[SANET-MG] please comment to APHIS on this dangerous grass

[jcummins <jcummins@UWO.CA>]

 *Deregulation of Glyphosate Tolerant Creeping Bentgrass Out of Question*


   Professor Joe Cummins

The Animal and Plant Health Inspection Service (APHIS) of the US 
Department of Agriculture (USDA) received a petition 03-104-01p from 
Monsanto company and Scotts company on 14 April 2003 requesting 
deregulation of creeping bent grass genetically modified for tolerance 
to the herbicide glyphosate. On 5 January 2004, APHIS solicited public 
comments on whether the modified creeping bentgrass would present a 
plant pest risk. A preliminary environmental review was prepared by 
APHIS, and on 12 October 2005, APHIS requested additional information on 
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 tolerant to the herbicide 
glyphosate. It contains a gene conferring tolerance to the herbicide 
similar to Roundup Ready maize, soybean, canola, sugar beet or alfalfa. 
The resistance gene is a synthetic approximation of the 
5-enolpyruvyshikimate-3 phosphate synthase from /Agrobacterium/ sp. 
Strain CP4 (CP4EPSPS), which is preceded by the /Arabidopsis/ 
chloroplast transit sequence which is required to direct the CP4ESPS to 
the chloroplast. Transcription is driven by the rice actin promoter and 
first intron, and terminated by /nos/3 from /Agrobacterium/. A second 
identical CP4EPSPS sequence is driven by the CaMV promoter with 
duplicate enhancers, the heat shock 70 intron, and terminated by the 
/nos3/ sequence from /Agrobacterium/. Finally the insert contains 
nopaline antibiotic resistance gene. Duplicate copies of the herbicide 
tolerance gene ensure a high level of 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 Mendelian 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 with natural grass species were found and most of them were 
fertile. Herbicide tolerant creeping bent grass or its hybrids could be 
established in various urban to rural and natural areas [2].

APHIS asked The Weed Society of America, an industry-oriented academic 
organization, 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 that 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 
could extend to 14 and 24 km [4]. Inter-specific hybridization between 
creeping bent grass and related grass species occurred at frequencies as 
high as six hybrids per thousand 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 cells within 18 hr at 
concentrations lower than recommended agricultural use, and Roundup more 
so than glyphosate. Surprisingly, Roundup was always more toxic than its 
active ingredient. The glyphosate-based herbicide disrupts aromatase 
activity and mRNA levels and interacts with the active site of the 
purified enzyme, and 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]. Relyea and his co-workers 
have documented the devastating impact of Roundup herbicide on amphibian 
communities in a series of reports [8-10]. Ho and Cummins have reviewed 
the problems associated with Roundup resistant weeds and the many human 
and animal health impacts including liver damage, cancers, neuro-defects 
and spontaneous abortion [11, 12].

The clear evidence of extensive gene flow and hybridization of 
glyphosate tolerant creeping bent grass, the growing problems of 
glyphosate resistant weeds plus the new evidence of glyphosate and 
Roundup toxicity to humans and lethality to amphibians should make any 
further release of glyphosate tolerant creeping bent grass out of the 
question, let alone its deregulation.

*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 . 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 USA/ 2004, 101(40),14533-8.

5. Belanger F, Meagher T, Day P, Plumley K and Meye 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, 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, 1125–34.

9. Relyea, Rick A. The lethal impact of roundup on aquatic and 
terrestial amphibiums. /Ecological Applications/: 2005, 15, 1118–24.

10. Relyea, Rick A. The impact of insecticides and herbicides on the 
biodiversity and productivity of aquatic communities . /Ecological 
Applications/ 2005,15, 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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