risk.
There has been substantial activist activity this year directed at labeling. I have not tried summarizing that recent activism. I will just list a couple of examples. The first was Occupy our Food Supply’s Global day of action on February 27. There is something of a report on the results here. As with the Occupy Movement in general it seems that the results did not indicate that the action was particularly effective. The driving force behind the movement seems to be the Rainforest Action Network. The second action which comes to mind is the Millions Against Monsanto campaign. The campaign is attempting to get a California bill requiring the labeling of food products with GM origins on the fall ballot, and is organizing a petition asking the FDA to label also. That action is organized by the Organic Consumers Association. Last year the Center for Food Safety had their own FDA petition campaign, called Just Label it. Their petition with 1.2 million signatures was submitted to FDA in September 2011. 8 These labeling activities deserve their own post.
These pro-labeling actions seem to be somewhat misguided from the perspective of those who accept the generally accepted scientific view that the there is no particular risk involved with the consumption of GM food. US law only calls for labeling if the consumer will benefit from the use of the information. Of course, the activists’ objections to the lack of labeling would be justified if one assumed that there was significant health risk associated with biotech food. That not being the case we have another indication that the objection in operationin this activist movement is an objection to the entire fabric of modern agriculture combined with the idea that there is a conspiracy at work to cover up problems.
Some of the less sophisticated protestors present old data which raises health questions in support of this new action. I found a site called Credo created by a group called Working Assets. 9 Working Assets specializes in collecting funds for groups like “Greenpeace, Doctors Without Borders, Planned Parenthood and the ACLU.” More importantly for those of us in the seed industry they have collected funds for Food Democracy Now! and the Organic Consumers Association. The Credo website makes reference to 3 scientific studies supporting risk associated with Monsanto’s new sweet corn products. The first refers to the famous rat feeding study involving Mon863. The article refers to a Huffington Post Article of 2011, making the study sound new. 10 But that article was actually posted in March 2010 and only updated in 2011. That Huffington post article is not in response to the study but in response to a blog by Randy Ananda in Jan. 2010. Randy Ananda keeps a website called Food Freedom dedicated to food safety activism. 11 She is not a scientific source. For that one has to go back to her references to the work of Gilles-Eric Séralini. Dr. Séralini did a well known re-analysis of some data on Mon863 which was published by Monsanto at the request of the regulatory authorities in Germany . The study was published in 2007. 12 The data itself was collected by scientific organizations contracted by Monsanto in 2000. The results have been gone over by various regulatory authorities around the world and found to be consistent with Mon863 being safe. Dr. Séralini was able to draw conclusions which found evidence of liver toxicity by subdividing the data. Generalized feeding studies like this track dozens and dozens of variables. The general standard for statistical significance is usually that if there is a 1 in 20 chance that a result is not the result of random variation it can be declared significant. In a large study with lots of individuals few results will pass the standard for significance. Out of 100 comparisons here there is no real difference one would expect 5 to be significant at the 0.95 level by chance. In smaller studies with few individuals there will be more results that are statistically significant because of random variation. By dividing the rat feeding study into smaller groups Dr. Séralini and company were able to generate a group of statistically significant results which could be talked about. And they have been talked about over and over by people like Ms. Ananda who don’t take the time to understand the statistics involved. In the intervening 10 years any number of groups like Greenpeace with ample funding could have repeated the Mon863 trial to see if they could duplicate the results. The scientifically astute among them choose not to do so because they know that there is very, very little chance that they could duplicate the patterns of variation which Dr. Séralini declared were important. The majority of those who use the study of Dr. Séralini as justification for health concerns are either misled or misleading. At best Dr. Séralini’s results were an invitation to further testing.
Citing Dr. Séralini’s work in reference to Mon88017 also suffers from the problem that Mon88017 and Mon863 are not the same trait, although they do express the same Bt toxin.
Roundup Ready is part of the Performance Series sweet corn package. This allows the Credo site to mention the January 17, 2011 letter of Dr. Huber to the USDA. The letter was about the possibility that Roundup, either glyphosate itself or the adjuvants use with it, might be associated with a new fungal pathogen of plants which might in turn produce mycotoxins which would damage animal and human health. The concern for the seed industry here is with the word “might,” the difference between what could possibly be happening and what actually is happening. Dr. Huber is a retired Purdue University plant pathologist with a record of finding potential problems with the use of roundup. 13 His letter prompted others as Purdue to give careful consideration to his assertions of health risk and loss from plant diseases. 14 The report points out that increases in disease effects on plants which have been sprayed with herbicides are possible but refutes the assertion that large increases in plant disease have appeared in U.S. Corn and Soybeans since the adoption of glyphosate tolerance. The authors also state some reasons for doubting that plant pathogens associated with Roundup use would be having any impact on human health. Dr. Huber’s observations do not seem to have led to confirmation of his fears. Scientific theories are not science because they have been proposed by scientist but because those theories have been confirmed by correspondence to the world they are trying to describe.
The third health risk related reference in the Credo site is a reference to a study done in Canada which found Cry1Ac Bt toxin, glyphosate, glyphosate breakdown products, and glufosinate in the blood of non-pregnant women, pregnant women and the umbilical cords of the babies of the pregnant women. The study by Aziz Aris and Samuel Leblanc was reported in early 2011. 15 There was not any indication that the substances detected were producing any negative health effects. The results of the study with respect to Bt was surprising in that a lot of previous work had indicated that most of the Bt proteins used in biotech crops, with the notable exception of the StarLink protein, brake down quickly in the gut. I have not researched the reaction to the study, but the authors were using Elisa tests for the detection of the Bt protein. Elisa tests are well known to give false positives in situations where the target protein is mixed with proteins which may interact with the Elisa compound. The positive results might disappear with other blood purification protocols. For those of you who are not familiar with the test, Elisa stands for enzyme linked immunosorbent assay. The “immuno” part gives you some indication of why the assay might go wrong. The assay depends on immunological attachments between the elisa compound and the target protein. It is possible for the elisa compound to attach to non-target proteins if they have a certain configurations and electro chemical patterns. There was a useful early analysis of the Aziz Aris and Samuel Leblanc article at which was assembled by Marcel Kuntz shortly after its release. 16 That article pointed out that the test was known to be weak in blood. Understanding of the implications of this study requires more research than I have allocated to it, but the study is anything but a confirmation of negative health impact of biotech traits.
If the groups involved had substantive new data they would be petitioning the EPA, rather than petitioning Wal-Mart. I have not found any new substantive new scientific food safety findings which support the decisions of the activists to protest Monsanto’s Performance Series sweet corn. The pattern of their research use is that research suggesting a concern will cited in activist literature repeatedly, but activist organizations will not support scientific studies to confirm the concerns. To be fair, trait originators hesitate to conduct some kinds of follow on studies also. The activist fear that bad things will not repeat and trait originators fear that good ones will not. The random nature of quantitative data would generate some of both if new experiments were conducted, especially if the test are of general health involving large number of traits.
The more sophisticated players in this activist program put less reliance on these weak links to negative health effects and more emphasis on more philosophical arguments which are harder to refute. Here is an example. The Center for Environmental Health cooperated in the CFS petition drive last year. This quote comes from the CFS website promoting the drive:
Charles Margulis, food program coordinator at the Center for Environmental Health. “This untested, unlabeled corn has no place on Wal-Mart shelves. We expect swift action by the world’s largest retailer to protect their consumers’ right to safe food choices.” [Emphasis added]
The world “untested” is important. Much of the opposition to existing agricultural biotechnology is associated with this accusation. There is a philosophical question here. Science is about the creation of knowledge. The application of that knowledge is not science as such. It is technology, engineering or agronomy. Sometimes it is the application of knowledge in regulation. Opponents of biotechnology are willing to use the tautology that the application of science is not science when it suits their rhetorical purpose, but they do not point out that most technical regulation is about applying existing science rather than testing every application. We do not wait for earthquakes before we move into new buildings. We insist that existing knowledge is applied when constructing them.
The regulation of biotechnology, like most regulation, relies heavily on existing knowledge. Rejection of regulatory decisions because existing knowledge about the world is incomplete has the potential to bring a lot of innovation to a stop. From a high level, opponents justify the extreme measures they recommend for testing in the regulation of biotechnology on arguments about the extreme novelty of biotechnology, or sometimes on the extreme ill intent of the commercial developers of agricultural biotechnology. The choice between the two depends on whether they come from the originally conservative but now postmodern tradition of rejection of the impact of technology on society, or from either the socialist and Marxist tradition that the individualism of business translates to greed and evil or the social conservatives who hold something similar, but with more tolerance of some private property. 17
From the standpoint of people who don’t hold either of these positions, the campaign about the acceptance of BT sweet corn is bit of a puzzle. From the perspective of a community which assumes that Monsanto is selfish and evil, it makes sense that Monsanto’s biotech sweet corn causes protest when Syngenta’s produced little commentary for 14 years. For this perspective all business is bad and if someone is successful then they must be really bad.
From the position of those who think that the world should be left as God or mother nature made it, science and technology cannot be trusted and both lead people away from the proper path to righteousness, and anything that can be done at any time to delay the development of such technology is a moral act. Unfortunately it is very difficult to argue against these positions in the normal scope of seed industry public relations. We normally and wisely focus on the positive side of our position: the material benefits of biotechnology, the scientific basis of the decisions which have been made about regulation, and the rights of farmers to make decisions about the best means to manage their production activities.
The sweet corn seed business is not large in the big scope of the seed industry. Keeping the focus of public consideration of biotechnology on the scientific basis of the regulation for biotechnology is very much in the interested of the seed industry and indirectly in the interests of our customers and the public in general.
1 Jack Kelsey, Monsanto To Sell Biotech Sweet Corn For U.S. Consumers, Bloomberg News, August 4, 2011.
2 Executive summary of Safety Assessment of Mon88034
3 EPA Biopesticide Registration Action Document Bacillus thuringiensis Cry1A.105 and Cry2Ab2 Insecticidal Proteins and the Genetic Material Necessary for Their Production in Corn
5 Randy Ananda, Monsanto GM Corn in Peril: Beetle develops Bt-resistance, Food Freedom Blog, August 24, 2011.
6 Pressure on Walmart to Rebuff GE Sweet Corn Intensifies, March 15, 2012
7 Center for Food Safety, Keep Pesticide-Ridden Corn Off Your Dinner Plate
10 Katherine Goldstein and Gazelle Emami, Monsanto’s GMO Corn Linked To Organ Failure, Study Reveals, Huffington Post, First Posted: 03/18/10 06, Updated: 05/25/11
12 Séralini G-E, Cellier D & de Vendomois JS (2007) New analysis of a rat feeding study with a genetically modified maize reveals signs of hepatorenal toxicity. Archives of Environmental Contamination & Toxicology. 52: 596-602
13 Monsanto, Statement About Alleged Plant Pathogen Potentially Associated with Roundup Ready Crops, Feb. 11, 2011.
14 Jim Camberato, Extension Soil Fertility Specialist, Purdue University; Shaun Casteel, Extension Soybean Agronomist, Purdue University; Peter Goldsbrough, Department Head, Botany and Plant Pathology Department, Purdue University; Bill Johnson, Extension Weed Scientist, Purdue University; Kiersten Wise, Extension Field Crop Pathologist, Purdue University; Charles Woloshuk, Extension Corn/Mycotoxin Pathologist, Purdue University;
15 Aris A, Leblanc S Maternal and fetal exposure to pesticides associated to genetically modified foods in Eastern Townships of Quebec, Canada, Reproductive Toxicology, 2011 May;31(4):528-33. Epub 2011 Feb 18..
16 Marcel Kuntz, Many Women no Cry. When David Tribe posted the article he gave the article an interesting title: If you record noise, you don’t get music — you get nonsense.
17 Those who are interested can consider the Quadrogesimo Anno encyclical of Pius XI in1931. The Catholic Church tried to show which economic approach is in keeping with the faith. The system he proposed was a corporatist system in which representatives of various sectors of society negotiated social and economic organization. The economic thought of M.K. Gandhi provides another conservative example.
Seed Key words:
Monsanto, seed, sweet corn, Performance Series, Wal-Mart, Seminis, Syngenta, Attribute, public relations, agricultural biotechnology, biotech, seed industry.