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Re: [SANET-MG] glyphosate tolerant creeping bentgrass out of the question
Hello every one,
I was contacted by people who would like help in submitting comments. I
have prepared something quick below. Once the comment is posted it may
be a problem to read because the browsers regard the comments to be pop
ups! sincerely, Joe
go to:http://www.regulations.gov/fdmspublic-bld61/component/main
scroll down to animal and plant health inspection service then submit
click on :APHIS-2005-0029
Title Environmental Impact Statement; Petition for Deregulation of
Genetically Engineered
Glyphosate-Tolerant Creeping Bentgrass
Type NONRULE
APHIS Docket ID 03-101-4
scroll down then click on submit comment. Reading the comment when it is
posted may be tricky
because the browsers view it as a "pop up" . Make sure that the pop-up
blocker for the site
is set for pop ups OK.
jcummins wrote:
http://www.i-sis.org.uk/DGTCBOQ.phpISIS Press Release 07/11/05
Deregulation of Glyphosate Tolerant Creeping Bentgrass Out of Question
This article has been submitted to the USDA on behalf of the
Independent Science Panel
Professor Joe Cummins
The Animal and Plant Health Inspection Service (APHIS) of the US
Department of Agriculture (USDA) received a petition 03-104-01p from
Monsanto company and Scotts company on 14 April 2003 requesting
deregulation of creeping bent grass genetically modified for tolerance
to the herbicide glyphosate. On 5 January 2004, APHIS solicited public
comments on whether the modified creeping bentgrass would present a
plant pest risk. A preliminary environmental review was prepared by
APHIS, and on 12 October 2005, APHIS requested additional information
on 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 tolerant to the herbicide
glyphosate. It contains a gene conferring tolerance to the herbicide
similar to Roundup Ready maize, soybean, canola, sugar beet or
alfalfa. The resistance gene is a synthetic approximation of the
5-enolpyruvyshikimate-3 phosphate synthase from Agrobacterium sp.
Strain CP4 (CP4EPSPS), which is preceded by the Arabidopsis
chloroplast transit sequence which is required to direct the CP4ESPS
to the chloroplast. Transcription is driven by the rice actin promoter
and first intron, and terminated by nos 3 from Agrobacterium . A
second identical CP4EPSPS sequence is driven by the CaMV promoter with
duplicate enhancers, the heat shock 70 intron, and terminated by the
nos3 sequence from Agrobacterium . Finally the insert contains
nopaline antibiotic resistance gene. Duplicate copies of the herbicide
tolerance gene ensure a high level of 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 Mendelian 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 with natural grass species were found and most
of them were fertile. Herbicide tolerant creeping bent grass or its
hybrids could be established in various urban to rural and natural
areas [2].
APHIS asked The Weed Society of America, an industry-oriented academic
organization, 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 that 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 could extend to 14 and 24 km [4]. Inter-specific
hybridization between creeping bent grass and related grass species
occurred at frequencies as high as six hybrids per thousand 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 cells within 18 hr at
concentrations lower than recommended agricultural use, and Roundup
more so than glyphosate. Surprisingly, Roundup was always more toxic
than its active ingredient. The glyphosate-based herbicide disrupts
aromatase activity and mRNA levels and interacts with the active site
of the purified enzyme, and 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]. Relyea
and his co-workers have documented the devastating impact of Roundup
herbicide on amphibian communities in a series of reports [8-10]. Ho
and Cummins have reviewed the problems associated with Roundup
resistant weeds and the many human and animal health impacts including
liver damage, cancers, neuro-defects and spontaneous abortion [11, 12].
The clear evidence of extensive gene flow and hybridization of
glyphosate tolerant creeping bent grass, the growing problems of
glyphosate resistant weeds plus the new evidence of glyphosate and
Roundup toxicity to humans and lethality to amphibians should make any
further release of glyphosate tolerant creeping bent grass out of the
question, let alone its deregulation.
References
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
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
Banks P, Branham B, Harrison K, Whitson . 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.
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 USA 2004, 101(40),14533-8.
Belanger F, Meagher T, Day P, Plumley K and Meye W. Interspecific
hybridization between Agrostis stolonifera and related Agrostis
species under field conditions Crop Science 2003, 43, 240-6.
Goss R, Gaussoin R. and Martin A. Phytotoxicity of clippings from
creeping bent grass treated with glyphosate. Weed Technology 2004,18,
575-9.
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, 113(6), 716-20.
Relyea, Rick A., Schoeppner, Nancy M., Hoverman, Jason T. Pesticides
and amphibiums : the importance of community context. Ecological
Applications 2005, 15, 1125–34.
Relyea, Rick A. The lethal impact of roundup on aquatic and terrestial
amphibiums. Ecological Applications : 2005, 15, 1118–24.
Relyea, Rick A. The impact of insecticides and herbicides on the
biodiversity and productivity of aquatic communities . Ecological
Applications 2005,15, 618–27.
HoMW and Cummins,J. Roundup ready sudden death, super weeds, allergens
ISIS 2005 http://www.i-sis.org.uk
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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