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October 20, 2003 an article by Prof. Joe Cummins ( his unedited personal opinion )
e-mail: jcummins@

" Biosafety standards for Molecular Farming "
Molecular Farming is primarily focused on the production of biopharmaceutical proteins in crop plants. Field testing of genetically modified (GM) corn, canola , tobacco, alfalfa, safflower, rice and tobacco mosaic virus. Seventy-seven such tests have been undertaken in the United States and a large number in other countries. These tests have been undertaken , for the most part, with extreme secrecy regarding location, nature of the product being tested and the safety considerations of the tests. The few published reviews of the environmental and human safety evaluations of the tests focused mainly on the possibility of pollen flow to nearby crops and weeds and ignored the real hazards of seed transfer by farm machinery and on vehicles of all types along with browsing animals. The likely pollution of surface and groundwater by crop leaves and roots debris and breakdown has been almost entirely ignored event though the pharmaceutical products were active in minute quantity.
Considering acceptable safety standards for undertaking field tests and production of biopharmaceutical crops the following recommendations should be considered:

1. Field tests and production facilities should be fully disclosed to the public in a timely way. Both the location and the nature of the product being grown should be made available to the public and any known deleterious side effects of the product should be disclosed. Public health authorities should be provided methods of detecting the product in environmental samples and in human blood and urine.

2. Production and testing of high potency biopharmaceutical products should be limited to fully isolated green house facilities. The facility should have restricted human contact ans to prevent access by insects and birds. Contact with the soil and groundwater should be controlled and only treated wastewater released from the facility. Most of the biopharmaceutical products are high value items that can be produced economically in a fully isolated facility. Organic waste from the facility should be incinerated on site.

3. All molecular farming production should undertake full studies on the spread of pollen and seeds from the production sites. Adequate methods for high sensitivity detection of pollutants in surface and groundwater should be made available and studies should be undertaken, if possible , by neutral third parties

Implementation of the standards described above should go a long ways towards making Molecular Farming acceptable by farmers and the public.

Biographical Sketch:
I am Professor Emeritus of Genetics , University of Western Ontario, London, Ontario. I was born in Whitefish , Montana Feb. 5, 1933. I obtained a BS degree in Horticulture, Washington State University 1955 and a PhD degree in Cellular Biology from University of Wisconsin 1962. My postdoctoral work was at Edinburgh , Palermo, Stockholm (Karolinska) and the Macardle Laboratory for Cancer Research University of Wisconsin. I taught genetics at Rutgers and the University of Washington, Seattle before joining The University of Western Ontario in 1972. My involvement in environmental issues arose in 1968 and I have been involved in a range of issues involving mercury, asbestos and PCB pollution and pesticide pollution along with waste sites and incinerators. My criticism of genetic modification by genetic engineering beginning in 1988 when I encountered the power of multinational corporations over the federal government and their refusal to face serious risk evaluations.
I have published over 200 scientific and popular articles, my most recent papers appeared in Nature Biotechnology, The Ecologist, and Biotechnology and Development Review. I have a number of reviews and comments listed on the website of The Institute of Science in Society, PO Box 32097, London NW1 OXR UK

© 2003