Industry proposal to grow safflower that is genetically engineered to produce carp growth hormone.

The biotech company SymBioSys, Inc applied for a permit to grow safflower that has been genetically modified so that it produces carp growth hormone in its seeds. SymBioSys intends to feed the GE seeds to fish in order to study its potential for use in commercial fish farming. However, no studies have been done to assess the impact of carp growth hormone on wild animals that could consume the seeds in the fields.

Download the letter here

February 21, 2007

Docket No. APHIS-2006-0190
Regulatory Analysis and Development,
PPD, APHIS
Station 3A-03.8
4700 River Road, Unit 118
Riverdale MD 20737-0190

cc: Federal eRulemaking Portal

RE: U.S. Department of Agriculture-Animal and Plant Health Inspection Service (USDA-APHIS) Draft Environmental Assessment in response to permit application (06-250-02r) received from SemBioSys, Inc. for a field-test to produce carp growth hormone in genetically engineered safflower (Carthamus tinctorius) seeds

Food & Water Watch is pleased to have the opportunity to comment on the USDA-APHIS Draft Environmental Assessment (EA or Assessment) for a field test of safflower genetically engineered to produce carp somatotropin. Food & Water Watch is a national non-profit consumer advocacy organization that seeks to ensure the health, nutritional and environmental integrity of our food and water supplies.

In particular, Food & Water Watch is concerned about the potential impacts of carp growth hormone on wild birds and animals that may consume the genetically engineered safflower. The Assessment’s conclusion that the safflower in question would not negatively affect wild mammals and birds is unreasonable due to the absence of scientific study to substantiate this claim. Before approving the field test of this safflower engineered to produce carp growth hormone, thorough scientific study must investigate its effects of the hormone on birds and mammals. Only if the results of scientific analysis support the claim that there will be no negative impact should APHIS consider approving the field test.

In the report, Environmental Effects of Transgenic Plants: the Scope and Adequacy of Regulations, the National Academy of Science notes that in previous environmental assessments, the Department of Agriculture has used the lack of evidence of risk to support the claim that there is no risk. However, the Academy report argues that the absence of scientific investigation into whether or not risk exists is not sufficient to prove that there would be no environmental impact. Unfortunately, the current Environmental Assessment continues this flawed pattern of argumentation.

It states: “APHIS has determined there will be no impact of carp growth hormone on birds or scavenging animals that could possibly ingest seed.” The Assessment then provides the following arguments in defense of its conclusion:

1. “(T)he long history of fish ingestion by numerous mammalian and avian species would indicate that it is not toxic at its natural level.”
2. “The ingestion safety of bovine somatotropin to mammals such as mice, cattle and humans has been described and it is deemed a safe protein even at high levels of exposure due to the breakdown of proteins in the mammalian and avian digestive process.”

However, the Assessment also concedes that “the safety of carp growth hormone to humans and animals other than fish has never been investigated.” Therefore, in the absence of scientific investigation, the above arguments do not sufficiently demonstrate the safety of carp growth hormone to wild birds and animals.

The first argument is not sufficient because the mammals and birds that would feed on safflower are not necessarily (and indeed, are unlikely) the same birds and mammals that consume carp. For example, rabbits, including the threatened pygmy rabbit, are herbivores. Many of the other seed-scavenging birds and mammals of the Pacific Northwest, despite being omnivores, do not have a “long history of fish ingestion.” The fact that some animals can safely consume fish does not indicate that other animals can safely consume safflower seeds containing carp somatotropin.

The second argument is also flawed. The effects of bovine somatotropin on mammals have not undergone adequate study. (The Assessment does not address the potential impact on birds in this portion of the argument.) Health Canada’s analysis of Monsanto’s 90-day rat oral toxicity study, rBST (Nutrilac) ‘Gaps Analysis’ Report, describes the need for further toxicological studies of bovine somatotropin. In this study, rBST was absorbed into the bloodstream of the rats, and 20-30 percent of the rats given a medium to high dose of the hormone exhibited an immunological effect (meaning it affected them). The report notes that: “The full immunological and potentially toxicological consequences of this observation were not investigated.” Without full scientific investigation, this imperfect comparison of carp to bovine somatotropin should not be used as evidence of the safety of carp growth hormone.

Food & Water Watch appreciates the opportunity to comment on the Draft Environmental Assessment in response to permit application 06-250-02r. Based on our analysis of the Assessment, we request that APHIS choose option A: No Action, pending study on the impacts of carp somatotropin on relevant birds and mammals. If you have any questions, please contact Andrianna Natsoulas at anatsoulas@fwwatch.org.

Sincerely,

Andrianna Natsoulas
Campaign Coordinator
Food & Water Watch