GMOs SPAWN REGULATORY CHALLENGES
Phillip B. C. Jones
On January 20, the U.S. National Academies'
National Research Council announced the release of its report on
strategies for biologically confining genetically
modified organisms. The Committee on the Biological
Confinement of Genetically Engineered Organisms cautioned that
far more work is required to ensure that GMOs do not
contaminate the food supply or eliminate natural species.
Commissioned by the Department of Agriculture, the
NRC committee considered how bioconfinement techniques
can prevent GMOs from escaping into natural
ecosystems where they may breed with or compete against their
wild-type counterparts or pass GM traits to other species.
The committee stressed that confinement options vary with
the precise species selected for transformation due to
variations in genetics, ecology, and dispersal biology.
What are these bioconfinement measures? An
approach for biologically confining GM mollusks is to generate
three sets of chromosomes in the animal's cell nuclei;
triploidy prevents successful cell division and reproduction. The
two main bioconfinement methods used in microbes are
the induction of suicide genes and "phenotypic
handicapping," a tactic that renders the microbes less suited for
competition with indigenous counterparts. For genetically
engineered plants, bioconfinement techniques include
interference with sexual and vegetative reproduction and the
use of a specific artificial stimulus to limit the expression of
the transgenic trait. A salicylic acid spray, the report
suggests, could provide the sole stimulus for expression of a
GM plant's transgene that synthesizes a pesticide protein.
Bioconfinement methods are expected to work best on
a small scale; the NRC warns that the efficiency of
these strategies decreases with the number of GMOs
involved and the size of the area they occupy. Moreover,
the probability of failure increases with the amount of time
that the GMOs persist in the natural environment.
To ensure confinement efficacy, the NRC
recommends that bioconfinement strategies should be devised at
the earliest stages of GMO development. And because
no single bioconfinement method is likely to be 100
percent effective, developers of GMOs could implement
redundant systems to decrease the chance of a failure, such as
a combination of biological, physical, and chemical
confinement measures. Taking aim at biopharming, the
NRC advises that alternative nonfood host organisms should
be sought for genes encoding products that must be
excluded from the human food and animal feed supplies.
Researchers have genetically engineered many nonfood plants,
such as tobacco, petunia, and duckweed. In passing, the
NRC notes that a decision not to produce a particular GMO
is also a form of bioconfinement.
A copy of the NRC report, "Biological Confinement of
Genetically Engineered Organisms," is available at The
National Academies Press website (http://www.nap.edu/books
/0309090857/html).
GM Bugs: An Oversight in Regulatory Oversight
The NRC committee report warns that there has been
little research on the bioconfinement of GM insects and that
the subject is inadequately understood. On January 22,
the Pew Initiative on Food and Biotechnology echoed
this sentiment with the release of its study on insect
engineering. During an online discussion hosted by the
Washington Post, Michael Fernandez, Director of Science for the
Pew Initiative, explained that his organization "published
this report in the hopes of jump-starting the dialogue about
the benefits, risks, and regulatory challenges of GM insects."
The Pew Initiative report surveys efforts to
genetically modify insects to benefit public health, enhance
agriculture, and provide new forms of economically useful
insects. Public health may be enhanced, for example, by the
release of GM mosquitoes that inject antigens into humans
to induce an immune response against a variety of
diseases. Mosquitoes can also be engineered to produce proteins
that disrupt the malaria parasite's life cycle within the insect.
Researchers are investigating a different tactic to stop
the spread of Chagas' disease, which is transmitted by
infected kissing bugs. In the paratransgenic strategy, an insect is
not genetically engineered, but rather harbors
symbiotic bacteria that have been genetically altered. To
control Chagas' disease, a bacterium that lives in the bug's gut
will be engineered to kill the parasite that causes the disease
as it passes through the insect's digestive system. A
similar scheme may be used to control the spread of
sleeping sickness: tsetse flies can be outfitted with
paratransgenic symbionts that hinder the development or transmission
of trypanosomes.
GM insects may also be used in genetic control
programs to fight insect pests as an alternative to pesticides.
Radiation or chemical mutagenesis is used to affect the
reproductive ability of a target insect population.
Mediterranean fruit flies, for example, are mass-reared and sterilized
by irradiation prior to the release of males. After liberation
into the environment, the sterile males mate with
wild-type females, hindering the ability of the females to reproduce.
Another conventional genetic control program targets
the pink bollworm, which feeds on cotton plants
throughout most of the southwestern cotton-growing states in
the United Statesexcept for California's San Joaquin
Valley. Here, a sterile insect technique program protects more
than 900,000 acres of cotton. The program requires millions
of male pink bollworm moths, which are sterilized by
irradiation and released to suppress reproductive success of
wild-type females. The sterile moths, weakened by exposure
to radiation, need to outnumber wild-type fertile moths
by nearly 60:1, resulting in costs that are prohibitive
for implementation in other areas. One way to eliminate
this need for large numbers of irradiated males is to
genetically engineer bollworms to carry a gene that would
prevent offspring from developing.
Genetic engineering can also be used to enhance
the characteristics of economically beneficial insects, such
as the honeybee. Honeybee populations have
decreased during the past ten years due to the insect's susceptibility
to diseases and parasites. Researchers are devising ways
to engineer honeybees that are more resistant to
diseases, parasites, and certain insecticides. Another useful
insect, the silkworm, can be modified to produce a
therapeutic protein or spider silk, a material that could be used to
make bulletproof vests, parachutes, and artificial ligaments.
Despite the potential benefits of GM insects, the
technology does present concerns about the long-term effects
of these designer bugs on the environment, public health,
and food safety. GM insects could disrupt ecosystems
in unintentional ways and pass on new traits to
wild-type insects. As noted in the NRC report, hordes of GM
insects will have to be released into the natural environment
to have an effect. These engineered insects cannot simply
be recalled after they have performed their service.
Fortunately, U.S. regulatory agencies maintain a tight watch
on insect engineering. Right? Well, not quite.
Established in the mid-1980s, the U.S. Coordinated
Framework for Regulation of Biotechnology directs the Food
and Drug Administration, the Department of Agriculture,
and the Environmental Protection Agency to regulate
biotech products according to their intended use. For example,
the FDA regulates food and feed; the USDA regulates
plant pests, plants and veterinary biologics; and the EPA
oversees the use of pesticides and novel microorganisms.
GM insects do not fit neatly into any pigeonholes supplied by
the regulatory framework.
Moreover, the Pew Initiative found that federal
agencies have not indicated if they would regulate GM insects,
how regulatory reviews would be performed, which
agencies would be involved, or how the agencies would
coordinate their efforts. Michael Rodemeyer, executive director of
the Pew Initiative, warns that without a clear roadmap
for regulation "the public has little reason to trust that the
risks and benefits are being appropriately weighed and
measured." The Pew Initiative recommends that the
United States should clarify its policies for regulating GM
insects before the need arises to advise international bodies on
the management of insect engineering.
See the Pew Initiative on Food and Biotechnology report
"Bugs in the System?" http://pewagbiotech.org.
USDA Recommends Regulation Renovation
During a January 22 press conference, Agriculture
Secretary Ann M. Veneman announced her agency's intent
to update and strengthen biotech regulations for the
importation, interstate movement, and environmental release
of GMOs. Secretary Veneman stated that the
regulatory framework must keep pace with technological advances
to ensure that regulations are based on sound
scientific principles and mitigation of risk. Moreover, she sees
"a system that will place a greater emphasis on risk
and additional flexibility for products that have
demonstrated their safety." The anticipated result of the
regulatory overhaul is that certain biotech products will be
subjected to less regulation, whereas products associated with
a greater perceived risk would be regulated more stringently.
As a first step, the USDA's Animal and Plant
Health Inspection Service will prepare an environmental
impact statement evaluating biotech regulations and
proposing changes. One USDA proposal is to broaden
APHIS' regulatory scope to include GMOs that may be used
as biological control agents. The agency defines a
"biological control organism" as any organism used to control a
plant pest or noxious weed; presumably, certain GM
insects would be covered under this category. The USDA
promises to consider all comments on its proposals that
it receives on or before March 23.
Selected References
Anonymous. (2004) New report finds genetically modified
insects may offer public health and agricultural benefits, but
clear regulatory oversight is lacking. January 22, 2004. Available
at: http://pewagbiotech.org.
USDA. (2004) Environmental impact statement; Introduction
of genetically engineered organisms. Federal Register,
69:3271-3272, January 23, 2004.
Phillip B.C. Jones, PhD., J.D.
Spokane, Washington
PhillJones@nasw.org

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