PO Box 155

                                                                        Kensington Park, SA, 5068

                                                                                                  Australia

 

 

 

Dr Kate Clinch-Jones

Dr Judy Carman

Ms Pola Lekstan

PO Box 155

Kensington Park SA 5068

 

 

Hon Lea Stevens

Minister for Health

Parliament House

North Terrace

Adelaide SA 5000

 

16 April 2004

 

 

Dear Minister,

 

We met with you on 5 April 2004 at the Lockleys Bowling Club, as part of the "Meet the Ministers" deputations in the West Torrens Council District, and spoke to you about our concerns about genetically modified (GM) foods and crops. We are grateful that you generously shared your time with us, especially as you may not have been expecting a scientific delegation. We felt the need to brief you on this issue as it is becoming increasingly important amongst medical professionals. 

 

As requested by you, we are providing a brief summary of the key points we presented to you. We appreciate the attention you are giving to this issue, and look forward to hearing the results of your enquiries. We respectfully request a continued dialogue with you on the complexities of GM foods and crops.

 

  1. The OGTR's definition of the environment appears to specifically exclude much of the Australian landmass, including roadside verges (which are often refuges for rare and endangered plants, particularly in agricultural areas), agricultural land, and any other disturbed land.  In fact, the OGTR definition of the environment appears to encompass only pristine wilderness.  This clearly raises serious questions about how comprehensive and meaningful their environmental assessments are.

 

  1. It is our understanding that AQIS still does not test for herbicide residues in any imported product, including GMOs specifically engineered to be herbicide resistant.  This is of particular concern as herbicide-resistant GMOs tend to be more frequently sprayed with their herbicide during growth, and hence may have excessive residue levels.

 

  1. It is our understanding that there is no formal testing programme to detect the presence of unapproved GMOs in the Australian food supply. We bring to the Minister’s attention the fact that open field trials have occurred overseas of food crops that have been modified to produce drugs and experimental animal vaccines, resulting in a high probability of these crops accidentally entering the human food supply.  Indeed, we are aware of two last-minute crop recalls in the USA as a result of this type of contamination. One of your aides advised us during our meeting with you that AQIS is responsible for monitoring this type of contamination. Is this correct? Has AQIS been directed to test for unapproved GMOs?  If this is the case, we request to be informed as to when such tests have been conducted and on what types and quantities of imports.  We also request to be informed as to the amount of testing that has been done to determine the level of StarLink corn contamination in Australia.

 

  1. We brought to your attention that it is a matter of public record that GM foods were originally approved in the US as a result of a political directive given to the US Food and Drug Administration, which overrode the warnings of the FDA's own experts that GM foods pose significant risks and warranted thorough testing. Internal FDA documents outlining the experts concerns can be seen on www.bio-integrity.org. The first GM foods to be approved by ANZFA (now FSANZ) were approved largely on the basis that they had first been approved by an overseas authority, that is, the FDA. Those GM foods are still on the market.

 

  1. We brought to your attention the fact that no GM foods have been safety tested on humans. We also described how grossly inadequate animal safety studies are.  Most involve only a single oral dose of the new protein(s) expected to be found in the GM plant and animals are generally only followed for 7-14 days, generally only to see if any animals die in that time.  The proteins tested do not generally even come from the GM plant, but from bacteria that have been genetically engineered to produce a similar protein.  If the animal is fed the whole plant, the animal is generally only followed for 28 days and the duration and nature of the studies do not permit the risks of a great many diseases to be determined, eg cancer, chronic disease, immune dysfunction, organ dysfunction (eg liver dysfunction), effects on the unborn or suckling infants.  Adverse effects have been found in these animal studies but have been dismissed as not being due to the GM crop without any proper supporting evidence. 

 

  1. FSANZ and the OGTR base their assessments on data provided by the proponent companies. They do no safety testing themselves.  We have found evidence that these authorities have often not even performed a basic literature search to find articles published in the peer reviewed scientific/medical literature during their investigations.

 

  1. FSANZ's own documents reveal that for a number GM foods, FSANZ only began safety assessments after the foods had been introduced into the Australian food supply; sometimes several years afterwards. 

 

  1. Preliminary scientific research shows that the cauliflower mosaic virus promoter, used in virtually all GM foods on the market, is taken up by cells in the gut lining of rats.

 

  1. There is preliminary evidence that people living adjacent to fields growing a Bt crop developed allergic disorders as a result of their exposure to the pollen from this crop.

 

  1. It is our understanding that the labelling laws for GM foods are essentially unenforceable. This is because although one Australian laboratory has been accredited to test for the presence of GM residue on a present/not present basis, no Australian laboratory has been accredited to quantitatively test for GM content (eg percentage of GM soy in soy). In other words, there is no legally-recognised testing available in Australia to monitor or enforce compliance with labelling thresholds.

 

  1. While the 3 year moratorium on commercial plantings in SA is to be commended, it does not recognise the potential damage from open field trials, in particular the potential risks from by cross-pollination of non-GM crops over a wide area. For example, bees routinely carry pollen at least 4.5 kilometres.  Wind can carry it much further. When this is combined with the fact that approximately 10% of canola seeds fall onto the ground at harvest to grow in later seasons, field trials could easily lead to a permanent presence of GM canola in this State.  It also means that a number of well-spaced trials of GM canola could cause contamination of much of the State's canola harvest, and potentially irreversibly damage our “clean and green” “GM free” market advantage.

 

Present at the meeting were: Hon Lea Stevens, Danny Broderick, Jim Hallion (representing Rory McEwen) and another person representing the government.  Our party consisted of Dr Judy Carman, Dr Kate Clinch-Jones and Ms Pola Lekstan. We had also requested to meet with the Environment Minister at the meeting, but were refused by the meeting organizers, apparently because the issue was not regarded as being an environmental issue. We dispute this assessment.

 

We personally gave you several documents during the meeting that supported our arguments.  These included:

 

 

 

We await with interest your response to these issues.

 

Yours faithfully,

 

 

 

 

 

Dr Kate Clinch-Jones

General Practitioner

Director, Institute of Health and Environmental Research

 

 

 

 

 

Dr Judy Carman

Director, Institute of Health and Environmental Research

Affiliate Senior Lecturer, Department of Public Health, University of Adelaide

Spokesperson on GM food, Public Health Association of Australia

 

 

 

 

Ms Pola Lekstan

 

cc Mike Rann

 

cc Rory McEwen

 

cc PHAA

 

cc DEA