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[SANET-MG] creeping bentgrass petition for deregulation
October 16, 2005
Prof. Joe Cummins
DejaVu Glyphosate Tolerant Creeping Bentgrass Petition for Deregulation
On April 14,2003 The Animal and Plant Health Inspection Service (APHIS)
of the U.S. Department of Agriculture (USDA) received a petition
03-104-01p from Monsanto company and Scotts company requesting
deregulation of creeping bent grass genetically modified for tolerance
to the herbicide glyphosate. On Jan.5,2004 APHIS solicited comments on
whether the modified creeping bentgrass would present a plant pest risk.
A preliminary environmental review was prepared by APHIS. On Oct.
12,2005 APHIS requested additional information . APHIS Docket ID
03-101-4 , Environmental Impact Statement; Petition for Deregulation of
Genetically Engineered Glyphosate-Tolerant Creeping Bentgrass Public
comments are due by 14 November ,2005:
http://www.regulations.gov/fdmspublic-bld61/component/main
Roundup ready creeping bent grass is resistant to the herbicide
glyphosate. The grass contain a gene conferring resistance to the
herbicide and the plant is modified similarly to roundup ready maize,
soy bean, canola , sugar beet or alfalfa. The resistance gene is a
synthetic approximation of the 5-enolpyruvyshikimate-3 phosphate
synthase from the Agrobacterium sp. Strain CP4 (CP4EPSPS). That sequence
is preceded by the rice actin promoter and first intron which drives
transcription of the CP4EPSPS gene and the Arabidopsis chloroplast
transit sequence which is required to direct the CP4ESPS to the
chlorpoplast. The protein coding sequence is followed by a transcription
termination gene NOS3 from Agrobacterium. A second CP4EPSPS sequence is
preceded by the CaMV promoter with duplicate enhancers , the heat shock
70 intron and chloroplast transit sequence from
Arabidopsis.Transcription is terminated by the NOS 3 seuquence from
Agrobacterium. Finally the insert contains nopaline antibiotic
resistance gene. Duplicate copies of the herbicide tolerance gene insure
the tolerance to glyphosate (1).
APHIS preliminary risk assessment concluded that genetically modified
(GM) creeping bent grass is phenotypicaly equivalent to unmodified
grass. The GM grass had a single insert of the duplicate CP4EPSPS gene
which behaved as a simple Menelian locus in crosses. The GM creeping
bent grass does not differ in susceptibility or resistance to pests and
diseases from its unmodified parent. However, the evidence was clear
that hybrids could be observed derived from natural grass species and
most were fertile. Herbicide tolerant creeping bent grass or its hybrids
could be established various urban to rural and natural areas (2).
APHIS asked an industry oriented academic organization, The Weed Society
of America to evaluate the release of herbicide tolerant creeping bent
grass in various crop and non-crop ecosystems. The report prepared on
behalf of the society concluded that off site movement of GM creeping
bent grass was inevitable but the GM grass or its hybrids could be
controlled using herbicides other than glyphosate (3).A study of gene
flow from GM creeping bent grass showed that most of the gene flow
occurred within 2 km of the field in which the GM grass was grown , but
maximal gene flow observed was 14 and 24 km (4).Inter-specific
hybridization between creeping bent grass and related grass species
occurred at frequencies as high as 6 hybrids per thousand related grass
plants (5). Clippings from treated GM creeping bent grass stands were
toxic to unmodified grasses and such clippings will require special
handling(6).
The impact of expanded urban and natural area use of glyphosate was
hardly discussed in the petition for deregulation and environmental
assessment, but that discussion was crucial and should have been
included. Glyphosate is toxic to human placental JEG3 cells within 18 hr
with concentrations lower than those found with agricultural use, and
this effect increases with concentration and time or in the presence of
Roundup adjuvant. Surprisingly, Roundup was always more toxic than its
active ingredient. Testing included the effects of glyphosate and
Roundup at lower nontoxic concentrations on aromatase, the enzyme
responsible for estrogen synthesis. The glyphosate-based herbicide
disrupts aromatase activity and mRNA levels and interacts with the
active site of the purified enzyme, but the effects of glyphosate are
facilitated by the Roundup formulation in microsomes or in cell culture.
The authors of the study conclude that endocrine and toxic effects of
Roundup, not just glyphosate, can be observed in mammals (7). The
devastating impact of roundup herbicide on amphibian communities has
been exposed in a series of reports by Relyea and his co-workers
(8,9,10). The problems associated with roundup resistant weeds and the
many human and animal health impacts including liver damage, cancers,
neuro defects and spontaneous abortion were reviewed by Ho and Cummins
(11,12).
The clear evidence of extensive gene flow and hybridization of
glyphosate resistant creeping bent grass alone should prevent the
deregulation of the GM grass. Add to that the growing problem of
glyphosate resistant weeds should prevent deregulation of the gm grass.
Finally the new evidence of human toxicity at very low levels of the
herbicide along with the evidence that roundup herbicide contributes to
the extinction of amphibians should close the book on glyphosate
resistant creeping bent grass. There seems to be no rational grounds for
deregulating glyphosate tolerant creeping bent grass.
References
1. Nelson,E. and Stone,T. Petition for determination of non-regulated
status: Roundup Ready Creeping Bent grass Event ASR368 Petition
#01-TR-054U 2003 http://www.aphis.usda.gov/brs/not_reg.html
2. USDA/APHIS APHIS Preliminary Risk Assessment on the Petition for a
Determination of Nonregulated Status for Creeping Bentgrass (Agrostis
stolonifera) Genetically Engineered (Event ASR368) for Tolerance to the
Herbicide Glyphosate submitted by Monsanto Company and the Scotts
Company. 2004 http://www.aphis.usda.gov/brs/not_reg.html
3. Banks,P,Branham,B,Harrison,K,Whitson,T. and Heap,I. Determination of
the Potential Impact from the Release of Glyphosate- and
Glufosinate-Resistant Agrostis stolonifera L. in Various Crop and
Non-Crop Ecosystems Weeds Society of America Report to USDA/APHIS 2003
4. Watrud LS, Lee EH, Fairbrother A, Burdick C, Reichman JR, Bollman M,
Storm M, King G and Van de Water PK. Evidence for landscape-level,
pollen-mediated gene flow from genetically modified creeping bentgrass
with CP4 EPSPS as a marker. Proc Natl Acad Sci U S A. 2004 Oct
5;101(40):14533-8
5. Belanger,F,Meagher,T,Day,P,Plumley,K and Meyer,W. Interspecific
Hybridization between Agrostis stolonifera and Related Agrostis Species
under Field Conditions Crop Science 2003 43:240-6
6. Goss,R,Gaussoin,R. and Martin,A. Phytotoxicity of clippings from
creeping bent grass treated with glyphosate Weed Technology 2004,18,575-9
7. Richard S, Moslemi S, Sipahutar H, Benachour N and Seralini GE.
Differential effects of glyphosate and roundup on human placental cells
and aromatase. Environ Health Perspect. 2005 Jun;113(6):716-20
8. Relyea, Rick A., Schoeppner, Nancy M., Hoverman, Jason T. Pesticides
and amphibiums : the importance of community context. Ecological
Applications: 2005. 15, No. 4, 1125–34
9. Relyea, Rick A. The lethal impact of roundup on aquatic and
terrestial amphibiums. Ecological Applications: 2005. 15, No. 4, 1118–24
10. Relyea, Rick A.The impact of insecticides and herbicides on the
biodiversity and productivity of aquatic communities . Ecological
Applications 2005 ,15, No. 2, 618–27
11. HoMW and Cummins,J. Roundup ready sudden death ,super weeds,
allergens ISIS 2005 http://www.i-sis.org.uk <http://www.i-sis.org.uk/>
12. Ho MW and Cummins,J. Glyphosate toxic and roundup worse /Science in
Society /2005, 26, 12. http://www.i-sis.org.uk/isisnews.php
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