Open Letter to New Zealand Royal Commission on Genetic Engineering

From: Dr. Mae-Wan Ho 
Director, Institute of Science in Society 
PO Box 32097 
London NW1 0XR 

August 13, 2001

To: Peter Hodgson (Research, Science & Technology)
Marian Hobbs (Environment) 
Jim Sutton (Agriculture)
Annette King 
Helen Clarke 

As one of the many scientists presenting evidence to the Royal Commission on Genetic Engineering, I had high hopes that New Zealand would assume moral
and intellectual leadership in rejecting this dangerous technology bolstered by degenerate science, so obviously serving the corporate agenda instead
of the public good. It is still not too late for New Zealand to take on this role.

It has become increasingly evident that GM technology is inherently hazardous and unreliable both in agriculture and in medicine. The list of failures
is growing apace. Let me mention a few recent examples that came to light since I presented evidence to the Commission. 

GM crops are inherently unstable, and this is fully borne out by numerous new scientific publications [1]. Even the top 'success', Roundup Ready soya,
is showing every sign of breakdown: reduced yield, non-germination, diseases and infestation by new pests [2]. Molecular genetic characterisation, the
first ever done on any commercially grown GM crop so far, has confirmed that both the GM construct of Roundup Ready soya and the host genome have been
scrambled (rearranged), and hundreds of basepairs of unknown DNA has got in as well [3]. 

The 'next generation' crops are even worse. I draw your attention especially to those developed with terminator technologies aimed at protecting
corporate patents and preventing farmers from saving and replanting seeds. Many are currently field tested and commercially grown as 'male sterile'
crops. Not only are the constructs more complicated and hence more unstable and prone to horizontal gene transfer, the gene products used are cell
poisons or recombinases, ie, genome scramblers. Female-sterile and even male-sterile genes (yes!) are being spread via pollen [4]. These dangerous
genes will spread and wipe out other crops as well as wild plant species.

It has become all too clear that GM agriculture cannot co-exist with other forms of agriculture. Bees are known to travel up to10km or more in
foraging for pollen [5]. And there is no way to prevent the horizontal spread of GM constructs to unrelated species, which can occur in all
environments, including the digestive and respiratory tracts of animals, as stated in evidence I have already presented. There are both sound a priori
reasons as well as empirical evidence to support my contention, shared by other scientists, that GM constructs may more likely spread horizontally
than non-manipulated DNA. Let me reiterate them here.

GM constructs are designed to cross species barriers and invade genomes. They possess homologies to a wide combination of viral and bacterial DNA and
are hence much more likely to recombine with, and transfer genes to all those agents. GM constructs are well known to be structurally unstable and
hence prone to fragment and recombine. Some constructs such as those with the CaMV 35S promoter are extra unstable on account of the presence of
recombination hotspots. I have mentioned the now abundant empirical evidence of structural instability of transgenic DNA and trangenic plants above.
The CaMV 35S promoter has been shown to be extra unstable in GM crops. And horizontal transfer of transgenic DNA has been demonstrated both in the
laboratory and in the field. 

I note from your report that Dr Daniel Cohen, a plant scientist in the Plant Health and Development group of HortResearch, had attempted to refute my
warnings about the CaMV 35S promoter. But he, like other GM proponents, had failed to counter my point that the isolated, recombined CaMV 35S promoter
cannot be equated with the promoter in the intact viral genome or the intact virus. The intact viral genome had evolved over millions of years. The
host range of the virus itself is restricted to the cabbage family, and it has a well-tried and tested life cycle in the host cell that does not
require integration into the host genome. The fact that no transfer from the virus into the plant genome has taken place in the course of evolution
attests to the effective biological barriers that keep species distinct. 

The same promoter, removed from the viral genome and put next to strange genes in the GM construct, is entirely different. It now functions
promiscuously across the living world, including animal and human cells. Its destabilising effect on GM crops is such that many scientists, including
those who pioneered its use, are now phasing it out. There is no justification for releasing any GM crop containing the CaMV35S promoter into the

I note that you have approved the field release of GM tamarillo (Cyphomandra betacea) for resistance to tamarillo mosaic virus at Kerikeri Research
Station. This crop not only contains CaMV 35S promoter, but also has a kanamycin resistance marker gene. The approval of this marker gene was a
regulatory blunder committed in the United States and elsewhere, as it is clear that kanamycin is still widely in clinical use, and the marker gene
confers resistance to new generation aminoglycosides as well [6]. There is also plenty of evidence that GM crops with viral genes are prone to give
rise to recombinant viruses, some of which more virulent than the 'wild type' [7]. 

When I first drew attention to horizontal gene transfer in 1995, proponents of GM technology reacted by denying it exists. Now they, like Dr. Daniel
Cohen, are saying it does not matter because it is a natural process. Horizontal gene transfer may have occurred in our evolutionary past, but GM
constructs are anything but natural. They are synthetic genes and new combinations of genes that have never existed in billions of years of evolution,
and cannot in any sense be regarded as natural. 

And, I am afraid, the GM proponents will have to change their tune again; for a rigorous reanalysis of the human genome and other data has failed to
substantiate the claim that the human genome has 113 to 226 bacterial genes transferred into it [8]. The actual number could well be no more than a
few, or none at all. What is the lesson? Precisely as I have always said, horizontal gene transfer does not readily happen without genetic
engineering. Genetic engineering enhances it, with dangerous consequences.

In biomedical applications, the gene-centred approach is equally misplaced and pernicious [9]. So-called 'health genomics' is a drain on our
intellectual and financial resources. It is preventing us from addressing the real, overwhelming causes of ill health: poverty, malnutrition, social
injustice and environmental pollution. It is stigmatising and victimising those most in need of care and treatment, and making even the most unethical
applications, such as human cloning and 'therapeutic human cloning', seem compelling. 

Furthermore, the 'cures' on offer are literally deadly. The toll from 'gene therapy' trials so far is at least 6 deaths and more than 650 adverse
events. It is now admitted that gene therapy has been oversold by the scientists themselves [10]. Presumed stem cells from human foetuses transplanted
into the brain of 5 Parkinson's patients turned into an irredeemable nightmare because the cells grew uncontrollably [11]. The latest verdict from an
international team of cloners is that mice embryonic stem cells are uncontrollably variable in culture, the clones themselves are also subject to
uncontrollable and unpredictable variations and defects [12].

And xenotransplantation is widely condemned because there is clear evidence that endogenous viruses from animal organs can cross into humans [13].

New lethal viruses continue to be created in genetic engineering labs, some of the latest being SHIVs, hybrids of human and monkey AIDS viruses that
can infect both [14]. Finally, AIDS virologists have issued serious warning against AIDS vaccines that undermine the immune system, making it more
susceptible to viral infections, and have the potential to generate lethal viruses and bacteria in the vaccinated populations [13].

A sweeping paradigm change is long overdue if we are to survive the destruction that reductionist science and technology have wrought on us and on our
planet. We have all the means to deliver genuine health and food security to the world without using GM technology and going against the wishes of the
vast majority of people. Only the political will is missing.

  1. Reviewed in "GM crops face potential genetic meltdown" by Joe Cummins, ISIS News 9/10, July 2001 ISSN: 1474-1547 (print) ISSN: 1474-1814 (online) enclosed
  2. "Bad news beans - A year of challenges confronts soybean growers" Duane Daily, Extension & Ag. Information, University of Missouri, July 27, 2001
  3. Windels P, Taverniers I, Depicker A, Van Bockstaele E and De Loose M (2001). Characterisation of the
    Roundup Ready soybean insert. Eur Food Res Technol DOI 10.1007/ s002170100336, © Springer-Verlag, reviewed in "Scrambled genome of RR soya" by
    Mae-Wan Ho and Joe cummins, ISIS News 9/10, July 2001 ISSN: 1474-1547 (print) ISSN: 1474-1814 (online) enclosed.
  4. The various terminator patents have been decoded in "Terminate the terminators" by Mae-Wan Ho and Joe Cummins, ISIS Report, July 23, 2001, enclosed.
  5. Capaldi E.A. et al (2000) - Ontogeny of orientation flight in the honeybee revealed by harmonic radar, Nature, Vol 403, p 537-40. Quote from this paper: "our findings suggest that bees take multiply orientation flights before becoming foragers in order to visit different, and larger, portions of the landscape around the hive. These flights provide them with repeated opportunities to view the hive and its surroundings from different positions, suggesting that bees learn the local landscape in a progressive fashion. Bees navigate using a combination of cues, including the position of the sun and the location of salient landscape features, but it is not known how or whether information about these cues, obtained during sequential flights, is integrated. It is an extraordinary feat for an animal the size of a honeybee to be able to find a small nest from distances as great as 10 km.
  6. "Kanamycin still in use and cross reacts" by Joe Cummins, ISIS News 9/10, July 2001 ISSN: 1474-1547 (print) ISSN: 1474-1814 (online) enclosed.
  7. Reviewed in Ho MW, Ryan A and Cummins J. Hazards of transgenic plants with the cauliflower mosaic viral promoter. Microbial Ecology in Health and Disease 2000, 12, 6-11.
  8. Stanhope MJ, Lupas A, Italia MJ, Koretke, KK, Volker C and Brown JR. Phylogenetic analyses do not support horizontal gene transfers
    from bacteria to vertebrates. Nature, 2001, 412, 940-4.
  9. Ho MW. Health genomics and health policy., Paper presented at WHO- Multi Regional Meeting on Genomics and Health, Bangkok, Thailand, 23-25 July, 2001, enclosed. 
  10. See "Gene therapy oversold by scientists" by Angela Ryan, ISIS
    News 9/10, July 2001 ISSN: 1474-1547 (print) ISSN: 1474-1814 (online) enclosed.
  11. "Cell implants in Parkinson's study cause catastrophe" by Gina Kolata, International Herald Tribune, 9 March 2001.
  12. Reviewed in "Cloning and ES cells both biting the dust" by Mae-Wan Ho, ISIS Report, July 11, 2001 enclosed. 
  13. Ho MW and Cummins JC. Xenotransplantation. How bad science and big business put the world at risk from viral pandemics. ISIS Sustainable Science Audit no.2, August 2000 ; also Third World Resurgence 2001, 127/128, 46-55.
  14. See "GM AIDS virus more deadly" by Joe Cummins and Mae-Wan Ho, ISIS Report July 19, 2001 enclosed.
  15. See "AIDS vaccines trials dangerous" by Mae-Wan Ho, ISIS Report July 29, 2001 enclosed. 


  1. ISIS News 9/10 
  2. "Terminate the terminators", by Mae-Wan Ho and Joe Cummins, ISIS Report July 23, 2001.
  3. Health genomics and health policy. Paper presented at WHO- Multi Regional Meeting on Genomics and Health, Bangkok, Thailand, 23-25 July, 2001.
  4. "Cloning and ES cells both biting the dust", by Mae-Wan Ho, ISIS Report, July 11, 2001.
  5. Xenotransplantation. How bad science and big business put the world at risk from viral pandemics. ISIS Sustainable Science Audit no.2, by Mae-Wan Ho and Joe Cummins, August 2000.
  6. "GM AIDS virus more deadly", by Joe Cummins and Mae-Wan Ho, ISIS Report July 19, 2001.
  7. "AIDS vaccines trials dangerous" by Mae-Wan Ho, ISIS Report July 29, 2001.


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