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Re: rice pharming in CA



Hi Greg,
Thanks for mentioning my report. It is very perplexing that US EPA did
not appear to have regulated GM rice with human lysozyme as a
biopesticide as they are required. Plants with GM human lysozyme were
patented to control bacterial and fungal diseases in the plants

(.Hain,R. and Stenzel,K. “Use of lysozyme gene structure in plants to
increase resistance” 1994 US Patent 5,349,122 pp 1-24) Of course I am
more concerned about the safety use of the human genes in rice but an
EPA review, even though late, might open the process to a fuller and
more public review. Fundamental questions about the safety of the
production of rice with human lysozyme and lactoferrin need to be
answered and clearly the separation distances being proposed seem to
invite pollution of many nearby rice crops. The issue should have much
broader discussion as it threatens organic rice production in California
and any other organic producer should take note of the fast and loose
approval of biopharmaceuticals. Sincerely,Joe



Raquel & Greg wrote:

Hi all.  Thought you might like an update on what is happening here in
California regarding the introduction of GM rice.  As you may know, there is
a biotech company that wants to grow rice that has been modified with human
genes for lactoferrin or lysozyme, human proteins found primarily in breast
milk.  Their protocol for the introduction includes growing this gm rice
within 100 feet of non-gm rice, with no limitations on where it will be
grown.  They are proposing a closed loop system with "dedicated" equipment.
As per California law, they are required to get permission from an advisory
board of the California Rice Commission when they scale up production past
the research stage.  This year, they want to grow 65 acres of their rice.

I have been to the last two meetings of the advisory board where this
company's protocol was discussed.  In my opinion, their protocol is flawed
in a number of ways.  Its strong dependence on human performance and
responsibility is inadequate to ensure zero contamination (required with an
inedible pharm crop).  It has no provisions to prevent spread of the seeds
by wildlife.  The 100 foot buffer zone is woefully inadequate (corn requires
one mile).  The proposed 1 year fallow period following their rice is
insufficient, because rice seed can remain viable in the soil for up to 12
years.  The science they have been presenting to the committee is, shall we
say, "selective" in nature.  Outcrossing rates of rice were underestimated
by 4 orders of magnitude at the December meeting (corrected in the January
meeting, but I don't believe this was a mistake).  Pollen flow and viability
have been reported much too low (with pollen flow, again, orders of
magnitude) as compared to the literature.

I have testified at both meetings of the committee, along with a number of
other farmers.  All public comment has been strongly negative, because quite
simply, we will lose a very significant portion of our export market if this
rice is released.  At the last meeting, I read a strongly worded statement
demonstrating my opposition to the protocol for release.  In it, using
numbers readily available in the scientific literature, I calculated that
there would be over 1.1 BILLION rice flowers within cross pollination
distance to a single escaped seed.  At these levels, even very rare events
become significant.

I do see some hope here.  The committee has some rice growers on it,
including the chair.  They seem to be asking some questions, and listening
to those of us who speak at the meetings.  Last week, the chair requested
that each committee member go home and make specific comments on the
protocol and indicate whether or not they would accept it.

Keep your fingers crossed.

Regards,
Greg

PS  Thanks to Joe Cummins for writing and posting the summary of pharm rice
on SANET a few weeks ago!

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