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[SANET-MG] cotton with a new kind of toxin

February 10, 2005
Prof. Joe Cummins
“ Comment on  the Syngenta  petition to deregulate  genetically modified
cotton  with a  new kind of insect toxin gene”
       Two years ago I wrote  about the Bacillus thuringiensis  toxin  VIP3A
whose gene had been isolated , a synthetic approximation prepared then
the gene was patented  for use in crop plant(1). The Bacillus
thuringiensis (Bt) toxin genes  currently employed in crops . are all
members of a class of  toxin proteins that accumulate , as crystals , in
stationary stage bacteria (bacteria that have completed their growth
cycle) these genes are designated Cry followed by numbers and letters
that indicate there origin and specificity  . These toxins  all create
pores in the insect cell membranes leading to osmotic lysis of the
cells. The VIP group of toxins are produced  in vegetative cells  , the
genes are designated  VIP followed by numbers and letters related to
their origin and specificity. .
       Syngenta modified cotton  with VIP3A  gene and selected  event COT102
as a strain to be deregulated. The company submission was posed as a
docket for public consulatation as shown below:
04-51-1 APHIS-2005-0007  Syngenta Seeds, Inc.; Availability of Petition
and Environmental Assessment for Determination of Nonregulated Status
for Cotton Genetically Engineered for Insect Resistance  01-28-2005
General Docket  Notice  03-29
04-51-2 Syngenta Petition 03-155-01p for Determination of Nonregulated
Status for Lepidopteran Resistant Event COT102
The comment I posted  is as follows:
The application by Sygenta claims that the insecticidal protein VIP3A is
known not to have catalytic or biologic functions other than the
insecticidal activity. The Syngentas patent,Estruch J, Warren G, Desai
N, Kozeil M, and Nye G. Plant Pest Control. US Patent 2001, 6 429 360,
pp 1-25 discussed the induction of apoptosis by VIP3A and the death
domains born by the gene. Certainly the death domains of VIP3A share
homology with such domains in mammals inclluding humans. The experiments
supporting deregulatuion were not adequate to identify the impacts of
induced apoptosis in mammals! Why are the death domains ignored by EPA
and APHIS? It seems like potentially deadly impacts of the cotton on
mammals are being ignored.
       I whish to urge others to look at the documents posted with  Syngenta
 03-28-2005 and to submit a comment prior to the closing dates for
comments :
 03-29-2005 . The main question is  “have adequate safety been done to
allow exposure to the toxin and its gene  in fiber, food and feed?” I do
not believe that the studies are at all adequate.
Cummins,J. New GM toxin looms over our food  2003
http://www.i-sis.org.uk/full/NGMTLOOFFull.phpISIS Press Release 02/12/03

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