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Risk Assessment generated by a regulatory process (RA)
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BCH-RA-BR-47844-4   |   PDF   |   Print   |  
published: 17 Dec 2008 last updated: 28 Mar 2013
General Information
Risk Assessment of herbicide tolerant cotton (MON1445)
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Risk assessment details
Methodology and points to consider
The inserted gene cp4-epsps was obtained from a specific stretch of  DNA of the Agrobacterium sp., CP4 strain, and codifies enzyme CP4-EPSPS (CP4 5-enolpyruvylshikimate-3-phosphate synthase) granting  to cotton plants the attribute that enables the  use, in post-emergence, of the glyphosate herbicide, for management of pest plants without injuring the  cotton crop. Gene nptll codified   the protein Neomycin Phosphotransferase type  II that grants tolerance to antibiotics neomycin and kanamycin. Gene aad, which codifies protein  AAD (3’(9)-O-aminoglycoside adenyltransferase – antibiotic resistance selection marker. Gene gox codifies enzyme GOX (glyphosate oxyreductase), responsible for metabolizing the  glyphosate herbicide. Gene gox was  not  transferred to cotton  and, consequently, the protein GOX was not detected in Roundup Ready Cotton Event MON1455. There is no evidence that the donor organisms of inserted genes are pathological  to humans. Molecular and segregation analyses (Mendelian standard  of  3:1) show  that T-DNA was  partially inserted in a single  locus of the cotton  genome. Genetic stability of  MON 1445 was determined by hereditary stability standard, integrity of inserted DNA and stability phenotype   in different environmental conditions determined in several generations of  lineages obtained by retro-crossing  with elite cultivars. This stability was additionally demonstrated by  the integrity of  inserted DNA and functionality of the protein CP4 EPSPS expressed  in lineages obtained by crossing with a cultivar adapted  for sowing in the Brazilian environment. Proteins EPSPS  and NPTII, which have no history of toxicity or allergenicity, resulting from the expression of transgenes, showed to  be equivalent to the ones present  in nature. Gene epsps  is present both in plants and in microorganisms, while nptll is present in several species of microorganisms, including intestinal  bacteria and in genus Bacillus found  in Brazilian soils. Studies in vitro demonstrated that  in simulated  intestinal fluids (pH 1.2 and pH 7.5) protein EPSPS  is rapidly degraded, which is common in the digestive tract  of mammals with proteins that pose a minimum risk of  toxicity and  allergenicity. Besides, studies of oral  acute toxicity in mice showed that both  EPSPS and NPTII fail to present toxic potential when orally administered at doses of 572mg/kg body weight and 5 mg/kg body weight, respectively. Both transgenic proteins, CP4  EPSPS and NPTII, are in the nature,  widely distributed  among microorganisms from where they are derived. The introgression of a transgene  to wild cotton plants could  only occur if  a strong selective advantage was granted, higher than the disadvantages granted  by the  alleles that are genetically linked to the transgene.  However, the  herbicide-tolerant characteristic is recognized as being unable to  grant receiving genotypes any adaptive advantage outside  agricultural areas, since outside  such areas the potentially receiving wild genotypes are not under  the  selective pressure from the  herbicide  and therefore any pollination  of such  genotypes would not result in genic introgression. Assessment of phenotypic and agronomic characteristics of Roundup Ready Cotton event MON 1445, cultivar DP50RR, conducted in Brazil reached results  similar to the ones found in other regions  of the world  in experimental and commercial crops. Except for tolerance  to the glyphosate herbicide, resulting from  expression of gene cp4 epsps, Roundup Ready Cotton event MON 1445 demonstrates phenotype and agronomic characteristics equivalent to  those of the standard conventional  kindred lineages and commercial cultivars of conventional cotton. Glyphosate  is a post-emergent herbicide, belonging to the chemical group of substituted glycines, classified as non-selective and  possessing  systemic action. It has a  wide spectrum action,  enabling the control of large and short-leaved annual and perennial weeds
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Long experience with traditional plant improvement techniques, over three decades of experience in research and over one decade of marketing transgenic varieties over the world, in addition  to knowledge advancements in the structure and dynamics of genomes, indicating whether a  certain gene or characteristic is safe, give a sign that the genetic engineering  process, by its own, leaves  little room for appearance of unexpected consequences  that would not be identified or eliminated  during the process of development of commercial GM varieties(14).
Whereas Roundup Ready Cotton Event MON 1445 belongs to  a well characterized species (Gossypium hirsutum)  with  a solid background  of safety for human use and that the cp4 epsps gene introduced  in this variety does not codify a toxic protein, being harmless to humans.
Whereas the  genic construct used to  insert the gene in cotton resulted in a stable insertion of  a functional copy of the cp4 epsps gene, granting the plants  tolerance to glyphosate.
Whereas:
1. Roundup Ready Cotton Event MON 1445 displays genetic stability in different environmental conditions determined in a number of generations of lineages obtained by retrocrossing with elite cultivars, including  a variety adapted for cultivation in Brazil.
2. Proteins CP4 EPSPS and NPTII were expressed in different tissues and development phases of Roundup Ready Cotton Event MON 1445 in extremely low levels.
3. Security assessments  of Roundup Ready Cotton Event MON 1445 and its products  ensured that  the genetically modified variety is safe for both the environment and use as food or food component for animals when compared to the risk posed by conventional  cotton.
4. The new  proteins expressed in the plants, CP4 EPSPS and NPTII  revealed to be safe in all aspects studied.
5. Protein CP4 EPSPS is  rapidly degraded in the gastrointestinal  system of  humans and animals for being a labile  enzyme; and, in addition,  its way of action, specificity  and absence of homology with toxic sequences  make this protein not risky to human health and to the environment.
6. Protein NPTII was assessed by the FDA  in 1994 and was found safe for use in  food. It is rapidly degraded in the human gastrointestinal system and its mode of action, specificity and absence of homology with toxic sequences lead to the conclusion that  the protein is not a toxic risk.
7. Potential allergenicity assessment studies verified that proteins CP4 EPSPS and NPTII  are not detectable in cotton products used as human and animal food and do not pose significant risk as  allergenic and are  not derived from allergenic forms.
8. Phenotypic and agronomic  characteristic studies of Roundup Ready Cotton Event MON 1445 cultivar DP50RR conducted in Brazil have reached results comparable  with experimental and commercial  farming studies  conducted in other regions of the world.
9. Field and farm experiments  conducted with a number of generations  and derivatives of Roundup Ready Cotton Event MON 1445 since 1993 show a stable phenotype of glyphosate tolerance occurring as a monogenic characteristic of high inheritability  that is little affected by the environment  in its expression.
10. Studies with animals show that a paste made of Roundup Ready Cotton Event MON 1445 kernels is  as safe and  nutritive as a paste  of conventional cotton kernel.
11. It is little likely that wild animals   feed on significant amounts of seeds or other parts of the cotton plant.
12. Protein EPSPS is present  in all plants and  also in bacteria, algae and fungi, being therefore widely distributed in nature. For  this reason, all living beings  that feed on plants and  microorganisms are already exposed to  EPSPS proteins.
13. The antibiotics neomycin and kanamycin are  not used in agriculture to control plant diseases originated from the soil. Therefore, it is not likely that the presence of the NPTII protein in the  soil may affect  the microbial  population of  the soil.
14. The transfer of the herbicide-tolerant  characteristic to outside  agriculture areas is extremely unlikely.
15. It is unlikely that the MON 1445 event transgene cp4 epsps be transferred to weeds, making them more invasive. The customary care  with  management  of culture and herbicides, such as rotation of cultures and rotation of  herbicides with different  action mechanisms shall  be the focus to mitigate the appearance of  herbicide-tolerant plants.
16. Data submitted, in addition to those existing in the literature, show that the impacts generated by the release in commercial scale to the field of the cotton event MON 1445 are similar to  those  presented by its kindred and other non-GM varieties currently cultivated in Brazil.
17. Event MON 1445  has already been approved  by several  countries, including U.S.A., Canada, Japan, Australia, Mexico, South Africa, Argentina, China, European Union, Philippines, Colombia and South Korea and has been cultivated  in some of these countries  without negative  effects to human and animal health and to the environment.
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not applicable
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Technical opinions related to agronomic performance reached a conclusion that there is equivalence between transgenic  and conventional plants. This way the information indicates that transgenic plants are not fundamentally different from the non-transformed cotton genotypes, except for the tolerance to glyphosate. In addition there is no evidence of adverse reactions to the use of Roundup Ready Cotton Event MON 1445. For the above reasons, there is no restriction to the use of this cotton and derivatives in human and animal food.
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As established by Article 11  of Law no. 11,460, of March 21, 2007 “research and cultivation of genetically modified organisms may not be conducted in indigenous lands and areas of  conservation units.”
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not applicable
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The cotton plant (G. hirsutum) has not shown itself with  any invading potential in Brazil, as well as in other  parts of the world  where it is  regularly cultivated in large scale.  At the  side  of highways where corn kernels are transported together with other cotton products, plants may appear that establish themselves only in places where there is, either  naturally or otherwise, accumulated humidity. There is not observable, however, any advance of  such plants towards other areas. Besides, within the Gossypium genus, there are no records of potential as an invading plant, except for  the G. tomentosum, that  does not exist  in Brazil
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molecular traditional methods
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Additional information
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