RA&RM of Living Modified Crops Resistant or Tolerant to Abiotic Stress

Hello all:

I am Elizabeth Bravo. I could not be present at the meeting in Montreal because of visa problems- I would make some contributions on the theme of Abiotic stress.

Abiotic stress is of particular importance at this stage because of the launch of new initiatives for a green revolution to Africa, where attempts to introduce varieties resistant to drought and other traits related to abiotic stress. The purpose of these initiatives is to include these lands that have traditionally been used in a sustainable manner, which now are called "marginal lands", to a large-scale agricultural mode

In this sense, it is not possible to conceive a system of risk assessment without taking into account socio - economic elements, in line with Article 26 of the Cartagena Protocol.

Given the limited understanding we have of how these “marginal ecosystems” function in a context of industrial agriculture, the core driver of the risk assessment should be the precautionary principle.

Although risk assessment should be made using the best available scientific information, which is low, the precautionary principle should be the lead element for both, the risk assessment process and the decision making process prior the introduction of new GM crops in these “marginal lands”. It can not be “a science driven decision.

We must consider that there is very little scientific research on all aspects that would be required before the introduction of industrial crops on land that by definition are extremely fragile, and where local populations depend on, and that they have been able to survive due to the delicate balance that they have developed with their environment.

Therefore, the effectiveness of risk assessment is limited because of these gaps, which creates great uncertainty and weaken the predictive power of science. The Cartagena Protocol itself acknowledges the existence of these gaps, and also acknowledges  that new scientific evidence might arise related with the dangers that this technology entails (See Art.12 of the Protocol).

Often in the risk assessment process arbitrary and pre-established assumptions are made, and extrapolation of not similar conditions are being used. In several national laws and regulations risk assessments use the principle of "familiarity", which is not recognized by the Protocol, and is based on procedures which has no scientific support, since it extrapolates and draws conclusions and decisions based on studies made in different environmental, socioeconomic and cultural contexts, and in the case of stress tolerant GMOs, with  different traits, which has not being subject to large scale industrial production.

In the case of abiotic tolerant GMO, stress risk assessments should take into account all the variables, especially when dealing with complex problems (both environmental and social ones). RA should consider cumulative and synergistic and long term effects of these new GMOs, they should go beyond conventional risk assessment.
Additionally, risk assessment in land with abiotic stress should include an assessment of the technological package to be implemented, not only of new traits, because the introduction of new crops and agricultural practices totally different from what have been conducted there before, and which would not be possible if it had not been genetically transformed, must be evaluated carefully in order to avoid irreversible damage to the sustainable use of biodiversity, as determined by the Article 1 of Annex 3 of the Protocol.

Dear Elizabeth and all:

First of all, it is nice to have your participation.

On reply message to Elizabeth,

The socio-economic elements should not be in the primary components of the RA, but after the first circle of the RA toward the end-point decision, it may be considered.  Thus, beyond abiotic stress traits, the aspect may be associated, but not essential with Roadmap. 

The consideration of socio-economic components do not fit well on logics construction of scientifically-sound evaluation for RA, which at first should be focused on the effect to the biodiversity/environment.
In considering also practicality of how the guidance document is provided to people who even does not have relevant experiences, complexity shall be avoided, and straight forward steps to be more appreciated, so far I see in many places.

LMOs(especially FFP or in extent LMO-Plants) with abiotic stress tolerance(s) are to be used in marginal land to protect and/or recover (hopefully) from environmental degradation.  Drought and salinity tolerances would be specific focus for discussion, for this practice: Environmental condition of direct application of LMOs  is obvious to make risk assessment. And to the folks already had experiences on RA on such LMOs, there are enough consideration made on the surrounding environments to examine whether adverse effect or not. In practicality, I do not see adding complication of  socio-economic components to RA on abiotic stress tolerances. it is outside scope of RA in any of risk assessment disciplines.

Also, I still have concern on expanding any of LMO RA discussion out from the focus of Annex III of the protocol which has been quite examined and discussed over times with more than cohorts of participants.

Kind regards,


Kazuo Watanabe

Abiotic stress tolerance is a complex trait. That is, it is thought to be controlled by several genes, possibly acting in an orchestrated fashion. Genetic engineering can insert genes into a plant but controlling the inserted genes presents more of a problem. Mostly, the genes are active in all the plant cells, during all stages of plants life. Commercial GE crops predominantly only involve simple traits (herbicide tolerance and insect resistance traits) that only involve single genes. The insertion of many genes (as would be required for expression of a multi gene trait) is possible through genetic engineering but, more difficult, is that all the genes would have to operate together (Bhatnagar-Mathur et al. 2007). Therefore, GE approaches to traits such as drought tolerance tend to only involve a single primary gene that is highly (or over-) expressed. This is exactly the case with Monsanto’s GE drought tolerant maize, a single primary gene (for cold tolerance) is inserted and under the control of switch (35S promoter) that make the gene on in every cell, all the time (Castiglioni et al. 2008 Plant Physiology, 147: 446-455).

The environmental and food safety of GE crops is unknown, even for those where the mechansim of how the inserted genes act (at least in theory) are understood.  This is because the inserted genes may disrupt the plant’s own genes, be unstable in their new environment, or function differently than expected. These concerns are heightened with this drought resistant GM maize because it isn’t known how the protein produced the inserted gene operates. Such consequences may not be linked directly to the drought-resistant trait, There is a high probability of unintended interferences with the plant’s own RNA. The consequences may not be realised in any testing undertaken to satisfy regulatory requirements in order to commercialise the crop, apparent in the short-term testing, or may only be apparent under stress. In addition, there may be unexpected effects on wildlife if this GE crop alters plant metabolism to become either toxic or have altered nutritional properties. Thus, any risk assessment becomes an extremely complex issue - to complex, in fact to provide a risk assessment. Thsi suggests the precautionary principel shoudl be employed.