Hello List

In keeping with other recent non topic posts recently I forward the
following .....

Ron

Date: 20/12/99 13:39

Greetings friends, associates, and acquaintances,

Please forgive the unsolicited mail, but I thought that
this communication would be of interest to you all.  At
least, it answers the question as to why the Soil
Association does not include provisions for composted GMO
contaminated materials in their standards.  Also, I consider
that the delete key is a quick and painless solution to
unwanted emails!

Take care all, and happy Xmas.

20 December, 1999

Dear XXX XXXXXX

UK MAFF investigated DNA fragmentation and found that GMO material would
need to be heated to 95C for at least 5 min in order to fragment the DNA
into sizes of less than 100bp - which would be enough to disrupt the
antibiotic resistance genes. But even this treatment would leave short
fragments of DNA which do retain some biological activity.  You simply
must try to ensure the material you compost is GMO free I'm afraid. MAFF
scientists have stated in their reports that GMO material must not be
used for silage, because DNA is not destroyed during composing and soil
micro-organisms can take it up and incorporate it - indeed, they do so
regularly.

The dispersal of naked GMO DNA in the environment is a major concern
here at ISIS and we are planning a number of papers about it next year.
Animal feed is a mess I agree and there is nothing easy about this awful
GMO situation for any sort of farmer.

I attach a critique on the UK MAFF study for your information.

Angela Ryan


The Institute of Science in Society

Critique of MAFF Report CS0116

"Effect of feed processing conditions on DNA fragmentation"

By Angela Ryan
Molecular Biologist, Open University   19th Nov 1999

Introduction

The purpose of this report was to determine the extent to which DNA is
fragmented in animal feed.  Animal feed is either fed raw or processed
under a variety of conditions in commercial mills.  The effect of
several methods of processing on the fragmentation of DNA in animal feed
was analysed.  DNA fragmentation in raw foodstuffs from a number of
commercial feeds and non-commercial feeds was also investigated.

This work set out to address concerns regarding the transfer of foreign
genes, especially antibiotic resistance genes introduced in GM crops, to
microbes rendering them antibiotic-resistant.  The report points to the
resurgence of tuberculosis as an example of the significant medical
problems that may come about from the transfer of such resistance to
micro-organisms and suggests transfer of resistance genes from GM crops
would exacerbate the problem of resistant strains of bacteria.

In order for gene transfer to occur, a gene would need to be complete
and therefore the DNA of which it is composed, stable and relatively
intact.  The report states that it is unlikely for transfer of such
genes from plant to microbe to be proved impossible.  It goes on:
"Therefore, if GM plants are to be licensed, it is necessary to know
what onditions are necessary in installations preparing animal feeds for
the prevention of gene transmission, i.e. sufficient disruption of DNA."
This report describes the results of a Pilot Study commissioned from
Leeds University by MAFF.  The study is on a small scale, has limited
resources and has been performed on non-GM material.  Nevertheless, the
results give every indication that further studies are needed, which the
scientists concerned were ready to undertake and were expecting further
funding for from MAFF.

Experimental Details
Processing Specifications
Three major UK animal feed companies were involved with this study,
providing advice on processing specifications and a range of animal feed
samples.  Ranges of laboratory treatments were carried out to determine
the conditions required during processing to sufficiently disrupt the
DNA. Wheat samples were subjected to mechanical grinding and milling at
different grist sizes in the laboratory.  The processing of oil seed
samples did not receive the closely monitored processing conditions
initially required by the project - processed oil samples were supplied
by the industry.

Samples
Samples of animal feed ingredients were obtained from the collaborating
companies and include:  Oil seeds, before and after oil extraction by
expulsion and compression; Wheat grains of the variety Riband subjected
to heating both dry and moist, at a range of temperatures and pressures
and for a range of durations. Smaller samples of 20 varieties of wheat
were subject to proximate analysis and five of these varieties were
subjected to dry heat treatment at 93 degrees centigrade;  Fresh maize
leaves and maize silage, from the University Farm; fresh maize cobs and
maize grains from the local supermarket; Maize gluten and flaked maize;
Fresh wet sugar beet and dried sugar beet pulp; Fresh ryegrass and rye
silage.

Experimental Protocol
DNA was extracted from the variety of animal feed samples by standard
procedures.  Two approaches were taken to monitor the extent of DNA
fragmentation.  The first allowed visualization of the DNA fragments by
electrophoresing them on an agarose gel followed by DNA staining with
ethidium bromide.  The gel was then photographed and the DNA fragment
sizes determined by comparing them with fragments of known length.  This
approach, whilst determining the sizes of fragments, does not give any
indication of their composition and also has limited sensitivity.  In
the second approach, the polymerase chain reaction (PCR) technique was
used to determine whether a specific gene sequence could survive
particular feed processing treatments.  This was adopted in order to
develop a means to increase the precision of the analysis of fragment
lengths,down to the level of single genes.  The Rubisco small
subunit (RbcS) gene from maize was sequenced and primers were designed
and made in order to amplify approx. 600bp of it from maize samples.
Should the DNA strand bearing this gene be disrupted between two primer
binding sites, then the PCR amplification would simply not take place
and no PCR product would be obtained.  Treatments which fragment the
RbcS gene would also fragment transgenes of comparable size in trangenic
plants.  NB: The B-lactamase gene used extensively in GM plants is
approx. 1200bp in length.

Results
Table of results showing treatment/sample and state of DNA.
SAMPLE/ TREATMENT
STATE OF DNA
wheat/grinding
intact
wheat/ milling
intact
linseed leaves
intact
linseed grains
intact
wheat leaves
intact
wheat grain
intact
soya leaves
intact
soya grain
intact
maize grain
intact
maize leaves
intact
maize silage
intact
rapeseed leaves
intact
rapeseed grain
Intact
fresh sugar beet pulp
intact
ryegrass
intact
ryegrass silage
intact
oil seed rape meal (after extraction)
degraded
oilseed rape cake
degraded
maize gluten
degraded
maize flaked
degraded
wheat, dry heat, 90 C or below for 30 min
intact
wheat, low pressure steam, 60 C, 30 min
intact
wheat dry heat, 93C, 4 min
intact
wheat dry heat, 93C, 5-15 min
partially degraded
wheat dry heat, 95C, 5min
degraded
wheat low pressure steam, 85 C, 10 min
partially degraded
wheat low pressure steam, 95-100 C, 30 sec or more
degraded

wheat high pressure steam at 100-124 C, 1min or more
degraded

PCR
Following extra purification of template genomic DNA from fresh maize
leaves, grains and silage, amplification of specific gene sequences
within maize RbcS1 and RbcS2 genome sequences was allowed and generated
PCR products of up to 577bp.

Conclusion
The results of this study clearly show that DNA remains stable in silage
and suggests that ensiled GM crops should not be used as animal feed.
In small-scale reactions under laboratory conditions, it was found that
temperatures of 95 C for at least 5 min were required to completely
fragment the DNA.  The report admits that most commercial-processed
animal feeds are subjected to temperatures that do not exceed 85 C.
Extrusion would only cause temperatures on the outside of particles to
reach 100 C and only briefly. Where steam is used to condition material
for pelleting, temperatures reach at least the mid-80s and the length of
time these temperatures are maintained is uncertain.  The results show
that DNA is only partially fragmenting in material subjected to 85 C for
10 min - maintained by steam. Physical extrusion or chemical extraction
of oilseed leaves a residue in which the DNA is highly fragmented. The
report concludes that most commercially produced animal feed contains
intact DNA fragments of a size greater than 1200bp - comparable to the
B-lactamase transgene used in many GM crops.   It states, "These
findings will be of considerable importance to the feedstuff industry."
The report recommends more extensive research to be done.

Critique
The  report states "There is no reason to believe that the conditions
necessary to fragment the DNA of GM plant material are any different
from unmodified material." Whilst in theory this assumption holds true,
this study works only with non-GM plant material.  Transgenic DNA in GM
plants may possess unknown and as yet un-investigated characteristics,
such as enhanced resistance to fragmentation. Therefore, duplicate
experiments using actual GM plant material are warranted and required
for reliable conclusions regarding GM crops. The report gives no
consideration to the transfer of other transgenic DNA used in GM crop
plants, such as the CaMV promoter.  The CaMV promoter is about 350bp in
length and contains a recombination hotspot as well as several modular
motifs that have specific molecular function (1). Recombination involves
the breaking of one DNA strand and joining of it to another DNA strand
and is the molecular mechanism by which gene transfer occurs.  CaMV is
closely related to human hepatitis B virus, and also has a reverse
transcriptase gene related to that in retroviruses such as the AIDS-
associated HIV (3).  Thus, the CaMV promoter not only enhances
horizontal gene transfer but has the potentialto reactivate dormant
viruses (which are in all genomes) and to generate new viruses by
recombination. The transfer of small DNA fragments or motifs of specific
molecular function are also given no consideration in this report.  For
example, an imperfect 19bp palindromic sequence has been isolated as the
recombination hotspot in the CaMV promoter and short poly-purine rich
tracts within the promoter act as binding sites for DNA processing
enzymes involved in recombination (2).  The approaches adopted by this
study would not be sensitive enough to detect such short DNA fragments.
In addition, the report defines 'completely degraded DNA' equal to DNA
fragments of 100bp or less.  Motifs bearing important molecular function
may therefore be present in samples said to contain completely
fragmented DNA. It was agreed early in the project that it would be
better to process the feed materials under closely monitored conditions
at a semi-commercial scale feed plant in the Roslin Institute, rather
than in commercial mills.  However, there was considerable delay in
commissioning the equipment at the Roslin Institute, which meant that
the samples came instead from commercial processing of oil seeds and
laboratory processing of wheat.  Research to detect "The effects of
commercial scale processing on the integrity of DNA in animal feed" has
been commissioned by the Chief Sciences Group and it has been confirmed
that the results of this study will be available by the end of March
next year. These results may provide further confirmation of the
conclusions drawn in this study. The scientists at Leeds are now working
on an "Assessment of the risks of transferring antibiotic resistance
determinants from transgenic plants to micro-organisms" which has also0
been commissioned by MAFF and is due to be completed in April 2001.
They are feeding GM plant material to animals and using the PCR
technique, with primers specific for antibiotic resistance genes, to
detect the transfer of these genes in the animal gut.  The fact that
this important study has been commissioned by MAFF suggests there is
still real concern about the consequences of using GM animal feed. After
this report was written, MAFF produced a second report "GM Materials in
Animal Feed", which makes reference to this report as a 'first look'
study.   However, it does not refer to the very important conclusions
presented clearly in this report - that most processed animal feed
contains intact DNA.  (It is admitted by the scientists that processed
animal feed is subjected to temperatures that do not exceed 85C and that
at least 95C for 5 min is required to completely degrade DNA. See p 8).
The follow on report does present important data regarding the level of
GM material in British animal feed.  It is clear that British animal
feed is presently comprised of at least 20% GM material obtained from
feed suppliers abroad, who do not segregate GM varieties from non-GM
varieties (p5).   It is also clear (p6) that 45% of raw materials used
in compound feed in GB in 1997/98 contained processed cereals, peas,
beans and vegetable residues containing farm wastes after harvest,
which may have contained intact DNA from genetically modified organisms.
This report gives no reference to other research pertaining to the
safety of using GM material as feed.  It has been shown by another MAFF
study that the human mouth contains bacteria capable of taking up and
expressing free DNA containing antibiotic resistance marker genes and
similar transformable bacteria are also present in the respiratory
tract (4).  In addition, in a letter from UK MAFF to the US FDA dated
Dec. 1998, it was pointed out that transgenic DNA may be transferred not
just by ingestion, but by contact with plant dust and air-borne pollen
during farm work and food processing(5). In general the experiments
conducted in this study were performed rigorously and the conclusions
drawn by the scientists are right and of considerable importance to the
animal feed industry.  We recommend that British animal feed companies
seek sources of GM free material for animal feed destined for this
country.  This approach alone would eliminate the significant risks
posed to human and animal health and well being, associated with the
transfer of transgenic DNA from GM material. The report highlights the
fact that the necessary safety assessments regarding the consumption of
GM material have not yet been carried out.  We suggest the need for an
immediate withdrawal of all GM material, from every point in the human
food chain, until such time as the results from these very important
ongoing studies are at least complete and satisfactory.

References
1. HO. M.W., Ryan, A., and Cummins. J. (1999). The cauliflower mosaic
viral promoter - A recipe for disaster? Micorbial Ecology Health and
Disease: 11 (4).

2. Kohli, A., Griffiths, S., Palacios, N,. Twyman, R.M., Vain, P.,
Laurie, D.D. and Christou, P. (1999).  Molecular characterisation of
transforming plasmid rearrangements in transgenic rice reveals a
recombination hotspot in the CaMV 35S promoter and confirms the
predominance of microhomology mediated recombination.  The plant Journal
17, 591-601.

3. Xiong, Y and Eickbush, T.H. (1990). Origin and evolution of
retroelements based upon their reverse transcriptase sequences. EMBO J.
9, 3353-3362.

4. Mercer, D.K., Scott, K.P., Bruce-Johnson, W.A. Glover, L.A. and
Flint, H.J. (1999).  Fate of free DNA and transformation of the oral
bacterium Streptococcus gordonii DL1 by plansmid DNA in human saliva,
Applied and Environmental Maicrobiology 65, 6-10.

5. See letter from N. Tomlinson, Joint Food Safety and Standards Group,
MAFF, to US FDA, 4th Dec, 1998.
-- 
Ron Cuthbertson


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