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[SANET-MG] creeping bentgrass petition for deregulation

October 16, 2005

Prof. Joe Cummins

DejaVu Glyphosate Tolerant Creeping Bentgrass Petition for Deregulation

On April 14,2003 The Animal and Plant Health Inspection Service (APHIS) of the U.S. Department of Agriculture (USDA) received a petition 03-104-01p from Monsanto company and Scotts company requesting deregulation of creeping bent grass genetically modified for tolerance to the herbicide glyphosate. On Jan.5,2004 APHIS solicited comments on whether the modified creeping bentgrass would present a plant pest risk. A preliminary environmental review was prepared by APHIS. On Oct. 12,2005 APHIS requested additional information . APHIS Docket ID 03-101-4 , Environmental Impact Statement; Petition for Deregulation of Genetically Engineered Glyphosate-Tolerant Creeping Bentgrass Public comments are due by 14 November ,2005: http://www.regulations.gov/fdmspublic-bld61/component/main

Roundup ready creeping bent grass is resistant to the herbicide glyphosate. The grass contain a gene conferring resistance to the herbicide and the plant is modified similarly to roundup ready maize, soy bean, canola , sugar beet or alfalfa. The resistance gene is a synthetic approximation of the 5-enolpyruvyshikimate-3 phosphate synthase from the Agrobacterium sp. Strain CP4 (CP4EPSPS). That sequence is preceded by the rice actin promoter and first intron which drives transcription of the CP4EPSPS gene and the Arabidopsis chloroplast transit sequence which is required to direct the CP4ESPS to the chlorpoplast. The protein coding sequence is followed by a transcription termination gene NOS3 from Agrobacterium. A second CP4EPSPS sequence is preceded by the CaMV promoter with duplicate enhancers , the heat shock 70 intron and chloroplast transit sequence from Arabidopsis.Transcription is terminated by the NOS 3 seuquence from Agrobacterium. Finally the insert contains nopaline antibiotic resistance gene. Duplicate copies of the herbicide tolerance gene insure the tolerance to glyphosate (1).

APHIS preliminary risk assessment concluded that genetically modified (GM) creeping bent grass is phenotypicaly equivalent to unmodified grass. The GM grass had a single insert of the duplicate CP4EPSPS gene which behaved as a simple Menelian locus in crosses. The GM creeping bent grass does not differ in susceptibility or resistance to pests and diseases from its unmodified parent. However, the evidence was clear that hybrids could be observed derived from natural grass species and most were fertile. Herbicide tolerant creeping bent grass or its hybrids could be established various urban to rural and natural areas (2).

APHIS asked an industry oriented academic organization, The Weed Society of America to evaluate the release of herbicide tolerant creeping bent grass in various crop and non-crop ecosystems. The report prepared on behalf of the society concluded that off site movement of GM creeping bent grass was inevitable but the GM grass or its hybrids could be controlled using herbicides other than glyphosate (3).A study of gene flow from GM creeping bent grass showed that most of the gene flow occurred within 2 km of the field in which the GM grass was grown , but maximal gene flow observed was 14 and 24 km (4).Inter-specific hybridization between creeping bent grass and related grass species occurred at frequencies as high as 6 hybrids per thousand related grass plants (5). Clippings from treated GM creeping bent grass stands were toxic to unmodified grasses and such clippings will require special handling(6).

The impact of expanded urban and natural area use of glyphosate was hardly discussed in the petition for deregulation and environmental assessment, but that discussion was crucial and should have been included. Glyphosate is toxic to human placental JEG3 cells within 18 hr with concentrations lower than those found with agricultural use, and this effect increases with concentration and time or in the presence of Roundup adjuvant. Surprisingly, Roundup was always more toxic than its active ingredient. Testing included the effects of glyphosate and Roundup at lower nontoxic concentrations on aromatase, the enzyme responsible for estrogen synthesis. The glyphosate-based herbicide disrupts aromatase activity and mRNA levels and interacts with the active site of the purified enzyme, but the effects of glyphosate are facilitated by the Roundup formulation in microsomes or in cell culture. The authors of the study conclude that endocrine and toxic effects of Roundup, not just glyphosate, can be observed in mammals (7). The devastating impact of roundup herbicide on amphibian communities has been exposed in a series of reports by Relyea and his co-workers (8,9,10). The problems associated with roundup resistant weeds and the many human and animal health impacts including liver damage, cancers, neuro defects and spontaneous abortion were reviewed by Ho and Cummins (11,12).

The clear evidence of extensive gene flow and hybridization of glyphosate resistant creeping bent grass alone should prevent the deregulation of the GM grass. Add to that the growing problem of glyphosate resistant weeds should prevent deregulation of the gm grass. Finally the new evidence of human toxicity at very low levels of the herbicide along with the evidence that roundup herbicide contributes to the extinction of amphibians should close the book on glyphosate resistant creeping bent grass. There seems to be no rational grounds for deregulating glyphosate tolerant creeping bent grass.


1. Nelson,E. and Stone,T. Petition for determination of non-regulated status: Roundup Ready Creeping Bent grass Event ASR368 Petition #01-TR-054U 2003 http://www.aphis.usda.gov/brs/not_reg.html

2. USDA/APHIS APHIS Preliminary Risk Assessment on the Petition for a Determination of Nonregulated Status for Creeping Bentgrass (Agrostis stolonifera) Genetically Engineered (Event ASR368) for Tolerance to the Herbicide Glyphosate submitted by Monsanto Company and the Scotts Company. 2004 http://www.aphis.usda.gov/brs/not_reg.html

3. Banks,P,Branham,B,Harrison,K,Whitson,T. and Heap,I. Determination of the Potential Impact from the Release of Glyphosate- and Glufosinate-Resistant Agrostis stolonifera L. in Various Crop and Non-Crop Ecosystems Weeds Society of America Report to USDA/APHIS 2003

4. Watrud LS, Lee EH, Fairbrother A, Burdick C, Reichman JR, Bollman M, Storm M, King G and Van de Water PK. Evidence for landscape-level, pollen-mediated gene flow from genetically modified creeping bentgrass with CP4 EPSPS as a marker. Proc Natl Acad Sci U S A. 2004 Oct 5;101(40):14533-8

5. Belanger,F,Meagher,T,Day,P,Plumley,K and Meyer,W. Interspecific Hybridization between Agrostis stolonifera and Related Agrostis Species under Field Conditions Crop Science 2003 43:240-6

6. Goss,R,Gaussoin,R. and Martin,A. Phytotoxicity of clippings from creeping bent grass treated with glyphosate Weed Technology 2004,18,575-9

7. Richard S, Moslemi S, Sipahutar H, Benachour N and Seralini GE. Differential effects of glyphosate and roundup on human placental cells and aromatase. Environ Health Perspect. 2005 Jun;113(6):716-20

8. Relyea, Rick A., Schoeppner, Nancy M., Hoverman, Jason T. Pesticides and amphibiums : the importance of community context. Ecological Applications: 2005. 15, No. 4, 1125–34

9. Relyea, Rick A. The lethal impact of roundup on aquatic and terrestial amphibiums. Ecological Applications: 2005. 15, No. 4, 1118–24

10. Relyea, Rick A.The impact of insecticides and herbicides on the biodiversity and productivity of aquatic communities . Ecological Applications 2005 ,15, No. 2, 618–27

11. HoMW and Cummins,J. Roundup ready sudden death ,super weeds, allergens ISIS 2005 http://www.i-sis.org.uk <http://www.i-sis.org.uk/>

12. Ho MW and Cummins,J. Glyphosate toxic and roundup worse /Science in Society /2005, 26, 12. http://www.i-sis.org.uk/isisnews.php

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