Ecological Society of America voices concern

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THIRD WORLD NETWORK BIOSAFETY INFORMATION SERVICE

15 June 2004

Dear Friends and colleagues,

RE: ECOLOGICAL SOCIETY OF AMERICA VOICES CONCERN

In a position paper published in earlier this year, the Ecological Society of America listed its concern about the environmental impact of GMOs and suggested recommendations in addressing them.

The paper reviews both current status and future prospects of all GMOs (plant, animal, virus,

bacteria, etc.), and provide what is considered “the most comprehensive review to date.” With over 170 cited references, it is a rich resource for anyone interested in the environmental consequences of GEOs.

The paper entitled “Genetically engineered organisms and the environment: current status

and recommendations” is available online at

http://www.esa.org/pao/esaPositions/Papers/geo_position.htm. The Executive Summary of the report and a review of the full paper are attached below.

With best wishes,

Lim Li Lin and Chee Yoke Heong

Third World Network

121-S Jalan Utama

10450 Penang

Malaysia

Email: twnet@po.jaring.my

Website: www.twnside.org.sg

REF: Doc.TWN/Biosafety/2004/G

THE ECOLOGICAL SOCIETY OF AMERICA VOICES ITS CONCERNS ISB News Report, USA, by Michelle Marvier

http://www.isb.vt.edu/news/2004/news04.may.html

5 May 2004

THE ECOLOGICAL SOCIETY OF AMERICA VOICES ITS CONCERNS

Almost every week, major newspapers carry some sort of story about genetically engineered organisms (GEO’s). The headlines range from promises of feeding the world, to corporate malfeasance, to the mislabeling of food, or the latest accidental release. With the media’s propensity for sensationalism, it is hard to sort through all of these stories and find a level-headed discussion of risks and policy options. Into this hubbub comes a new position paper from the Ecological Society of America (ESA) entitled “Genetically modified organisms and the environment: current status and recommendations [1.]” This paper was authored by a team of well respected ecologists-Allison Snow, David Andow, Paul Gepts, Eric Hallerman, Alison Power, James Tiedje, and LaReesa Wolfenbarger-each of whom has expertise in some aspect of the environmental risk assessment of GEO’s. As an official position paper, the manuscript underwent extensive peer-review and has received the approval of the ESA Governing Board. The paper (available at http://www.esa.org/pao/esaPositions/Papers/geo_position.htm ) is both a position statement, complete with direct recommendations regarding the development, risk assessment, and regulation of GEOs, and a thorough review that will help readers navigate the fast-paced developments regarding the environmental effects of GEOs and their risk assessment.

Although the environmental effects of GEOs have been reviewed previously, most past reviews focus on either a subset of organisms (e.g., GE plants) or a subset of GE traits (e.g., herbicide resistance). By reviewing both current status and future prospects of all GEOs (plant, animal, virus, bacteria, etc.), the authors provide the most comprehensive review to date. The literature cited section alone, with over 170 cited references, is a tremendously valuable resource for anyone interested in the environmental consequences of GEOs. This paper will also help readers appreciate the amazing variety of applications to which genetic engineering has been or will be applied. Indeed, the potential applications of genetic engineering appear to be limited only by our imaginations, and the ever-expanding breadth of these applications is highlighted in five text boxes within the position paper.

In our fervor for progress, however, there are some important issues that tend to get overlooked. The ESA position statement does an excellent job of reminding us of the salient concerns. The review offers six clear and well-reasoned recommendations regarding the future and on-going evaluation of environmental effects associated with GEOs. Below, I quote and comment upon each of these six recommendations (italicized text is quoted directly from the position paper):

1. Early planning in GEO development - GEOs should be designed to reduce unwanted environmental risks by incorporating specific genetic features, which might include sterility, reduced fitness, inducible rather than constitutive gene expression, and the absence of undesirable selectable markers.

Although early planning to avoid problems is obviously a wise recommendation, a recent report from the National Research Council cautioned that no means of biological containment will be foolproof and that incorporating several distinct mechanisms of biological containment into a GEO will help to delay, but not entirely prevent, transgene escape [2]. Genetic mechanisms for biological containment will help to reduce risk, but they are no silver bullet solution. Recommendations to shift toward inducible gene expression should be especially helpful in delaying the evolution of resistance among pest species targeted by transgenic traits.

2. Analyses of environmental benefits and risks - Rigorous, well-designed studies of the benefits and risks associated with GEOs are needed.

It is worth reiterating here the authors’ point that the presumed benefits of GEOs are often taken for granted, but that these benefits (especially the environmental benefits) have not been well documented. To actually test whether the anticipated benefits are materializing will require much better data on the geographic patterns of GEO implementation than are currently available. But it is not only the benefits that have been poorly quantified. The risk assessment studies used to support decisions for deregulation suffer almost universally from poor replication, short duration, small scale, and other design flaws that greatly reduce their chance of detecting an existing problem [3]. Improving studies of both benefit and risk will require improved communication and cooperation among ecologists, molecular biologists, and other scientists with diverse expertise.

3. Preventing the release of unwanted GEOs - Strict confinement of GEOs is often impossible after large-scale field releases have occurred. Therefore, we recommend that large-scale or commercial release of GEOs be prevented if scientific knowledge about possible risks is inadequate or if existing knowledge suggests the potential for serious unwanted environmental (or human health) effects.

Here the authors make the often overlooked point that some releases of GEOs may be irreversible, and that this potential for irreversibility should invoke a precautionary approach. All too often, the release of GEOs has been compared to the release of an agrichemical e.g. [4] . In fact, GEOs and agrichemicals are fundamentally different-chemicals eventually degrade and become diluted as they spread, whereas transgenes have the potential to persist indefinitely and to spread without dilution. Certainly, we should proceed more cautiously when we may not be able to return the environment to its original state.

4. Monitoring of commercial GEOs -Well-designed monitoring will be crucial to identify, manage, and mitigate environmental risks when there are reasons to suspect possible problems. In some cases, post-release monitoring may detect environmental risks that were not evident in small- scale, pre-commercial risk evaluations. Because environmental monitoring is expensive, a clear system of adaptive management is needed so that monitoring data can be used effectively in environmental and regulatory decision-making.

The authors argue not only that risk assessment studies should be made more rigorous, but also that no matter how rigorous these pre-release studies become, they will always fall short when it comes to detecting certain low probability or low magnitude effects. Because of these problems, post-release monitoring will be essential. Several creative possibilities for initiating such a system are discussed within the paper.

5. Regulatory considerations -Science-based regulation should: (a) subject all transgenic organisms to a similar risk assessment framework, (b) recognize that many environmental risks are GEO- and site-specific, and therefore that risk analysis should be tailored to particular applications, and (c) incorporate a cautious approach to environmental risk analysis.

The timing of the release of this paper couldn’t be better as the USDA is currently considering modifying its regulations regarding GEOs [5]. Hopefully, federal regulators will take notice of these recommendations and incorporate many of them into their new rules.

6. Multidisciplinary training - Ecologists, agricultural scientists, molecular biologists, and others need broader training to address the above recommendations. We strongly encourage greater multidisciplinary training and collaborative, multidisciplinary research on the environmental risks and benefits of GEOs.

Given that the current trend in biological education is to move toward ever more specialized curricula, calls for multidisciplinary training seem to be falling on deaf ears. But having a narrow background can lead to some highly undesirable consequences. For example, I recently met a scientist from India who was working to genetically engineer an endangered fish so that it might better tolerate waters that had become intensely polluted with heavy metals. With just a little training in ecology, this molecular biologist would likely have recognized the foolishness of his research ambition-after all, having one species of fish tolerate heavy metals would only mean those metals could be accumulated and passed up the food chain, possibly even to humans. The need for breadth in biological training simply cannot be overstated. Ecology is a science that has documented numerous indirect linkages among species and environmental surprises following disturbances-this is a perspective too often lacking in the training of molecular biologists. Conversely, ecologists often shun biotechnology without appreciating the opportunities it offers.

Overall, the ESA position paper on GEOs provides balanced and concrete advice for scientists and regulators. The message of this paper, the scientific credentials of its authors, and its rigorous peer-review combine to make it a must-read for anyone involved in the policy or science of GEO risk assessment. Sadly, when one considers recent mishaps with corn engineered to produce pharmaceuticals [6], the gap between the recommendations made in the ESA position paper and reality is huge.

Michelle Marvier

Biology Department and Environmental Studies Institute

Santa Clara University

mmarvier@scu.edu

Literature Cited

1. Snow AA, Andow DA, Gepts P, Hallerman EM, Power A, Tiedje JM, Wolfenbarger LL. (2004) Genetically engineered organisms and the environment: current status and recommendations. http://www.esa.org/pao/esaPositions/Papers/geo_position.htm

2. NRC (2004) Biological confinement of genetically engineered crops . The National Academies Press: Washington, D.C.

3. Marvier MA. (2002) Improving risk assessment for nontarget safety of transgenic crops. Ecological Applications 12:1119-1124.

4. Freckleton RP, Sutherland WJ, Watkinson AR. (2003) Deciding the future of GM crops in Europe. Science 302: 994-996.

5. Gewin V. (2004) New ways to regulate GMOs. Frontiers in Ecology and the Environment 2:60.

6. Gillis J. (2002) Soybeans mixed with altered corn; Suspect crop stopped from getting into food. The Washington Post November 13, 2002

Item 2

ESA Position Paper Submitted to the ESA Governing Board November 21, 2003

Accepted by the ESA Governing Board February 26, 2004

“Genetically engineered organisms and the environment: Current status and recommendations”

A. A. Snow1., D. A. Andow2., P. Gepts3., E. M. Hallerman4., A. Power5., J. M. Tiedje6., and L. L. Wolfenbarger7.

1.Department of Evolution, Ecology, and Organismal Biology, Ohio State University, Columbus, OH 43210-1293 USA

2.Department of Entomology and Center for Community Genetics, University of Minnesota, St. Paul, MN 55108 USA

3.Department of Agronomy and Range Science, University of California at Davis, Davis, CA 95616-8515 USA

4.Department of Fisheries and Wildlife Sciences, Virginia Polytechnic Institute and State University, Blacksburg, VA 24061-0321 USA

5.Department of Ecology and Evolutionary Biology, Cornell University, Ithaca, NY 14853-2701 USA

6.Center for Microbial Ecology, Michigan State University, East Lansing, MI 48824-1325 USA

7.Department of Biology, University of Nebraska at Omaha, Omaha, NE 68182-0040 USA

Key words: biosafety, environmental risks and benefits of genetic engineering, genetically modified organisms, monitoring, benefit and risk assessment, risk management, transgenic, agriculture, aquaculture, ecology

EXECUTIVE SUMMARY

The Ecological Society of America has evaluated the ecological effects of current and future uses of field-released genetically engineered organisms (GEOs), as described in this position paper. GEOs have the potential to play a positive role in sustainable agriculture, forestry, aquaculture, bioremediation, and environmental management, both in developed and developing countries. However, deliberate or inadvertent releases of GEOs into the environment could have negative ecological impacts under some circumstances. For example, fast-growing transgenic salmon that escape from aquaculture net-pens might jeopardize native fish populations. Ecological knowledge about potential environmental effects of transgenic organisms is crucial for understanding and avoiding these types of risks.

We reaffirm that risk evaluations of GEOs should focus on the phenotype or product rather the process of genetic engineering (e.g., NRC 1987, 2000, 2002a; Tiedje et al. 1989), but we also recognize that some GEOs possess novel characteristics that require greater scrutiny than organisms produced by traditional techniques of plant and animal breeding. Also, unlike commercialized crops or farm-raised fish, some GEOs are organisms for which there is little previous experience with breeding, release, and monitoring. Future applications of genetic engineering extend far beyond traditional breeding, encompassing transgenic viruses, bacteria, algae, fungi, grasses, trees, insects, fish, shellfish and many other non-domesticated species that occur in both managed and unmanaged habitats.

The environmental benefits and risks associated with GEOs should be evaluated relative to appropriate baseline scenarios (e.g., transgenic versus conventional crops), with due consideration of the ecology of the organism receiving the trait, the trait itself, and the environment(s) into which the organism will be introduced. Long-term ecological impacts of new types of GEOs may be difficult to predict or study prior to commercialization, and we strongly recommend a cautious approach to releasing such GEOs into the environment. Engineered organisms that may pose some risk to the environment include cases where:

there is little prior experience with the trait and host combination;

· the GEO may proliferate and persist without human intervention;

· genetic exchange is possible between a transformed organism and non-domesticated organisms; or

· the trait confers an advantage to the GEO over native species in a given environment.

An assessment of environmental risk is needed to minimize the likelihood of negative ecological effects such as:

· creating new or more vigorous pests and pathogens;

· exacerbating the effects of existing pests through hybridization with related transgenic organisms;

· harm to non-target species, such as soil organisms, non-pest insects, birds, and other animals;

· disruptive effects on biotic communities; and

· irreparable loss or changes in species diversity or genetic diversity within species.

GEOs should be evaluated and used within the context of a scientifically based regulatory policy that encourages innovation without compromising sound environmental management. The process by which this occurs should be open to public scrutiny and broad-based scientific debate. In addition, current regulatory policies should be evaluated and modified over time to accommodate new applications of genetic engineering. In light of these points, we offer the following recommendations regarding the development, evaluation, and use of GEOs in the environment.

2. Analyses of environmental benefits and risks - Rigorous, well-designed studies of the benefits and risks associated with GEOs are needed.

a. Ecologists, evolutionary biologists, and a wide range of other disciplinary specialists should become more actively involved in research aimed at quantifying benefits and risks posed by GEOs in the environment.

b. Because of the inherent complexity of ecological systems, this research should be carried out over a range of spatial and temporal scales.

c. We further recommend that the government and commercial sectors expand their support for environmental risk assessment (including environmental benefits) and risk management research.

4. Monitoring of commercial GEOs - Well-designed monitoring will be crucial to identify, manage, and mitigate environmental risks when there are reasons to suspect possible problems. In some cases, post-release monitoring may detect environmental risks that were not evident in small-scale, pre-commercial risk evaluations. Because environmental monitoring is expensive, a clear system of adaptive management is needed so that monitoring data can be used effectively in environmental and regulatory decision-making.

5. Regulatory considerations - Science-based regulation should: (a) subject all transgenic organisms to a similar risk assessment framework, (b) recognize that many environmental risks are GEO- and site-specific, and therefore that risk analysis should be tailored to particular applications, and (c) incorporate a cautious approach to environmental risk analysis.

In summary, we urge scientifically-based assessment of the benefits and risks of GEOs that are proposed for release into the environment, and scientifically-based monitoring and management for environmental effects that may occur over large spatial scales and long time frames. GEOs that are phenotypically similar to conventionally bred organisms raise few new environmental concerns, but many novel types of GEOs are being considered for future development. These include baculoviruses that are engineered for more effective biological control, microorganisms that promote carbon storage, fast-growing fish, and fast-growing plants that tolerate cold, drought, or salinity. The Ecological Society of America is committed to providing scientific expertise for evaluating and predicting ecological benefits and risks posed by field-released transgenic organisms.

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