Rebuild the African Breadbasket with the Power of Fertilizer and Promise of Biotechnology

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Africa’s farmers must do better.

The population of our continent continues to grow, but our ability to produce food remains stuck in the past. Experts say that global food production has to double by 2050 in order to meet demand–yet here in Africa, the average yield of grain crops hasn’t increased since the 1960s.

There’s no simple solution to Africa’s problems, and the root causes involve everything from political instability to unrelenting poverty. These challenges won’t vanish soon. Yet a few simple steps would make them appear less daunting: The nations of Africa should embrace agricultural biotechnology and also make sure farmers have ready access to fertilizer.

We have nothing to lose and everything to gain.

GM crops will guard against one of the most significant threats to farming in Africa: crop failure. Pest outbreaks can turn an excellent harvest into a rotten one, almost overnight. Biotechnology, however, offers seeds that will grow into healthy plants that naturally fight off insect predators. These tools also can help farmers survive severe weather, by making crops more resistant to heat, frost, and droughts.

The genetic modification of fruits and vegetables can prevent spoilage on the way to market. Success in this area could reduce wastage and expand trade opportunities. Farmers around the world rely on exports–and there’s no reason why Africa can’t improve its export opportunities through better science.

Biotechnology affords environmental benefits as well. Because GM crops boost yield, we’ll produce more food from less land. Farmers will preserve African wilderness, rather than turn forests and wetlands into acreage for crops.

We can even put damaged land back into circulation. Unsustainable irrigation practices have injected too much salinity into much of the African soil. Biotechnology holds the key to growing salt-resistant crops–advances won’t come soon, but they’ll be essential for my continent’s long-term food security.

Biotech crops also may contribute to bioremediation–the restoration of nutrients and soil structure. Throughout much of Africa, the soil has been severely depleted. Fertilizers that would begin to restore them are prohibitively expensive. It costs a farmer in sub-Saharan Africa about twice as much as a farmer in Europe to buy a bag of fertilizer.

Personally, I put fertilizer on everything I grow, including at least 75 kgs of per acre of maize. Every informed farmer should do the same. It makes a tremendous difference: In my region, yield from unfertilized crops is less than one-quarter of the yield from fertilized crops – even much less.

Yet fertilizer can be difficult to obtain. For the last month, Kenyan newspapers have been awash with stories of farmers who can’t get the fertilizer they require. Bureaucratic delays are a major stumbling block: Obtaining subsidized fertilizer demands a complicated ritual of signatures from local agriculture officials, banking instructions, approvals from the National Cereals and Produce Board, and plenty of travel in between. It’s a logistical nightmare. Even if it goes smoothly, there’s no guarantee that fertilizer will be available.

Some farmers go without fertilizer entirely. Others use a bit but not enough.

Just about everybody in farming appreciates the importance of fertilizer. Biotechnology is a different matter. Only three African countries–Burkina Faso, Egypt, and South Africa–have approved the technology that the United States and much of the rest of the developed world take for granted.

Three other countries–Kenya, Nigeria, and Uganda–are dragging their feet, but at least they’re conducting trials that could lead to commercialization. They’re moving too slowly, but at least they’re moving in the right direction. It looks like Malawi may join them soon.

Put together, that’s a mere seven African nations. That leaves 47 sovereign states in Africa that aren’t giving nearly enough thought to this essential tool of food production. We should aspire to the agricultural success of the developed world, rather than assume that we must remain forever behind in food production.

The promise of biotechnology and the power of fertilizer, put together, hold the potential to turn Africa into a breadbasket of food production.

The choice is ours: We can take advantage of these amazing opportunities or cling to the methods that already have failed us.

Gilbert Arap Bor grows maize, vegetables and dairy cows on a small-scale farm of 25 acres in Kapseret, near Eldoret, Kenya.  He also teaches at the Catholic University of Eastern Africa, Eldoret campus.  Mr. Bor is the 2011 Kleckner Trade & Technology Advancement Award recipient and a member of the Truth About Trade & Technology Global Farmer Network.

 

Gilbert Arap Bor

Gilbert Arap Bor grows maize, vegetables and dairy cows on a small-scale farm of 25 acres in Kapseret, near Eldoret, Kenya. Mr. Bor, a lecturer at the Catholic University of Eastern Africa’s Eldoret Campus (Gaba), is a member of the Truth About Trade & Technology Global Farmer Network and was recently honored as the 2011 Kleckner Trade & Technology Advancement Award recipient.

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7 Comments

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  2. Christopher Stampar said:

    I find many of the claims in this article to be shocking and fundamentally misguided.

    Firstly, concerning the use of fertilizer, it is crazy that one could so heavily promote the use of fertilizer when we know it’s devastating effects on the environment and farmers. For one, poor rural farmers simply cannot rely on such expensive chemical inputs, which the use of GM crops will only continue to require the use of. We also know that extensive use of fertilizer destroys the biodiversity and organic matter in soil, which not only makes our crops less nutritious, but seriously contributes to the GHG emissions associated with agriculture, as the ability of soil to sequester carbon is greatly diminished with the loss of organic matter.

    On top the high price for chemical inputs, the article fails to mention the astronomical prices of GM seeds that farmers would have to buy, year after year, and that are strategically designed to reap profits from poor farmers, not support their livelihoods.

    Moreover the idea that crops grown without fertilizer or GM seeds cannot produce sufficient yields is simply untrue. Here (http://www.fao.org/organicag/oa-faq/oa-faq7/en/) is just one example of the many where the FAO declares that in many circumstance organic agriculture can actually INCREASE yields.

    But this relentless emphasis on yields is also misguided. The world does not need MORE food. The world needs better distribution systems based on local small holder farmers to allow better access to the surplus of food we already produce. We should be focused on security, access, and distribution, not just production and yield numbers.

    This only scratches the surface of the inappropriate and harmful suggestions contained in this article.

    I find it dangerous to conclude and seriously suggest that “The promise of biotechnology and the power of fertilizer, put together, hold the potential to turn Africa into a breadbasket of food production,” when much of our current knowledge (from the FAO, IAASTD, http://www.agassessment.org) would suggest that this combination will continue to destroy food security, nutrition, the environment, and farmers lives.

    • Allan B Simons said:

      One wonders just where commenter Stampar lives and how he subsists – one assumes that it must be in the midst of a metropolis, a circumstance ONLY made possible by the kind of agriculture he excoriates so severely. His residence cannot resemble the small-farm African circumstances of the author whom he so roundly questions. This comment is a first-order rant and declaration of misanthropy.

      So, we humans, who have evolved to be able to determine the genetic and chromosomal makeup of every organism on earth are destined to wither because we might destroy the biodiversity of the soil and its organic matter? Does this mean that soil biodiversity is definable and static? What, plants don’t enjoy the optimum nutrition supplied by fertilizer nutrients discovered by humans, thus hugely increasing their vigor and health? Somewhere, there is probably an authoritative discourse on the manner in which various ethnic groups of Homo sapiens evolved according to the amount and nutritive value of the food they consumed.

      Yes, the world needs MORE food where it is now in short supply from nearby sources. Transportation and distribution does matter, especially where donkeys and carts are the main means of conveyance to big city markets throughout much of Africa.

      I’m rather pleased to be starting my 8th decade after a career in crop science and production agriculture because I shudder to consider the potential future state of mankind if nihilistic philosophies such as espoused by the commenter are to prevail.

  3. R Andrew Ohge said:

    Dr. Don Huber is an expert in an area of science that relates to the toxicity of genetically engineered (GE) foods.

    (Alternative terms for GE foods include genetically modified (GM), or “GMO” for genetically modified organism.)

    His specific areas of training include soil-borne diseases, microbial ecology, and host-parasite relationships.

    Dr. Huber also taught plant pathology, soil microbiology, and micro-ecological interactions as they relate to plant disease as a staff Professor at Purdue University for 35 years.

    GE Crops are Breaking the Agricultural System…

    Agriculture is a complete ‘system’ based on inter-related factors, and in order to maintain ecological balance and health, you must understand how that system works as a whole.

    Any time you change one part of that system, you change the interaction of all the other components, because they work together.

    It is simply impossible to change just one minor aspect without altering the entire system…

    Dr. Huber’s research, which spans over 55 years, has been devoted to looking at how the agricultural system can be managed for more effective crop production, better disease control, improved nutrition, and safety. The introduction of genetically engineered crops has dramatically affected and changed all agricultural components:

    The plants
    The physical environment
    The dynamics of the biological environment, and
    Pests and diseases (plant-, animal-, and human diseases)
    In this interview, Dr. Huber reveals a number of shocking facts that need to become common knowledge in order to stop this catastrophic alteration and destruction of our environment, our food supply, and ultimately, our own biology.

    I urge you to listen to the interview in its entirety, or read through the transcript to understand fully appreciate the importance of this development.

    Herbicides and Pesticides Immobilize Specific Nutrients

    One of the major modifications done to genetically engineered food crops is the introduction of herbicide resistance. Monsanto is the leader in this field, with their patented Roundup Ready corn, cotton, soybean and sugar beets, which can survive otherwise lethal doses of glyphosate—the active ingredient in Roundup.

    The working premise is that by making the plants resistant to the herbicide, farmers can increase yield by cutting down on weed growth. This premise has been found to be severely flawed however, as farmers around the world are now losing acreage to glyphosate-resistant super-weeds at an alarming rate. According to the British Institute of Science in Society, the US has fared the worst, now combating 13 different glyphosate-resistant weed species in 73 different locations.

    But the introduction of glyphosate-resistance has also had a direct impact on soil microbes.

    While the link between an herbicide (which is directed toward plants) and soil microbes may not be immediately apparent, this ripple effect occurs because, again, it’s an inter-related system. In a nutshell, herbicides are chelators that form a barrier around specific nutrients, preventing whatever life form is seeking to utilize that element from utilizing it properly. That applies both to plants and soil microbes—as well as animals and humans.

    This may actually be one of the primary reasons why genetically engineered foods appear to be able to cause such profound health problems in those who consume them. Any organism that has the same physiological pathways for these nutrients will be impacted in the same manner.

    Dr. Huber explains:

    “You have to realize what an herbicide, or a pesticide, is. They are metal chelators. In other words, they immobilize specific nutrients… [I]t’s a compound that can grab onto another element and change either its solubility or its availability for the critical function it has physiologically. We have herbicides and pesticides that are quite specific just for a particular essential micronutrient like copper, zinc, iron, or manganese.

    Glyphosate is very unique and was first patented as a chelator by Stauffer Chemical Co. in 1964, because it could bind with any positively charged ion. If you look at the essential minerals for plants, you see calcium, magnesium, potassium, copper, iron, manganese, zinc, and all of those other critical transition elements, as well as structural components for some of them… They all have an ion associated with them. It’s the micronutrient that is an ion—that is a transition element, or that element that is really critical for a particular enzyme function.

    If you can chelate and, in that chelation process, essentially immobilize that essential nutrient, you have provided an opportunity to either kill a weed or damage and kill an organism—any organism… that have that particular requirement for that physiologic pathway with glyphosate or the shikimate pathway…

    You have to realize that this mode of action immobilizes a critical essential nutrient. Those nutrients aren’t just required by the weed, but they’re required by microorganisms. They’re required by us for our own physiologic functions. So if it’s immobilized, it may be present if we do a regular test. But it’s not necessarily physiologically available in the same efficiency that it would have been if it wasn’t chelated with glyphosate…”

    The Dangers of Glyphosate that Most People Have NO Idea Of

    Glyphosate, even in plants genetically engineered to withstand it, affects about 25 different enzymes in the process of chelating, or immobilizing, critical micronutrients, because those ions (the micronutrients) are required in order to “drive” the physiological engines that make the plant or organism function properly.

    “It is well documented that… having that foreign gene inserted reduces the capability of that plant to take up nutrients and to translocate nutrients,” Dr. Huber says. “Then, when you apply the chemical [glyphosate], you have a further compounding effect in reducing the efficiency of the plants at rates as low as 12 grams per acre.”

    According to Dr. Huber, the nutritional efficiency of genetically engineered (GE) plants is profoundly compromised. Micronutrients such as iron, manganese and zinc can be reduced by as much as 80-90 percent in GE plants!

    Many staunch defenders of genetically engineered foods are under the misconception that GE foods are “better” or have improved nutrition when the exact opposite is true. They also don’t understand that the glyphosate residue cannot be removed or washed off—it actually becomes part of the plant. It cannot be washed off because it’s systemic within the plant itself.

    “It’s going to be in your root tips, your shoot tips, your legume nodules, and in the food that you eat,” Dr. Huber warns.

    Furthermore, about 20 percent of the glyphosate migrates out of the plant’s roots and into the surrounding soil. Once in the soil, the glyphosate affects beneficial soil microorganisms in the same way that it affects weeds, because they have the same critical metabolic pathway. With each new Roundup Ready crop approved, the glyphosate residues in the soil increases, and the tolerance levels in the crop increases as well.

    This is explosive information that should make warning bells go off in most people’s heads! Personally, I firmly believe we must all become activists to eliminate this threat to our food supply as soon as possible.

    Food Quality is Related to Soil Quality

    The quality of the food is almost always related to the quality of the soil. The most foundational and critical components of the soil are the microorganisms that thrive there—more so than the necessary nutrients, because it’s the microorganisms that allow the plants to utilize those nutrients.

    According to Dr. Huber:

    “The plant can only utilize certain [reduced] forms of all the nutrients… The way that it becomes reduced in the soil is through those beneficial microorganisms. We also have microorganisms for legumes like soybeans, alfalfa, peas, or any of the other legumes that can fix up to 75 percent of their actual nitrogen for protein in amino acid synthesis that actually comes from the air through the microorganisms in the soil.

    Glyphosate is extremely toxic to all of those organisms.

    What we see with our continued use and abuse of this powerful weed killer is that it is also totally eliminating many of those organisms from the soil. We no longer have the same balance that we used to have. Consequently, we see an increase of over 40 new plant diseases, and diseases we used to have under fairly effective control, which now all of a sudden is another serious problem.”

    GE Foods Fueling Deadly Botulism in Cattle

    The normal biological control organisms—the beneficial gut bacteria—in animals and humans are also very sensitive to residual glyphosate levels.

    For example, toxic botulism is now becoming a more common cause of death in dairy cows whereas such deaths used to be extremely rare. The reason it didn’t occur before was because beneficial organisms served as natural controls to keep the Clostridium botulinum in check. Without them, the Clostridium botulinum is allowed to proliferate in the animal’s intestines and produce lethal amounts of toxins.

    “Again, the agricultural system, as well as our own ecology, is really a balance,” Dr. Huber says. “It’s a system, not just a bunch of silver bullets that are stacked in a chamber of a revolver. It’s how that ecological system is modified and changed that brings us a new level of diseases and problems with sustainability of our agriculture, our own health, and well-being.”

    MOST Major US Food Crops are Now Genetically Engineered!

    Many still don’t realize just how much of our food supply has been genetically engineered (GE). As of this year, 93 percent of soybeans grown in the US are genetically engineered, as are:

    86 percent of all corn
    93 percent of canola
    93 percent of cottonseed oil
    Between 2008 and 2009, a full 95 percent of all sugarbeets planted were also Roundup Ready.

    This means that virtually every processed food you encounter at your local supermarket that does not bear the “100% USDA Organic” label is likely to contain at least one GE component! Earlier this year, the US Department of Agriculture (USDA) also deregulated genetically engineered alfalfa, which is a perennial crop commonly used in cattle feed.

    According to Dr. Huber:

    “Alfalfa is our fourth most important economic crop, by far the most nutritional feed for our herbivores. They, all of a sudden, can definitely be threatened—not only because of the direct effect of glyphosate on microorganisms, but also because it predisposes and can make that plant very susceptible to some common diseases…

    We see this on corn… where we have the sister organism with the Goss’s wilt, a bacterial disease. In that situation, we find that when we put glyphosate on, it nullifies all the genetic resistance that, in the past, made that disease of almost no consequence…Now we find it from coast to coast, East to West, from Mexico to Canada. For four years now, we have a major epidemic in a major food production area in the Midwest, just from that disease.

    That is a direct result of our genetic engineering process, which reduces the genetic resistance, and the application of the herbicide that it was designed to tolerate.”

    Important Questions Still Unanswered…

    According to Dr. Huber, there’s currently enough residual glyphosate in animal feed and food to make an otherwise benign organism lethal…

    Unfortunately, research is still lacking to ascertain exactly how great the risk to human health is. It’s possible that those who do not consume an all-organic diet, which is the majority of Americans, to some extent or another, are destroying their gut flora with every bite of food they eat. According to Dr. Huber, the reduction in mineral content through chelation by glyphosate residues in GE plants would certainly make you far more susceptible to potentially dangerous pathogens.

    Studies have already confirmed that glyphosate alters and destroys beneficial gut flora in animals, as evidenced by the increasing instances of lethal botulism in cattle.

    I’ve written extensively about the importance of your gut flora on your health. You NEED beneficial bacteria in your gut, or health problems are virtually guaranteed. Optimizing your gut flora may be one of the single most important things you can do to maintain good physical and mental health, so the fact that GE foods may be adversely impacting your intestinal balance is of extreme importance and needs to be understood.

    Another important question that does not at present have an answer is whether or not glyphosate accumulates in animal- and human tissues once consumed. We don’t even know if glyphosate is fat-soluble, which would definitely make it accumulate in fat tissues.

    GE Foods Brings Brand New Threat

    Earlier this year, Dr. Huber wrote a letter to USDA Secretary Tom Vilsack, informing him of the issues discussed above, as well as another groundbreaking new finding that could spell absolute disaster for our entire food supply. It’s a brand new micro-fungal organism associated with something called Sudden Death Syndrome (SDS) in soy. It’s also found in a large variety of livestock given GE feed who experience both spontaneous abortions and infertility.

    Dr. Huber urged the USDA to investigate the matter and suspend approval of GE alfalfa until proper studies have been completed. His warnings have so far been largely ignored, and GE alfalfa was deregulated earlier this year…

    “When you look at the tremendous increase in human diseases that can have a potential tie directly back to either the chemical or the engineering process, it’s critical for that research to be done as quickly as possible. We need resources to do it. The private funds, again, aren’t going to do everything because there’s just too much to be done.”

    The organism was initially identified by veterinarians around 1998—about two years after the introduction of Roundup Ready soybeans, which is one of the staple feeds. The vets were puzzled by sudden high reproductive failure in animals. While sporadic at first, the phenomenon has continued to increase in severity.

    “We [recently] received a call from a county extension educator, indicating that he has a dairy that has a 70 percent abortion rate. You put that on top of 10 to 15 percent of infertility to start with, and you’re not going to have a dairy very long. In fact, a lot of our veterinarians are now becoming very concerned about the prospects for being able to have replacement animals,” Dr. Huber says.

    The cause-effect relationship between high reproductive failure and this new microbial entity has been established, but the research has not yet been published. The reason for the delay is because they really do not know what the organism is…

    “It’s not a fungus. It’s not bacteria. It’s not a mycoplasma or a virus – it’s about the same size of a small virus; you have to magnify it from 38 to 40,000 times. They have pictures of it… You can see the interactions with it. They can now culture it. It’s self-replicating and cultured. It doesn’t grow very well by itself.

    Like most of our very fastidious organisms, it tends to die out after three or four sub-culturing, but grows very well with other organisms. If you have yeast, bacteria, or a fungus in the culture, this entity grows very well.

    We’re waiting on getting enough material, pure material, for DNA analysis, but also looking at some other possibilities… Until you can put a name on it, all it does is create a great deal of speculations.”

    What is known is that it’s an entirely new entity, previously unknown to science, and it’s definitely found in genetically engineered corn and soybeans. It’s also been established that it causes infertility and miscarriage in cattle, horses, pigs, sheep, and poultry.

    “We can anticipate with that broad spectrum of animal species, which is extremely unusual, that it will also be with humans,” Dr. Huber says. “We’ve seen an increasing frequency of miscarriage and a dramatic increase in infertility in human populations in just the last eight to 10 years.”

    Why is the USDA Ignoring Such Urgent Warnings?

    Dr. Huber received a response from Dr. Parham, head of the USDA-APHIS, assuring him that “all of the decisions that the USDA makes are based on peer-reviewed science.” Dr. Huber responded with another letter, pointing out 130 published peer-reviewed articles documenting all of his concerns.

    “I asked if they could provide me a peer-reviewed scientific study that would justify the regulation of those products,” he says. “I’m still waiting for that. I haven’t found anyone that can produce that type of document.

    … I did receive a call from Risk Management about two weeks after writing the letter, asking if I could provide details, because there wasn’t anything in the letter. The letter was written to a politician. I didn’t want to disclose names of scientists or details because of the retaliatory effect that we see with anyone researching this area – they can be either fired from their job or their program shut down. That’s a real fact.”

    The Red-Tape Nightmare of GE Safety Research

    Crazy as it sounds, researchers cannot perform whatever safety studies on GE foods they see fit because the way the red tape has been put in place, they could easily be found guilty of breaking the law by performing research on a patented product.

    “If you read the technology agreement that the farmer has to sign, he can’t even do research on his own farm to compare whether this crop or this product is better than another one without violating the terms of that technology agreement,” Dr. Huber explains. “It’s essentially a closed system to guarantee success.”

    … A group of us that are working together on the new entity causing reproductive failure… have obtained private funding, and have taken it to experts in the areas of specific diseases and tried to encourage them to work on it. In the past year, they have been prohibited from working on it by their universities or department heads…

    That’s one of the reasons why we needed that contact with the USDA officials, in hopes that we could share the problems that concern them, that they would recognize the serious nature of this, and that we could obtain their support and use their resources for funding of individuals and specialists, so that we could overcome that barrier that seems to be there for anyone working on genetically engineered crops that might indicate that they’re not quite everything they were cut out to be.

    It’s almost as though you have to belong to that religion, if you’re going to do any research or publish your research.”

    Obviously, such as setup will produce highly biased and prejudiced results, and can easily obfuscate the truth…

    GE Food and Premature Aging

    Another astonishing effect of this brand new mystery organism associated with GE crops is profound premature aging. Research done in Iowa three years ago showed that prime beef from a two-year old cow had to be downgraded to that from a 10-year old cow!

    So what effect will eating this GE-fed beef have on you? No one knows. But I would bet it won’t make you any healthier… And if animals are any indication, it could spell disaster for your overall health and fertility.

    “When the veterinarians wanted to find the source for this [brand new] entity, they went to the feed. The first place where they found high concentrations was in the soybean mill. Since then we’ve found it in the corn. We find it in silage. Primarily in high concentrations only where we have a genetically engineered crop that has glyphosate applied to it. Those are the crops that we also see high Goss’s wilt, high SDS. They are all correlated together in that relationship.

    The other place you see it, though, is where they have used the manure that has a high glyphosate residue level in it. The manure also has very high concentrations, if the chickens or the animals that have been fed these feeds with high concentrations. When that manure is applied to pastures and cattle graze on it, we also see high infertility rates there.

    It occurs in the placenta, in the fetus, in the sperm and inseminators.

    Stating that it takes twice as much semen now to get a conception and as many as four to eight inseminations rather than the typical 1.2 to 1.5 for a dairy because of that reduced fertility… I was on a plane with a bull breeder who commented that 40 percent of his bulls had to be pulled out of service, because they can’t get conception anymore.”

    But that’s not all. Glyphosate can also disrupt a number of other biological systems aside from your reproductive system.

    ” … When you have a very potent chelator, it disrupts all kinds of systems, not just the EPSPs system that we find in certain microorganisms and plants, but also all of the other systems involved in liver function, blood function, and hormonal function. They all go right back to that basic nutrient process that keeps all systems functional,” Dr. Huber explains.

    Glyphosate is actually a very potent endocrine disruptor that can affect your:

    Endocrine system
    Thyroid function
    Pituitary function
    Important Summary

    As Dr. Huber said

    “When future historians come to write about our era they are not going to write about the tons of chemicals we did or didn’t apply. When it comes to glyphosate they are going to write about our willingness to sacrifice our children and to jeopardize our very existence by risking the sustainability of our agriculture; all based upon failed promises and flawed science.

    The only benefit is that it affects the bottom-line of a few companies. There’s no nutritional value.”
    As if hundreds of years of Slavery and Colonial Oppression just wasn’t enough…

  4. R Andrew Ohge said:

    And here’s a little Peer Reviewed Real Science to scry through-of course the big Agri-Business Companies don’t subscribe to this stuff:

    Genetically modified crops safety assessments: present limits and possible improvements
    Gilles-Eric Séralini1*, Robin Mesnage1, Emilie Clair1, Steeve Gress1, Joël S de Vendômois2 and Dominique Cellier3
    • *Corresponding author: Gilles-Eric Séralini criigen@unicaen.fr
    Author Affiliations
    1Laboratory of Biochemistry – IBFA, University of Caen, Esplanade de la Paix, 14032 Caen, Cedex, France
    2CRIIGEN, Paris, France
    3University of Rouen LITIS EA 4108, 76821 Mont-Saint-Aignan, France
    For all author emails, please log on.
    Environmental Sciences Europe 2011, 23:10 doi:10.1186/2190-4715-23-10
    The electronic version of this article is the complete one and can be found online at: http://www.enveurope.com/content/23/1/10
    Received: 17 January 2011
    Accepted: 1 March 2011
    Published: 1 March 2011

    © 2011 Séralini et al; licensee Springer.
    This is an Open Access article distributed under the terms of the Creative Commons Attribution License (http://creativecommons.org/licenses/by/2.0), which permits unrestricted use, distribution, and reproduction in any medium, provided the original work is properly cited.
    Abstract
    Purpose
    We reviewed 19 studies of mammals fed with commercialized genetically modified soybean and maize which represent, per trait and plant, more than 80% of all environmental genetically modified organisms (GMOs) cultivated on a large scale, after they were modified to tolerate or produce a pesticide. We have also obtained the raw data of 90-day-long rat tests following court actions or official requests. The data obtained include biochemical blood and urine parameters of mammals eating GMOs with numerous organ weights and histopathology findings.
    Methods
    We have thoroughly reviewed these tests from a statistical and a biological point of view. Some of these tests used controversial protocols which are discussed and statistically significant results that were considered as not being biologically meaningful by regulatory authorities, thus raising the question of their interpretations.

    Results
    Several convergent data appear to indicate liver and kidney problems as end points of GMO diet effects in the above-mentioned experiments. This was confirmed by our meta-analysis of all the in vivo studies published, which revealed that the kidneys were particularly affected, concentrating 43.5% of all disrupted parameters in males, whereas the liver was more specifically disrupted in females (30.8% of all disrupted parameters).
    Conclusions
    The 90-day-long tests are insufficient to evaluate chronic toxicity, and the signs highlighted in the kidneys and livers could be the onset of chronic diseases. However, no minimal length for the tests is yet obligatory for any of the GMOs cultivated on a large scale, and this is socially unacceptable in terms of consumer health protection. We are suggesting that the studies should be improved and prolonged, as well as being made compulsory, and that the sexual hormones should be assessed too, and moreover, reproductive and multigenerational studies ought to be conducted too.
    Background, aim, and scope
    Recently, an ongoing debate on international regulation has been taking place on the capacity to predict and avoid adverse effects on health and the environment for new products and novel food/feed (GMOs, chemicals, pesticides, nanoparticles, etc.). The health risk assessments are often, but not always, based on the study of blood analyses of mammals eating these products in subchronic tests, and more rarely in chronic tests. In particular, in the case of GMOs, the number and nature of parameters assessed, the length of the necessary tests, the statistics used and their interpretations are the subject of controversies, especially in the application of Organization of Economic Cooperation and Development (OECD) norms. Confusion is perceived even in regulatory agencies, as in the European Food Safety Authority (EFSA) GMO panel working group and its guidelines. Doubt has arisen on the role and necessity of animal feeding trials in safety and nutritional assessments of GM plants and derived food and feed [1]. Based on the literature data, EFSA first admitted (p. S33) that for other tests than GMOs: “For 70% (57 of 81) of the studies evaluated, all toxicological findings in the 2-year tests were seen in or predicted by the 3-month subchronic tests”. Moreover, they also indicated (p. S60) that “to detect effects on reproduction or development [...] testing of the whole food and feed beyond a 90-day rodent feeding study may be needed.” We fully agree with these assumptions. This is why we think that in order to protect large populations from unintended effects of novel food or feed, imported or cultivated crops on a large scale, chronic 2-year and reproductive and developmental tests are crucial. However, they have never been requested by EFSA for commercial edible crops. We therefore wish to underline that in contrast with the statements of EFSA, all commercialized GMOs have indeed been released without such tests being carried out, and as it was the case recently with maize stacked events without 90-day in vivo mammalian tests being conducted. GM stacked events have the cumulated characteristics of first generation of GMOs (herbicide tolerance and insecticide production), which are mostly obtained by hybridization. For instance, Smarstax maize contains two genes for herbicide tolerance and six genes for insecticide production. In fact, this contradictory possibility was already highlighted in the same review by EFSA (p. S60), when substantial equivalence studies and other analyses were performed: “animal feeding trials with rodents [...] adds little if anything [...], and is not recommended.” This is why, in this work we will analyze and review deficiencies in GMO safety assessments, not only performed by biotech companies, but also by regulatory agencies.
    We will focus on the results of available 90-day feeding trials (or more) with commercialized GMOs, in the light of modern scientific knowledge. We also suggest here an alternative to conventional feeding trials, to understand the biological significance of statistical differences. This approach will make it possible to avoid both false negative and false positive results in order to improve safety assessments of agricultural GMOs before their commercialization for cultivation and food/feed use and imports.
    Overview of the safety studies of GMOs performed on mammals
    Our experience in scientific committees for the assessment of environmental and health risks of GMOs and in biological, biostatistical research, and medicine, as well as in the research relative to side effects [2-6] allowed us to review and criticize mammalian feeding trials with GMOs and make new proposals. Mammalian feeding trials have been usually but not always performed for regulatory purposes in order to obtain authorizations or commercialization for GM plant-derived foods or feed. They may have been published in the scientific literature afterwards; however, without public access to the raw data.
    We have obtained, following court actions or official requests, the raw data of several 28- or 90-day-long safety tests carried out on rats. The thing we did was to thoroughly review the longest tests from both a biostatistical and a biological point of view. Such studies often analyze the biochemical blood and urine parameters of mammals eating GMOs, together with numerous organ weights and histopathology. We have focused our review on commercialized GMOs which have been cultivated in significant amounts throughout the world since 1994 (Table 1). We observe and emphasize that all the events in Table 1 correspond to soybean and maize which constitute 83% of the commercialized GMOs, whilst other GMOs not displayed in the table, but still commercialized, are canola or cotton. However, they are not usually directly consumed [7]. Only Sakamoto’s and Malatesta’s studies have been more than 90 days long (104 weeks and 240 days with blood analyses in Japanese for the first one). Moreover, such tests are not obligatory yet for all GMOs. No detailed blood analysis is available for Malatesta’s study, as it mostly includes histochemistry at the ultrastructural level; moreover, the latter tests have not been used to obtain the commercial release by the firm. However, this work has been performed by researchers independent from the GMO industry; it is an important element to take into account for an objective interpretation of the facts, as pointed out in the case of the risk assessments conducted by regulatory agencies with Bisphenol A. For instance in the latter case, it was observed that none of the industry-funded studies showed adverse effects of Bisphenol A, whereas 90% of government-funded studies showed hazards at various levels and various doses [8]. However, regulatory agencies still continue to refer only to industry-funded studies because they are supposed to follow OECD norms, even if such standards are not always appropriate for the detection of environmental hazards [9]. In this paper, Myers et al. showed that hundreds of laboratory animals and cell culture studies were rejected by regulatory authorities because they did not follow the Good Laboratory Practices (GLP). The Food and Drug Administration and EFSA have based their final decision on two industry-funded studies, claiming that they were superior to the others because they followed GLP. Yet, GLP are based on ancient paradigms. They have serious conceptual and methodological flaws, and do not take into account the latest knowledge in environmental sciences. For example, in the case of Bisphenol A assessment, the animal models used are known to be insensitive to estrogen (CD-1 mouse). Also, assays and protocols in some OECD guidelines are out of date and insensitive. It is obvious that new product assessments should be based on adapted studies using state-of-the-art experiments. The significant gap between scientific knowledge and regulations should be filled also in the case of GMOs [9]. Therefore, some tests presented here show controversial results or statistically significant results that were not considered as biologically significant by EFSA, raising the question of their interpretation.
    Table 1. Review of the longest chronic or subchronic toxicity studies in mammals fed with commercialized GM soybean and maize representing more than 80% of edible GMOs (2010).
    First of all, the data indicating no biological significance of statistical effects in comparison to controls have been published mostly by companies from 2004 onwards, and at least 10 years after these GMOs were first commercialized round the world. This is a matter of grave concern. Moreover, only three events were tested for more than 90-days in feeding experiments or on more than one generation. This method was not performed by industries which conducted 90-day tests (with blood and organ analyses), but it was in some cases only. However, a 90-day period is considered as insufficient to evaluate chronic toxicity [1,5]. All these commercialized cultivated GMOs have been modified to contain pesticides, either through herbicide tolerance or by producing insecticides, or both, and could therefore be considered as “pesticide plants.” Almost all GMOs only encode these two traits despite claims of numerous other traits. For instance, Roundup ready crops have been modified in order to become insensitive to glyphosate. This chemical together with adjuvants in formulations constitutes a potent herbicide. It has been used for many years as a weed killer by blocking aromatic amino acid synthesis by inhibition of 5-enolpyruvylshikimate-3-phosphate synthase (EPSPS). Most Roundup ready plants have been modified thanks to the insertion of a mutated EPSPS gene coding for a mutated enzyme, which is not inhibited by glyphosate. Therefore, GM plants exposed to glyphosate-based herbicides such as Roundup do not specifically degrade glyphosate. They can even accumulate Roundup residues throughout their life, even if they excrete most of such residues. Glyphosate and its main metabolite AMPA (with its own toxicity) are found in GMOs on a regular and regulatory basis[10,11]. Therefore, such residues are absorbed by people eating most GM plants (as around 80% of these plants are Roundup tolerant). On the other hand, about 20% of the other GMOs do synthesize new insecticide proteins through the insertion of mutated genes derived from Bacillus thuringiensis (Bt).
    Usually, pesticides are tested over a period of 2 years on a mammal, and this quite often highlights side effects. Additionally, unintended effects of the genetic modification itself cannot be excluded, as direct or indirect consequences of insertional mutagenesis, creating possible unintended metabolic effects. For instance, in the MON810 maize, the insertion of the transgene in the ubiquitine ligase gene caused a complex recombination event, leading to the synthesis of new RNA products encoding unknown proteins [12]. Thus, genetic modifications can induce global changes in the genomic, transcriptomic, proteomic, or metabolomic profiles of the host. The frequency of such events in comparison to classical hybridization is by nature unpredictable. In addition, in a plant producing a Cry1Ab-modified toxin, a metabolomic study [13] revealed that the transgene introduced indirectly 50% changes in osmolytes and branched amino acids.
    Review of statistical effects after GMO consumption
    Some GMOs (Roundup tolerant and MON863) affect the body weight increase at least in one sex[2,14]. It is a parameter considered as a very good predictor of side effects in various organs. Several convergent factors appear to indicate liver and kidney problems as end points of GMO diet effects in these experiments [2,5,15,16]. This was confirmed by our meta-analysis of all in vivo studies published on this particular topic (Table 2). The kidneys are particularly affected, concentrating 42% of all parameters disrupted in males. However, other organs may be affected too, such as the heart and spleen, or blood cells [5].
    Table 2. Meta-analysis of statistical differences with appropriate controls in feeding trials
    Liver parameters
    For one of the longest independent tests performed, a GM herbicide-tolerant soybean available on the market was used to feed mice. It caused the development of irregular hepatocyte nuclei, more nuclear pores, numerous small fibrillar centers, and abundant dense fibrillar components, indicating increased metabolic rates [17]. It was hypothesized that the herbicide residues could be responsible for that because this particular GM plant can absorb the chemicals to which it was rendered tolerant. Such chemicals may be involved in the above-mentioned pathological features. This became even clearer when Roundup residues provoked similar features in rat hepatic cells directly in vitro [18]. The reversibility observed in some instances for these parameters in vivo[19] might be explained by the heterogeneity of the herbicide residues in the feed [20]. Anyway, these are specific parameters of ultrastructural dysfunction, and the relevance is clear. The liver is reacting. The Roundup residues have been also shown to be toxic for human placental, embryonic, and umbilical cord cells [21-23]. This was also the case for hepatic human cell lines in a comparable manner, inducing nuclei and membrane changes, apoptosis and necrosis [24].
    The other major GMO trait has to do with the mutated (mBt) insecticidal peptidic toxins produced by transgenes in plants. In this case, some studies with maize confirmed histopathological changes in the liver and the kidneys of rats after GM feed consumption. Such changes consist in congestion, cell nucleus border changes, and severe granular degeneration in the liver [16]. Similarly, in the MON810 studies, a significantly lower albumin/globulin ratio indicated a change in hepatic metabolism of 33% of GM-fed male rats (according to EFSA opinion on MON810 and [5]). Taken together, the results indicate potential adverse effects in hepatic metabolism. The insecticide produced by MON810 could also induce liver reactions, like many other pesticides. Of course, the mCry1Ab and other mBt (mutated Bt toxins derived from native Bacillus thuringiensis toxins) in GMOs are proteic toxins; however, these are modified at the level of their amino acid sequence by biotechnologies and introduced by artificial vectors, thus these could be considered as xenobiotics (i.e., a molecule foreign to life). The liver together with the kidneys are the major reactive organs in case of food chronic intoxication.
    Kidney parameters
    In the NK603 study, statistically significant strong urine ionic disturbances and kidney markers could be explained by renal leakage [5], which is well correlated with the effects of glyphosate-based herbicides (like Roundup) observed on embryonic kidney cells [23]. This does not exclude metabolic effects indirectly due to insertional mutagenesis linked to the plant transformation. Roundup adjuvants even stabilize glyphosate and allow its penetration into cells, which in turn inhibit estrogen synthesis as a side effect, cytochrome P450 aromatase inhibition [21]. This phenomenon changes the androgen/estrogen ratio and may at least, in part, explain differential impacts in both sexes.
    Kidney dysfunctions are observed with mBt maize producing mutated insecticides such as in MON863. For instance, we quote the initial EFSA report: “Individual kidney weights of male rats fed with the 33% MON863 diet were statistically significantly lower compared to those of animals on control diets”, “small increases in the incidences of focal inflammation and tubular regenerative changes in the kidneys of 33% MON863 males.” This was confirmed by the company tests [25] and another counter analysis revealed disrupted biochemical markers typical of kidney filtration or function problems [2]. The first effects were not always but sometimes greater than the ones with non-isogenic maize (called reference lines), which contain different salts, lipids, or sugars. Moreover, both results described are different between males and females; this is quite usual in liver or kidney pesticide reactions. These facts do not exclude that such effects can be considered as treatment-related. Other studies also confirmed effects on kidneys. Tubular degeneration and not statistically significant enlargement in parietal layer of Bowman’s capsules were also observed with GM maize fed rats [16].
    Last but not least, a total of around 9% of parameters were disrupted in a meta-analysis (Table2). This is twice as much as what could be obtained by chance only (generally considered as 5%). Surprisingly, 43.5% of significant different parameters were concentrated in male kidneys for all commercialized GMOs, even if only around 25% of the total parameters measured were kidney-related. If the differences had been distributed by chance in the organs, not significantly more than 25% differences would have been found in the kidney. Even if our own counter analysis is removed from the calculation, showing numerous kidney dysfunctions [2], around 32% of disturbances are still noticed in kidneys.
    Discussion
    Need for chronic tests and other tests
    Chronic toxicity tests (both with males and females) and reproductive tests with pregnant females and then with the developing progeny over several generations (none of these steps exist at present) are called as a whole the Toxotest approach (or Risk management test, see “Details on the new suggested Toxotest approach”). This could address the long-term physiological or pathological relevance of the previous observations. The physiological interpretations of 90-day-based effects are otherwise somewhat limited. These studies should be complementary to the present regulations or the Safotest and the sentinel test suggested by EFSA [1]. The Toxotest could provide evidence of carcinogenic, developmental, hormonal, neural, and reproductive potential dysfunctions, as it does for pesticides or drugs. Additionally, it is obvious that the 90-day-long trials on mature animals performed today cannot scientifically replace the sensitivity of developmental tests on neonates. A good example is the gene imprinting by drugs that will be revealed only at maturity; this is an important subject of current research, and many findings have been reported for some chemicals such as bisphenol A [26,27]. Even transgenerational effects occur after epigenetic imprinting by a pesticide [28]. These effects cannot be detected by classical 90-day feeding trials and will be visible after many decades by epidemiology in humans if any, as illustrated in the case of diethylstilbestrol, which induced female genital cancers among other problems in the second generation [29]. The F3 multigenerational study for a GMO (Table 1) was too rarely performed. This is why, because of the number of parameters disrupted in adult mammals within 90 days, the new experiments should be systematically performed to protect the health of billions of people that could consume directly or indirectly these transformed products.
    The acute toxicity approach (less than a month of investigations on rodents with high doses) may give effects which are more proportional to the dose, as it might correspond to a rapid poisoning of the animals, generally with force-fed experiments. However, for many pesticide studies in the scientific literature, some long-term side effects of pesticides at environmental doses are described, which are not apparent in short-term experiments [30]. Classical toxicology is quite often based on the concept of revealing linear dose-responses as defined by Paracelsus, which generally fails to evidence U or J curves observed after hormonal sex-specific disruptions. Moreover, the effects of mixtures are also neglected in long-term studies, when supposed active principles of pesticides are not assessed with their adjuvants, which also are present as residues in GMOs. Such pesticides may have the capacity to disrupt the “cell web”, i.e., to interfere with a signaling pathway, and this could be unspecific. For instance Roundup is known to disrupt the EPSPS in plants, but is also known to interact with the mammalian ubiquist reductase [21] common and essential to cytochromes P450, a wide class of detoxification enzymes. The so-called Roundup active principle, glyphosate, acts in combination with adjuvants to increase glyphosate-mediated toxicity[21,31], and this may apply to other environmental pollutants [22]. Moreover, all new metabolites in edible Roundup ready GMOs, as acetyl-glyphosate for the new GAT GMOs, have not been assessed for their chronic toxicity [11], and we consider this as a major oversight in the present regulations.
    Therefore, as xenobiotic effects are complex, the determination of their toxic effects cannot be determined using a single method, but rather converging pieces of evidence. In GMO risk assessment, the protocols must be optimized to detect side effects, in particular for herbicide-treated GM plants. These cannot be reduced to GM assessment on one side and herbicide residues with any diet on the other side, but unfortunately this has been the case, and this approach has been promoted up to now by regulatory authorities.
    In fact, it is impossible, within only 13 weeks, to conclude about the kind of pathology that could be induced by pesticide GMOs and whether it is a major pathology or a minor one. It is therefore necessary to prolong the tests, as suggested by EFSA, since at least one third of chronic effects visible with chemicals are usually new in comparison to the ones highlighted in subchronic studies[1]. The so-called Toxotests, which are supposed to include the studies of chronic pathologies in particular, should be performed on three mammalian species, with at least one non-rodent, similar to the type of rodents used for pesticides and drugs. However, the chronic feeding tests for GMOs cannot be based on the no observed adverse effect level, nor on the lowest observed adverse effect level approach, as in classical toxicology. There are several reasons for that. There is not only one chemical, but also several unknown metabolites and components, in Roundup tolerant varieties for instance, and therefore toxicity is enhanced thanks to the fact that they are mixed together. There is also no possibility of increasing the doses of GMOs in an equilibrated diet over an acceptable level. The diets should be rather representative of an equilibrated diet with GMOs like it could be the case in a real population in America. To prolong 90-day subchronic tests with three normal doses of GM in the diet (11%, 22%, 33% for instance) is the solution.
    Sex- or dose-specific pathological effects are common
    When there is a low or environmental dose impregnation of the feed (with a pesticide GM plant for instance), the chronic effects could be more differentiated according to the sex, the physiological status, the age, or the number of intakes over such and such a period of time in the case of a drug. These parameters (chronic intake, age of exposure, etc.) are more decisive for pathologies like cancers, than the actual quantity of toxin ingested in one intake. This is in part because the liver, kidney, and other cytochrome P450-rich organs are concerned for long-term metabolism and detoxification, and this phenomenon is hormone dependent. It is also due to the process of carcinogenesis or hormone-sensitive programming of cells [32]. The liver for instance is a sex differentiated organ as far as its enzymatic equipment is concerned [4]. An effect in subchronic or chronic tests cannot be disregarded on the rationale that it is not linear to the dose (or dose-related) or not comparable in genders. This would not be scientifically acceptable. However, this reasoning was adopted both by companies and EFSA for several GMOs, as underlined by Doull et al. [33]. Indeed, most xenobiotics or pollutants may have non-linear effects, and/or may have sex- and age-specific impacts.
    One of the pivotal requirements for regulators nowadays, in order to interpret a significant difference as biologically relevant, is to observe a linear dose-response. This allows them to deduce a causality. However, this dose-response cannot be studied with only two points, which is nonetheless the case for all major commercial GMOs today, which are given in the diet in 11% and 33% concentrations only, in subchronic tests. This is true overall if no preliminary data has been obtained to choose the given doses, which is the case in regulatory files. As we have already emphasized, most of pathological and endocrine effects in environmental health are not directly proportional to the dose, and they have a differential threshold of sensitivity in both sexes[34]. This is, for instance, the case with carcinogenesis and endocrine disruption.
    Improving the knowledge on impacts of modified Bt toxins
    One of the interpretations of the side effects observed (Tables 1 and 2) would be that the insecticide toxins in maize lines may have more pleiotropic or specific actions than originally supposed. The toxins could generate particular metabolites, either in the GM plant or in the animals fed with it. The Bt toxins in GMOs are new and modified, truncated, or chimerical in order to change their activities/solubility in comparison to wild Bt. For instance, there is at least a 40% difference between the toxin in Bt176 and its wild counterpart [10]. None of the modified Bt toxins have been authorized separately for food or feed, neither has the wild Bt, and neither have they been tested by themselves on animal or human health to date. Even if some studies were performed, the receptors have not been cloned and the signaling pathways have not been identified as yet, nor required for authorizations, and the metabolism of these proteins in mammals are unknown [35]. Thus, the argument about “safe use history” of the wild Bt protein (not designed for direct consumption, in contrast to several GMOs) cannot, on a sound scientific basis, be used for direct authorizations of the above-cited GM corns, overall without in vivo chronic toxicity tests (or Toxotest approach), as it is requested for a pesticide. Some improvements may even be included with regard to pesticide legislation, since these human modified toxins considered as xenobiotics are continuously produced by the plants devoted to consumption.
    The proteins usually compared (modified Bt toxins and wild ones) are not identical, and the tests on human cells of Bt proteins are not performed nor are they requested by authorities. Their stability has been assessed in vitro, and GM insecticide toxins are never fully digested in vivo[36]. If some consumers suffer from stomach problems or ulcers, the new toxins will possibly act differently; the digestion in children could be affected too; however, these GMOs could be eaten anywhere and all proteins are never fully decomposed in amino acids by the digestive tract.
    Details on the new suggested Toxotest approach
    The suggested Toxotest would basically include an extension of the existing 90-day tests, but with at least three doses plus controls (0%, 11%, 22%, 33% GMOs for instance; today the equilibrated diets tested contain 0%, 11%, and 33% GMOs in the best regulatory tests). The purpose would be to characterize scientifically the dose-response approach. The latter cannot be taken seriously with only two GM doses. The final goal is the best health protection for the population without really possible clinical trials, in our case for practical and ethical reasons. There is also no epidemiological follow-up for lack of traceability and labeling in GM-producing American countries. In addition, the fact that the Toxotest includes the best possible toxicological approach will also be in favor of the biotechnology economy and the European Community because it is more expensive to address an issue concerning a whole population afterwards, rather than to work with laboratory animals beforehand; it is also more ethical to work on rats and other mammalian experiments, in order to get the relevant information, rather than to give pesticide plants directly to humans on a long-term basis.
    As previously underlined, the health effects such as those suggested in Table 2 (if any, are revealed by adapted studies, such as Safotests or Toxotests), could only be due to two possibilities:
    Firstly, the side effects may be directly or indirectly due to a pesticide residue and/or its metabolites. The direct effect is about the pesticide effect on the consumer, and the indirect one is about a metabolism disruption that it has provoked within the plant first. This could not be visible by a detailed compositional analysis, such as the one performed to be assessed by a substantial equivalence study. This concept is not a well-defined one (how many cultivations of crops, over how many years, under which climate, and to measure what precise parameters).
    Secondly, the pathological signs may be due to the genetic transformation itself, its method provoking either insertional mutagenesis or a new metabolism by genetic interference. This is the reason why separating intended effects (the direct genetic trait consequence itself) from unintended effects (linked to biotechnology, e.g., insertional mutagenesis), such as spiking the control diet with the purified toxin in the Toxotest approach, is clearly inadequate. It could work in the case of a direct action of the toxin in mammals, but conversely one could not conclude, between an insertional mutagenesis and a specific metabolic action in the plant due to the toxin. However, this is more a research question about the mode of genesis of an effect on health, and new research avenues could be, for instance, to compare the GM diet with or without herbicide treatment in long-term tests with the isogenic control diet including herbicide residues added. This is only necessary for the understanding of the potential signs of toxicity and not for a conclusion of the Safotest or the Toxotest, which would rather suggest, if positive, excluding immediately the corresponding GMO from food and feed.
    Improvement of statistical analysis
    A serious experimental design is based on a proper choice of the groups, with only one question studied per experiment if possible, and balanced sample sizes. In several authorized GMOs, the sample sizes appear inadequate in 90 days: ten animals per group for the measurement of biochemical parameters out of 20, as performed by the major stakeholders, and accepted by EFSA for MON863, MON810, or NK603 for instance. This is too limited a size to ensure that parametric statistical methods used by the company are reliable. Moreover, an important discrepancy between GMO-treated rats (40 measured out of 80) and the total number of animals (400) renders more difficult the evidencing of relevant effects, and confusion factors are brought in at the same time with six different reference diets in addition to the two normal control groups as performed in three commercialized GMOs at least [5,6]. This introduces new uncontrolled sources of variability about the effects of the diets and new unnecessary questions not relevant to the GMO safety. The representation of a standard diet with multiple sources could have been studied with only one control group of the same size than the GMO group, eating a mix of six different regular non-GM diets.
    Several questions have been raised by companies and authorities as well as comments on statistically significant effects that would supposedly not be biologically meaningful. A subjective part is introduced at this level because it is necessary to take into account the context and the general and detailed knowledge of toxicology and endocrine disruption, as EFSA underlines. This might be highly expert dependent. This is why, to avoid or prevent any misunderstanding, we suggest, in addition to a new statistical approach based on classical methods, to analyze the 90-day tests, even with control and reference diets called the “SSC method” (according to the initials of the authors in [2]).
    Briefly, following the necessity to model and analyze the growth curves, multivariate data analysis and data mining of all parameters can be used to correlate, cluster, and select meaningful variables. This kind of approach is not performed at all today. Thereafter, the detailed comparison between GM-treated and control groups, fed with the near isogenic line (because the real isogenic line does not often exists anymore), will necessarily be followed by the study of specific diet effects, when there are non-substantially equivalent diets for reference groups. For that purpose, the controls will be first compared using multivariate inference with reference groups, and thereafter, similarly GMO-treated groups with reference groups. The significant differences linked to the GMO and/or the composition of the diet will be classified according to organ and function. The results will appear more clearly than with the simple statistics accepted today by the authorities (that is, comparison of the highest GM dose group with the mean value of all six control groups), and will reveal in addition new information, as it can be demonstrated.
    As recommended by EFSA, an appropriate and relevant statistical analysis is crucial. It should follow the following series of steps, allowing the use of several methods depending on the questions raised:
    • Obtaining and modeling the growth curves and feed consumption, assessed by non-linear regression, validation, and statistical comparisons in order to test if the curves are significantly different, thus taking into account individual variability. This necessitates the use of time series analysis, selection models, and non-parametric tests, Akaike Information Criteria and related methods. Water consumption should also be an important factor to follow-up and therefore better understand kidney and urine data.
    • The study of dose-response predictions using non-linear regression should be the goal, but the only two doses generally used in these tests do not make it possible to evidence linearity as we indicated. Moreover, in the cases where there are not dose-related trends or relationships using the two doses mentioned, the absence of linear dose-response curves cannot be a reason to neglect the effects. For instance, as previously cited, U or J curves may be characteristic of endocrine effects [37], and spiky irregular curves may be detected in carcinogenesis.
    • Simultaneous analysis of all observed variables: multivariate data analysis, principal component analysis, correlations analysis, factorial analysis and clustering
    • Multivariate comparisons of the different variables: hypothesis testing, multiple ways ANOVA, MANOVA, and others to determinate if the groups differ relative to the different questions: specific GMO effect or diet effect per se. To evidence a detail, when comparing two mean values, SEM should be calculated to determine confidence intervals; however, SD have been used up to now by the company for MON863 and NK603 files for instance.
    Apart from empirical curves in some instances, ANOVA and univariate hypothesis testing only the GMO effect, none of the other statistical approaches is currently used nor requested by the authorities.
    Human tests and post-market monitoring
    For the record, it must be said that very few tests on humans have been carried out up to now. Moreover, epidemiological studies are not feasible in America, since there is no organized traceability of GMOs anywhere on the continent, where, by far, most of edible GMOs are cultivated (97%). As a consequence, a post-market monitoring (PMM) is offered to the population. The Cartagena Biosafety Protocol identifying GMOs at the borders of a country has now been signed by over 150 countries, including the member states of the European Union. PMM may have some value in detecting unexpected adverse effects. It could therefore be considered as a routine need. This approach makes it possible to collect information related to risk management. It can be relied upon as a technique for monitoring adverse events or other health outcomes related to the consumption of GM plant-derived foods, provided that the Toxotest approach, together with the SSC method, should have already been applied. The PMM should be linked with the possibility of detecting allergenicity reactions to GMOs in routine medicine, thanks to the very same routine cutaneous tests that should be developed prior to large-scale commercialization. A screening of serum banks of patients with allergies could be also put forward in order to search for antibodies against the main GMOs and not only their transgenic proteins, since they may induce secondary allergenic metabolites in the plant not visible in the substantial equivalence study.
    The traceability of products from animals fed on GMOs is also crucial. The reason for this is because they can develop chronic diseases which are not utterly known today. Such possible diseases could be linked to the hepatorenal toxicity observed in some GMO-related cases (Table1).
    Moreover, labeling animals fed on GMOs is therefore necessary because some pesticide residues linked to GMOs could pass into the food chain and also because nobody would want to eat disabled or physiologically modified animals after long-term GMOs ingestion, even if pesticides residues or DNA fragments are not toxic nor transmitted by themselves.
    Conclusion
    Transcriptomics, proteomics and other related methods are not ready yet for routine use in the laboratories, and moreover they may be inappropriate for studying toxicity in animals, and could not in any way replace in vivo studies with all the physiological and biochemical parameters that are measured with organs weight, appearance, and histology. By contrast, afterwards, new approaches could well help to explain pathological results or action mechanisms of pesticides present in the GM plants or GM-fed animals, if found.
    To obtain the transparency of raw data (including rat blood analyses) for toxicological tests, maintained illegally confidential, is crucial. It has also become crucial to apply objective criteria of interpretation like the criteria described here: sex-specific side effects or non-linear ones. Such data can be put online on the EFSA website with a view to provide a fuller review to the wider scientific community, and in order to better inform the citizen to make biotechnologies more socially acceptable. Since fundamental research is published on a regular basis, it should be the same for this kind of applied research on long-term health effects, as suggested by the CE/2001/18 and the corresponding 1829/2003 regulations.
    We can conclude, from the regulatory tests performed today, that it is unacceptable to submit 500 million Europeans and several billions of consumers worldwide to the new pesticide GM-derived foods or feed, this being done without more controls (if any) than the only 3-month-long toxicological tests and using only one mammalian species, especially since there is growing evidence of concern (Tables 1 and 2). This is why we propose to improve the protocol of the 90-day studies to 2-year studies with mature rats, using the Toxotest approach, which should be rendered obligatory, and including sexual hormones assessment too. The reproductive, developmental, and transgenerational studies should also be performed. The new SSC statistical method of analysis is proposed in addition. This should not be optional if the plant is designed to contain a pesticide (as it is the case for more than 99% of cultivated commercialized GMOs), whilst for others, depending on the inserted trait, a case-by-case approach in the method to study toxicity will be necessary.
    Competing interests
    The authors declare that they have no competing interests.

    Authors’ contributions
    GES designed and coordinated the review. RM participated in the drafting of the manuscript and final version. EC, SG, JSV and DC helped the writing, compiling the literature, revising in details and proofreading the manuscript. All authors read and approved the final manuscript.
    Acknowledgements
    We thank the CRIIGEN scientific committee for helpful discussions and structural support, as well as the Risk Pole (MRSH-CNRS, University of Caen, France). We acknowledge the French Ministry of Research for financial support and the Regional Council of Basse-Normandie. We are grateful to Herrade Hemmerdinger for the English revision of this manuscript.
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